At an Open Meeting last week, the Federal Communications Commission (FCC)  unanimously adopted a Further Notice of Proposed Rulemaking (FNPRM) that proposes to permit more intensive and efficient use of the 12.7 GHz and 42 GHz bands by satellite communications, either as an alternative or complement to terrestrial wireless.  Chairman Carr emphasized that, if adopted, the Proposed Rule would make 20,000 megahertz of spectrum available for satellite-based services, which Chairman Carr characterized as a necessary step for U.S. leadership in spectrum and a clear sign to China.  Carr stated that the additional spectrum, in conjunction with other actions the FCC is taking across multiple spectrum bands, would protect American technological leadership.

The FNPRM builds upon the FCC’s recent requests for comments on providing increased access to spectrum for terrestrial wireless services.  This FNPRM expands upon that record to contemplate authorizing satellite communications in the 12.7 GHz and 42 GHz bands and seeks comment on the feasibility of allowing satellite communications in those bands in both the Earth-to-space and space-to-Earth directions.

The 12.7 GHz band

The 12.7 GHz band is currently allocated for satellite and terrestrial wireless uses, with limited Federal operations in the band.  The 12.75-13.25 GHz portion of the band is also allocated for NASA to operate its Deep Space Network.  The FCC’s U.S. Table of Frequency Allocations, which outlines how radio spectrum is allocated for use by various entities including Federal government and private sector entities, precludes fixed-satellite service (FSS) systems in geostationary orbit from using the 12.75-13.25 GHz band for domestic services.  The FNPRM asks whether it is still necessary to prohibit FSS deployment in the 12.7 GHz band, or if there are other ways to protect incumbent operations without prohibiting domestic satellite operations. 

This FNPRM follows the FCC’s recent efforts to more effectively utilize the 12.7 GHz band.  In October 2022, the FCC released the 12.7 GHz Notice of Inquiry to solicit input on how the FCC could encourage more efficient use of the 12.7 GHz band and whether it should authorize mobile broadband in the band.  In May 2023, the FCC moved forward with expanding the use of the 12.7 GHz band and issued a Notice of Proposed Rulemaking proposing to repurpose some of the 12.7 GHz band for mobile terrestrial broadband, or other uses.

The FNPRM adopted last week seeks comment on ways to minimize or eliminate existing regulatory burdens that prevent use of the 12.7 GHz band by geostationary orbit (GSO) and non-geostationary orbit (NGSO) satellite systems.  GSO operations in the 12.7 GHz band are currently only authorized for communications between domestic and international points.

The FNPRM also explores expanding the use of the 12.7 GHz band by Earth Stations in Motion (ESIM), which operate aboard aircraft and vessels, and to permit blanket-licensed earth stations.  ESIM operations with NGSO FSS are already authorized in the space-to-Earth direction in the adjacent 12.2-12.7 GHz band.  Under the 2023 World Radio Conference, ESIMs are authorized in the 12.7 GHz band for use on aircraft and vessels communicating with GSO FSS stations on a global level.  The FNPRM thus would align the U.S. allocation of 12.7 GHz to include ESIM operations in the Earth-to-space direction.

The FNPRM invites comment on ways to protect incumbent users in the 12.7 GHz band and Federal operators in adjacent 13.25-13.4 GHz band, which is used by the Department of Defense (DoD) and Federal Aviation Administration (FAA), as well as operators in the 13.4-13.75 GHz band, which is used by DoD, the National Oceanic and Atmospheric Administration (NOAA), NASA, and other Federal operators.  The Further Notice notes that NTIA previously has expressed concern that increased use of the 12.7 GHz band will cause interference with NASA and NOAA satellite operations, as well as DoD radar, and invites comment on that issue.

The 42 GHz band

The 42 GHz band is not currently allocated for FSS services in the United States and has no incumbent licensees.  In 2010, the FCC considered adding a primary allocation for space-to-Earth satellite communications, which is how the spectrum band is designated in international spectrum allocations.  However, in 2016, the FCC declined to adopt that allocation and reserved the 42.0-42.5 GHz for Upper Microwave Flexible Use Service (UMFUS), the collective term the FCC uses for innovative fixed, temporary fixed, mobile and Internet of Things (IoT) terrestrial wireless services.  The FCC affirmed that decision in 2018.  The FNPRM requests comment on whether changes to technology and spectrum demand since 2016 support revisiting that determination and allocating the 42 GHz band to satellite spectrum.  In June 2023, the FCC released a Notice of Proposed Rulemaking seeking comment on proposals to increase terrestrial wireless players’ access to the 42 GHz band by authorizing fixed service (FS) and mobile service (MS) operations on a shared basis. 

According to the FNPRM, NGSO FSS operators have sought authority to use the 42 GHz band to expand broadband services.  The FNPRM responds to that request by proposing to allocate the 42 GHz band for FSS.  The FNPRM requests comments on both an allocation for space-to-Earth operations on a secondary basis and on a primary basis, with particular emphasis on avoiding harmful interference and protecting the radioastronomy operations in the adjacent 42.5-43.5 GHz band.

Finally, the FNPRM seeks comment on whether there are cross-border coordination mechanisms in either of the 12.7 GHz and 42 GHz bands that should be reviewed or terminated.  

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Comments on the FNPRM will be due 30 days after publication in the Federal Register, which has not yet occurred.  Reply comments will be due 60 days after publication in the Federal Register.

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Photo of Gerard J. Waldron Gerard J. Waldron

Gerry Waldron represents communications, media, and technology clients before the Federal Communications Commission and Congress, and in commercial transactions. Gerry served as chair of the firm’s Communications and Media Practice Group from 1998 to 2008. Prior to joining Covington, Gerry served as the…

Gerry Waldron represents communications, media, and technology clients before the Federal Communications Commission and Congress, and in commercial transactions. Gerry served as chair of the firm’s Communications and Media Practice Group from 1998 to 2008. Prior to joining Covington, Gerry served as the senior counsel on the House Subcommittee on Telecommunications. During his work for Congress, he was deeply involved in the drafting of the 1993 Spectrum Auction legislation, the 1992 Cable Act, the Telephone Consumer Protection Act (TCPA), CALEA, and key provisions that became part of the 1996 Telecommunications Act.

Gerry’s practice includes working closely on strategic and regulatory issues with leading IT companies, high-quality content providers in the broadcasting and sports industries, telephone and cable companies on FCC proceedings, spectrum entrepreneurs, purchasers of telecommunications services, and companies across an array of industries facing privacy, TCPA and online content, gaming, and online gambling and sports betting-related issues.

Gerry has testified on communications and Internet issues before the FCC, U.S. House of Representatives Energy & Commerce Committee, the House Judiciary Committee, the Maryland Public Utility Commission, and the Nevada Gaming Commission.

Photo of Andrew Longhi Andrew Longhi

Andrew Longhi advises national and multinational companies across industries on a wide range of regulatory, compliance, and enforcement matters involving data privacy, telecommunications, and emerging technologies.

Andrew’s practice focuses on advising clients on how to navigate the rapidly evolving legal landscape of state…

Andrew Longhi advises national and multinational companies across industries on a wide range of regulatory, compliance, and enforcement matters involving data privacy, telecommunications, and emerging technologies.

Andrew’s practice focuses on advising clients on how to navigate the rapidly evolving legal landscape of state, federal, and international data protection laws. He proactively counsels clients on the substantive requirements introduced by new laws and shifting enforcement priorities. In particular, Andrew routinely supports clients in their efforts to launch new products and services that implicate the laws governing the use of data, connected devices, biometrics, and telephone and email marketing.

Andrew assesses privacy and cybersecurity risk as a part of diligence in complex corporate transactions where personal data is a key asset or data processing issues are otherwise material. He also provides guidance on generative AI issues, including privacy, Section 230, age-gating, product liability, and litigation risk, and has drafted standards and guidelines for large-language machine-learning models to follow. Andrew focuses on providing risk-based guidance that can keep pace with evolving legal frameworks.

Max Larson

Max Larson is an associate in the firm’s Washington, DC office. She is a member of the Technology and Communications Regulation Practice Group.