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Representatives from 11 communications and technology policy organizations wrote a joint letter to the FCC this week calling on the Commission to update rules for satellite power limits. 

Earlier this year, the FCC invited comment on equivalent power-flux density limits (EPFD) limits, which facilitate spectrum sharing by Geostationary Orbit (GEO) and Non-Geostationary Orbit (NGSO) operators.

The individuals argue that the FCC can update the EPFD limits while protecting GEO systems from interference, and updating the limits will increase LEO capacity and lower prices for customers and encourage competition in the satellite market. 

“Updating the EPFD limits will boost competition in the satellite market. The current outdated rules create a high barrier to entry for new and smaller companies, stifling innovation and limiting consumer choice. But increased power levels would mean higher capacity, allowing smaller constellations to offer high-capacity networks at lower costs because fewer launches and satellites would be needed to deploy constellations,” the letter says. 

The letter was signed by individuals from the International Center for Law & Economics, the Open Technology Institute at New America, and the Digital First Project. These organizations launched the Alliance for Satellite Broadband, along with Amazon in 2023, to advocate for updating EPFD rules ahead of the World Radiocommunication Conference (WRC). 

The letter also includes representatives from the Software & Information Industry Association; Public Knowledge; the Computer & Communications Industry Association; and others. 

EPFD limits were a contentious issue at WRC-23 spectrum conference, where NGSO operators Amazon and SpaceX urged the conference to adopt a future agenda item to study and potentially update the rules, while some GEO operators and countries strongly opposed this, arguing it would disrupt services from GEO. 

The outcome was that EPFD limits are not on the formal agenda for WRC-27. There will be studies through 2027, but they are not intended for regulatory action to be taken at WRC-27.

The letter called the ITU’s current EPFD rules “outdated,” and encouraged the FCC to take action on the limits and encourage changes at the ITU level as well.