# 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