August 30, 2025
Several satellite operators acknowledge an openness to revisiting EPFD limits in their recent comments to the FCC.

SES

  • “Epfd adjustments could be explored in the Ka-band”
  • “If the Commission is inclined to act unilaterally, then it should consider potential adjustments to the Ka-band epfd limits.” 
  • “[W]hen the Ka-band epfd limits are converted into I/N ratios, the results show that the upper Ka-band epfd downlink limits are more protective of GSO links than the ITU’s long-established, recommended I/N criteria for such links. As a result, Ka-band epfd limit adjustments might be possible without appreciable impact to existing GSO operations.”

EchoStar

  • “EchoStar supports the Commission’s fresh look at the current sharing framework, is willing to acknowledge that further technical analysis is necessary to evaluate the appropriateness of the current epfd limits, and uniquely understands the need to modernize the rules under which NGSOs operate while preserving sufficient protection from harmful interference for GSOs.”

Telesat

  • “The comments in this proceeding reflect broad support for revisiting the EPFD limits on NGSO systems in the Ku- and Ka-bands that were developed decades ago and were intended solely to protect GSO systems, without regard to the impact that overly restrictive limits have on NGSO systems.”

Related Resources

Reforming the ITU’s EPFD framework: GSO and NGSO sharing in Ku and Ka bands

This paper outlines the Ofcom (UK) position to ensure the ITU's EPFD framework remains relevant and evolves to reflect how modern satellites are designed, deployed, and used.

Out of Orbit: How Outdated Spectrum Rules Hold Back Satellite Broadband

This issue brief from the International Center for Law & Economics examines EPFD limits and calls on international regulators to replace EPFD limits with standards that reflect how modern satellite networks perform.

Modernizing Space Policy: Unleashing Low Earth Orbit Satellite Connectivity

This one-pager from the Connect Everyone Coalition urges policymakers to modernize outdated space regulations, including EPFD rules, to unleash LEO satellite broadband and close the digital divide.