On April 29, 2025, the FCC released a Notice of Proposed Rulemaking (NRPM) proposing to update the outdated rules that govern how geostationary (GSO) and non-geostationary (NGSO) satellite systems share the 10.7-12.7 GHz, 17.3-18.6 GHz, and 19.7-20.2 GHz bands. The NPRM was adopted at the April Open Meeting.
These rules, particularly the Equivalent Power-Flux Density (EPFD) limits developed in the 1990s, are now seen as overly restrictive for modern NGSO constellations, such as those providing broadband services, according to the FCC. As NGSO networks have rapidly expanded their reach and technical capabilities, the FCC is concerned that these legacy limits may unnecessarily constrain performance and competition in the satellite broadband market.
To address this, the FCC is seeking comment on whether alternative interference protection standards—like degraded throughput methodologies—might better reflect the needs of both GSO and NGSO operators today. The proposal explores whether short-term and long-term protection criteria could replace the current EPFD framework, and how new sharing regimes might improve efficiency and service quality. It also asks how improved coordination, data sharing, and more realistic modeling of satellite operations might ease spectrum congestion and reduce unnecessary burdens on NGSO systems. Importantly, the FCC states any changes would preserve the protection of terrestrial and radio astronomy services while enhancing the flexibility of satellite operators to serve U.S. consumers.
This rulemaking was initiated in response to a petition by Space Exploration Holdings (SpaceX) and is supported by several other NGSO stakeholders, although some GSO providers have expressed concern over deviating from international norms. Nonetheless, the FCC emphasizes that it has the authority to regulate domestic spectrum use independently and that having an open docket will facilitate both domestic and international coordination. By leading this process, the Commission hopes to establish a more modern, competitive, and technically sound framework for the rapidly evolving U.S. satellite industry.
The following notable changes were made from the draft item:
- ¶ 25 – Rather than asking whether degraded throughput is the best method for non-geostationary and geostationary (NGSO-GSO) sharing when a GSO satellite uses Adaptive Coding and Modulation (ACM), the FCC tentatively concludes that degraded throughput is the more appropriate methodology in that context.
- ¶ 28 and fns. 88-90 – Similar to the above, the FCC moves beyond broadly questioning the suitability of equivalent power-flux density (EPFD)-based sharing and the respective responsibilities of GSO and NGSO operators, and instead tentatively concludes that adopting a degraded throughput methodology—already used internationally and in recent FCC decisions—would be a more efficient approach to NGSO-GSO sharing in certain bands when GSO systems use ACM. It proposes specific short-term and long-term interference protection criteria based on this methodology and suggests a minimum avoidance angle (e.g., four degrees) as a fallback when realistic GSO data is unavailable.
- ¶ 37 – The NPRM builds upon the draft’s questions about transition timelines and the phaseout of outdated protections by proposing the eventual sunset of existing GSO protections in the key frequency bands (10.7–12.7, 17.3–18.6, and 19.7–20.2 GHz) to enhance competition and efficiency, while seeking comment on how to implement this transition.
Comments are due 45 days after publication in the Federal Register, and reply comments are due 75 days after publication.
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