What’s Happening

The FCC, under the banner of “Space Month 2025,” has prioritized a broad agenda of satellite and spectrum reform. Akin – Akin, an Elite Global Law Firm+2Via Satellite+2 One prominent component is a review of spectrum sharing rules intended to unlock more capacity for space-based telecommunications, particularly in upper microwave flexible use (UMFUS) bands. Akin – Akin, an Elite Global Law Firm+2Via Satellite+2 In parallel, by reorganizing licensing rules and creating new categories under the proposed Part 100, the FCC is implicitly endorsing more aggressive spectrum reuse, secondary access, and larger satellite-terrestrial coexistence regimes. Wiley Notably, the draft NPRM also proposes changes to siting rules for earth stations in high-frequency bands (70/80/90 GHz) to simplify registration, and modifications of protection criteria under § 25.137 for interference in UMFUS bands. Akin – Akin, an Elite Global Law Firm+1 The Commission is signaling that its spectrum policy must evolve from terrestrial priority toward more intensive satellite usage. Via Satellite+1

Why It Matters

Across the satellite industry, spectrum constraints are becoming more acute. Many SmallSat or CubeSat missions operate in contested bands or near the edge of interference thresholds. The FCC’s reform agenda seeks to shift the balance toward enabling more satellite usage, provided operators maintain interference discipline. For mission planners and regulatory leads, this presents an opportunity—but only if they are ready: systems must be designed with spectral sharing in mind, interference modeling must be robust, and mission allocations must be defensible under new policy regimes.

If the FCC loosens some legacy constraints on power or modifies the sharing rules, operators that already have high-performance, interference-aware designs will benefit disproportionately. Conversely, operators relying on margin stacking or aggressive out-of-band emissions may find themselves squeezed by new enforcement or tighter standards.

Moreover, the changes suggest that future licensing may expect operators to demonstrate not only their own compliance, but their cooperative spectrum behavior—participation in sharing frameworks, dynamic adaptation to interference, and even voluntary data publication for coordination. The regulatory shift is toward viewing satellites as participants in a shared spectral ecosystem, not as isolated users.

How It Affects SmallSat / CubeSat Operators

Operators should begin designing systems with adaptive frequency management, more conservative spectral templates, and dynamic interference suppression (e.g. nulling, beam steering). Link budgets must account for more aggressive coexistence, not just “safe territory” assumptions. Satellite and earth station licensing strategies will need to factor in shared band risk, and tools will need to simulate cross-system interference under worst-case conditions.

Those planning to use UMFUS or adjacent high-frequency bands must follow closely the forthcoming rules for siting, interference criteria, and registration simplification. If new earth station registration models are adopted, that may lower the bar for deploying uplink/downlink hubs, but only for those who comply with stricter interference protections.

In a more speculative vein, operators might be required to offer spectrum usage telemetry or reporting to regulators or third-party coordination entities. Operators who preemptively accommodate open telemetry and sharing may gain regulatory goodwill or fast-track treatment under future Part 100 frameworks.

To stay ahead, CubeSat teams will benefit from compliance platforms capable of spectral simulation, interference flagging, and adaptive licensing logic. Astrolytics is developing modules around these capabilities—optimizing mission design against both current FCC rules and the spectrum reform trajectory. We invite you to explore how our tools embed spectral awareness into compliance at Astrolytics.