An Analytical Comparison of Geostationary (GSO) and Non-Geostationary (NGSO) Satellite Filings Submitted to the Federal Communications Commission (FCC) Between 2012 to 2022
28 Pages Posted: 3 Aug 2023
Date Written: August 1, 2023
Abstract: The Federal Communications Commission’s (FCC) International Bureau Filing System (IBFS) and Experimental Licensing System (ELS) have received an unprecedented number of satellite applications with IBFS intended for commercial licenses while ELS is for experimental ones. From 2012 to the end of 2022, this record pace has culminated in the Commission receiving 4,113 total satellite filings, 1,278 IBFS geostationary (GSO) and 2,835 non-geostationary (NGSO) applications split between 302 IBFS and 2,533 ELS. GSO applications were submitted by 279 unique entities, IBFS NGSO had 54, and ELS NGSO had 67, but the top ten filers made up 82.9% of all IBFS GSO filings versus, 55.0% for IBFS NGSO, and 58.6% for ELS NGSO. Overall, GSO applications had a higher Grant of Authority rate than commercial NGSO applications: 76.5% compared to 67.2% for IBFS NGSO. But, both were below the 85.9% Grant rate of ELS NGSO filings. The two most requested bands for IBFS GSO applications were Ku-band (56.4%) and Ka-band (27.3%) while for IBFS NGSO they were Ka-band (36.3%) and Ku-band (15.8%). ELS NGSO applications were far more focused on lower bands with S-band (45.0%) and L-band (15.4%) being the most requested. IBFS GSO applications contained 164 regulatory waiver requests with the three most requested waivers being for regulations 2.106, 25.283(c), and 25.114(d)(14)(ii). These rules pertain to use of frequencies not in accordance with the FCC’s frequency allocation table, the discharge of stored energy sources onboard spacecraft, and orbital debris mitigation, respectively. NGSO filings contained 169 regulatory waiver requests with 2.106, 25.157, and 25.156 being the most requested. Where 25.157 pertains to the method of processing applications generally and 25.156 pertains to the consideration of NGSO applications specifically. The starkest distinction between GSO and NGSO filings was observed in the number of days until an application received an action from the Commission. Over the last decade, the overall average for an IBFS Part 25 GSO filing was 137.7 days versus 231.3 days for IBFS NGSO. Special Temporary Authority (STAs) had the shortest delay for both systems with IBFS GSO STA being 35.2 days versus 51.7 days for NGSO. ELS had an average wait time of 70.5 days. These longer delays can mostly be explained by the increased complexity related to assessing a constellation of NGSO satellites versus a single GSO satellite. By understanding filing trends for the last decade, it is possible to see the current and future direction of the space industry at large and help policy makers review and make regulations that meet the needs of this rapidly evolving sector.
Keywords: Satellite, Federal Communications Commission, Geostationary, Non-Geostationary
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