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Publications: Ellis Scherer

September 28, 2026

Policy Considerations for Orbital Data Centers

Orbital data centers could complement terrestrial infrastructure by processing selected workloads in space, particularly where data is generated in orbit. Their value will depend on technical performance, life cycle economics, market demand, and a regulatory environment that does not hinder testing and deployment.

September 24, 2026

Reply Comments to FCC Regarding Reliable Access to Spectrum for Space Launch Activities

Spectrum is a critical component for space launch, and frequency coordinators play a vital role in balancing the spectrum needs of the aviation and the space sectors, both of which are essential for American technological leadership.

September 17, 2026

Comments to FCC Regarding Build America: Eliminating Barriers to Wireline Deployments

The Commission should establish predictable federal guardrails to address wireline deployment barriers while preserving legitimate state and local ROW-management functions. These measures would give providers and governments clearer expectations and reduce some regulatory uncertainty surrounding deployments that require state or local authorization.

August 31, 2026

Comments to Federal Aviation Administration Regarding Commercial Space Launch and Reentry Actions

Eliminating harmful NEPA review is a necessary reform that will help America continue to lead in space innovation. However, the NPRM's uniform waiver across environmental laws and launch and reentry sites forgoes the risk-based, evidentiary approach that justifies deregulatory action.

August 4, 2026

Comments to FCC Regarding Reforming the High-Cost Program For an All-IP Future

Phasing out legacy High-Cost mechanisms, allowing time-limited deployment programs to sunset as scheduled, and establishing a leaner USF focused on broadband affordability and adoption would better serve consumers, strengthen competition, and improve stewardship of USF resources.

July 21, 2026

Comments to FCC Regarding Assignment and Transfer of Control of Licenses and Authorizations Held by Globalstar to Amazon

The Commission should approve this transaction because it will serve the public interest by increasing spectrum productivity, increasing competition in the emerging D2D marketplace, and extending mobile communications coverage to remote and underserved areas.

July 15, 2026

US Spaceports Need More Funding to Prevent a Launch Bottleneck

The United States is the global power in space, but insufficient spaceport infrastructure threatens the growth of the American space industry. Congress, NASA, and Space Force must address the problem before it undermines U.S. leadership.

July 7, 2026

Comments to the FCC Regarding AT&T’s Petition for Preemption and Declaratory Ruling on California’s Carrier of Last Resort and Related Requirements

The Commission should thoughtfully consider AT&T’s petition because it could catalyze the retirement of outdated copper networks, accelerate network modernization, and advance the transition to a modern, all-IP communications ecosystem.

July 1, 2026

Rigid Space Spectrum Allocations Could Limit Productivity

Overly restrictive spectrum allocations have left terrestrial bands underutilized. Regulators should not repeat those mistakes as they develop new policies for the orbital economy.

June 16, 2026

Comments to the California Public Utilities Commission Regarding Carrier of Last Resort Requirements

At a time of unprecedented growth in the broadband market, California’s broadband laws remain unchanged, and it is costing consumers faster, more reliable Internet.

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