The FCC’s Space Bureau has opened a consultation period into a SpaceX modified application to launch 15,000 satellites into a Very Low Earth Orbit (VLEO).

According to the FCC’s Public Notice DA 25-1018 (released December 5th) the Space Bureau confirmed the application meets the baseline technical requirements for consideration. This procedural milestone triggers a 30-day window for interested parties to file petitions to deny or comments on the proposal. The designation moves the filing from a provisional status to an active regulatory proceeding but does not constitute final approval.

The SpaceX filing outlines a distinct architectural shift for the Starlink constellation. While the network’s initial generations operate primarily in the 550-kilometre height region, the proposed “Gen3/MSS” layer targets the 300-kilometre VLEO domain. This altitude reduction is designed to minimise free-space path loss, a physical constraint critical to closing link budgets for unmodified consumer smartphones utilising Direct-to-Cell (D2D) connectivity.

By lowering the orbital altitude, SpaceX intends to decrease signal latency and increase frequency reuse density. These technical adjustments are necessary to support the throughput required for mass-market voice and data services. The VLEO environment, however, subjects spacecraft to significantly higher atmospheric drag, requiring the continuous propulsion capabilities integrated into the Gen3 bus design to maintain orbit.

Analysts estimate that maintaining a 15,000-satellite VLEO fleet will require launching thousands of replacement units annually as satellite orbits decay.

Competitors, particularly those in the VLEO and MSS sectors such as AST SpaceMobile and Amazon’s Leo project, are expected to challenge the modification on grounds of aggregate interference and collision risk in the crowded lower LEO bands.

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Categories: Blogs, Inside Satellite, Regulation, Satellite

Tags: FCC, LEO, spacex