On 30 April 2026 the FCC adopted FCC 26-26, the Report and Order titled "Modernizing Spectrum Sharing for Satellite Broadband," in SB Docket No. 25-157. The Order was released 1 May 2026 and published in the Federal Register on 13 May 2026 at 91 FR 26928. The substantive rules are effective 13 July 2026; two narrow amendatory instructions — §§ 25.146(a)(3) and 25.289(a)(2) — are indefinitely delayed, and the Commission will publish a separate Federal Register notice announcing the effective date for those subsections.
The Order is the U.S. domestic side of an argument that has been live in international fora since WRC-23: whether the EPFD limits that protect GSO networks from NGSO transmissions in the Ku- and Ka-band FSS downlinks still describe the technology and traffic of the satellite broadband market. The Commission's answer is that they do not. The framework that was adopted at WRC-2000 and folded into 47 CFR Part 25 in 2003 is being unbundled — coordination becomes the default, EPFD compliance ceases to be the relevant compliance demonstration, and four performance-based criteria sit underneath as backstops when coordination fails.
What did EPFD actually do, and what does it stop doing on 13 July?
Equivalent power flux-density is a calculation of the cumulative downlink power flux-density that an entire NGSO constellation produces at a point on the ground, expressed in dB(W/m²) within a defined reference bandwidth and integrated over the constellation's statistical distribution of satellites. The ITU Radio Regulations Article 22 limits were derived in the late 1990s for hypothetical NGSO constellations of that era and were incorporated domestically through §§ 25.146 and 25.289 of the Commission's rules. Compliance is demonstrated at the application stage using ITU software that the Order describes as relying on a worst-case-geometry satellite-selection algorithm and a relatively sensitive GSO reference antenna pattern.
Operationally, EPFD compliance forces NGSO operators into three concessions. The first is a low number of co-frequency beams serving any one area — typically Nco of 1, where the testing record shows Nco of 8 is technically achievable. The second is a wide GSO-arc avoidance angle, often 18 degrees, which forces extra satellites into the constellation to maintain coverage. The third is power back-off outside the avoidance angle to keep off-axis emissions under the limit. The combined effect is that compliance with EPFD limits, as currently interpreted by the ITU software, leaves NGSO systems operating 30 dB below the actual limit in parts of the upper Ka-band — meaningfully overprotective of GSO networks relative to the protection GSO networks afford each other through the Commission's two-degree orbital-spacing policy.
On 13 July 2026, §§ 25.146 and 25.289 are amended to remove the EPFD compliance pathway for NGSO FSS systems operating in the 10.7-12.7, 17.3-18.6, and 19.7-20.2 GHz bands, and to substitute the new coordination-and-backstop framework described below. EPFD remains the international framework under ITU Radio Regulations Article 22, and ITU Radio Regulations explicitly permit administrations to authorize exceedances on their own territory — which is the legal mechanism the FCC is exercising. PFD limits for terrestrial-service protection in the band segments where they apply, separately, are not affected by this Order.
How does the coordination-first framework actually work?
The Order makes good-faith coordination between NGSO and GSO operators the default. An NGSO applicant must demonstrate at the licensing stage that its system will meet the four backstop criteria against the set of 328 GSO reference links the Order incorporates as Appendix B; once an NGSO operator completes a coordination agreement with a particular GSO network operator, the NGSO operator may revise its technical showing by omitting the reference links of the coordinated GSO network. The compatibility analysis is then re-run against the remaining uncoordinated links. The Order is explicit that this carries over the implementation framework from the 2024 NGSO-NGSO degraded-throughput rules, including the C/N threshold conventions and the rain-fade flexibility from those proceedings.
Where coordination has not been reached, the four backstops apply against the relevant GSO reference link.
What are the four backstop criteria?
- Long-term, ACM GSO links: 3% time-weighted-average degraded throughput. This is the same metric the Commission adopted in the 2024 NGSO-NGSO sharing context and is harmonized with the ITU framework for the Q- and V-bands above 37.5 GHz.
- Short-term, all GSO links: 0.1% absolute increase in link unavailability. Notably tighter than the 0.4% threshold the Commission adopted for NGSO-into-NGSO sharing, and the Order explicitly chose absolute (not relative) increase to avoid the volatility of relative measures applied to links that already operate at 99.99% availability.
- Long-term, non-ACM GSO links (e.g., point-to-multipoint video, BSS): −10.5 dB interference-to-noise for 80% of the time. The Commission's stated rationale is that a Ku-band GSO link experiencing −10.5 dB I/N from an NGSO system is approximately as disturbed as it would be by a GSO competitor 6.5 degrees away on the arc — a separation at which ITU coordination is not required.
- All NGSO operations: a minimum 3-degree avoidance angle from the GSO arc. The Order treats this as a permanent additional layer of protection during the transition to the new framework, and reserves the option to revisit it once operating experience accumulates.
The Commission expressly declined to adopt aggregate interference limits across multiple NGSO systems, concluding that worst-case aggregation assumptions on top of the individual backstops would defeat the efficiency gains. It also declined to grandfather operations authorized under the old EPFD framework, on the rationale that no operator has a vested right in a particular spectrum-sharing regime and that the new rules increase efficiency without imposing retroactive liability.
How does this affect equipment authorization and conformity testing?
The Order is a satellite-system licensing rule, not an equipment-authorization rule, and so it does not directly change the FCC ID equipment-certification path under 47 CFR Part 2 for NGSO or GSO user terminals. What it changes is the technical envelope that a system-level authorization can describe — and therefore the operational parameters that user-terminal equipment, particularly NGSO user terminals, can be designed to. A user-terminal radio module that today is built around a power and elevation envelope sized for Nco of 1 and an 18-degree avoidance angle is operating well inside what its NGSO host system can be authorized to do once the new framework takes effect.
The downstream consequence for conformity testing is on the system side: NGSO applicants will be required to submit transparent compatibility demonstrations against the 328 GSO reference links, replacing the ITU EPFD-software outputs that have historically accompanied applications under §§ 25.146 and 25.289. The Order delegates authority to the Space Bureau to revise the reference-link set after a focused 60-day comment proceeding to be opened within 15 days of the Order's release. That proceeding is the operational document most worth tracking — it sets the actual technical envelope that compatibility analyses will be measured against in steady state.
What is the relationship to the WRC-27 process?
WRC-23 considered, and declined, to adopt a U.S.-and-nine-co-signatory CITEL proposal to put EPFD review on the WRC-27 agenda. The conference instead invited ITU-R Working Party 4A to conduct technical studies without regulatory consequences, and that work is still in progress. The Order's framing is that domestic action is permissible under ITU Radio Regulations Article 22 — which allows EPFD limits to be exceeded on the territory of any administration that so authorizes — and that waiting for the ITU process would forfeit several years of broadband-capacity benefit. The Commission anticipates that the U.S. record may inform WRC-27 deliberations but does not condition its rule on an international outcome.
Cross-border emission containment remains an obligation: NGSO systems notified by the United States are still required to respect EPFD limits on the territory of adjacent countries that have not authorized exceedances. The Commission's view, which is supported by the SpaceX and Amazon testing records cited in the Order, is that modern NGSO satellite beams are narrow enough to do this without separate cross-border agreements.
What should an NGSO or GSO operator do before 13 July?
- Re-baseline any pending or recently filed NGSO application against the new framework. The Commission applies the new rules to current licensees, market-access grantees, and pending applications. An application that today is supported by ITU-software EPFD compliance will need a compatibility demonstration against the Appendix B reference links — and that work can be started now against the published reference set.
- GSO operators should inventory their U.S.-served networks against the Appendix B reference-link set and identify which of their links rely on parameters not reflected in the reference links. The Order specifically allows the Space Bureau to add reference links following a focused proceeding, and a GSO operator with a representative high-availability link not currently covered has a 60-day window to make that case.
- Both sides should treat coordination as the primary path. The Order is structurally designed to push real-world interference outcomes into private agreements. An NGSO operator that completes coordination with a given GSO network removes that network's reference links from the compatibility test the FCC will run.
- For non-ACM GSO video links in particular — the most exposed category under the new framework — operators should validate that the −10.5 dB I/N for 80% of the time backstop is achievable for their current earth-station antenna populations, and identify any terminals that may need replacement or reconfiguration to maintain headroom against the new criterion.
- Track the Space Bureau's reference-link proceeding (to open within 15 days of the Order's release) and the separate Federal Register notice that will set the effective date for the §§ 25.146(a)(3) and 25.289(a)(2) amendments. Both are operational documents that will affect the actual content of compatibility analyses.
What does CTS take from this for client work?
Most CTS clients are not satellite system operators, so the direct compliance impact of this Order is narrow. The indirect impact is broader: NGSO user-terminal product roadmaps that have been constrained by the old EPFD envelope can be re-planned against a meaningfully larger operating envelope, which has consequences for antenna design, off-axis emission characterization, and the EMC test conditions that satellite-broadband CPE products are typically exercised against. For ground-segment equipment in the affected bands, the relevant compliance documents remain the equipment-certification rules under 47 CFR Part 2 and the band-specific terrestrial PFD limits — none of which this Order touches.
The forward-looking item to watch is the WRC-27 agenda. The Order is a unilateral U.S. action; if the international framework converges on a similar revision, the practical effect for hardware portfolios serving multiple jurisdictions is meaningfully different than if it does not. The Commission has stated that the U.S. record will be made available to ITU-R WP 4A, and the SpaceX and Amazon real-world testing record cited in the Order is unusually substantial relative to typical ITU input documents.