SB Docket No. 26-54 | Adopted March 26, 2026 | Released March 27, 2026
The FCC has finally confronted a reality the commercial space sector has known for years: its spectrum framework does not fit modern space operations.
The Federal Communications Commission (FCC) has released a Notice of Proposed Rulemaking (NPRM) titled “Spectrum Abundance for Weird Space Stuff” (SB Docket No. 26-54), marking a meaningful shift in how the Commission approaches spectrum access for non-traditional space missions.
At its core, this proceeding reflects the FCC acknowledging, perhaps belatedly, that its legacy framework does not align with the missions the commercial space sector is building today. In the FCC’s own framing, the goal is to go from zero non-Federal spectrum available for emergent space operations to at least 25 megahertz, and potentially much more if all proposals are adopted.
Deadlines
• Comments: Due May 11, 2026
• Reply Comments: Due June 8, 2026
What the FCC Is Really Doing
The Commission is trying to solve a structural problem: emergent space operations, including ISAM, lunar missions, and commercial stations, require reliable TT&C spectrum but do not fit cleanly into existing service categories.
Rather than creating a new regulatory construct, the FCC is proposing to expand and reinterpret existing ones. The Commission estimates net annual regulatory cost savings of approximately $6.8 million from these proposals, primarily by reducing the expensive, case-by-case NTIA coordination that emergent operators currently face.
Key Proposals
The NPRM focuses on several core proposals:
Spectrum Piggybacking: The Commission proposes to codify “piggybacking,” allowing a servicing spacecraft to operate in the same frequency bands already authorized for use by the client spacecraft it is working with.
Standalone TT&C in FSS Bands: The FCC proposes to allow emergent operators to conduct standalone TT&C in Fixed Satellite Service (FSS) bands on an unprotected, non-interference basis.
Expanding the TT&C Definition: The NPRM asks whether the definition of TT&C should be broadened to include mission-critical data (e.g., video used during rendezvous and proximity operations, docking, or crewed operations).
2320–2345 MHz Band (SiriusXM Leasing): The FCC proposes to add a secondary Space Operation Service (SOS) allocation (Earth-to-space) in this band and to permit SiriusXM, the exclusive licensee, to lease spectrum to earth station operators for command uplinks. Importantly, SiriusXM is not currently required to lease; the NPRM asks whether SiriusXM should be required to lease, but under current rules no such obligation exists. If SiriusXM declines, access depends entirely on private negotiation.
AT&T WCS Bands (Potential Extension): The NPRM also proposes extending the similar leasing framework to AT&T’s Wireless Communications Service (WCS) bands at 2305–2315 MHz and 2350–2360 MHz, plus adjacent guard bands at 2315–2320 MHz and 2345–2350 MHz. If all bands are included, that represents up to 55 megahertz of nearly contiguous S-band spectrum, a significant expansion beyond the SiriusXM band alone.
Space Research Service (SRS) Pathway: The NPRM proposes that certain emergent operations may qualify to operate under the SRS allocation when they are funded, contracted, or otherwise sponsored by NASA or another federal research agency. This is a narrower pathway, but meaningful for government-adjacent operators who may have struggled with regulatory classification. Purely commercial ISAM missions may not qualify, but operators performing research‑driven activities or supporting government‑funded programs could gain a clearer and more predictable licensing route.
Intersatellite Links: The FCC is considering whether to authorize licensed satellite operators (such as Iridium) to use their existing constellations and intersatellite links to provide TT&C and payload data relay services to emergent spacecraft, eliminating the need for individual modification filings.
Aegis Insights
1. Spectrum access is shifting from a regulatory right to a commercial asset.
The proposed leasing framework signals a broader shift. Access to spectrum for certain space operations may increasingly depend on private negotiations with incumbents, not just FCC authorization. This introduces pricing power, strategic gatekeeping, and potential competitive asymmetries into what has historically been a regulatory process. The risk is amplified by the fact that SiriusXM bears no current legal obligation to lease.
2. “Non-Interference” may become the default rather than the exception.
Many of the proposed pathways rely on operations on an unprotected, non-interference basis. The FCC itself calls this out as an open question, explicitly asking whether unprotected TT&C is adequate for rendezvous and proximity operations, docking, and inhabitable spacecraft. Operators may need to design systems assuming less regulatory protection and more operational redundancy.
3. The FCC appears to be prioritizing speed over structural reform.
Rather than creating a dedicated service or allocation for emergent space operations, the FCC is adapting existing frameworks.[1] This approach may accelerate near-term access but could result in a patchwork regime that requires ongoing interpretation, waivers, and coordination.
4. Infrastructure providers may gain a strategic advantage.
Proposals related to intersatellite links and leasing models could favor operators with existing satellite constellations or entities offering ground station or relay services. The AT&T WCS band extension further enlarges this dynamic. This dynamic may further incentivize vertical integration or strategic partnerships across the space value chain.
What This Means for You
This NPRM is not just about spectrum. It is about how access to space-supporting spectrum, and the infrastructure behind it, may increasingly depend on commercial arrangements as well as regulatory approvals.
Companies should consider their tolerance for operating without interference protection, whether to pursue leased or shared access models, whether they qualify for the SRS pathway if NASA-funded, and how regulatory positioning today could affect long-term operational flexibility.
Recommended Next Steps
We recommend that stakeholders evaluate whether to participate in this proceeding, particularly with respect to:
• Interference protections and reliability standards for safety-critical operations
• The structure, oversight, and incumbents’ obligations under spectrum leasing arrangements
• The scope of permissible TT&C operations, including data and video downlinks
• The SRS pathway for NASA-contracted or government-adjacent operators
• The potential extension of the leasing framework to AT&T’s WCS bands
Bottom Line
The FCC is not creating a clean solution. It is creating multiple imperfect but usable pathways.
[1] Aegis Space Law’s November 2024 ex parte filing in the prior ISAM proceeding is cited in this NPRM, reflecting prior advocacy on spectrum access for emergent operators.