The Federal Communications Commission (FCC or Commission) has circulated a draft Notice of Proposed Rulemaking (NPRM) for consideration at its March 26, 2026, Open Meeting. The draft NPRM proposes two paths to making spectrum available for “emergent space operations” (a.k.a., cutting-edge non-telecommunications-focused space operations). If adopted, comments will be due 30 days after the draft NPRM is published in the Federal Register, and reply comments will be due 30 days later.

Titled “Spectrum Abundance for Weird Space Stuff,” the draft NPRM reflects the Commission’s growing emphasis on ensuring that the United States maintains its leadership in the rapidly expanding commercial space sector. In particular, the Commission notes that many emerging space missions — such as satellite servicing, orbital laboratories, and robotic activities on the lunar surface — require reliable spectrum for operational and safety functions. However, these non-telecommunications-focused services have not traditionally commanded the FCC’s regulatory attention and face a shortage of usable and readily accessible spectrum.

The draft NPRM proposes to address the spectrum needs of these technologies by: (1) exploring ways to clarify existing regulations to enable spectrum access, and (2) identifying new spectrum bands for potential use by emerging technologies.

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Photo of Kathryne Dickerson Kathryne Dickerson

Kathryne (Kate) C. Dickerson is a dynamic and results-focused advocate with over 15 years of experience representing clients in the communications, space, technology, and broadcast media sectors. She works at the intersection of law, innovation, and policy to provide counsel in regulatory and…

Kathryne (Kate) C. Dickerson is a dynamic and results-focused advocate with over 15 years of experience representing clients in the communications, space, technology, and broadcast media sectors. She works at the intersection of law, innovation, and policy to provide counsel in regulatory and rulemaking proceedings, enforcement and compliance matters, and transactional issues.

Kate’s experience spans advocacy before the Federal Communications Commission (FCC), the National Telecommunications and Information Association (NTIA), and other federal agencies, as well as international regulators such as the UK’s Ofcom. She focuses on matters related to non-geostationary (NGSO) and geostationary (GSO) satellite operators, spectrum allocation, licensing, and compliance, with the ability to advise established companies as well as new entrants. Kate is skilled at developing creative and effective advocacy strategies for clients navigating the federal notice-and-comment rulemaking process or seeking regulatory approvals in emerging sectors, including the new space economy. Her broad experience also extends to advising commercial and noncommercial broadcasters on a wide range of regulatory issues, including assignments, transfers of control, content and technical rules, and transactional and contracts matters.

Photo of Laura Cummings Laura Cummings

Laura Cummings focuses her practice on space law and commercial space regulation, providing legal support to businesses dealing with complex matters pertaining to space, satellite, and telecommunication industries. Her work scope is global, involving policy-making, legislative interpretation, and application of regulatory frameworks. She…

Laura Cummings focuses her practice on space law and commercial space regulation, providing legal support to businesses dealing with complex matters pertaining to space, satellite, and telecommunication industries. Her work scope is global, involving policy-making, legislative interpretation, and application of regulatory frameworks. She is involved in virtually all areas of space regulatory affairs including spectrum advocacy, remote sensing, export compliance, payload authorization, and providing guidance on in-space servicing, assembly, and manufacturing mission authorization.

Laura has deep experience influencing international telecommunications regulations and policy. Laura has served as a member of the U.S. Delegation to International Telecommunication Union conferences, including the 2023 World Radiocommunication Conference, contributing to ongoing work around space sustainability. Similarly, she advocates for evolved U.S. domestic space regulations that are cohesive with international law and foreign domestic laws, working across a variety of jurisdictions and legal systems.