The Federal Communications Commission adopted its Space Modernization for the 21st Century order on July 22, replacing the Part 25 rules that have governed satellite licensing with a framework called Part 100. Geostationary operators no longer post a surety bond, and neither do non-geostationary systems that stay out of processing rounds. Systems that opt into a processing round post a $10 million bond that steps down to zero once 90 percent of the constellation is deployed. Applications now move on standardized schedules and yes-or-no certifications rather than narrative filings, with closer review reserved for waivers, market access requests, spectral priority elections, federal coordination and certification failures. The attorney who wrote her firm’s first alerts on the new rules takes the Satellite Innovation stage at Silicon Valley Space Week in October.
Kathryne Dickerson is a Shareholder in Greenberg Traurig’s Technology, Media and Telecommunications practice in Washington, which she joined from Wiley Rein in February 2025. She has spent nearly two decades before the Federal Communications Commission, the National Telecommunications and Information Administration, the Department of Commerce and international regulators, representing satellite operators, earth station operators, broadcasters and emerging space companies. She has obtained Supplemental Coverage from Space authorizations for direct-to-device systems, secured modifications to existing satellite licenses, and obtained U.S. market access for foreign-licensed systems. She represents clients in rulemaking proceedings and in enforcement matters. She wrote the opening installments of her firm’s Part 100 series, on the bond and milestone framework in early August and on the licensing process a week later.
The program bills the brief as space licensing rebuilt. The bonds and the deployment clocks changed together. Non-processing-round systems in non-geostationary orbit now run on the International Telecommunication Union timeline: one satellite within seven years, 10 percent within nine, half within twelve and the full constellation within fourteen. Processing-round systems keep the older six and nine year marks, but missing the six-year milestone no longer caps a constellation permanently, and the operator instead loses its priority and drops into a later round. Geostationary operators keep a five-year launch milestone and a twenty-year term, and the option to extend by five years is gone. SatNews covered the proposal in February, when it was still a plan to retire Part 25 in favor of modular filings and the licensing process was described as struggling to keep pace with application volumes and increasingly complex missions. AST SpaceMobile had filed formal comments the month before. SatNews reported this month that Cowboy Space’s 20,000-satellite filing implies roughly 400,000 tonnes of hardware against a 3,193-tonne launch year, and that the commission has no field for mass.
Dickerson gives the brief on Tuesday, October 27, from 10:15 a.m. to 10:30 a.m. in the Hahn Auditorium at the Computer History Museum in Mountain View. The program lists no other speaker, and fifteen minutes is the whole slot. It follows the session on regulators as capacity allocators, which seats the FCC’s deputy satellite division chief and NTIA’s spectrum management director at the same table, and it runs up to the morning break in the Grand Hall.
Silicon Valley Space Week runs Tuesday, October 27 through Thursday, October 29 at the Computer History Museum, with Satellite Innovation across the first two days and the MilSat Symposium across the last two. Dickerson’s brief comes mid-morning on the opening day. The rules take effect 60 days after they are published in the Federal Register, and some sections are subject to review at the Office of Management and Budget.
Greenberg Traurig, where the speaker is a shareholder, is a sponsor of Silicon Valley Space Week, which SatNews produces.
