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ARTICLE · 22 SEPTEMBER 2026

FCC Space Modernization Series (Part 5): A New Licensing Framework For Variable Trajectory Space Stations

Greenberg Traurig
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The Federal Communications Commission has established a new Variable Trajectory Space Station licensing category to accommodate spacecraft with non-traditional orbital characteristics, including orbital transfer vehicles, rendezvous and proximity operations platforms, and lunar missions. This framework introduces an operational envelope approach that allows operators to conduct missions across multiple orbital regimes without seeking modifications for each trajectory change, while maintaining space safety r

United StatesMedia, Telecoms, IT, Entertainment

In the first four articles of this series, we examined the Federal Communications Commission’s overhaul of its space licensing rules, including the Commission’s revised milestone and surety-bond requirements, new licensing framework, and reforms to the earth station licensing process. This fifth article examines another aspect of the Commission’s July 2026 Report and Order: the creation of a new licensing category for spacecraft that do not fit neatly within the traditional geostationary-orbit (GSO) or non-geostationary-orbit (NGSO) frameworks. For additional analysis of the FCC’s Space Modernization for the 21st Century Report and Order, see Part 1, Part 2, Part 3, and Part 4 of this series.

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