FCC Will Update Schedule S and Proposes Other Streamlining

You know how when you schedule an appointment with a new doctor and they send you all those medical history forms to fill-out online??And then when you actually arrive at the doctor’s office you inevitably have to fill out the same forms, this time on paper??Well, Schedule S may be equally annoying (and I say that kindly). It’s supposed to contain most of the technical parameters for space station applications, but the Schedule S form itself is so outdated that its fields don’t allow applicants to accurately input those technical parameters.?As a result, applicants must file a request to waive the requirement to complete Schedule S in order to submit an exhibit that contains the appropriate technical parameters.? It’s… let’s just say cumbersome.

But fear not!? In a draft Report and Order and Further Notice of Proposed Rulemaking released on August 31, the FCC affirms that “We are also updating the fields in the Schedule S to better align with technical rules.” Satellite operators (and advocates for administrative efficiency), rejoice!? And it sounds like the improvements won’t just be a one-time thing.?The draft R&O also states that “The Space Bureau expects to continue dialogue with system users about possible further improvements after the initial modifications of ICFS are introduced.”?Awesome.

Additionally, the draft R&O contains other items of interest to satellite operators, including (among many others) that the FCC would:

• Continue its current practice of not immediately dismissing applications that contain omissions or internal inconsistences, instead working with applicants to correct information so that the application may be acceptable for filing;??
• Amend Section 25.112 so that applications seeking waiver to operate in a frequency band not allocated internationally for satellite use may be put on Public Notice and considered; and
• Amend Section 25.159(b) and Section 25.137(d)(5) to allow applicants to apply for another NGSO license or market access grant when it has an already licensed-but-unbuilt NGSO system for the same frequencies.?

As for the Further Notice portion of the document, the Commission seeks comment on topics including whether to:

• Expand the list of minor modifications that can be made without prior authorization by the Commission;
• Allow operations other than TT&C during satellite drift, if the operator certifies operations have been coordinated;
• Allow for an equivalent to STA for space station market access grantees to communicate with U.S. licensed earth stations; and
• Expand the current 60-day window for earth station licensees to submit a renewal application to no earlier than 180 days and no later than 30 days prior to expiration.?

Comments on these and other items proposed in the Further Notice will be due after the document is published in the Federal Register.?As for meaningful reform to the tyranny of medical history forms… I’m not holding my breath.?

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