Comments of National Taxpayers Union
Center for Emerging Technologies
Before the
Federal Communications Commission
Washington, DC 20554
Ensuring Reliable Access to Spectrum for Space Launch Activities to Achieve the Goals of the President’s National Space Transportation Policy
RM-12025
ET Docket No. 13-115
National Taxpayers Union (NTU) supports modernizing the process for coordinating spectrum used in commercial space launches. The Federal Communications Commission should move routine coordination toward automated, database-assisted review while preserving the technical protections that federal users, flight-test operators, broadcasters, and medical users rely on today. The Commission should also make the cost and performance of that process visible to the public.
NTU is a nonpartisan taxpayer advocacy organization founded in 1969. We do not launch rockets or hold spectrum licenses. We are commenting because the federal government purchases substantial commercial launch services, and an inefficient coordination process can increase the cost of those missions. The record should therefore address not only how much spectrum launch operators need, but also what the coordination process costs, how long it takes, and whether it treats competing providers fairly.
The Commission has a legitimate obligation to protect incumbent operations against harmful interference. Launch communications share spectrum with sensitive federal systems and non-federal services, including aeronautical flight-test telemetry and Medical Body Area Networks. NTU does not ask the Commission to reduce any interference protection standard, change the priority of an existing allocation, or select a technical criterion without an adequate engineering record. The issue is whether those protections can be administered more efficiently and predictably.
The need for a scalable process is apparent. Public Notice DA 26-887 states that approximately 200 launch activities occur annually in the United States. National Security Presidential Memorandum 17 sets a goal for United States ranges to support more than 1,000 launches and reentries each year by 2030. That figure is a policy goal, not a forecast. The Federal Aviation Administration projects 507 authorized operations in its high case and 282 in its low case by fiscal year 2036, compared with 204 actual operations in fiscal year 2025. The difference between the current baseline, the forecast, and the national goal makes it especially important to measure whether the coordination process can accommodate higher volume and frequent schedule changes.
The existing record shows sharply different expectations about timing. In DA 25-270, the Wireless Telecommunications Bureau noted that the Aerospace and Flight Test Radio Coordinating Council (AFTRCC) requested 80 days of advance review. SpaceX argued that most coordination can be completed within days and later proposed an initial period of five to ten days. United Launch Alliance stated that the industry does not typically manifest 60 days before launch. Blue Origin and Virgin Galactic also sought greater flexibility. The Bureau declined to impose a mandatory submission period. Flexibility may be appropriate, but the absence of a fixed deadline should not mean the absence of a measurable service standard.
First, the Commission should require the space launch frequency coordinator to publish performance data. At a minimum, that should include median and 90th-percentile processing times, the number and cause of repeat coordinations, the number of requests conditioned or denied, and prompt written reasons for adverse outcomes. The Commission can distinguish routine requests from complex cases and allow expedited review when weather or technical conditions change. This would preserve flexibility while giving the Commission evidence about whether the process is working.
Second, the Commission should require neutral governance and a public, cost-based fee schedule. In the 2360-2395 MHz band, Part 26 framework calls for coordination with the Part 87 frequency coordinating committee, currently AFTRCC. AFTRCC has substantial technical expertise. Its currently published membership and board also include firms with commercial interests in aerospace and launch markets. NTU alleges no misconduct. That structure simply makes clear conflict rules, nondiscrimination requirements, data-security protections, and written explanations for adverse decisions necessary. Any coordinator, including a successor, should disclose its fees, the costs those fees recover, and any differences among users or request types. The Commission should retain authority to review unreasonable or discriminatory charges.
Third, the Commission should automate routine coordination and preserve expert review for exceptions. The Launch Communications Act already directs the Commission to improve coordination with the National Telecommunications and Information Administration through increased automation. The same approach should guide the broader workflow where technically feasible. Standardized data and machine-to-machine exchange can reduce repetitive work. Human review should remain available for complex interference questions, proprietary information, national-security concerns, and unresolved disputes.
These requests would help the Commission answer the taxpayer’s questions with evidence. NSPM-17 requires the Secretary of Commerce and the Chairman of the Commission to report to the President within 180 days and every two years thereafter on their approach to reliable spectrum access. That report should identify coordination lead times, repeat coordination, fees, administrative burdens, and any launch delays for which spectrum coordination was a material contributing factor. It should also examine whether those burdens affected federally purchased launch services. If the agencies do not yet collect that information, the report should say so and establish a method for collecting it.
NTU takes no position in this comment on additional spectrum bands, primary allocation status, or the technical protection criteria appropriate for incumbent services. Those questions require a developed engineering record. The Commission can act now, however, to make the existing process more transparent, neutral, measurable, and capable of handling growth.
Thank you for the opportunity to comment.
Respectfully submitted,
Alessandra Desiderio
Director of Technology Policy
National Taxpayers Union