As the race for global space-based connectivity accelerates, the FCC is poised to ease existing regulatory barriers standing between U.S. innovation and the next generation of satellite services. On July 17, 2025, the Federal Communications Commission (FCC) unveiled a draft of its Second Report and Order (“Proposed Order”) aimed at modernizing and streamlining the licensing process for satellite and earth stations. This proposed action—set for a Commission vote on August 7, 2025—is especially focused on unlocking Ground-Station-as-a-Service (GSaaS) models. It reflects the FCC’s commitment to fostering innovation and maintaining U.S. leadership in the rapidly evolving space economy.
What is GSaaS, and Why Now? GSaaS is a business model where independent ground station operators offer satellite operators access to terrestrial infrastructure on a pay-as-you-go basis, rather than requiring each satellite operator to build, license, and maintain its own ground stations. This approach is critically important because it lowers entry barriers for space startups and smaller operators, speeds up deployment of new satellite-based services, and provides greater flexibility to meet surging demand for data downlinks, broadband, and real-time communications from space. As satellite constellations rapidly expand and diversify, GSaaS enables more efficient, scalable, and cost-effective connections between earth and space—making it a pivotal enabler of the modern space economy.
The Commission’s Proposed Order would introduce substantial deregulation for GSaaS providers, reduce administrative paperwork, and bring significant new flexibilities—particularly for startups and new market entrants hoping to connect with space in novel ways.
Practical Guidance: What Are the Key Takeaways from the GSaaS Proposed Order? There are several proposed rules that satellite network operators, ground station providers, and space economy investors alike should pay attention to:
- Streamlined Baseline Licensing for Earth Stations. Historically, earth station applicants were required to identify the specific satellite(s)—the so-called ‘point of communication’—before commencing operations, a hurdle for GSaaS business models hoping to attract multiple satellite operator customers. The Proposed Order would address this by creating a new “baseline license” that could be granted without identifying a satellite point of contact. GSaaS operators could then establish ground infrastructure and contract with satellite clients after licensing, smoothing the path to market for new service models and operators.
- Simple Notification for Adding or Removing Points of Communication. Instead of time-consuming license modification applications, operators could add or remove satellite points of communication by simply notifying the FCC, accompanied by several technical certifications. In most cases, operations could begin immediately after notification and fee payment—including during the 15-day review window—unless the Commission directs otherwise. This would resolve the classic “chicken-and-egg” problem—new GSaaS sites wouldn’t have to wait for their first customer to be licensed, and adding clients would become more streamlined.
- Expanded List of Modifications Not Requiring Prior Authorization for Satellite Operators. The Proposed Order would broaden the types of equipment changes and system upgrades that licensees—including both geostationary and non-geostationary satellite (“NGSO”) operators—could implement without pre-clearance. Equipment swaps that do not increase interference risk could happen without prior notice. This would reduce delays for system improvements, benefiting both commercial flexibility and rapid technology adoption.
- Procedural and Administrative Modernization.
- No More Paperwork: The FCC requirement to retain physical copies of filings (approximately 21,000 pages per year) would be eliminated.
- Ex Parte Transparency: Space and earth station applications would become “permit-but-disclose” by default, enabling broader participation and transparency in the application process.
- Renewal Shot Clock: A new 30-day shot clock would be established for FCC action on earth station renewal applications.
- Expanded Renewal Windows: Operators would be able to file for earth station license renewals up to a year before expiration, providing greater certainty.
- Market Access and Special Temporary Authority (STA) for Non-U.S. Licensed Satellite Operators. Non-U.S. licensed satellite operators with U.S. market access could obtain special temporary authority using procedures previously reserved for U.S. licensees, reducing regulatory friction, especially in urgent or time-limited scenarios.
What’s Next? Some ideas—such as a “Permitted List” for NGSO systems and universal processing timelines—were not adopted in this Proposed Order but remain under consideration as the FCC signals more reforms ahead.
Key Takeaways. If adopted as drafted, these reforms would make it dramatically easier for GSaaS providers and ground station operators to launch, scale, and maintain services. The new rules emphasize flexibility, reduce administrative hurdles, and promote faster innovation throughout the satellite industry.
If you are preparing to leverage GSaaS opportunities, evaluating how to respond to the FCC’s Proposed Order, or planning to expand your satellite ground presence, reach out to Sheppard Mullin’s telecommunications group for guidance on next steps and compliance.