Orientation summary — a fast, cited starting point, not a substitute for reading the filings. Generated from the public ECFS record.
Key issues (auto-discovered)
The appropriateness of revising EPFD limits for NGSO systems to reflect technological advancements and improve spectrum efficiency.
Filers split on: “The Commission should adopt revised EPFD limits for NGSO systems.”
23 filers engaged this issue.
- Telesat Corporation Telesat (support) — The commenter believes that the existing EPFD limits are outdated and overly restrictive for NGSO systems, which hinders efficient spectrum use and broadband service delivery.
- Chamber of Progress Chamber of Progress Modern (support) — The commenter argues that modernizing EPFD limits would improve broadband capacity and reduce costs, benefiting consumers and fostering competition in the satellite broadband market.
- Chamber of Progress FCC EPFD (support) — The commenter highlights that updating the EPFD rules could lead to a substantial increase in broadband capacity and lower costs for new providers, fostering competition in the market.
- Software Information Industry Association 2025 (support) — The commenter asserts that updating the EPFD limits is a deregulatory action that will facilitate market efficiency and is consistent with the FCC's mission to alleviate unnecessary regulatory burdens.
- International Center for Law Economics 2025 EP (support) — The commenter highlights that modernizing the EPFD framework could lead to increased consumer access to broadband, lower service costs, and enhanced competition in the satellite sector.
- The Software Information Industry Association (support) — The commenter argues that the FCC's adherence to outdated EPFD limits undermines its goals of promoting connectivity and supporting American companies in a competitive global market.
The need to ensure that GSO networks are protected from interference when revising EPFD limits for NGSO systems.
Filers split on: “The Commission should require NGSO operators to prioritize GSO network protection in any EPFD limit changes.”
14 filers engaged this issue.
- Hispasat S.A. (support) — The commenter argues that opponents of the EPFD framework have failed to provide substantiated claims for change, warning that such changes could result in harmful interference to GSO systems. They stress the necessity for proposed reference links to accurately represent a meaningful subset of GSO operations to safeguard against interference, highlighting the vulnerability of GSO networks to disruptions from NGSO systems and the importance of maintaining current EPFD limits for their protection.
- Astranis Space Technologies (modify) — Astranis argues that proposals prioritizing NGSO expansion could harm GSO operators and their customers, stressing the need for realistic operational parameters and updated GSO reference links for effective NGSO-GSO sharing. They highlight the critical role of GSO systems in serving important U.S. missions and advocate for innovation across all satellite orbits, while warning that a 0.4% increase in absolute unavailability could jeopardize GSO systems' ability to meet service level agreements, undermining their competitive advantage.
- Phoenix Center for Advanced Legal Economic Pub (oppose) — The commenter argues that the current EPFD limits, designed to protect GSO networks, have become a significant barrier to the deployment of NGSO satellite systems that provide superior broadband services.
- EchoStar Corporation EchoStar NGSO GSO Sharing (modify) — EchoStar argues that a careful phase-in of new rules is necessary to protect existing investments and service quality for both GSO and NGSO operators, emphasizing that GSO operators have made significant investments based on current regulations and that any changes should not jeopardize these investments. The company expresses its commitment to collaborate with the Commission and stakeholders to develop a framework that safeguards GSO systems while facilitating advancements in satellite communications.
- DIRECTV (support) — DIRECTV argues that an absolute increase in unavailability would undermine GSO networks' quality of service and impose harmful quality standards, emphasizing that GSO networks, especially satellite broadcast networks without ACM, face unique challenges in mitigating interference from NGSO systems and require tailored protections; they also highlight that existing EPFD limits are crucial for protecting GSO networks from harmful interference, which could lead to service interruptions for customers.
- SES S.A. and Affiliates SES EPFD (support) — SES argues that the Ku-band is a well-established GSO band with effective EPFD limits that protect GSO services, and contends that the alternatives proposed by EPFD opponents lack technical rigor and would increase interference, thereby undermining the reliability of GSO services.
The implications of changing the Ku-band sharing framework and its impact on existing services and interference levels.
Filers split on: “The Commission should reject changes to the Ku-band sharing framework that increase interference risks.”
8 filers engaged this issue.
- National Association of Broadcasters NAB (modify) — NAB acknowledges the potential of Ku-band but asserts it cannot fully replace C-band services due to the critical role of legacy GSO satellites, and they argue that any changes to the existing Ku-band sharing framework should align with ongoing ITU studies to prevent significant interference issues.
- Gogo Business Aviation (modify) — Gogo recommends that the Commission consider a phased approach to changes in satellite sharing rules, aligning with international discussions to ensure stability and predictability for customers.
- Shaping Our Appalachian Region EPFD Support to (oppose) — The commenter believes that the revisions will allow providers like Starlink to expand capacity and enhance service reliability, which is crucial for their communities.
- SES S.A. and Affiliates SES EPFD (support) — SES warns that increased interference in the Ku-band could hinder the migration of high-reliability services from the Upper C-band, affecting service quality.
- CORF National Academy of Sciences CORF (modify) — CORF emphasizes the need for improved coordination to mitigate the potential increase in radio frequency interference (RFI) challenges for radio astronomy due to changes in satellite sharing rules.
- Central Council of the Tlingit Haida Indian Tr (oppose) — The commenter believes that the changes will lead to increased speeds and expanded network capacity, improving the effectiveness and reliability of services provided to their community.
The role of LEO satellite broadband in expanding internet access to underserved and rural areas.
Filers split on: “The Commission should permit LEO broadband expansion to improve rural internet access.”
7 filers engaged this issue.
- Mary Guenther July 2025 PPI EFPD Filing (support) — The commenter emphasizes that LEO satellite broadband can reach underserved populations that traditional broadband cannot, thus playing a vital role in bridging the digital divide.
- Phoenix Center for Advanced Legal Economic Pub (support) — The commenter emphasizes the importance of NGSO services in providing affordable broadband access to high-cost rural areas, which is crucial for meeting national broadband goals.
- Central Council of the Tlingit Haida Indian Tr (support) — The commenter highlights the importance of Starlink in providing critical communications infrastructure for education, telehealth, remote work, and emergency services in their region.
- Computer Communications Industry Association C (support) — CCIA emphasizes that LEO broadband connectivity is crucial for connecting millions of Americans who currently lack reliable internet access, particularly in rural areas.
- Software Information Industry Association 2025 (support) — The commenter argues that LEO technology can significantly reduce the costs associated with broadband installation, particularly in rural areas, making it a viable alternative to traditional cable.
- Shaping Our Appalachian Region EPFD Support to (support) — The commenter emphasizes that reliable Internet access is crucial for telehealth, remote learning, and job training, which are vital for families and jobseekers in their region.
The potential impact of EPFD limit changes on terrestrial services and the need for comprehensive studies to assess this.
Filers split on: “The Commission should require studies to assess the impact of EPFD changes on terrestrial services.”
6 filers engaged this issue.
- Hispasat S.A. (support) — The commenter urges the Commission to support the ongoing studies at the ITU regarding EPFD limits, emphasizing that changes should not be made until these studies are complete.
- EchoStar Corporation EchoStar NGSO GSO Sharing (support) — The company acknowledges the need for technical studies but insists that existing protections should not be discarded without thorough assessment.
- Utilities Technology Council (support) — UTC agrees with other commenters that any modifications to the limits should be based on comprehensive studies that assess the potential impacts on terrestrial microwave systems, ensuring that their reliability is not compromised.
- Fixed Wireless Communications Coalition fl.202 (support) — The FWCC points out that the NPRM's questions regarding the protection of terrestrial operations have not been sufficiently addressed by commenters, which could hinder the Commission's ability to make informed decisions.
- American Astronomical Society American Astrono (oppose) — The AAS warns that significant changes to the regulatory framework could disrupt the balance between commercial interests and the protection of existing services, which have been effective until now.
- Space Exploration Holdings — The commenter notes that since the tests are still in progress, the results should be considered preliminary and not definitive until all phases are completed.
Most-cited authorities
- FCC 25-23 — cited by 39 filer(s)
- 47 CFR § 2.106 — cited by 10 filer(s)
- FCC-25-23A1 — cited by 7 filer(s)
- 47 CFR § 25.140. — cited by 6 filer(s)
- FCC 25-13 — cited by 4 filer(s)
- 47 C.F.R. §25.289 — cited by 4 filer(s)
- FCC 24-117 — cited by 3 filer(s)
- FCC 25-29 — cited by 3 filer(s)
- 47 CFR § 25.208 — cited by 3 filer(s)
- 47 CFR §§ 25.146 — cited by 3 filer(s)
- 47 U.S.C. § 151 — cited by 3 filer(s)
- FCC 24-136 — cited by 2 filer(s)
Who filed (43)
ATT Services ATT, American Astronomical Society American Astrono, Appalachian Broadband Innovators ABI FCC, Astranis Space Technologies, Avanti Hylas 2 Limited AH2L reply comments for, CORF National Academy of Sciences CORF, CTIA 250728 CTIA, CTIA 250827 Draft CTIA, Central Council of the Tlingit Haida Indian Tr, Chamber of Progress Chamber of Progress Modern, Chamber of Progress FCC EPFD, Commercial Space Federation 07.28.25 FCC Moder, Computer Communications Industry Association C, Comsearch an ANDREW Company Comsearch GSO NGSO, DIRECTV, Dr. Rebecca Grant 7.21.25 RG FCC, EchoStar Corporation EchoStar NGSO GSO Sharing, Fixed Wireless Communications Coalition fl.202, Gogo Business Aviation, Hispasat S.A., Information Technology and Innovation Foundati, International Center for Law Economics 2025 EP, Jack Kennedy VIA ELECTRONIC MAIL FCC, Kuiper Systems, Mary Guenther July 2025 PPI EFPD Filing, National Association of Broadcasters NAB, National Radio Astronomy Observatory NRAO, National Radio Astronomy Observatory NRAO Repl, NetChoice NetChoice, Nokia Nokia GSO NGSO Sharing, Ovzon, Phoenix Center for Advanced Legal Economic Pub, Public Knowledge PK OTI Spectrum Sharing, SES S.A. and Affiliates SES EPFD, Shaping Our Appalachian Region EPFD Support to, Software Information Industry Association 2025, Space Exploration Holdings, TechNet 250728 TechNet FCC, Telesat Canada Telesat, Telesat Corporation Telesat, The Software Information Industry Association , Utilities Technology Council, Viasat