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Re: Comprehensive Review of Licensing and Operating Rules for Satellite Services

, IB Docket No. 12-

The longest journey begins with a single step, but one step is never enough. Take today's
proceeding. It began more than a decade ago, when the staff of the International Bureau first identified
the need to streamline and revise our satellite rules as part of our biennial regulatory review process.1
After years of fits and starts, including staff's reiteration of the need for reform in 2005 and 2007,2 the
Commission finally heeded those calls last September, when it commenced this rulemaking process.3
Today, just 11 months later, we act on that Notice of Proposed Rulemaking. The sheer breadth of
our satellite rules suggests what a striking accomplishment this is. Part 25, which covers satellite
communications, has 114 rules spanning 7 subparts and 157 pages. With today's order, we amend the
majority of those rules, eliminating some, clarifying others, and consolidating a few more. The end result
is a modernized framework that better reflects today's technology and marketplace. That's yeoman's
work, and the staff of the International Bureau, as well as their colleagues throughout the Commission
that aided in the task, should be proud.
But our labors don't end with today's order. Last September, I called on satellite
communications providers and other stakeholders to tell us "not only about the modifications proposed in
[the] Notice but also about larger-scale reforms to our satellite licensing and operating rules."4 They
obliged--I gave up counting the number of proposals proffered once it hit 50. And today, we follow suit.
Indeed, we commit to moving forward with a Further Notice to explore more far-reaching changes to our
rules, such as EchoStar's recommendation to expand the scope of our rain-fade rules5 and SIA's
suggestion to target our coordination requirements to those satellites actually affected by an earth station.6
And I hope the Further Notice will consider other forward-looking proposals, such as ORBCOMM's
recommendation to let the Federal Aviation Administration determine whether certain cargo-tracking
devices can be safely operated aboard civil aircraft7 and Boeing's recommendation to reduce the burden

1 Federal Communications Commission, Biennial Regulatory Review 2000 Updated Staff Report at paras. 7677
(Jan. 17, 2000), available at The Commission promptly followed up on this
recommendation, but did not comprehensively revise its rules. See 2000 Biennial Regulatory Review --
Streamlining and Other Revisions of Part 25 of the Commission's Rules Governing the Licensing of, and Spectrum
Usage by, Satellite Network Earth Stations and Space Stations
, IB Docket No. 00-248, Notice of Proposed
Rulemaking, 15 FCC Rcd 25128 (2000).
2 2004 Biennial Review, IB Docket No. 04-177, International Bureau Staff Report, 20 FCC Rcd 343 (2005); 2006
Biennial Regulatory Review
, IB Docket No. 06-154, International Bureau Staff Report, 22 FCC Rcd 3138 (2007).
3 Comprehensive Review of Licensing and Operating Rules for Satellite Services, IB Docket No. 12-267, Notice of
Proposed Rulemaking, 27 FCC Rcd 11619 (2012).
4 Id. at 11709 (Statement of Commissioner Ajit Pai).
5 EchoStar Comments at 67; Order at para. 59. Our rain-fade rules allow certain satellite and earth station
operators to increase the power of their uplink transmissions when it rains to compensate for increased signal
6 SIA Comments at 47, 6162 (discussing modifications to rules 25.138 and 25.223); Order at notes 324 and 443.
7 See ORBCOMM Comments at 11 (proposing to amend rule 25.285 to replace "installed" with "operated"). Absent
such a change, a device covered by rule 25.285 but not installed in the aircraft (such as cargo-tracking devices)
could not be used even if the Federal Aviation Administration approved it as safe for aircraft use.

of our milestone review process.8 We should commence that rulemaking in the near term, move forward
with similar speed, and continue our efforts to make the United States the most desirable country in the
world for licensing and operating satellites.

8 See Boeing Comments at 410; see also ORBCOMM Comments at 12; EchoStar Reply at 56; Inmarsat Reply at
3; Intelsat Reply at 36.

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