Pitched roof

3 April 2026

FCC considers “spectrum abundance” for emergent space operations

The Federal Communications Commission (FCC or Commission) has adopted a Notice of Proposed Rulemaking (NPRM) titled “Spectrum Abundance for Weird Space Stuff,” seeking comment on measures to expand and clarify spectrum access for “emergent space operations,” which are identified as spacecraft or operations using radio spectrum for control or communications that are not traditional communications satellites.

The NPRM aims to address the acute shortage of readily accessible spectrum for telemetry, tracking, and command (TT&C); leverage existing allocations; explore new allocations; and consider market‑based access mechanisms. The Commission predicts that ultimate adoption of the NPRM’s proposals could result in at least 25 MHz of spectrum for access by emergent space operations.

Key considerations in the NPRM

Establishing regulatory clarity using existing allocations and traditional regulatory classifications

Through the NPRM, the FCC aims to establish regulatory clarity for emergent space operations, including in-space servicing, assembly, and manufacturing (ISAM); rendezvous and proximity operations; and other novel missions, by codifying existing policies and exploring new spectrum access pathways. To do so, the FCC seeks comment on several proposals, including:

  • Spectrum “piggybacking”: The FCC proposes to formally codify frequency “piggybacking,” a practice which allows a servicing spacecraft to communicate using the authorized frequencies of a consenting client spacecraft during operations performed in close proximity or while connected. While this practice has been previously authorized by the Commission on a case-by-case basis, the FCC is considering how to codify the practice and seeks comment on practical implementation, such as how to define “client spacecraft,” what constitutes requisite certificates or evidence of consent for regulatory approval, how to broadly address a wide range of use-case scenarios, and how to handle piggybacking with non-United States licensed spacecraft.

  • Standalone TT&C in FSS bands: The FCC seeks input regarding whether emergent space operators should be permitted to conduct TT&C functions within existing Fixed-Satellite Service (FSS) allocations on an unprotected, noninterference basis, subject to coordination with incumbent users. The FCC specifically requests feedback from stakeholders regarding whether unprotected status would provide sufficient reliability for command-and-control functions critical to spacecraft safety. The FCC also queries whether the proposed framework could be applicable to Mobile Satellite Service (MSS) and Broadband Satellite Services (BSS) spectrum allocations.

  • Broadening the definition of TT&C: The FCC is considering whether TT&C definitions should be interpreted more broadly to encompass video and wideband data downlinks during maneuvers such as docking or inhabitable spacecraft operations, while seeking comment on whether such expanded use could crowd out existing narrowband TT&C operations.

  • Use of existing service allocations, including EESS and SRS: The FCC tentatively concludes that it should continue to evaluate, on a case-by-case basis, whether an ISAM operator’s proposed communications fit within existing service allocation definitions, rather than preemptively excluding any allocation. Specifically, the FCC declines to categorically bar access to Earth Exploration-Satellite Service (EESS) bands while emphasizing that stringent International Telecommunication Union interference-protection standards remain in force. The FCC also proposes that communications supporting emergent space operations funded by NASA or other federal research agencies could qualify under the Space Research Service (SRS) allocation, and it seeks comment on adding a US Table footnote to formalize this pathway.

Unlocking more spectrum for emergent operations

The FCC is also exploring ways to make spectrum already allocated for non-Federal use available for emergent space operations, particularly in geographic areas where it is underutilized, while avoiding interference with existing users. In particular, the Commission seeks comment on what changes to the US Table and its rules would be necessary to enable more intensive and flexible domestic spectrum use.

2320–2345 MHz (SDARS band)

The FCC proposes adding a secondary allocation for Space Operation Service (SOS) in the earth-to-space direction in the 2320–2345 MHz band to support TT&C functions for emergent space operations. To facilitate this proposal, the FCC seeks to add the secondary allocation to the US Table and to permit SiriusXM, the exclusive licensee in the SDARS band, to lease spectrum for individual or ground-station-as-a-service earth stations for emergent spacecraft command operations.

The Commission has identified three factors that make the SDARS band attractive for TT&C use:

  1. The SDARS band sits within the S-band near the 2025–2110 MHz and 2200–2290 MHz bands, which are used for Federal and certain non-Federal space operations, demonstrating a likelihood that the SDARS band could be used similarly.

  2. The SDARS band has very few incumbent users, reducing coordination complexity.

  3. SiriusXM, the current licensee in the band, does not currently serve Hawaii, northern Alaska, or US Pacific territories, creating geographic areas where new operations could proceed with reduced interference risk.

Under the adopted NPRM, the proposed SOS allocation would be secondary to the existing primary BSS allocation and limited to the earth-to-space direction, reflecting a tentative finding that uplink transmissions are less likely to interfere with SiriusXM's service links to subscribers. The FCC further proposes to require applicants to certify that operations have been coordinated with and approved by SiriusXM and seeks further stakeholder input regarding codification of protective technical requirements, such as power limits, antenna elevation angle restrictions, and geographic limitations.

Furthermore, the FCC seeks comment on several alternative measures, including access through a non-governmental footnote rather than a secondary allocation, permitting operations in defined geographic areas without SiriusXM coordination, and using competitive bidding.

Allocations to non-SDARS bands

The FCC is exploring whether frequency bands beyond 2320–2345 MHz, particularly those adjacent to it, could likewise be opened for command uplinks to non-communications spacecraft engaged in emergent space operations. Although the NPRM presents the 2320–2345 MHz band as particularly suitable, the Commission seeks input on whether neighboring bands – including the 2315–2320 MHz and 2345–2350 MHz and the 2305–2315 MHz and 2350–2360 MHz bands – share similar characteristics that would support more intensive use for emergent space operations.

Intersatellite links for emergent space operations

The FCC also seeks comment on proposals related to the use of Commission-licensed satellites and intersatellite links to provide communications for use in emergent space operations. First, the FCC proposes to permit licensed operators to use their licensed links to provide downlink communications without requiring license modifications or additional authorizations. Second, the FCC proposes to permit licensed space stations to use intersatellite links generally for both downlink and uplink communications for TT&C and payload data transmission. Additionally, the FCC seeks comment on whether notification to the Commission should be required for the latter proposal.

Next steps

The FCC voted to adopt the NPRM during its open meeting on March 26, 2026 and seeks public comment on its proposals. Comments are due 30 days after publication in the Federal Register, with reply comments due 60 days after publication.

For more information, please contact the authors.

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