Washington, D.C., January 20, 2026
Before the Federal Communications Commission,
Washington, D.C. 20554
In the Matter of
Space Modernization for the 21st Century
(SB Docket No. 25-306)
COMMENTS OF THE AMERICAN ASTRONOMICAL SOCIETY
The American Astronomical Society (AAS)1, the major organization of professional astronomers in the United States representing over 8500 members, appreciates the opportunity to provide comments in response to this Public Notice (FCC 25-69) regarding proposed changes to the Federal Communications Commission (FCC) licensing process for space and Earth stations.
I. Introduction
In this Notice of Proposed Rulemaking (NPRM), the FCC proposes rule changes with the goal of streamlining the licensing process and adding more flexibility for satellite system operators. The proposed changes involve three pivots from the current licensing framework:
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To presume “bright-line” criteria for acceptable operations, defaulting towards approving compliant applications and expediting the review process.
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To re-design the license application interface to reduce both operator and FCC burden in processing system information.
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To add flexible options for system design, operations, and license types, as long as they do not trigger exceptions to the proposed “bright-line” criteria. This includes creation of a new category of Variable Trajectory Spacecraft System (VTSS) for systems that do not necessarily follow geostationary or non-geostationary orbits (GSO/NGSO).
The AAS, representing a scientific community that pursues groundbreaking progress and discovery, appreciates the Commission’s intent to enable and encourage innovation in the space industry through these proposed changes. We also appreciate continued recognition of the Radio Astronomy Service (RAS) as serving the public interest and the inclusion of commensurate coordination requirements under this new licensing framework, as described below. However, we are concerned by the proposal to reduce comment periods to only 15 days, which would hamper the ability of many organizations to provide informed comments.
II. Coordination with the Radio Astronomy Service
We thank the Commission for preserving existing requirements that satellite operators coordinate with the U.S. National Science Foundation (NSF) Electromagnetic Spectrum Management Unit (ESMU), and for including the following new RAS coordination requirements in this proposed licensing framework:
The new category of Variable Trajectory Spacecraft System (VTSS) is of particular interest to the astronomical community, as many scientific missions (including space telescopes and exploratory probes) follow trajectories within the Solar System that do not fit into typical GSO or NGSO orbital categories. We thank the Commission for recognizing these non-traditional orbits, and for ensuring early coordination between VTSS applicants and relevant government entities to avoid harmful interference with the RAS.
The recognition of the growing use of Non-Voice, Non-Geostationary Mobile-Satellite Service (NVNG MSS) operations in the 137-138 MHz (space-to-Earth), 148-150.05 MHz (Earth-to-space), 399.9-400.05 MHz (Earth-to-space), and 400.15-401 MHz (space-to-Earth) bands is also appreciated by the astronomical community. While the RAS does not have frequency allocations in these bands, Footnotes 5.208A and 5.208B to the International Table of Frequency Allocations (ITU-R Radio Regulations Article 5) require that all practicable steps be taken to protect the RAS from harmful interference in the bands 137-138 MHz, 150.05-153 MHz, and 400.15-401 MHz, according to the guidance in Recommendation ITU-R RA.769 and Resolution 739 (Rev. WRC-19). Furthermore, the NVNG MSS bands 137-138 MHz and 148-150.05 MHz overlap with the frequency range in which astronomers have detected unintended electromagnetic radiation (UEMR) associated with Starlink satellites, in which low-frequency broad- and narrow-band emissions appear to originate from operating satellite electronics.2 Large numbers of satellites have the potential to produce aggregate interference, especially with UEMR being an uncontrolled phenomenon coincident with intentional transmissions from NVNG MSS in these bands. The identification of these risks and early coordination and mitigation measures at the application stage will help to protect the RAS from various potential sources of harmful interference.
Regarding proposed changes to terrestrial system applications, we thank the Commission for including explicit coordination requirements for operations geographically near the U.S. National Radio Quiet Zone (NRQZ) surrounding Green Bank, WV. The National Radio Astronomy Observatory (NRAO), which oversees the NRQZ and Green Bank Observatory, has an extensive demonstrable history of productive coordination efforts with wireless operators, from the establishment and preservation of the NRQZ since 1958 to building an Operational Data Sharing (ODS) system in collaboration with SpaceX which broadcasts telescope pointing information to operators so that their satellites can avoid direct boresight conjunctions with RAS systems.3 Notification and coordination with RAS astronomy facilities during the application and licensing stage ensures that potential impacts on science operations are identified and mitigated early, preserving and enabling groundbreaking research.
We would particularly like to highlight the new coordination requirements for growing 1.6/2.4 GHz Mobile-Satellite Service (MSS) operations, including the provision to establish protection zones around current and future RAS and Very Long Baseline Array (VLBA) facilities. The extension of these protections to future observatories—especially with the recent advent and expansion of Supplemental Coverage from Space (SCS) and direct-to-device MSS operations in the 1400-2700 MHz range—is particularly valuable for the long-term planning of space science facilities. Given that RAS receivers are among the most sensitive radiocommunication instruments, we also appreciate the Commission’s acknowledgement of potentially harmful harmonics and the inclusion of proposed mitigation methods for harmful interference, including coordination of transmission schedules to avoid peak traffic periods. We also thank the Commission for including coordination requirements for MSS Ancillary Terrestrial Components (ATC).
III. Concluding remarks
The astronomical community is pleased by the continued recognition of RAS operations as being in the public interest and the inclusion of new coordination requirements under this licensing framework overhaul. We also appreciate the Commission’s continued facilitation of Coordination Agreements between satellite operators and the NSF ESMU, which has proved indispensable both for preserving RAS operations in the United States and for generating innovative means for protecting RAS that set an example for the rest of the world.
However, we are apprehensive about the potential reduction of public comment periods for applications that request exemptions to the proposed “bright-line” criteria to only 15 days. How much this change would reduce the ability of the general public to respond to concerning applications will depend on adopted “bright-line” criteria and how extensive requested exemptions to the criteria may be. Regardless, this proposed shortening of the public comment period may hamper the response ability of organizations that may not have staff dedicated to monitoring and replying to FCC matters.
On behalf of the American Astronomical Society (AAS), thank you for your consideration of the above comments.
Dara Norman, Ph.D.
President, American Astronomical Society
1 The American Astronomical Society webpage: https://aas.org/
2 Di Vruno et al., “Unintended electromagnetic radiation from Starlink satellites detected with LOFAR between 110 and 188 MHz”, Astronomy & Astrophysics, 676, A75 (2023) https://www.aanda.org/articles/aa/full_html/2023/08/aa46374-23/aa46374-23.html
3 Nhan et al., “Toward Spectrum Coexistence: First Demonstration of the Effectiveness of Boresight Avoidance between the NRAO Green Bank Telescope and Starlink Satellites”, The Astrophysical Journal Letters, 971, L49 (2024) https://iopscience.iop.org/article/10.3847/2041-8213/ad6b24/pdf