# FCC Part 100 Space Modernization Rulemaking

**Type:** Regulatory framework proposal
**Status:** NPRM stage (as of May 2026)
**Jurisdiction:** United States
**Scope:** US-licensed space station operators

## Overview

The FCC's "Space Modernization for the 21st Century" Notice of Proposed Rulemaking proposes to replace legacy Part 25 satellite licensing rules with a new "Part 100" framework, described as a "licensing assembly line" to process satellite applications more efficiently.

## Key Provisions

### Mandatory SSA Data Sharing
- Proposes that space station operators must share Space Situational Awareness data (orbital position, health status, collision avoidance maneuvers)
- First binding transparency requirement for constellation health data
- Addresses voluntary governance failure by making data sharing regulatory rather than voluntary

### License Terms and Modifications
- Extends most space and earth station licenses to 20 years (up from shorter current terms)
- Expands modification rights without prior approval
- Reduces administrative burden but potentially reduces regulatory oversight frequency

### Deorbit Requirements
- NASA commented during review period: large constellations should be required to use propulsion to deorbit (not passive drag)
- Would require active deorbit for all large operators, aligning with FCC's existing 5-year rule

### Framing
- Explicitly positioned as "support and accelerate space economy" initiative
- Governance improvements packaged within deregulatory/streamlining framework
- Morgan Lewis characterizes overall direction as pro-commercial acceleration, not regulatory tightening

## Limitations

Does not address:
- Active debris removal requirements
- Atmospheric deposition from reentry
- International operators who don't need FCC licenses

## Timeline

- **2025-12-05** — NPRM published in Federal Register
- **2026-01-20** — Comment deadline
- **2026-02-18** — Reply comment deadline
- **2026-05** — No final rule published (5 months after NPRM)
- **Expected** — Final rule potentially Q3-Q4 2026

## Strategic Implications

SpaceX has publicly advocated for mandatory semi-annual FCC reporting for all operators, aligning with Part 100's SSA data sharing proposal. If passed, this would:
- Make SpaceX's WEF non-endorsement strategically moot (data sharing becomes regulatory)
- Create minimal additional burden for SpaceX (already sharing this data)
- Make competitors' non-compliance publicly visible

Suggests regulatory substitution strategy: achieving industry transparency through domestic regulation while eliminating governance authority of non-US bodies.

## Sources

- Federal Register: "Space Modernization for the 21st Century" NPRM, December 5, 2025
- FCC document: FCC-25-69A3.pdf
- Morgan Lewis: "Modernizing Space: FCC Pushes to Support and Accelerate the Space Economy," April 2026
- NASA comments to FCC, January 2026
- Communications Daily, January 22, 2026