Follow the Gretzky Test on Space Fees, SpaceX Advises FCC

Regulatory fees for satellite and earth station licensing should be approved in a way that looks to the future, SpaceX said in comments posted Friday. Filings on a February Further NPRM were due Thursday in docket 24-85 (see 2502260017). SpaceX, a company led by Trump administration adviser Elon Musk, said “any changes to the existing framework” must meet what FCC Chairman Brendan Carr calls the “Gretsky [sic] Test.” NHL Hall of Famer Wayne Gretzky advised skating “to where the puck is going, not where it has been,” SpaceX noted.

“The commission’s fee framework for [non-geostationary orbit] systems should apportion fees on a risk-informed basis using operating altitude as a proxy for system risk and complexity,” SpaceX said. “Operating altitude bears a direct and physical relationship to orbital debris and interference risks and, by extension, to the amount of time staff should spend licensing and overseeing a given NGSO system.”

The FNPRM is “well-timed -- the number of full-time employees dedicated to space activities has significantly increased and so has the overall share of regulatory fees that are borne by the space industry,” said Amazon’s Kuiper Systems. It said the FCC should assess fees on “authorized space station systems rather than just operational space station systems” and “should adopt a common unit system to replace the current methodology.”