Mega Constellations Fight Higher Regulatory Fees for Big Systems Proposal

yet operational and for phasing in any big fee hikes. The FCC in March adopted an NPRM on regulatory fee changes for satellite and earth stations due to the agency reorganization that created the Space Bureau, with initial comments received last month (see 2404150040). Amazon's Kuiper said the agency should reject proposals such as putting a particularly big share of NGSO fees' burden on large constellations that are not backed by full-time equivalent (FTE) staff allocations. SpaceX said the relative activity in licensing dockets isn't a reasonable proxy for apportioning fees. As a result, the agency shouldn't impose higher fees on NGSO mega constellations based on the number of filings in those NGSO licensing dockets. Increased fees would reward obstructionist competitors gaming the comment system, SpaceX said. FCC records show the largest NGSO constellations are responsible for a disproportionate share of the regulatory burden, Telesat said. It said the record shows substantial support for allocating a share of at least 30% of aggregate Space Bureau regulatory fees to earth station regulation. Phase in any new or hiked Space Bureau regulatory fees over years to ease the financial burden, NCTA said. It said the FCC should stick to its calculations for how many FTEs work on earth station matters, rather than considering unsubstantiated arguments for shifting more of the Space Bureau's regulatory fee burden onto earth station operators. It said no one has offered an argument for putting regulatory fees on receive-only earth stations, and thus the agency shouldn't do so. Eutelsat/OneWeb called "reasonable" the proposed 60/40 allocation between geostationary and NGSO systems, respectively. Also backing tiers of NGSO regulatory fees based on constellation size, it said larger constellations "raise additional issues that require more FTE time," such as orbital debris and larger earth station networks. EchoStar and DirecTV also backed the NGSO subcategories based on constellation size and assessing fees on authorized but not yet operational systems, as did SES/O3b, which also urged a several-year phase-in of fee increases due to the Space Bureau's creation. Viasat also urged that NGSOs cover a greater allocation of satellite fees and backed the NGSO subcategories. The $400,000 annual regulatory fee that small non-voice, non-geostationary mobile satellite systems are facing under the FCC proposal is "unsustainable" and make operating NVNG MSS systems in the U.S. a challenge, Myriota said. NVNG MSS systems consume fewer FCC resources than other small NGSO constellations, it added.