Rule2025-12579

Assessment and Collection of Space and Earth Station Regulatory Fees for Fiscal Year 2024

Primary source

Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.

Published
July 7, 2025
Effective
September 14, 2025

Issuing agencies

Federal Communications Commission

Abstract

In this document, the Federal Communications Commission (Commission or FCC) adopts targeted revisions to its existing methodology of assessing regulatory fees for space and earth stations that will be effective for fiscal year 2025.

Full Text

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<title>Federal Register, Volume 90 Issue 127 (Monday, July 7, 2025)</title>
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[Federal Register Volume 90, Number 127 (Monday, July 7, 2025)]
[Rules and Regulations]
[Pages 29760-29773]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2025-12579]


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FEDERAL COMMUNICATIONS COMMISSION

47 CFR Part 1

[MD Docket No. 24-85; FCC 25-31; FR ID 301014]


Assessment and Collection of Space and Earth Station Regulatory 
Fees for Fiscal Year 2024

AGENCY: Federal Communications Commission.

ACTION: Final rule.

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SUMMARY: In this document, the Federal Communications Commission 
(Commission or FCC) adopts targeted revisions to its existing 
methodology of assessing regulatory fees for space and earth stations 
that will be effective for fiscal year 2025.

DATES: Effective on September 14, 2025.

FOR FURTHER INFORMATION CONTACT: Stephen Duall, 202-418-1103, 
<a href="/cdn-cgi/l/email-protection#0a597e6f7a626f64244e7f6b66664a6c6969246d657c"><span class="__cf_email__" data-cfemail="2d7e59485d4548430369584c41416d4b4e4e034a425b">[email&#160;protected]</span></a>.

SUPPLEMENTARY INFORMATION: This is a summary of the Commission's Third 
Report and Order in MD Docket No. 24-85, FCC 25-31, adopted June 5, 
2025, and released June 9, 2025. The full text of this document is 
available online at <a href="https://docs.fcc.gov/public/attachments/FCC-25-31A1.pdf">https://docs.fcc.gov/public/attachments/FCC-25-31A1.pdf</a>. The full text of this document is also available for 
inspection and copying during business hours in the FCC Reference 
Center, 45 L Street NE, Washington, DC 20554. To request materials in 
accessible formats for people with disabilities, send an email to 
<a href="/cdn-cgi/l/email-protection#35737676000501755356561b525a43"><span class="__cf_email__" data-cfemail="83c5c0c0b6b3b7c3e5e0e0ade4ecf5">[email&#160;protected]</span></a> or call the Consumer & Governmental Affairs Bureau at 
202-418-0530 (voice), 202-418-0432 (TTY).
    Final Regulatory Flexibility Analysis. The Regulatory Flexibility 
Act of 1980, as amended (RFA), requires that an agency prepare a 
regulatory flexibility analysis for notice and comment rulemakings, 
unless the agency certifies that ``the rule will not, if promulgated, 
have a significant economic impact on a substantial number of small 
entities.'' The Commission has prepared an Final Regulatory Flexibility 
Analysis (FRFA) concerning the potential impact of the proposed rule 
and policy changes contained in the Commission's Third Report and 
Order. The FRFA is set forth in the appendix of the FCC Document 
<a href="https://docs.fcc.gov/public/attachments/FCC-25-31A1.pdf">https://docs.fcc.gov/public/attachments/FCC-25-31A1.pdf</a> and a summary 
is included below.
    Final Paperwork Reduction Act Analysis. The Commission's Third 
Report and Order does not contain new or modified information 
collection requirements subject to the Paperwork Reduction Act of 1995 
(PRA), Public Law 104-13. In addition, the Commission notes that 
pursuant to the Small Business Paperwork Relief Act of 2002, Public Law 
107-198, see 44 U.S.C. 3506(c)(4), the Commission previously sought 
specific comment on how the Commission might further reduce the 
information collection burdens for small business concerns with fewer 
than 25 employees. In the Commission's Third Report and Order, the 
Commission assessed the effects of its adoption of rules implementing 
the Part 25 licensing and operating provisions and technical 
requirements. The Commission finds that such requirements are unlikely 
to directly impact businesses with fewer than 25 employees.
    Congressional Review Act. The Commission has determined, and the 
Administrator of the Office of Information and Regulatory Affairs, 
Office of Management and Budget, concurs that this rule is non-major 
under the Congressional Review Act, 5 U.S.C. 804(2). The Commission 
will send a copy of the Third Report and Order to Congress and the 
Government Accountability Office, pursuant to 5 U.S.C. 801(a)(1)(A).

Synopsis

I. Introduction

    1. In the Third Report and Order (Order), the Commission adopts 
targeted amendments to its existing methodology of assessing regulatory 
fees for space and earth stations pursuant to section 9 of the 
Communications Act of 1934 (Act), as amended. These changes will be 
effective for the fiscal year 2025 (FY 2025) assessment and collection 
of regulatory fees.
    2. The Commission began this proceeding after the creation of the 
Space Bureau in 2023 to ensure that its regulatory fees structure for 
space and earth station fee payors remain fair, administrable, and 
sustainable in light of the substantial changes in the space industry 
in recent years. The Commission is mindful of the significance of 
ensuring its work is consistent with such overarching goals because the 
fee schedule adopted for fiscal year 2024 contained sizable increases 
in the fees assessed to space and earth station fee payors compared to 
the previous fiscal year.
    3. In the Order, the Commission takes two key actions for the 
current fiscal year to address this situation. First, the Commission 
assesses regulatory fees on stations once they are authorized, rather 
than when the stations are certified to be operational, as is currently 
the case. Second, the Commission splits existing regulatory fee 
categories for Space Stations (Non-Geostationary Orbit) into two new 
fee categories: small constellations (fewer than 1000 authorized space 
stations) and large constellations (1000 authorized space stations or 
more). These changes will better distinguish between space station 
regulatees and will more accurately apportion fee burdens among them, 
which should result in lower per unit regulatory fees for the majority 
of space station fee payors compared to fiscal year 2024. The Order 
also adopts an approach that broadens the base of regulatory fee payors 
to better align fees with the benefits of regulation and that is less 
subjective than the current system that allocates fees based on the 
estimated ``complexity'' of an NGSO system.
    4. The changes adopted support the Commission's goal that its 
regulatory fees are fair, administrable, and sustainable. The 
Commission views the targeted changes adopted as a step to quickly 
improve the assessment of regulatory fees for the current fiscal year, 
but the Commission also recognizes that as the industry develops, and 
as the Commission seeks to streamline much of the Space Bureau's 
operations, that additional improvements to the methodology may be 
proposed in future fiscal years.

II. Background

    5. Section 9 of the Act obligates the Commission to assess and 
collect regulatory fees each year in an amount that can reasonably be 
expected to equal the amount of its annual salaries and expenses (S&E) 
appropriation. Thus, the Commission has no discretion regarding the 
total amount to be collected in any given fiscal year. In accordance 
with the statute, each year the Commission proposes adjustments to the 
prior fee schedule under section 9(c) to ``(A) reflect unexpected 
increases or decreases in the number of units subject to the payment of 
such fees; and (B) result in the collection of the amount required'' by 
the Commission's annual

[[Page 29761]]

appropriation. The Commission will also propose amendments to the fee 
schedule under section 9(d) ``if the Commission determines that the 
schedule requires amendment so that such fees reflect the full-time 
equivalent number of employees within the bureaus and offices of the 
Commission, adjusted to take into account factors that are reasonably 
related to the benefits provided to the payor of the fee by the 
Commission's activities.'' In administering its regulatory fee program, 
the agency strives to adhere to the goals of ensuring that the program 
is fair, administrable, and sustainable.
    6. The Commission released the Space and Earth Station Regulatory 
Fees NPRM on March 13, 2024, which initiated an examination and review 
of regulatory fees for space and earth station payors that are 
regulated by the new Space Bureau. When the Commission adopted 
regulatory fees for FY 2023, it noted that it would be the last year 
for doing so using the nomenclature of certain fee payors being 
regulated by the International Bureau. The Commission noted that the 
creation of the Space Bureau and Office of International Affairs could 
result in changes in the assessment of regulatory fees for space and 
earth station fee payors resulting from changes in FTEs, due to 
increased oversight on various relevant industries. The Commission 
anticipated that the changes in the industry that resulted in the 
creation of the Space Bureau would likely also result in changes in the 
relative FTE burdens between and among space and earth station fee 
payors. Accordingly, the Commission sought comment in the Space and 
Earth Station Regulatory Fees NPRM on a range of proposed changes 
related to the assessment of regulatory fees for space and earth 
stations under its existing regulatory fee methodology, as well as 
under a proposed alternative methodology for assessing space station 
regulatory fees.
    7. In June 2024, the Commission adopted an order in this proceeding 
that amended the methodology used to calculate regulatory fees for 
small satellites by no longer calculating it as a percentage of the 
NGSO ``less complex'' and ``other'' space station fee categories. 
Instead, the Commission set the regulatory fee for ``Space Stations 
(per license/call sign in non-geostationary orbit) (47 CFR part 25) 
(Small Satellite)'' for FY 2024 at the level set for FY 2023 ($12,215), 
with annual adjustments thereafter to reflect the percentage change in 
the FCC appropriation, unit count, and FTE allocation percentage from 
the previous fiscal year. It also determined to assess regulatory fees 
for space stations that are principally used for Rendezvous & Proximity 
Operations (RPO) or On-Orbit Servicing (OOS), including Orbit Transfer 
Vehicles (OTV), using the existing fee category for ``small 
satellites'' on an interim basis until the Commission can develop more 
experience in how these space stations will be regulated.
    8. In September 2024, the Commission adopted a Second Report and 
Order in this proceeding that revised the allocation of space station 
regulatory fees using the existing methodology for calculating their 
proportional share of regulatory fees from 80% of space station 
regulatory fees being allocated to GSO space station fee payors and 20% 
of the space station regulatory fees being allocated to NGSO space 
station fee payors to 60% of space station regulatory fees being 
allocated to GSO space station payors and 40% to NGSO space station 
payors (that is, changing from an ``80/20 GSO/NGSO split'' to a ``60/40 
GSO/NGSO split''). It also adopted a re-apportionment of regulatory 
fees between earth and space station payors based on the percentage of 
direct FTEs involved in the licensing and regulation of each category.
    9. The Commission did not act on the remaining proposals that were 
made in the Space and Earth Station Regulatory Fees NPRM. It instead 
concluded that action on these issues may benefit from further 
consideration, and stated that further comment on these remaining 
proposals would be sought in a further notice of proposed rulemaking. 
In February 2025, the Commission released a further notice in this 
proceeding (Space and Earth Station Regulatory Fees FNPRM) that sought 
comment on the proposals made in the Space and Earth Station Regulatory 
Fees NPRM that were not adopted for FY 2024. Those proposals include 
assessing regulatory fees on authorized, but not operational, space and 
earth stations; using an alternative methodology for assessing space 
station regulatory fees; establishing tiers within existing NGSO space 
station fee categories based on the number of space stations in the 
system; and creating new categories of earth station regulatory fees.
    10. Comments in response to the Space and Earth Station Regulatory 
Fees FNPRM were due on March 27, 2025, and replies were due on April 
11, 2025. The Commission received 19 comments and 17 reply comments. In 
addition, several entities made presentations to the Commission 
pursuant to its rules governing ex parte communications.

III. Discussion

    11. The Commission now amends its existing methodology for 
assessing regulatory fees for space and earth stations by (1) assessing 
regulatory fees based on when stations were authorized, rather than 
when the stations are certified to be operational, as is currently the 
case, and (2) eliminating the existing regulatory fee categories for 
``Space Stations (Non-Geostationary Orbit)--Less Complex'' and ``Space 
Stations (Non-Geostationary Orbit)--Other'' and creating new fee 
categories for ``Space Stations (Non-Geostationary Orbit)--Small 
Constellations (fewer than 1000 authorized space stations)'' and 
``Space Stations (Non-Geostationary Orbit)--Large Constellations (1000 
authorized space stations or more).'' The Commission adopts these 
changes to become effective for fiscal year 2025. The Commission 
declines at this time to adopt the alternative methodology to remove 
the distinction between geostationary and non-geostationary space 
stations and to assess space and earth station regulatory fees based on 
a common unit of space station fees that was put forth in this 
proceeding, as well as other suggestions to change its regulatory fee 
methodologies for space and earth stations made by commenters. The 
Commission also makes no changes at this time to the existing 
methodology for assessing regulatory fees for earth stations.

A. Objectives of Proceeding

    12. As explained above, the Commission commenced this proceeding in 
2024 to focus on space and earth station regulatory fees. In 
implementing its statutory authority, the Commission considers the 
adoption of a new regulatory fee category or a change in an existing 
regulatory fee category only when the Commission develops a sufficient 
basis for doing so under Section 9 ensuring that its actions are 
consistent with the overarching goal that its regulatory fees are fair, 
administrable, and sustainable. These goals must work within the 
explicit statutory requirements of section 9 that the Commission 
collect fees by determining ``the full-time equivalent number of 
employees'' performing specified activities in the Bureaus and Offices, 
and they are intended to guide adjustments that the Commission must 
make from time to time to its regulatory fee assessments. As discussed 
below, the Commission finds that it can better achieve these statutory 
requirements and overarching goals by adopting targeted changes to its 
existing fee

[[Page 29762]]

methodology than by adopting an entirely new regulatory fee 
methodology.

B. Continued Use of the Existing Methodology

    13. For fiscal year 2025, the Commission continues to use the 
Commission's existing methodology, with targeted changes identified 
below, to assess the regulatory fees for Space Bureau fee payors. 
Accordingly, the Commission declines at this time to adopt the 
alternative fee methodology set forth in the Space and Earth Station 
Regulatory Fees NPRM, and for which additional comment was sought in 
the Space and Earth Station Regulatory Fees FNPRM.
    14. The Commission is acutely aware of the financial impact of 
regulatory fees, particularly on smaller and less capitalized space 
companies. Accordingly, the Commission is presently focused on reducing 
the total fee burden to be divided among regulated entities by making 
the Space Bureau's operations more efficient. The Commission finds that 
continued use of the existing methodology will maintain stability and 
prevent unnecessary disruption while broader reforms are ongoing. At 
the same time, targeted changes to the existing methodology will 
substantially reduce the fee burden for a large class of payors.
    15. Central to the alternative methodology is a common initial unit 
of regulatory fee payment for all space stations, regardless of which 
orbit they are designed to operate in, and the elimination of all 
separate fee categories for GSO and NGSO space stations, except for the 
fee category for Space Stations (per license/call sign) (Small 
Satellite), which would be retained in its existing form. The 
alternative methodology would create a single space station fee 
category for ``Space Stations (Per Call Sign in Geostationary Orbit or 
Per System in Non-Geostationary Orbit).'' The category would be tiered, 
with a single GSO space station or a NGSO system with up to 100 
authorized space stations constituting this initial tier and being 
counted as one unit for assessment of space station regulatory fees. 
Additional tiers would be created to account for NGSO systems with more 
than 100 authorized space stations, for example 500 or 1000 space 
stations per NGSO system per additional tier. Each tier would be 
counted as an additional unit for assessment of space station 
regulatory fees. The total number of units (initial and additional 
units) would be added together and the total space station allocation 
of the Space Bureau share would be evenly divided among the total 
number of units, resulting in a per unit regulatory fee for the fiscal 
year.
    16. The Commission emphasizes that its decision not to adopt the 
alternative methodology at this time does not foreclose consideration 
of it (or a variation of it) in a future proceeding. As the Commission 
has observed, the alternative methodology could achieve its goals of 
making its Space Bureau regulatory fees fair, administrable, and 
sustainable. Furthermore, comments received in response to the Space 
and Earth Station Regulatory Fees FNPRM broadly supported adoption of 
the alternative methodology as the preferred option for amending the 
methodology for assessing space station regulatory fees. Nonetheless, 
as the Commission streamlines and modernizes the Space Bureau's 
licensing and related activities, there are likely to be corresponding 
changes to FTE burdens related to oversight of Space Bureau regulatory 
fee payors. Consequently, the Commission finds that now is not the time 
to adopt a wholly new methodology for space station regulatory fees. 
Rather, the Commission finds that the overarching goals of fair, 
administrable, and sustainable regulatory fees can equally be achieved 
by targeted changes to the existing methodology.
    17. The Commission observes that the changes in the space industry 
that led to the creation of the Space Bureau and the Commission's re-
examination of space and earth station regulatory fees are still 
ongoing. The Commission is accordingly mindful that any wholesale 
departure from its existing methodology at this juncture runs 
significant the risk of adopting a new fee methodology that still 
reflects past assumptions about licensing and regulation of space and 
earth stations. For example, the alternative methodology remains 
committed to GSO space stations as the ``standard'' unit for assessing 
space station regulatory fees, with fees for NGSO systems expressed in 
terms of equivalence to a GSO space station. It is unclear whether this 
is a suitable foundation on which to build a new regulatory fee 
structure. Furthermore, the very nature of GSO space stations is 
undergoing change with the increasing availability of ``small GSO'' 
space stations, which raise questions about whether the same level of 
oversight is needed to license and regulate as traditional, large GSO 
space stations upon which the alternative methodology relies. Thus, the 
Commission declines to adopt an entirely new regulatory fee methodology 
at this time while these substantial changes in the space industry are 
still ongoing.
    18. As the Commission has redoubled its efforts in recent months to 
simplify and modernize its licensing and related operations, the 
Commission expects changes in the FTE burden will be needed for 
oversight of Space Bureau regulatory fee payors. The Commission also 
agrees with comments that it should not undertake a major overhaul of 
its space and earth station regulatory fee methodologies in light of 
the ongoing modernization efforts. Since the fiscal year ends on 
September 30, these modernization efforts may not be completed in time 
to impact the FTE burden of oversight or otherwise relate to the 
statutory framework for the exercise of its regulatory fee assessment 
for fiscal year 2025. The Commission, however, expects these efforts to 
bear fruit in the near future and, assuming so, will consider them in 
relevant future fiscal years as they relate to its statutory authority 
to assess and collect regulatory fees.
    19. For all these reasons, the Commission determines that the best 
course during these changing times is to focus on the core 
responsibilities that the Commission undertakes during its regulatory 
fee proceedings: to follow the requirements set forth in section 9 of 
Act, with the overarching goals of making its regulatory fees fair, 
administrable, and sustainable. For the reasons set forth below, the 
Commission finds that it can meet these requirements and goals with 
targeted amendments to its existing space and earth station regulatory 
fee methodology. Since the Commission can do this, while preserving the 
flexibility to make future targeted amendments in the future, the 
Commission shall follow that course.

C. Assessment of Fees on Authorized Space and Earth Stations

    20. Overview. The Commission amends its current methodology for 
assessing regulatory fees for space and earth station regulatees from 
assessing fees only after notification that the station is operational 
to assessing fees when the station has received a license or grant of 
market access from the Commission. In past years, regulatory fees for 
space stations were assessed only when the space stations are certified 
by their operator to be operational. An earth station payor was 
required to pay regulatory fees only after it had certified that the 
earth station's construction was complete, but in the rare instances in 
which a license limits an earth station's operational authority to a 
particular satellite system, the fee

[[Page 29763]]

was not due until the first satellite of the related system becomes 
operational within the meaning of the Commission's rules. The 
Commission finds, however, that the objectives of section 9 of the Act 
would be better met by assessing regulatory fees once a space or earth 
station is licensed or authorized, rather than, as now, waiting until a 
space or earth station becomes operational.
    21. As the Commission has previously observed, significant FTE 
burdens are involved with the licensing of space and earth stations, 
even before a station becomes operational. A licensee or grantee 
already benefits from the FTE levels necessary to review and grant the 
application for future operations of the station, as well as from the 
FTE levels used to protect the benefits conferred by the grant of a 
license or of U.S. market access, such as use of spectrum and orbital 
resources and protection from interference, which convey upon issuance 
of the license or grant. Moreover, given the bespoke nature of many 
satellite systems, Space Bureau staff expertise is used by the industry 
before, during, and after an application (including modifications 
thereof) or petitions for rulemaking are filed. In such situations, fee 
payors with systems that become operational earlier than other licensed 
systems bear the entire fee burden of regulatory work done on behalf of 
all regulated systems. Furthermore, if an authorized space station 
never becomes operational, then the licensee would never be subject to 
regulatory fees to recover the FTE burdens associated with regulating 
such space stations, and other licensees with operational satellites 
must bear the costs associated with space stations that were 
authorized, but never become operational. In addition, assessing 
regulatory fees on authorized, not just operational stations, broadens 
the base of regulatory fee payors, spreading the recovery of fees from 
all licensees who benefit from the Space Bureau's licensing and 
regulatory activities, and potentially lowering the per unit regulatory 
fee burden by increasing the number of units on which fees are 
assessed.
    22. Comments nearly unanimously support assessing regulatory fees 
when space and earth stations are authorized, rather than when they are 
operational, based on the observations previously made in the 
proceeding. Only two objections were made to the proposal: one asking 
not to apply regulatory fees to authorized, but not yet operational, 
earth stations; and one arguing that the Commission should continue its 
practice of assessing regulatory fees solely on operational stations, 
absent explicit authority from Congress to do otherwise. Regarding the 
former, the Commission sees no reason to treat earth stations 
differently from space stations, because significant FTE burdens are 
involved with the licensing of both prior to becoming operational, and 
both benefit from FTE burdens used to protect the benefit conferred by 
the authorization itself. As to the latter objection, Congress has 
explicitly directed the Commission to recover its annual S&E 
appropriation through regulatory fees, and the S&E appropriation 
includes funding for FTE burdens spent reviewing and granting 
applications, which is accrued regardless of when a station becomes 
operational. Congress has also already explicitly provided the 
Commission authority, in section 9(d) of the Act, to adjust its 
regulatory fees by rule if it determines that the schedule of fees 
requires amendment, and such adjustment by rule is what is being 
adopted in this proceeding. Section 9 does not limit the assessment of 
regulatory fees to operational stations, and Congress affirmatively 
deleted, as obsolete, the prior portion of section 9 that was the basis 
for the Commission's previous decision to assess regulatory fees only 
on operational space stations. Accordingly, the assessment of 
regulatory fees on authorized stations is wholly within the explicit 
authority given by Congress and is consistent with section 9 of the 
Act.
    23. Consistent with past practice and for purposes of fiscal year 
2025, the Commission will continue, however, to assess regulatory fees 
on station licenses and market access grants as of the start of the 
fiscal year, i.e. October 1, 2024. Although there is support on the 
record for alternative methods for assessing regulatory fees on any 
space station authorized during the fiscal year. At this time, the 
Commission finds that it is not administrable to assess fees on space 
stations authorized at any point during the fiscal year. One proposal 
in the record is to assess regulatory fees on authorized space and 
earth stations regardless of when in the fiscal year an authorization 
is granted, and to ``pro rate'' the assessed fee based on the number of 
calendar days or fiscal quarters that the station has been authorized 
in the fiscal year. Because in most cases the Commission assesses 
regulatory fees based on FTE share of the category of fee payors 
divided by the number of units of fee payors, pro-rated regulatory fees 
would require the Commission to take into account partial units, which 
would introduce complexity into the calculation without clear benefit. 
Such a result would not serve the Commission's goal of ensuring that 
its fees are administrable. Accordingly, the Commission will continue 
to assess regulatory fees on space and earth stations that are 
authorized as of the start of the fiscal year.
    24. Similarly, the Commission will continue the practice of 
providing a list of all space stations that are eligible to be assessed 
regulatory fees in an appendix to the annual notice of proposed 
rulemaking for the assessment and collection of regulatory fee for the 
fiscal year. Comments widely support the utility of this practice, and 
the Commission agrees that it has been an efficient method of providing 
notice and awareness of which fee payors are subject to regulatory fees 
for the fiscal year. The Commission declines to rely instead on the 
Space Bureau's Approved Space Station List for notice and awareness of 
which space stations are subject to regulatory fees for the fiscal 
year. The Commission finds that an appendix to the annual notice of 
proposed rulemaking will better serve its goal of providing space 
stations with notice of regulatory fees.
    25. The Commission declines to adopt exceptions or other carve-outs 
to assessing fees on all authorized space and earth stations, 
regardless of their operational status. As an initial matter, the 
Commission lacks the authority to exempt whole categories of fee payors 
from regulatory fees, since the decision to exempt whole categories of 
fee payors resides with Congress under section 9 of the Act. The 
Commission also finds that broadening the base to include authorized, 
but not operational, stations more accurately allocates the FTE burdens 
and result in lower per unit regulatory fees for most space and earth 
station operators. In any event, the rationales for assessing fees on 
stations when they are authorized remain applicable, even in the 
circumstances discussed below where proposals were made to exempt or 
carve out certain categories of stations that are authorized, but are 
non-operational or conduct solely non-revenue producing operations. 
Each are discussed in turn.
    26. Pre-operational stations. The Space and Earth Station 
Regulatory Fee FNPRM sought comment on whether to adopt new, separate 
fee categories for space and earth stations that are authorized, but 
not fully operational, based on a suggestion that the FTE burdens 
associated with licensing and oversight of authorized, but non-
operational, stations are less than those associated with operational 
stations. After review of the record, the

[[Page 29764]]

Commission affirms the prior tentative conclusion that substantial FTE 
burdens in the Space Bureau are dedicated to the review and action on 
space and earth station applications, and that entities with 
authorized, but not yet operational stations, still benefit from these 
burdens, as well as from a wide-range of regulatory benefits, utilizing 
both direct and indirect FTEs. In addition, the record did not provide 
a sufficient basis for differentiating FTE burdens for authorized, but 
not yet operational, stations, and the Commission agrees with comments 
that adopting separate fees for such stations would complicate the 
regulatory fee regime without clear benefit.
    27. Post-operational and TT&C-only space stations. The Space and 
Earth Station Regulatory Fee FNPRM sought comment on whether it is 
feasible to assess a separate category of annual regulatory fees for 
space stations that remain authorized solely to conduct telemetry, 
tracking, and command (TT&C) operations, for example in order to 
complete end-of-life disposal plans pursuant to orbital debris 
mitigation plans approved by the Commission as part of the 
authorization process. Most of the parties who commented on the 
proposal supported the concept of continuing to not assess fees, or to 
assess a lower fee, for non-operational, ``TT&C-only'' space stations, 
although some comments oppose any different treatment of authorized 
space stations. No party provided any information as to the feasibility 
of a separate fee or how such a fee should be calculated.
    28. The Commission appreciates but remains unconvinced by arguments 
to not assess regulatory fees on space stations solely for TT&C 
operations or space stations solely conducting TT&C operations 
necessary to complete end-of-life disposal plans. In both instances, 
regulatory fees may be assessed when the space station is not intended 
to generate revenue from its authorized communications, or is no longer 
generating revenue from them. Indeed, the Commission has previously 
held that a non-U.S. licensed space station that communicates with a 
U.S.-licensed earth station solely for TT&C purposes does not fall 
within the category of a non-U.S. licensed space station with access to 
the U.S. market for regulatory fee purposes. It has also found that 
regulatory fees are not assessed on space stations that have ceased 
operations and are authorized solely for TT&C to conduct experimental 
communications, or to conduct end-of-life disposal maneuvers.
    29. The Commission's prior precedent, however, is inapplicable to a 
fee structure that assesses fees on authorized stations, such as the 
one adopted in the Order. The Commission previously declined to assess 
fees for TT&C-only space stations during the time it limited regulatory 
fees to operational stations. Applying that exclusion to a fee 
structure that assesses fees on authorized stations is inconsistent 
with the rationale for adopting the new methodology and will undermine 
the purposes underlying it, including widening the base of regulatory 
fee payors. The Commission has previously recognized that assessing 
regulatory fees on non-operational stations has the potential to impose 
costs and create financial risk. Nonetheless, the Commission 
tentatively concluded that these concerns do not outweigh the need to 
assess regulatory fees on regulatees of the same class who benefit from 
its FTE efforts, which the Commission affirms in the Order in adopting 
the proposal to assess fees on authorized space and earth stations, 
even before such stations become operational. As stated above, the 
objectives of section 9 of the Act would be better met by assessing 
regulatory fees once a space or earth station is licensed or authorized 
because significant FTE burdens are involved with the licensing of 
space and earth stations, even before a station becomes operational, 
and because Space Bureau staff expertise is utilized by the industry 
before, during, and after an application (including modifications 
thereof) is filed. These reasons also apply to space and earth stations 
that are used solely for TT&C, or are being used for TT&C solely for 
post-mission disposal purposes. These TT&C communications are still 
radiocommunications authorized by the Commission and they continue to 
be subject to regulatory oversight by the Commission. This is true even 
in instances of TT&C solely for post-mission disposal, due to 
Commission oversight of compliance with the terms of their orbital 
debris mitigation plans. Accordingly, there is not a sufficient basis 
to find that regulatory fees should not be assessed on TT&C only space 
stations, or stations that are no longer operational, under the amended 
methodology adopted in the Order.
    30. Furthermore, excluding TT&C-only space stations may be 
inequitable for other reasons. As an example, the Commission is 
considering how to modify its rules to better accommodate the licensing 
and regulatory oversight of space stations that are used primarily in 
support of in-space servicing, assembly, and manufacturing (ISAM), 
including how to assess regulatory fees for such stations. Because 
these stations often are authorized to use radiocommunications solely 
for TT&C, without any other revenue-producing radiocommunication 
service being provided, categorically exempting TT&C-only space 
stations from regulatory fees now could prematurely exclude such 
stations wholly from regulatory fee assessments, even though such 
stations benefit from Commission FTEs as part of their licensing and 
regulatory oversight. In addition, exempting non-U.S. licensed space 
stations from regulatory fee assessments when communications with U.S.-
licensed earth stations are solely for TT&C purposes would provide non-
U.S. licensed space stations with an unfair advantage, unless the 
Commission were to do the same for all U.S.-licensed space stations, 
which the Commission does not find best serves the objectives of 
section 9 of the Act for the reasons stated above.
    31. To facilitate the transition to the amended methodology, 
however, the Commission will not assess regulatory fees on authorized 
space stations that have already commenced post-mission disposal plans 
as of the release date of the Order, provided that the authorized space 
stations are conducting TT&C solely for the purpose of executing 
approved post-mission disposal plans. Comments suggest that there is 
merit to assessing regulatory fees for space stations that have reached 
the end of life, but that such fees should apply prospectively. The 
Commission agrees that prospective application is appropriate in this 
limited instance, since it is highly unlikely that operators already 
undertaking disposal plans are able to adjust their plans and such 
operators are few in number.
    32. The Commission also expects to examine again in a future 
proceeding whether it is feasible to ascertain whether FTE burdens 
ascribed to the licensing and regulatory oversight of space stations 
authorized solely for TT&C communications are lower, such that a new, 
separate fee category might be able to be created for such stations. At 
this time, however, the Commission does not have sufficient record to 
reach a determination on this issue.
    33. Stations with multiple authorizations and RPO/OOS stations. The 
Commission sought comment on a proposal to assess regulatory fees in 
instances where there are separately identifiable space station 
authorizations, but which the space stations have not been considered 
to be separably operational and therefore have not been subject to 
separate regulatory fees. For example, a GSO satellite may operate in

[[Page 29765]]

certain frequency bands under a license by the Commission and may 
communicate with U.S.-licensed space stations in other frequency bands 
pursuant to a grant of U.S. market access. Likewise, a NGSO space 
station fee payor may operate some space stations in its system under a 
U.S. license and may operate other space stations under a grant of U.S. 
market access. In the past, the space station fee payor has been 
assessed only a single regulatory fee, rather than one for each 
authorization or grant of market access. The Commission also previously 
tentatively concluded that a space station attached to a GSO space 
station as part of RPO or OOS operations would not be assessed fees 
separate from, and in addition to, any regulatory fees assessed on the 
space station that is being serviced or that is having its mission 
extended. The premise underlying the prior tentative conclusion was 
that the RPO or OOS space station is operating as part of an existing 
GSO space station, rather than as a separate operational space station, 
and therefore the regulatory fee burden for the RPO or OOS space 
station would be included in the fee collected from the GSO space 
station fee payor. Upon further consideration, the Commission reversed 
its position and tentatively concluded that the requirements and 
purpose of section 9 of the Act would be better met by separately 
assessing regulatory fees on such attached RPO or OOS space stations.
    34. Comments in this proceeding support continuing not assessing 
separate regulatory fees for the same satellite, even in circumstances 
where there are multiple space station authorizations and call signs. 
No party commented on the Commission's tentative conclusion regarding 
assessing regulatory fees on RPO and OOS space stations, regardless of 
whether they are attached to another station or not.
    35. The Commission disagrees with commenters' that argue that the 
Commission should continue to assess only a single regulatory fee in 
instances where there are separately identifiable space station 
authorizations for the same satellite and where existing Commission 
rules do not permit the consolidation of authorizations after grant. 
The commenters' arguments for an exception are premised on the nature 
of the operations of the space station authorizations, but the 
Commission has determined that operational status is no longer the 
appropriate basis for determining whether to assess regulatory fees. In 
the case of a satellite that is in part U.S.-licensed, and is in part 
non-U.S. licensed, there are separate and distinct licenses and grants, 
each evidenced by a separate call sign, often to different licensees/
grantees, which cannot be consolidated under the Commission's existing 
rules into a single call sign. This is also true of an RPO or OOS space 
station, even if it is attached to another space station for servicing. 
A single regulatory fee might make sense if the Commission's fees were 
intended to recover solely the FTEs associated with regulatory 
oversight of a satellite's operations, but section 9 of the Act 
requires the Commission to recover all aspects of its licensing and 
regulatory functions--before, during, and after authorization. Where 
there are separate station authorizations for a single satellite, 
evidenced by separate call signs, the Commission finds it is more in 
line with Congress's intent to assess separate regulatory fees to 
recover the separate FTE burdens associated with each authorization. 
This is also true for small satellites or spacecrafts, which the 
Commission has similarly determined should be assessed regulatory fees 
per license or call sign, rather than per system. Accordingly, the 
Commission will assess regulatory fees based on separate license or 
grant of market access in these cases, as evidenced by separate call 
signs. To the extent that comments argue that Commission rules do not 
allow them to combine authorizations or call signs for separate space 
stations because these authorizations are not for a single NGSO system, 
the Commission finds that it is more appropriate to address this 
situation through the Space Bureau's attempts to modernize the 
licensing and regulation of these new types of space services before 
seeking changes to the regulatory fee methodology.
    36. For NGSO space stations that are not within the category of 
small satellites or spacecraft, the Commission has previously 
determined that licensing and assessment of regulatory fees is 
appropriate per system of NGSO space stations, rather than per call 
sign. This in part is due to the nature of NGSO space stations 
operating as constellations rather than individual satellites, and in 
part due to the nature of how NGSO space stations are licensed, using 
processing rounds, which may necessitate, or at least provide strong 
incentives for, applicants filing for new frequency bands for the use 
in the same constellation as new applications that are automatically 
assigned new call signs by the Commission's electronic filing system, 
International Communications Filing System (ICFS). Generally, NGSO 
licenses are able to consolidate these separate call signs under a 
single call sign post-authorization if they are part of a single 
system. This consolidation of authorizations and call signs is not 
possible, however, for a system that includes both U.S.-licensed space 
stations and non-U.S. licensed space stations, since the system would 
consist of two distinct forms of authorization: one is a license to a 
Commission-licensed space station and the other is a grant of market 
access for a communications between a non-U.S. licensed space station 
and U.S.-licensed earth stations.
    37. The Commission observes that, in instances where a NGSO system 
has some space stations licensed by the U.S., and some space stations 
licensed by another administration, there is reason to require separate 
regulatory fees based on the reasoning above that there are separate 
and distinct licenses and grants, each evidenced by a separate call 
sign, often to different licensees/grantees. The Commission declines, 
however, to change its existing policy at this time, since the record 
to date does not provide sufficient information to assess fully the 
possible impacts of a change from assessing fees on NGSO space stations 
as ``systems,'' rather than by authorizations evidenced by separate 
call signs, particularly when calculating whether a system would be 
categorized as a small or large constellation under the amended fee 
categories adopted in the Order.
    38. Co-located stations and on-orbit spares. The Space and Earth 
Station Regulatory Fee FNPRM sought comment on whether regulatory fees 
should be assessed on GSO space stations that are co-located with other 
GSO space stations or that serve as non-operational ``on-orbit spares'' 
for other operational GSO space stations. Such stations are not 
currently considered to be separably operational and have not been 
assessed regulatory fees for this reason. The Commission has observed, 
however, that separable direct FTEs are utilized to license and 
regulate these space stations. Comments largely support the 
continuation of not assessing regulatory fees on on-orbit spares and 
GSO space stations co-located with another GSO space station, although 
support is not universal.
    39. The Commission finds that the goals of section 9 are not served 
by continuing to not assess regulatory fees on space stations simply 
because they are co-located with other operational space stations or 
serve as on-orbit spares to other operational space stations. The 
premise that underlies both instances is that the space stations were 
not

[[Page 29766]]

considered to be separately operational, but the Commission has 
determined that operational status is no longer the appropriate basis 
for determining whether to assess regulatory fees. As is the case for 
stations with multiple authorizations, a single regulatory fee would 
make sense if the Commission's fees were intended to recover solely the 
regulatory oversight of satellite's operations, but section 9 of the 
Act requires the Commission to recover all aspects of its licensing and 
regulatory functions--before, during, and after authorization. In the 
case of co-located or on-orbit spare space stations, the amount of FTE 
resources required to license these space stations does not appear to 
be substantially different from that required to license other space 
stations, since staff must still evaluate the applications to determine 
compliance with the Commission's rules and policies, and such space 
stations receive licenses that confer benefits to the licensees. 
Accordingly, where there are separate station authorizations for co-
located space stations or on-orbit spare space stations, evidenced by 
separate call signs, the Commission finds it is more in line with 
Congress's intent to assess separate regulatory fees to recover the 
separate FTE burdens associated with each authorization.

D. Amendment of Existing Methodology To Establish NGSO--Small 
Constellations and NGSO--Large Constellations To Replace NGSO--Less 
Complex and NGSO--Other

    40. Under the current system, 80% of the share of NGSO space 
station fees are allocated to the NGSO--Other fee category and 20% to 
the NGSO--Less Complex fee category, after subtracting a pro rata 
amount of the total fees assessed for NGSO--Small Satellites from each 
category. These allocated fees are then divided equally among the 
number of units in each category. For fiscal year 2024, fee payors in 
the NGSO--Other fee category were assessed fees of $964,200 per unit, 
regardless of the number of space stations authorized for each fee 
payor. Payors in the NGSO--Less Complex fee category were assessed per 
unit fees of $441,925, also regardless of the number of space stations 
authorized for each fee payor. NGSO space station payors have 
previously argued that this ``one fee fits all'' assessment is unfair, 
as it assesses the same regulatory fee on an NGSO system consisting of 
100 space stations as the fee assessed for an NGSO system consisting of 
potentially 10,000 or more space stations.
    41. The Space and Earth Station Regulatory Fees FNPRM sought 
comment on two proposals to address this shortcoming. First, it sought 
comment on a proposal to create sub-categories within the existing 
NGSO--Other fee category for small and large constellations of NGSO 
space stations, based on the number of authorized space stations in a 
system. Second, it sought comment on whether to eliminate the existing 
NGSO--Less Complex fee category and assess fees on all NGSO space 
stations (other than small satellites) as small or large constellations 
or, alternatively, to create sub-categories of small and large 
constellations within the NGSO--Less Complex category.
    42. The Commission finds that the overarching goals of making its 
regulatory fee structure fair, administrable, and sustainable would be 
met by assessing regulatory fees on all NGSO space stations (other than 
those eligible for paying regulatory fees under the small satellites 
category) within new fee categories of NGSO--Small Constellations 
(fewer than 1000 authorized space stations) and NGSO--Large 
Constellations (1000 authorized space stations or more) and by 
eliminating the NGSO--Less Complex category entirely. Furthermore, the 
Commission will allocate fees between small and large constellations on 
a 60/40 basis, that is, 60% of NGSO space station fees would be 
allocated to small constellations and 40% to large constellations. As 
with its existing approach, the Commission will subtract small 
satellite fees on a pro rata basis between small and large 
constellations.
    43. First, the new methodology is fair because creation of separate 
fee categories for small and large constellations recognizes that NGSO 
space station constellations with more authorized space stations are 
likely to benefit more from the Commission's licensing and regulatory 
efforts than constellations with substantially fewer authorized space 
stations. NGSO systems with a larger number of authorized space 
stations provide service in a larger geographic area (usually globally) 
and provide more transmission capacity in order to provide higher-data 
rate, two-way connectivity. In addition, a larger number of earth 
stations are needed to support global, high-data rate two-way 
connectivity, and larger spectrum authorizations are required to 
provide the spectrum bandwidth needed for the desired services. The 
Commission finds it reasonable that such constellations benefit more 
from FTE burdens than smaller constellations and should be assessed 
greater regulatory fees, per unit.
    44. The adoption of fee categories for small and large 
constellations also ensures that the additional benefit received by 
large NGSO constellations is not linearly related to the number of 
authorized space stations. This new methodology will account for 
diminishing amounts of FTE burdens required to license and regulate 
these systems as the number of authorized space stations grows beyond a 
certain size. In the Commission's experience, the Commission finds that 
once an operator has 1000 or more authorized space stations, it is 
reasonably distinguishable from smaller constellations in terms of the 
FTE benefits received and can be separated into a category with similar 
systems for regulatory fee purposes. Once it is in this separate 
category, the regulatory fees will not increase further based on the 
number of authorized space stations. Thus, the Commission will mitigate 
the adoption of exceptionally high fees for any one particular fee 
payor when such fees may not correlate reasonably to the FTE benefits 
accrued. The majority of commenters also support the division between 
small and large constellations at 1000 or more authorized space 
stations.
    45. Second, the Commission finds that this methodology is 
administrable. Using the number of authorized space stations in an NGSO 
system to allocate FTE burdens is simpler than the current system of 
using complexity as a proxy for FTE burdens. The number of space 
stations authorized for a NGSO system is an objective measure and is 
readily available as part of the space station license or grant of 
market access. The Commission finds this is a more administrable metric 
than space station features such as mass that could rely on data that 
may not be required by, or contained in, its licensing processes, or 
that require a multi-element accounting system, without a clear 
correlation between such feature and FTE burdens.
    46. This new methodology will also lessen the probability of sudden 
or unpredictable swings in the number of units within the fee category. 
Using the number of authorized space stations will help avoid 
unpredictable and rapid shifts in fee rates from one year to the next, 
and is consistent with prior Commission use of this metric as the basis 
for its regulatory fees. Also, by eliminating the separate fee category 
for NGSO--Less Complex, all NGSO space stations (other than small 
satellites) will be placed into two tiers, which will result in a 
greater number of fee payors per tier. In turn, this lessens the

[[Page 29767]]

potential for rapid and unpredictable changes in fees from year to year 
when a single fee payor in each tier is added or removed. In contrast, 
use of more than two fee tiers to account for more granular 
distinctions in the size of NGSO space station systems would be 
susceptible to rapid shifts in regulatory fees for all space station 
payors if there is a significant reduction in the number of authorized 
GSO space stations from one year to the next because the number of 
authorized GSO space stations accounts for a large percentage of total 
units. This would also require a comparison of the FTE burdens for each 
tier with those required for a single GSO space station.
    47. Third, the Commission finds that the amended methodology 
adopted in the Order is sustainable because the fee system will have 
flexibility to adapt to changes in technologies. Notably, the amended 
methodology is not defined by technology or services provided, but 
rather solely by the number of authorized space stations in an NGSO 
system. If technologies and the space industry change, as the 
Commission expects that they will, the number of authorized space 
stations in an NGSO system is a broad metric for assessing FTE burdens 
and is likely to remain relevant. In the event that further amendments 
are needed to adjust the methodology to changes in technologies, the 
methodology adopted in the Order preserves the ability to do so.
    48. The Commission also finds that allocating a larger share to 
small constellations on a 60/40 basis between small and large 
constellations, respectively, is appropriate at this time and 
particularly sustainable as it relates to smaller constellations. 
Currently, there are substantially more small NGSO constellations than 
large NGSO constellations--an estimated 24 NGSO small constellations as 
compared to three NGSO large constellations. Going forward, the 
Commission anticipates that there will be greater growth in the number 
of authorized small constellations due to the considerable additional 
resources needed to launch and operate NGSO systems with a thousand or 
more space stations. Given this disparity in numbers, the Commission 
finds that it is reasonable that more than half of the FTE benefits 
realized by NGSO space station systems at this time are attributable to 
small constellations, in aggregate. The 60/40 split should result in 
much lower regulatory fees for small constellations on a per unit basis 
compared with large constellations, while also recognizing that small 
constellations currently take up more than 50% of the FTE burdens used 
for the licensing and regulation of NGSO space stations.
    49. The Commission makes one additional amendment to the 
methodology used to assess space station regulatory fees necessitated 
by the amendments adopted in the Order: instead of subtracting the 
amount of regulatory fees anticipated to be collected from small 
satellites on a pro rata basis between NGSO--Less Complex and NGSO--
Other, the Commission will instead subtract small satellite fees on a 
pro rata basis between small and large constellations. This maintains 
the existing approach, but makes changes to reflect the elimination of 
the NGSO--Less Complex fee category and creation of the NGSO small and 
large constellation fee categories.
    50. The Commission clarifies that fees will be assessed based on 
the total number of authorized space stations for an NGSO system, not 
just the number of space stations authorized to be simultaneously 
operating. Comments observe that the appendices in the Space and Earth 
Station Regulatory Fees FNPRM listed the number of authorized space 
stations for some systems based on the total number of space stations 
authorized over the license term, whereas for some systems the number 
was based on the total number of simultaneously-operating space 
stations that were authorized. Comments urge consistency in determining 
which space stations are authorized for regulatory fee purposes and 
advocate calculating fees based on the number of space stations 
authorized to be operational simultaneously, rather than authorized 
over the license term.
    51. Although the Commission finds that this distinction is less 
relevant under the methodology adopted in the Order than under the 
alternative methodology that the Commission is not adopting, the 
Commission clarifies that fees will be assessed based on the total 
number of authorized space stations for an NGSO system, not just the 
number of space stations authorized to be simultaneously operating. The 
methodology adopted no longer relies on operational status of a space 
station for assessing regulatory fees, so it would be inconsistent to 
use operational status, rather than authorized status, as a basis for 
assessing regulatory fees. Although comments stress that assessing fees 
solely on space stations that are authorized to be simultaneously-
operating would be consistent with the Commission's decision not to 
assess regulatory fees on on-orbit spares or co-located space stations 
that were not considered to be separably operable, such space stations 
are subject to regulatory fees under the amended methodology adopted. 
Furthermore, the Commission does not find that the record supports 
contentions that it is solely the operational status of the space 
stations that goes into assessing the FTE burdens attributable to the 
category of regulatory fees. As observed above, its regulatory fees are 
intended to recover the costs of licensing and regulation before, 
during, and after operations, so limiting regulatory fees to 
operational stations does not best serve the purpose of section 9 of 
the Act.
    52. The Commission finds that alternative proposals for assessing 
regulatory fees on NGSO space stations are more complicated to 
administer than the methodology the Commission adopts in the Order. The 
Commission declines to assess regulatory fees based on the number of 
authorizations that a fee payor holds. Such a methodology would be more 
complex to administer than the one the Commission adopts, and the 
record lacks specifics as to how to implement such a system. The 
Commission also declines to adopt a ``risk-informed'' methodology, 
which would inject policy decisions regarding the regulation of space 
stations that are not suitable for resolution in regulatory fee 
proceedings to assess regulatory fees.
    53. The Commission finds that the goals of this proceeding are best 
served by adopting, at this time, two categories for NGSO space 
stations, small and large constellations, based on a dividing line of 
1000 authorized space stations, rather than multiple categories based 
on different numbers of authorized space stations, as suggested by some 
comments. Adopting more than two tiers or categories of NGSO space 
station fees based on alternative number of authorized space stations 
is less administrable than the amended methodology the Commission 
adopts. Dividing NGSO space station systems into many tiers will result 
in a smaller number of fee payors per tier, which in turn has the 
potential to result in rapid and unpredictable changes in fees from 
year to year, if a single fee payor in each tier is added or removed. 
Simply put, having fee categories with larger number of units per 
categories is more administrable, all things being equal, as a single 
dividing line is less complex to administer and is likely to be more 
stable over time. The majority of comments support this approach, at 
least in the event that the alternative methodology is not adopted.
    54. The Commission also declines at this time to adopt a fee 
category for ``truly small'' NGSO systems with ``well under'' 100 
authorized space stations. Although comments argue that their

[[Page 29768]]

systems are closer in kind to NGSO systems authorized under the 
Commission's small satellite rules and should be assessed much lower 
regulatory fee comparable to those assessed to those systems, the 
Commission observes that the lower regulatory fees assessed for small 
satellites is based on their ability to meet certain criteria for their 
system, which permits streamlined processing of these applications and 
requires fewer FTE burdens to license and regulate such systems. This 
is not the case for all NGSO systems, however, even if the total number 
of authorized space stations in their systems is close to the ten or 
fewer space stations permitted to be authorized under a small satellite 
authorization. Accordingly, the Commission does not find that the 
record, at this time, supports a finding that creating new fee 
categories for NGSO space stations achieves its goals better than the 
small and large constellation categories that the Commission adopts. In 
addition, the Commission dismisses calls to revisit and revise the 
Commission's prior decision to allocate regulatory fees between GSO and 
NGSO space stations on a 60/40 basis, rather than the prior 80/20 
basis, because they are outside the scope of proposals for which 
comment was sought in the Space and Earth Station Regulatory Fees FNPRM 
and they raise no new arguments that have not already been fully 
considered and rejected by the Commission.

E. Adoption for Fiscal Year 2025

    55. The Commission adopts the amendments to its methodology for 
assessing space and earth station regulatory fees in time for them to 
be effective for fiscal year 2025. Comments widely support making the 
changes effective immediately, given the notice of the intended changes 
since early 2024 and the increased fairness and administrability of the 
amended methodology. The Commission declines to postpone until fiscal 
year 2026 the assessment of regulatory fees on GSO space stations that 
were considered to be non-operational and not previously subject to 
regulatory fees, as proposed by one commenter. Although it is argued 
that additional time is needed for fee payors to plan for such fees and 
to allow them to assess whether to deactivate non-operational space 
stations at an earlier date than planned, the Commission finds that 
there has been ample time for fee payors to plan for the possibility of 
such fees and to take actions in anticipation of such fees. 
Accordingly, the Commission will immediately provide notice to Congress 
of these amendments pursuant to section 9 of the Act so that they can 
become effective after 90 days.

F. Earth Station Regulatory Fees

    56. The Commission declines to create additional subcategories of 
earth station regulatory fees at this time. Both the notice of proposed 
rulemaking and the further notice in this proceeding sought comment on 
whether the creation of additional earth station fee categories was 
feasible and whether additional fee categories would better 
differentiate the amount of regulatory fee burdens with different types 
of earth station licenses. The Commission determines that the record 
does not support creation of additional categories of earth station 
regulatory fees at this time.
    57. The Space and Earth Station Regulatory Fees NPRM sought comment 
on the question of whether to create subcategories of earth station 
regulatory fee payors, in addition to the existing single category of 
``Transmit/Receive & Transmit Only (per authorization or 
registration).'' As examples, the Commission asked if the former 
distinct fee categories for Very Small Aperture Terminals (VSAT), 
Mobile-Satellite Earth Stations, and Fixed Earth Stations should be 
reinstated. Comments in response to the Space and Earth Station 
Regulatory Fees NPRM expressed doubt that the creation of subcategories 
of earth stations with differing fee amounts is feasible and urged that 
the record be further developed before creating subcategories of earth 
station regulatory fees. The Space and Earth Station Regulatory Fees 
FNPRM sought further comment on these issues, particularly whether 
there are certain types of earth station licenses that require more FTE 
burdens to license and regulate, for which a higher regulatory fee 
should be assessed?
    58. The record continues to be insufficient to determine that the 
creation of additional categories of earth station regulatory fees at 
this time is either necessary or feasible. The majority of comments 
continue to oppose the creation of additional earth station regulatory 
fee categories as difficult to administer fairly or efficiently, and 
having limited utility given the relatively small variation in fees any 
changes would produce. Although some comments suggest the possibility 
of creating a separate fee category for blanket licensed earth 
stations, the record is not sufficiently developed as to which earth 
stations would be included in this category since there are many 
different types of earth stations that can be authorized under blanket 
licenses, such as earth stations in motion (ESIMS), mobile-satellite 
service earth stations, and fixed-satellite service VSAT networks. 
Furthermore, at this time and based on the record before us, the 
Commission is not able to attribute with any degree of reasonableness 
the allocation of FTE burdens attributable to blanket earth stations, 
either by individual service type or collectively, compared to non-
blanket licensed stations. It may be possible to do so with a more 
complete record, but the Commission is not able to do so for fiscal 
year 2025 and declines to do so now.
    59. The Commission also declines to assess regulatory fees on 
registered receive-only earth stations, which currently are not 
assessed regulatory fees. The registration of receive-only earth 
stations is not an authorization, but rather a database entry to record 
the existence of an earth station that is entitled to protection from 
interference under rules adopted for other services. The Commission's 
experience is that such registrations typically require few, if any, 
FTE burdens to process or regulate, and therefore it is unnecessary to 
re-create a separate regulatory fee category for such stations.

IV. Final Regulatory Flexibility Analysis

    60. As required by the Regulatory Flexibility Act of 1980, as 
amended (RFA), the Commission incorporated an Initial Regulatory 
Flexibility Analysis (IRFA) in the Space and Earth Station Regulatory 
Fees FNPRM. The Commission sought written public comment on the 
proposals in the Space and Earth Station Regulatory Fees FNPRM, 
including comment on the IRFA. No comments were filed addressing the 
IRFA. This Final Regulatory Flexibility Analysis (FRFA) conforms to the 
RFA.

A. Need for, and Objectives of, the Rules

    61. The Commission is required by Congress pursuant to section 9 of 
the Act to assess and collect regulatory fees each year to recover the 
regulatory costs associated with the Commission's oversight and 
regulatory activities in an amount that can reasonably be expected to 
equal the amount of its annual appropriation. As part of last year's 
adoption of regulatory fees, the Commission noted that FY 2023 would be 
the last year where the Commission will do so for the International 
Bureau, given the creation of the Space Bureau, and Office of 
International Affairs. The Commission also noted that an examination of 
the regulatory fees, and categories for NGSO space stations

[[Page 29769]]

would be useful in light of changes resulting from the creation of the 
Space Bureau, and as part of a more holistic review of the FTE burden 
of the Space Bureau in FY 2024. In FY 2024, the Commission took certain 
steps to revise regulatory fees for space and earth station payors, but 
also determined that further consideration, as part of a future notice 
of proposed rulemaking, would be beneficial. The Space and Earth 
Station Regulatory Fees FNPRM continued the Commission's examination 
and review of regulatory fees for space and earth station payors 
regulated by the new Space Bureau, specifically seeking comment on a 
range of proposed changes to the assessment of regulatory fees for 
space and earth stations remaining from the FY 2024 Space and Earth 
Station Regulatory Fees NPRM. The Commission examined and sought 
comment on assessing regulatory fees on authorized, but not operational 
space and earth stations; using an alternative methodology for 
assessing space station regulatory fees; establishing tiers with sub-
categories for small and large constellations of NGSO space stations 
within the existing Space Stations (Non-Geostationary Orbit)--Other fee 
category based on the number of authorized space stations in the NGSO 
system; and creating new sub-categories of earth station regulatory 
fees.
    62. The goal of these proposals is to update the regulatory fees 
and categories for earth and space stations in light of changes 
resulting from the creation of the Space Bureau and as part of a more 
holistic review of the regulatory fees for earth and space stations. 
The Commission also sought to implement changes to make regulatory fees 
more equitable, administratively manageable, sustainable, and to 
provide the Commission flexibility to evolve and make adjustments as 
the space industry continues to evolve.
    63. In the Order, the Commission takes steps towards these goals by 
adopting changes to assess regulatory fees on stations once they are 
authorized, instead of the current process of assessing regulatory fees 
when the stations are certified to be operational. The Commission also 
splits existing regulatory fee categories for Space Stations (Non-
Geostationary Orbit) into two new fee categories: small constellations 
(fewer than 1000 authorized space stations) and large constellations 
(1000 authorized space stations or more) to better distinguish between 
space station regulatees and to more accurately apportion fee burdens 
among them. This delineation should result in lower per unit regulatory 
fees for the majority of small and other space station fee payors 
compared to fiscal year 2024. Additionally, the Commission adopts a fee 
assessment approach that broadens the base of regulatory fee payors to 
better align fees with the benefits of regulation and that is less 
subjective than the current system that allocates fees based on the 
estimated ``complexity'' of an NGSO system.

B. Summary of Significant Issues Raised by Public Comments in Response 
to the IRFA

    64. No comments were filed addressing the impact of the proposed 
rules on small entities.

C. Response to Comments by the Chief Counsel for Advocacy of the Small 
Business Administration

    65. Pursuant to the Small Business Jobs Act of 2010, which amended 
the RFA, the Commission is required to respond to any comments filed by 
the Chief Counsel for Advocacy of the Small Business Administration 
(SBA), and provide a detailed statement of any change made to the 
proposed rules as a result of those comments. The Chief Counsel did not 
file any comments in response to the proposed rules in this proceeding.

D. Description and Estimate of the Number of Small Entities to Which 
the Rules Will Apply

    66. The RFA directs agencies to provide a description of, and where 
feasible, an estimate of the number of small entities that may be 
affected by the rules adopted herein. The RFA generally defines the 
term ``small entity'' as having the same meaning as under the Small 
Business Act. In addition, the term ``small business'' has the same 
meaning as the term ``small business concern'' under the Small Business 
Act.'' A ``small business concern'' is one which: (1) is independently 
owned and operated; (2) is not dominant in its field of operation; and 
(3) satisfies any additional criteria established by the SBA.
    67. Small Businesses, Small Organizations, Small Governmental 
Jurisdictions. The Commission's actions, over time, may affect small 
entities that are not easily categorized at present. The Commission 
therefore describes, at the outset, three broad groups of small 
entities that could be directly affected herein. First, while there are 
industry specific size standards for small businesses that are used in 
the regulatory flexibility analysis, according to data from the SBA's 
Office of Advocacy, in general a small business is an independent 
business having fewer than 500 employees. These types of small 
businesses represent 99.9% of all businesses in the United States, 
which translates to 34.75 million businesses.
    68. Next, the type of small entity described as a ``small 
organization'' is generally ``any not-for-profit enterprise which is 
independently owned and operated and is not dominant in its field.'' 
The Internal Revenue Service (IRS) uses a revenue benchmark of $50,000 
or less to delineate its annual electronic filing requirements for 
small exempt organizations. Nationwide, for tax year 2022, there were 
approximately 530,109 small exempt organizations in the U.S. reporting 
revenues of $50,000 or less according to the registration and tax data 
for exempt organizations available from the IRS.
    69. Finally, the small entity described as a ``small governmental 
jurisdiction'' is defined generally as ``governments of cities, 
counties, towns, townships, villages, school districts, or special 
districts, with a population of less than fifty thousand.'' U.S. Census 
Bureau data from the 2022 Census of Governments indicate there were 
90,837 local governmental jurisdictions consisting of general purpose 
governments and special purpose governments in the United States. Of 
this number, there were 36,845 general purpose governments (county, 
municipal, and town or township) with populations of less than 50,000 
and 11,879 special purpose governments (independent school districts) 
with enrollment populations of less than 50,000. Accordingly, based on 
the 2022 U.S. Census of Governments data, the Commission estimates that 
at least 48,724 entities fall into the category of ``small governmental 
jurisdictions.''
    70. Direct Broadcast Satellite (DBS) Service. DBS service is a 
nationally distributed subscription service that delivers video and 
audio programming via satellite to a small parabolic ``dish'' antenna 
at the subscriber's location. DBS is included in the Wired 
Telecommunications Carriers industry which comprises establishments 
primarily engaged in operating and/or providing access to transmission 
facilities and infrastructure that they own and/or lease for the 
transmission of voice, data, text, sound, and video using wired 
telecommunications networks. Transmission facilities may be based on a 
single technology or combination of technologies. Establishments in 
this industry use the wired telecommunications network facilities that 
they operate to provide a variety of services, such as wired telephony 
services, including Voice over internet

[[Page 29770]]

Protocol (VoIP) services, wired (cable) audio and video programming 
distribution; and wired broadband internet services. By exception, 
establishments providing satellite television distribution services 
using facilities and infrastructure that they operate are included in 
this industry.
    71. The SBA small business size standard for Wired 
Telecommunications Carriers classifies firms having 1,500 or fewer 
employees as small. U.S. Census Bureau data for 2017 show that 3,054 
firms operated in this industry for the entire year. Of this number, 
2,964 firms operated with fewer than 250 employees. Based on this data, 
the majority of firms in this industry can be considered small under 
the SBA small business size standard. According to Commission data 
however, only two entities provide DBS service--DIRECTV (owned by AT&T) 
and DISH Network, which require a great deal of capital for operation. 
DIRECTV and DISH Network both exceed the SBA size standard for 
classification as a small business. Therefore, the Commission must 
conclude based on internally developed Commission data, in general DBS 
service is provided only by large firms.
    72. Fixed Satellite Small Transmit/Receive Earth Stations. Neither 
the SBA nor the Commission have developed a small business size 
standard specifically applicable to Fixed Satellite Small Transmit/
Receive Earth Stations. Satellite Telecommunications is the closest 
industry with an SBA small business size standard. The SBA size 
standard for this industry classifies a business as small if it has $44 
million or less in annual receipts. For this industry, U.S. Census 
Bureau data for 2017 show that there was a total of 275 firms that 
operated for the entire year. Of this total, 242 firms had revenue of 
less than $25 million. Consequently, using the SBA's small business 
size standard most fixed satellite small transmit/receive earth 
stations can be considered small entities. The Commission notes 
however, that the SBA's revenue small business size standard is 
applicable to a broad scope of satellite telecommunications providers 
included in the U.S. Census Bureau's Satellite Telecommunications 
industry definition. Additionally, the Commission does not request nor 
collect annual revenue information from satellite telecommunications 
providers, and is therefore unable to more accurately estimate the 
number of fixed satellite small transmit/receive earth stations that 
would be classified as a small business under the SBA size standard.
    73. Fixed Satellite Very Small Aperture Terminal (VSAT) Systems. 
Neither the SBA nor the Commission have developed a small business size 
standard specifically applicable to Fixed Satellite Very Small Aperture 
Terminal (VSAT) Systems. A VSAT is a relatively small satellite antenna 
used for satellite-based point-to-multipoint data communications 
applications. VSAT networks provide support for credit verification, 
transaction authorization, and billing and inventory management. 
Satellite Telecommunications is the closest industry with an SBA small 
business size standard. The SBA size standard for this industry 
classifies a business as small if it has $44 million or less in annual 
receipts. For this industry, U.S. Census Bureau data for 2017 show that 
there were a total of 275 firms that operated for the entire year. Of 
this total, 242 firms had revenue of less than $25 million. Thus, for 
this industry under the SBA size standard, the Commission estimates 
that the majority of Fixed Satellite Very Small Aperture Terminal 
(VSAT) System licensees are small entities. The Commission notes 
however, that the SBA's revenue small business size standard is 
applicable to a broad scope of satellite telecommunications providers 
included in the U.S. Census Bureau's Satellite Telecommunications 
industry definition. Additionally, the Commission does not request nor 
collect annual revenue information from satellite telecommunications 
providers, and is therefore unable to more accurately estimate the 
number of Fixed Satellite VSAT System licenses that would be classified 
as a small business under the SBA size standard.
    74. Home Satellite Dish (HSD) Service. HSD or the large dish 
segment of the satellite industry is the original satellite-to-home 
service offered to consumers and involves the home reception of signals 
transmitted by satellites operating generally in the C-band frequency. 
Unlike DBS, which uses small dishes, HSD antennas are between four and 
eight feet in diameter and can receive a wide range of unscrambled 
(free) programming and scrambled programming purchased from program 
packagers that are licensed to facilitate subscribers' receipt of video 
programming. Because HSD provides subscription services, HSD falls 
within the industry category of Wired Telecommunications Carriers. The 
SBA small business size standard for Wired Telecommunications Carriers 
classifies firms having 1,500 or fewer employees as small. U.S. Census 
Bureau data for 2017 show that there were 3,054 firms that operated for 
the entire year. Of this total, 2,964 firms operated with fewer than 
250 employees. Thus, under the SBA size standard, the majority of firms 
in this industry can be considered small.
    75. Mobile Satellite Earth Stations. Neither the SBA nor the 
Commission have developed a small business size standard specifically 
applicable to Mobile Satellite Earth Stations. Satellite 
Telecommunications is the closest industry with a SBA small business 
size standard. The SBA small business size standard classifies a 
business with $44 million or less in annual receipts as small. For this 
industry, U.S. Census Bureau data for 2017 show that there were 275 
firms that operated for the entire year. Of this number, 242 firms had 
revenue of less than $25 million. Thus, for this industry under the SBA 
size standard, the Commission estimates that the majority of Mobile 
Satellite Earth Station licensees are small entities. The Commission 
notes however, that the SBA's revenue small business size standard is 
applicable to a broad scope of satellite telecommunications providers 
included in the U.S. Census Bureau's Satellite Telecommunications 
industry definition. Additionally, based on Commission data as of 
February 1, 2024, there were 16 Mobile Satellite Earth Stations 
licensees. The Commission does not request nor collect annual revenue 
information from satellite telecommunications providers, and is 
therefore unable to estimate the number of Mobile Satellite Earth 
Station licensees that would be classified as a small business under 
the SBA size standard.
    76. Satellite Master Antenna Television (SMATV) Systems, also known 
as Private Cable Operators (PCOs). SMATV systems or PCOs are video 
distribution facilities that use closed transmission paths without 
using any public right-of-way. They acquire video programming and 
distribute it via terrestrial wiring in urban and suburban multiple 
dwelling units such as apartments and condominiums, and commercial 
multiple tenant units such as hotels and office buildings. SMATV 
systems or PCOs are included in the Wired Telecommunications Carriers' 
industry which includes wireline telecommunications businesses. The SBA 
small business size standard for Wired Telecommunications Carriers 
classifies firms having 1,500 or fewer employees as small. U.S. Census 
Bureau data for 2017 show that there were 3,054 firms in this industry 
that operated for the entire year. Of this total, 2,964 firms operated 
with fewer than 250

[[Page 29771]]

employees. Thus, under the SBA size standard, the majority of firms in 
this industry can be considered small.
    77. Satellite Telecommunications. This industry comprises firms 
``primarily engaged in providing telecommunications services to other 
establishments in the telecommunications and broadcasting industries by 
forwarding and receiving communications signals via a system of 
satellites or reselling satellite telecommunications.'' Satellite 
telecommunications service providers include satellite and earth 
station operators. The SBA small business size standard for this 
industry classifies a business with $44 million or less in annual 
receipts as small. U.S. Census Bureau data for 2017 show that 275 firms 
in this industry operated for the entire year. Of this number, 242 
firms had revenue of less than $25 million. Consequently, using the 
SBA's small business size standard most satellite telecommunications 
service providers can be considered small entities. The Commission 
notes however, that the SBA's revenue small business size standard is 
applicable to a broad scope of satellite telecommunications providers 
included in the U.S. Census Bureau's Satellite Telecommunications 
industry definition. Additionally, the Commission neither requests nor 
collects annual revenue information from satellite telecommunications 
providers, and is therefore unable to more accurately estimate the 
number of satellite telecommunications providers that would be 
classified as a small business under the SBA size standard.
    78. All Other Telecommunications. This industry is comprised of 
establishments primarily engaged in providing specialized 
telecommunications services, such as satellite tracking, communications 
telemetry, and radar station operation. This industry also includes 
establishments primarily engaged in providing satellite terminal 
stations and associated facilities connected with one or more 
terrestrial systems and capable of transmitting telecommunications to, 
and receiving telecommunications from, satellite systems. Providers of 
internet services (e.g. dial-up ISPs) or VoIP services, via client-
supplied telecommunications connections are also included in this 
industry. The SBA small business size standard for this industry 
classifies firms with annual receipts of $40 million or less as small. 
U.S. Census Bureau data for 2017 show that there were 1,079 firms in 
this industry that operated for the entire year. Of those firms, 1,039 
had revenue of less than $25 million. Based on this data, the 
Commission estimates that the majority of ``All Other 
Telecommunications'' firms can be considered small.

E. Description of Economic Impact and Projected Reporting, 
Recordkeeping and Other Compliance Requirements for Small Entities

    79. The RFA directs agencies to describe the economic impact of 
proposed rules on small entities, as well as projected reporting, 
recordkeeping and other compliance requirements, including an estimate 
of the classes of small entities which will be subject to the 
requirement and the type of professional skills necessary for 
preparation of the report or record.
    80. The Order does not adopt any changes to the Commission's 
current reporting or recordkeeping requirements for small entities. The 
Order does however adopt changes to the regulatory fee payment 
structure applicable to small and other stations that subjects a 
licensee or grantee to fee payment obligations when the license or 
grant of market access is received from the Commission. As a result, a 
small licensee or grantee will be subject to regulatory fee payment 
requirements sooner. In addition, the broadened base of regulatory fee 
payors which recovers fees from all licensees who benefit from the 
Space Bureau's licensing and regulatory activities should lower the per 
unit regulatory fee burden by increasing the number of units on which 
fees are assessed and may result in reduced fees for some small 
entities.
    81. There could also be a positive economic impact for small 
entities from Commission's eliminations of the existing regulatory fee 
categories for Space Stations (Non-Geostationary Orbit) and creation of 
a distinct fee category for small constellations having less than 1000 
authorized space stations which the Commission believes appropriately 
apportion fees commensurate with Space Bureau resources attributable to 
regulating these licensees and grantees, and will remove the ``one-fee 
fits all'' assessment commenters considered unfair. Further, the 
Commission finds it reasonable that larger constellations that benefit 
more from the use of Commission resources than smaller constellations, 
should be assessed greater regulatory fees, per unit. Lastly, 
consistent with the Commission's objective of revising the current 
regulatory fee structure to be more fair, administrable, and 
sustainable, small entities will be impacted by its adoption of 
regulatory fees on all NGSO space stations (other than those eligible 
for paying regulatory fees under the small satellites category) within 
new fee categories of NGSO--Small Constellations (fewer than 1000 
authorized space stations) and NGSO--Large Constellations (1000 
authorized space stations or more) and by eliminating the NGSO--Less 
Complex category entirely. Fees between small and large NGSO 
constellations will be apportioned on a 60/40 basis, with 60% of NGSO 
space station fees allocated to small constellations and 40% to large 
constellations. Consistent with the Commission's existing approach 
small satellite fees will be deducted on a pro rata basis between small 
and large constellations.
    82. The Commission considered a proposal from the Space and Earth 
Station Regulatory Fee FNPRM to assess regulatory fees in instances 
where there are separately identifiable space station authorizations, 
but which the space stations have not been considered to be separably 
operational and therefore have not been subject to separate regulatory 
fees under Commission rules. While a single regulatory fee might make 
sense if regulatory fees were intended to recover solely the FTE 
burdens associated with regulatory oversight of satellite's operations, 
section 9 of the Act requires the Commission to recover all aspects of 
its licensing and regulatory functions--before, during, and after 
authorization. Thus, where there are separate station authorizations 
for a single satellite, evidenced by separate call signs, the 
Commission finds it is more in line with Congress's intent to assess 
separate regulatory fees to recover the separate FTE burdens associated 
with each authorization, which could impact small entities.
    83. The Space and Earth Station Regulatory Fee FNPRM also sought 
comment on whether regulatory fees should be assessed on small and 
other GSO space stations that are co-located with other GSO space 
stations or that serve as non-operational ``on-orbit spares'' for other 
operational GSO space stations. Finding that the goals of section 9 of 
the Communications Act are not served by continuing to exclude space 
stations from regulatory fees simply because they are co-located with 
other operational space stations or serve as on-orbit spares to other 
operational space stations, the Commission will now assess regulatory 
fees on small and other GSO space stations co-located with other GSO 
space station. The premise that underlies exclusion in both instances 
is that the space stations were not considered to be separately 
operational, but the Commission has determined that operational status 
is no

[[Page 29772]]

longer the appropriate basis for determining whether to assess 
regulatory fees. As is the case for stations with multiple 
authorizations, a single regulatory fee would make sense if regulatory 
fees were intended to recover solely the regulatory oversight of 
satellite's operations, but section 9 of the Act requires the 
Commission to recover all aspects of licensing and regulatory 
functions--before, during, and after authorization. In the case of co-
located or on-orbit spare space stations, the amount of FTE burdens 
required to license these space stations does not appear to be 
substantially different from that required to license other space 
stations, since staff must still evaluate the applications to determine 
compliance with the Commission's rules and policies, and such space 
stations receive licenses that confer benefits to the licensees.
    84. Small and other regulated entities are required to pay 
regulatory fees on an annual basis. The cost of compliance with the 
annual regulatory assessment for small entities is the amount assessed 
for their regulatory fee category based on the rules adopted in the 
Order and should not require small entities to hire professionals to 
comply.
    85. The regulatory fees resulting from the Order will be payable in 
FY 2025, and small entities that qualify can take advantage of the 
exemption from payment of regulatory fees allowed under the de minimis 
threshold. Under the Commission's rules, small and other entities may 
request a waiver, reduction, and/or deferral of their regulatory fees. 
The waiver process provides smaller entities that may not be familiar 
with the Commission's procedural filing rules an easier filing process 
than their larger counterparts.

F. Discussion of Significant Alternatives Considered That Minimize the 
Significant Economic Impact on Small Entities

    86. The RFA requires an agency to provide, ``a description of the 
steps the agency has taken to minimize the significant economic impact 
on small entities. . .including a statement of the factual, policy, and 
legal reasons for selecting the alternative adopted in the final rule 
and why each one of the other significant alternatives to the rule 
considered by the agency which affect the impact on small entities was 
rejected.''
    87. In the Order, the Commission considered but declined to adopt 
an alternative methodology with a tiered structure for assessing space 
station regulatory fees that eliminates the distinction between GSO, 
NGSO, and all the subcategories of NGSO, while preserving a separate 
fee category for small satellites, in favor of the proposal in the 
Space and Earth Station Regulatory Fees FNPRM to assess regulatory fees 
on stations under the existing methodology once they are authorized, 
versus when the stations are certified to be operational. While there 
may have been some been some benefit to small entities with the tiered 
approach alternative methodology, a fee structure that allocates 
payment obligations in proportion to the use of Commission resources 
associated with of oversight of licensees, and grantees, and broadening 
the base of regulatory fee payors thereby spreading the recovery of 
fees from all licensees who benefit from the Space Bureau's licensing 
and regulatory activities, better achieves the Commission's compliance 
with the objectives of section 9 of the Act. The impact for small 
entities is potentially reduced since lowering the per unit regulatory 
fee burden by increasing the number of units on which fees are assessed 
allows benefits to accrue to all space and earth station licensees. 
Comments in response to the Space and Earth Station Regulatory Fees 
FNPRM strongly support assessing regulatory fees when space and earth 
stations are authorized, rather than when they are operational. In 
addition, the record did not provide a sufficient basis for assessing a 
separate, lower fee for stations that are authorized, but not yet 
operational. The Commission also considered but declined to adopt an 
approach that would exclude assessment of fees on small and other space 
stations that are authorized solely for TT&C operations. While fee 
assessment on such space stations has the potential to impose costs and 
create financial risk for these space station fee payors, the 
Commission determined that these concerns do not outweigh the need to 
assess regulatory fees on regulatees of the same class who benefit from 
FTE burdens. TT&C communications are still radiocommunications 
authorized by the Commission and they are subject to regulatory 
oversight by the Commission. Significant FTE burdens are involved with 
the licensing of stations, even before a station becomes operational, 
and staff expertise is utilized by the industry before, during, and 
after an application (including modifications thereof) are filed. This 
also applies to space and earth stations that are used solely for TT&C. 
Thus, the Commission determined at this time that there is insufficient 
basis to find that regulatory fees should not be assessed on TT&C-only 
space stations. The Commission expects, however, to reexamine in a 
future proceeding whether it is feasible to ascertain whether fewer FTE 
burdens can be reasonably ascribed to the licensing and regulatory 
oversight of space stations authorized solely for TT&C communications, 
so that a new, separate fee category might be able to be created for 
such stations.
    88. As discussed in the section E above, the two new fee 
categories, ``Space Stations (Non-geostationary orbit)--Small 
Constellations (fewer than 1,000 authorized space stations)'' and 
``Space Stations (Non-geostationary orbit)--Large Constellations (1,000 
or more authorized space stations),'' will likely benefit small 
entities. By eliminating the separate fee category for ``Less Complex'' 
space stations, all non-geostationary orbit space stations (other than 
small satellites) will be placed into two tiers, which will result in a 
greater number of fee payors per tier. In turn, the probability of 
sudden or unpredictable swings in the number of units within the fee 
category will be decreased, as well as the potential for rapid and 
unpredictable changes in fees from year to year when a single fee payor 
in each tier is added or removed. These new space station 
categorizations are reasonable and fair because creation of separate 
fee categories for small and large constellations recognizes that non-
geostationary orbit space station constellations with more authorized 
space stations are likely to benefit more from the Commission's 
licensing and regulatory efforts than constellations with substantially 
fewer authorized space stations. Further, using the number of 
authorized space stations in an non-geostationary orbit satellite 
system to allocate FTE burdens is simpler than the current system of 
using complexity as a proxy for FTE burdens.
    89. Acutely aware of the financial impact of regulatory fees, 
particularly on smaller and less capitalized space companies, the 
Commission retained the existing regulatory fees methodology with 
targeted modifications rather than adopting a completely different 
alternative methodology for assessing space station regulatory fees.
    90. The Commission is presently focused on reducing the total fee 
burden to be divided among regulated entities by making the Space 
Bureau's operations more efficient. It finds that continued use of the 
existing methodology will maintain stability and prevent unnecessary 
disruption while broader reforms are ongoing. At the same time, 
targeted changes to the existing methodology will substantially reduce 
the fee burden for a large class

[[Page 29773]]

of payors. Accordingly, the Commission finds that now is not the time 
to adopt a wholly new methodology for space station regulatory fees. 
Rather, the overarching goals of fair, administrable, and sustainable 
regulatory fees can equally be achieved by targeted changes to the 
existing methodology. The Commission observes that the changes in the 
space industry that led to the creation of the Space Bureau and the 
Commission's re-examination of space and earth station regulatory fees 
are still ongoing. Any wholesale departure from the existing 
methodology at this juncture runs significant the risk of adopting a 
new fee methodology that still reflects past assumptions about 
licensing and regulation of space and earth stations. Comments agree 
that the Commission should not undertake a major overhaul of its space 
and earth station regulatory fee methodologies in light of the ongoing 
modernization efforts.
    91. Finally, in light of an insufficient record to determine that 
the creation of additional categories of earth station regulatory fees 
at this time is either necessary or feasible, the Commission considered 
but declined to adopt new categories of regulatory fees for earth 
stations. The majority of comments continue to oppose the creation of 
additional earth station regulatory fee categories as difficult to 
administer fairly or efficiently, and having limited utility given the 
relatively small variation in fees any changes would produce. On the 
other hand although there are some comments that suggest the 
possibility of creating a separate fee category for blanket licensed 
earth stations, the record is not sufficiently developed as to which 
earth stations would be included in this category since there are many 
different types of earth stations that can be authorized under blanket 
licenses, such as earth stations in motion, mobile-satellite service 
earth stations, and fixed-satellite service VSAT networks. Furthermore, 
at this time and based on the record, the Commission is not able to 
attribute with any degree of reasonableness the allocation of FTE 
burdens to blanket earth stations, either by individual service type or 
collectively, compared to non-blanket licensed stations.

Federal Communications Commission.
Marlene Dortch,
Secretary.
[FR Doc. 2025-12579 Filed 7-3-25; 8:45 am]
BILLING CODE 6712-01-P


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