 Federal Communications Commission  FCC 23-114 
Before  the 
Federal Communications Commission  
Washington, D.C. 20554  
 
In the Matter of  
 
Modifying Emissions Limits for the 24.25 -24.45 
GHz and 2 4.75-25.25 GHz Bands  ) 
) 
) 
) 
  
 
ET Docket No. 21 -186  
 
 
NOTICE OF PROPOSED RULEMAKING  
 
Adopted:  December 12, 2023        Released:  December 2 2, 2023  
 
Comment Date:  30 days after publication in the Federal Register  
Reply Comment Date:   45 days after publication in the Federal Register  
 
By the Commission: Chairwoman Rosenworcel and Commissioner Gomez issuing separate statement s; 
Commissioners Carr and Simington dissenting and issuing separate statements.  
 
I. INTRODUCTION  
1. In this Notice of Proposed Rulemaking  (Notice) , we propose to implement certain 
decisions regarding the 24.25 -27.5 GHz band made in  the World Radiocommunication Conference held 
by the International Telecommunication Union (ITU) in 2019 (WRC -19).  Specifically, we propose to 
align part 30 of the Commission’s rules for mobile operations with the Resolution 750 limits on unwanted 
emissions into the passive 23.6 -24.0 GHz band that were adopted at WRC -19.  These proposed rule 
changes would help to facilitate the  protection of p assive sensors used for weather forecasting and 
scientific research in the 23.6 GHz -24.0 GHz band, while continuing to promote flexible commercial use 
of the 24.25 -24.45 GHz and 24.75 -25.25 GHz bands (collectively, 24 GHz band).   We also seek comment 
on alternatives to the proposals we make, and on other  related  issues.     
II. BACKGROUND  
2. The 23.6 -24.0 GHz band is allocated to the Earth Exploration Satellite Service (EESS) 
(passive), Space Research Service (passive), and Radio Astronomy Service (RAS)  on a primary basis.1  
EESS utilizes passive sensors located on satellites to measure the power level of naturally occurring radio 
emissions from water vapor and cloud liquid water molecules in the atmosphere, critical measurements 
for climatology science and weather forecasti ng.2  The National Oceanic and Atmospheric Administration 
(NOAA) uses such passive sensors to measure moisture data and determine water vapor in its weather 
forecast models.3  Because these naturally occurring emissions in the 23.6 -24.0 GHz band are very weak, 
the passive sensors measuring them are sensitive and vulnerable to interference.4  As these sensors receive 
 
1 47 CFR § 2.106 (a); see also CORF Comments at 9  (noting that EESS and RAS have co -primary allocations at 
23.6-24.0 GHz) . 
2 ITU Radiocommunication Bureau,  Handbook on Use of Radio Spectrum for Meteorology: Weather, Water and 
Climate Monitoring and Prediction  75, 78 (2017  ed.), https://library.wmo.int/doc_num.php?explnum_id=3793 ; see 
also NTIA Comments at 3 -4; CORF Comments at 4 -5 (describing how observations in the 23.6 -24 GHz band are 
critical to accurately measuring atmospheric humidity over oceans and water vapor in the lowest one kilometer in 
the atmosphere, which are important inputs to developing accurat e weather forecasts).   CORF notes that accurate 
weather forecasting is critical for safety of life and can reduce the costs of a natural disaster.   Id. at 5. 
3 NTIA  Comments at 4. 
4 See NTIA  Comments at 3-4; see also CORF  Comments at 3-4 (describing specifics of how interference in the 
23.6–24 GHz band affects the overall observing system) .  Federal Communications Commission   FCC 23 -114  
 2 all natural and man -made emissions in general, passive sensors are not able to differentiate these two 
sources of signals.  
3. The Commission first authorized service in the 24.25 -24.45 GHz and 25.05 -25.25 GHz 
bands in 1997, when it transitioned the Digital Electronic Messaging Service (DEMS) to th ese band s 
from the 18 GHz band .5  In 2000, the Commission adopted competitive bidding and service rules for th ese 
bands and created a 24 GHz Service.6  This 24 GHz Service ha d a total of 176 Economic Areas ( EA) or 
EA-like service areas.7  In 2004, the Commission held  Auction 56, in which it made 88 0 24 GHz licenses 
available.  Only seven of the 88 0 licenses were sold .8  As of 2017, there were 33 active DEMS licenses in 
these bands.9   
4. In 2017, the Commission authorized the 24 GHz band for Upper Microwave Flexible Use 
Services (UMFUS), and generally applied the same licensing and technical rules to UMFUS in the 24 
GHz band that it applied to UMFUS in other upper microwave bands.10  The UMFUS rules allow 
licensees flexibility as to the services they will deploy and the architecture of their networks.  Under these 
rules , licensees are able to deploy mobile services,11 but they also may implement fixed point -to-point and 
point -to-multipoint systems.12  Among other things, the UMFUS rules specify that emissions outside of a 
licensee’s assigned frequency block must be limited to –13 dBm/MHz.13  With respect to the passive 
systems operating in the 23.6 -24 GHz band, the Commission noted that ongoing international studies 
 
5 See Amendment of the Commission’s Rules to Relocate the Digital Electronic Message Service from the 18 GHz 
Band to the 24 GHz Band and To Allocate the 24 GHz Band for Fixed Services , ET Docket No. 97 -99, Order , 12 
FCC Rcd 3471 (1997) (reallocating DEMS from the 18 GHz band to the 24 GHz Band), reconsideration denied , 
Memorandum Opinion and Order , 13 FCC Rcd 15147 (1998); see also Amendment of the Commission’s Rules to 
Relocate the Digital Electronic Message Service from the 18 GHz Band to the 24 GHz Band and To Allocate the 24 
GHz Band for Fixed Services , ET Docket No. 97 -99, Order , 12 FCC Rcd 8266 (PSPWD 1997) (modifying DEMS -
based licenses to change authorized band of operations from 18 GHz to 24 GHz).  
6 See Amendments to Parts 1, 2, 87 and 101 of the Commission’s Rules to License Fixed Services at 24 GHz , WT 
Docket No. 99 -327, Report and Order , 15 FCC Rcd 16934, 16937, para. 3 (2000) (“ 24 GHz R&O ”) (adopting 
competitive bidding and service rules for 24 GHz Band).  
7 See 47 CFR  § 101.523  (2016) . 
8 See 24 GHz Service Spectrum Auction Closes, Winning Bidders Announced , Public Notice, 19 FCC Rcd 14738 
(WTB 2004).  
9 See Use of Spectrum Bands Above 24 GHz For Mobile Radio Services, et al., GN Docket No. 14 -177, IB Docket 
Nos. 15-256 and 97 -95, WT Docket No. 10 -112, Second Report and Order, Second Further Notice of Proposed 
Rulemaking, Order on Reconsideration, and Memorandum Opinion and Order , 32 FCC Rcd 10988 , 10995, para. 16  
(2017)  (Spectrum Frontiers 2 nd R&O ).  While the former DEMS licenses were converted to UMFUS licenses, they 
were subsequently cancelled.  See, e.g. , FiberTower Spectrum Holdings, LLC , Order on Remand and Memorandum 
Opinion and Order, 33 FCC Rcd 253 (WTB BD 2018) . 
10 See 47 CFR pt. 30, Subpart C.  The Commission previously adopted licensing and technical rules for UMFUS 
services in the 27.5 -28.35 GHz band, the 37.6 -38.6 GHz band, and the 38.6 -40 GHz band.  See Use of Spectrum 
Bands Above 24 GHz For Mobile Radio Services, et al ., GN Docket No. 14 -177, IB Docket Nos. 15 -256 and 97 -95, 
RM-11664 , WT Docket No. 10 -112, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 
8014 , 8023 -63, paras. 17 -124 (2016) (Spectrum Frontiers 1st R&O ). 
11 47 CFR §§ 30.6(a), 30.202(a).  
12 47 CFR pt. 30 Subpart E.   
13 47 CFR § 30.203(a).  In  the bands immediately outside and adjacent to the licensee's frequency block, having a 
bandwidth equal to 10 percent of the channel bandwidth, the conductive power or the total radiated power of any 
emission shall be −5 dBm/MHz or lower .  As the 23.6 -24 GHz passive band is 250 megahertz away from the 
UMFUS bands, the −5 dBm/MHz does not apply within that passive band for UMFUS licensees.    Federal Communications Commission   FCC 23 -114  
 3 include d analyses to determine  International Mobile Telecommunications (IMT)14 unwanted  emission s 
limits necessary to protect passive sensors , and it acknowledged that the Commission’s UMFUS rules 
might be revisited o nce the se international studies ha d been completed.15 
5. WRC -19 allocated 24.25 -25.25 GHz to mobile (except aeronautical) on a primary basis 
in Regions 1 and 2 , globally identified the 24.25 -27.5 GHz band for IMT, and established limits o n 
unwanted emissions applicable to IMT in the 24.25 -27.5 GHz band to protect EESS passive systems in 
the 23.6 -24.0 GHz band from harmful interference.16  To protect EESS passive systems, WRC -19 
modified a footnote to the International Table of Allocations to add a new limit contained in  Resolution 
750 (Rev. WRC -19).17  Resolution 750 specifies unwanted emission s limits in terms of Total Radiated 
Power (TRP)18 as the amount of power that may be radiated into any 200 megahertz block of the 23.6 -
24.0 GHz passive band by IMT base stations and IMT mobile stations operating in the 24.25 -27.5 GHz 
band.  Resolution 750 s ets emissions limits for current IMT devices as well as more stringent emission s 
limits for  IMT devices  that will be brought into use in the 24.25 -27.5 GHz band on or after September 1, 
2027.19  These two sets of unwanted emission s limits are shown in Table 1.   
 
Table 1: WRC -19 Resolution 750 Unwanted emissions permitted within any 200 megahertz in the 
23.6-24 GHz passive band  
Type of Station  Current TRP Limits  TRP Limits After Sept. 1, 2027  
IMT Base Stations  –33 dBW  –39 dBW  
IMT Mobile Stations  –29 dBW  –35 dBW  
 
6. On April 26, 2021, the Office of Engineering and Technology and the Wireless 
Telecommunications Bureau issued a Public Notice  that sought  to develop a record on whether and how 
the Commission  could implement the emission s limit s contained in Resolution 750 for the  active services 
in the 24 GHz band . 20  The Public Notice  specifically sought comment on the possibility of amending 
part 30 of the Commission’s rules to conform to the unwanted emissions limits into the passive 23.6 -24.0 
 
14 IMT is the generic term used by the ITU to designate broadband mobile systems and encompasses IMT -2000, 
IMT- Advanced and IMT -2020 .  See https://www.itu.int/en/ITU -R/Documents/ITU -R-FAQ -IMT.pdf  (last visited 
September 18, 2023 ). 
15 Spectrum Frontiers 2nd R&O , 32 FCC Rcd at 10997, para. 22 ; see also  Use of Spectrum Bands Above 24 GHz 
For Mobile Radio Services, et al. , GN Docket No. 14 -177, WT Docket No. 10 -112, Third Report and Order, 
Memorandum Opinion and Order, and Third Further Notice of Proposed Rulemaking, 33 FCC Rcd 5576 , 5581 -82, 
para. 15 (2018)  (recognizing  the need to protect passive satellite operations that provide important data necessary for 
weather predictions and warnings , and stating that “[o] nce interference protection standards are agreed upon 
internationally we will, if necessary, consider through notice and comment whether any modification of our current 
out-of-band limits may be needed .”) 
16 ITU Radio Regulations (2020), Resolution 750 (Rev.WRC -19), Table 1, Vol. 3 at 519, 
https://www.itu.int/en/myitu/Publications/2020/09/02/14/23/Radio -Regulations -2020 .  Resolution 750 specifies 
limits of unwanted emission power for IMT base stations and mobile stations.   
17 ITU Radio Regulations (2020), footnote 5.338A, Vol. 1 at 100.  
18 ITU Radio Regulations (2020), Resolution 750 (Rev.WRC -19), Note 5, Vol. 3 at 522.  
19 For IMT base stations and mobile stations brought into use prior to September 1, 2027, the more relaxed 
unwanted emission s limits will continue to apply.  ITU Radio Regulations (2020), Resolution 750 (Rev.WRC -19), 
Table 1, Vol. 3 at 519, 522.  
20 See Office of Engineering & Technology and the Wireless Telecommunications Bureau Seek Comment on 
Emission Limits for the 24.25 -27.5 GHz Band , Public Notice, 36 FCC Rcd 7561  (OET WTB  2021) ( Public Notice ).  Federal Communications Commission   FCC 23 -114  
 4 GHz band that were adopted at WRC -19 and/or to add footnotes to the United States Table of Frequency 
Allocations  at part 2 of the Commission’s rules .21  
7. The Public Notice  sought comment regarding what level of emissions could be expected 
within the 23.6 -24.0 GHz band  from UMFUS transmitters, and whether and to what extent new 5G 
deployments  at the current UMFUS emissions limit s could cause  harmful interference to passive systems 
operating in the 23.6 -24.0 GHz.22  It also asked how equipment intended for use under the UMFUS rules 
in the 24 GHz band could be reconfigured  to conform to both the current and future Resolution 750 
unwanted emissions limits .  In addition, the Public Notice asked whether licensees could meet the  
Resolution 750  deadlines , as well as  whether the Commission could help facilitate a more accelerated 
timeframe.23  It also inquired whether such emissions limits should be measured as conducted power or 
total radiated power.24  
8. The Public Notice  also sought comment on the scope of operations that would be covered 
if the Commission were to adopt the emission s limits in Resolution 750 for the 24.25 -27.5 GHz band .  In 
particular, it sought comment on whether the Resolution 750 unwanted emissions limits should apply to 
(1) IMT mobile systems only, (2) all mobile systems, or (3) all systems, including fixed point -to-point 
and point -to-multipoint systems.25  As noted above, the unwanted emission s limits of Resolution 750 
apply only to IMT base stations and mobile stations.  IMT standards are not specific technologies, but 
rather specifications and requirements for high -speed mobile broadband service.26  The Public Notice  
noted that Resolution 750 specified TRP as the only means of measuring whether equipment met the 
required emissions limits.27  It asked if there are any difficulties in performing over the air TRP 
measurements at such low signal levels in the 24.25 -24.45 GHz and 24.75 -25.25 GHz  bands, and whether 
a conductive power methodology should be permitted as an alternative means of demonstrating 
compliance with the emissions limits for equipment certification.28   
9. Comments on the Public Notice  were due  June 26, 2021 , and reply comments were due 
July 26, 2021.29  The Office of Engineering and Technology and Wireless Telecommunications Bureau 
received ten comments, and four reply comments.  A list of commenters, reply commenters, and ex parte  
filers is contained in Appendix C.  
III. DISCUSSION  
A. Revision of Commission Rules to Adopt Resolution 750 Unwanted Emissions Limits  
10. We propose to adopt the Resolution 750 unwanted emissions limits adopted at WRC -19, 
to apply them to all mobile systems in the 24 GHz band, and to incorporate those limits into our part 30 
technical rules  as well as codifying them in a new US footnote to the Table of Frequency Allocations  
 
21 Public Notice , 36 FCC Rcd at 7561, 7563 (citing 47 CFR § 2.106; 47 CFR pt.30). 
22 Public Notice , 36 FCC Rcd at 7563.  
23 Public Notice , 36 FCC Rcd  at 7563.  See also infra , para. 25 (seeking comment on adopt ing a timetable wherein 
deployments would be required to meet the first phase limits as of the effective date of any rules adopted, and 
deployments after September 1, 2027 would be required to meet the stricter second phase limits) . 
24 Public Notice , 36 FCC Rcd  at 7564.   
25 Public Notice , 36 FCC Rcd  at 7564.   
26 See https://www.itu.int/en/ITU -R/Documents/ITU -R-FAQ -IMT.pdf  (last visited Oct. 15 , 2021).   The 
Commission’s rules do not define IMT and do not require that equipment complying with a particular technical 
standard be used in a band licensed under the UMFUS rules.   
27 Public Notice , 36 FCC Rcd at 7564.  
28 Public Notice , 36 FCC Rcd at 7564.  
29 Emission Limits for the 24.25 -27.5 GHz Band , 86 Fed. Reg. 28522  (May 27, 2021).   Federal Communications Commission   FCC 23 -114  
 5 (Allocation Table) .30  Under this proposal, as of the effective date of the rules, mobile operations in the 24 
GHz band would be required to comply with the current TRP limits adopted at WRC -19.  We seek 
comment on this proposal and on alternative limits, including the  effect of any changes to existing limits 
on smaller entities .  We also seek comment on the schedule for adoption of any revised limits, including 
adjustments that should be made for smaller entities to come into compliance.  Appropriate out -of-band 
emissions limits in the 24.25 -27.5 GHz band are important to protec t passive sensing operations in the 
23.6-24.0 GHz band, which are central to weather forecasting and scientific research.31 
11. Based on the record before us, it appears that the proposed Resolution 750 unwanted 
emission limits likely strike the appropriate balance between protecting passive sensing and facilitating 
use of the 24 GHz band.32  NTIA, AT&T, CTIA, Nokia, T -Mobile, Erics son, Marcus  & Jornet, and 
AGU/AMS/NWA support adopting these limits .33  They argue that adopting the se limits would provide 
important protection to extremely sensitive passive satellite operations,34 would allow 5G to continue to 
develop and deploy in the U.S.,35 would be consistent with U.S. policy as a signatory to the treaty of the 
text of the Radio Regulations,36 and would promote international harmonization.37  Moreover, NTIA 
asserts that adopting the rules would help to meet the Administration’s goals for climate monitoring and 
climatological science, would enable the U.S. to maintain its position as a world leader in 
telecommunications, and would enable manufacturers to produce equipment marketable across the 
globe.38  We ask parties that support adopting the Resolution 750 limits to quantify the benefits of these 
limits.   
12. We note that, while equipment manufacturers support adopting the Resolution 750 
limits,39 Qualcomm, in its comments to the Public Notice , opposes adopting these limits because it alleges 
 
30 See Letter from Eddie Johnson, Chairwoman and Frank Lucas, Ranking Member, Congressional Committee on 
Science, Space, and Technology, to Jessica Rosenworcel, Acting Chairwoman, FCC, at 2 (Aug. 10, 2021) (on file in 
ET Docket No. 21 -186) (Johnson & Lucas Congressional Letter) at 2 (advocating that the Commission enact 
changes to the 24 GHz technical standard s through a formal rulemaking to amend the part 30 rules ); see also 
Auctions of Upper Microwave Flexible Use Licenses for Next-Generation Wireless Servs. Notice & Filing 
Requirements, Minimum Opening Bids, Upfront Payments, & Other Procs. for Auctions 101 (28 G Hz) & 102 (24 
GHz) Bidding in Auction 101 Scheduled to Begin Nov. 14, 2018 , 33 FCC Rcd. 7575, 7619, para. 121 (2018) 
(reminding potential bidders that licenses are subject to changes in the conditions and regulations applicable to 
spectrum licenses, including by Commission rulemaking).  
31 Public Notice , 36 FCC Rcd  at 7563.  
32 We note that, in 2017, the Commission provided notice that ongoing international  studies  include d analyses to 
determine IMT -2020 OOBE limits necessary to protect passive sensors onboard weather satellites in the 23.6 -24 
GHz band, and that once the studies were completed , new rules might be necessary for protection of these 
operations.  In the Matter of Use of Spectrum Bands Above 24 GHz for Mobile Radio Servs. , 32 FCC Rcd. 10988, 
10997, para. 22 (2017).  
33 See NTIA Comments  at 5-6; CTIA Comments  at 2; Ericsson Comments  at 5; Nokia Comments  at 1; and T -
Mobile Comments  at 1; AGU/AMS/NWA  Reply Comments at 4; AT&T Reply Comments  at 2; CTIA Reply 
Comments  at 1; Letter from Lexi Shultz, VP Science Policy & Gov. Relations, American Geophysical Union, Stella 
Kafka, Executive Director, American Meteorological Society, Janice Bunting, CEO, National Weather Association, 
and Antonio Busalacchi, President, University Corporation for Atmospheric Research to Marlene H. Dortch, 
Secretary, FCC, ET Docket No. 21-186 (filed Dec. 22, 2022) at 2 (AGU/AMS/NWA/UCAR  Ex Parte ). 
34 NTIA Comments  at 2; CTIA Comments at 2; Ericsson Comments  at 4, 6; Marcus & Jornet Comments  at 1.  
35 NTIA Comments  at 2; CTIA Comment s at 2, 6; AT&T Reply Comments at 3 -4. 
36 T-Mobile Comments  at 3. 
37 NTIA Comments at 1 -2; T-Mobile Comments  at 3.  
38 NTIA Comments  at 2, 4. 
39 Ericsson Comments  at 5; Nokia Comments  at 1.  Federal Communications Commission   FCC 23 -114  
 6 that they will require equipment that uses the 24 GHz UMFUS band to operate with lower in -band power 
levels .40  We seek comment on Qualcomm’s concerns.  In particular, we ask parties that argue that 
adoption of the Resolution 750 limits would increase network deployment costs to quantify these 
additional costs and to specify the impact on existing and future service.  Commenters should separately 
discuss deployment costs associated with the current limits and limits recommended for implementation  
after Sept. 1, 2027 .  
13. We propose  to adopt the limits set forth in Resolution 750 .  In doing so, we also seek 
comment on whether some  changes to these limits may be appropriate  to help strike the best balance and 
better serve the public interest  in the United States  while protect ing EESS operations in the 23.6 -24.0 
GHz band.  For example, CORF asserts that the WRC limits are not stringent enough  to protect EESS 
operations , and it requests that the Commission should either adopt the European OOBE standard it 
offered going into WRC -19 (–42 dBW in 200 MHz)41 or the World Meteorological Organization (WMO) 
proposal ( –54 dBW in 200 MHz).42  CORF also points out that although the primary focus of the Public 
Notice  was protecting EESS, RAS also has a co -primary allocation at 23.6 -24.0 GHz.43     
14. AT&T, T -Mobile, and CTIA request that the Commission reject the more stringent limits 
suggested by CORF.44  AT&T argues that the stricter limits may hinder the roll -out and growth of 5G 
services.45   T-Mobile notes that the Resolution 750 limits from the ITU were carefully considered and are 
a product of extensive collaboration, and that CORF has not demonstrated why these limits are 
inadequate.46  CTIA argues that adopting CORF’s proposal would conflict with the notice that it asserts 
was given to bidders in the 24 GHz auction that the Commission would not adopt limits that  are 
significantly  stricter than what was agreed to at WRC -19.47  We seek comment on CORF ’s proposal in the 
record .  Parties supporting changes to the  Resolution 750  unwanted emission limits should provide 
additional technical justification  and explain why any stricter changes are necessary to protect EESS 
operations in the United States .  While CORF also raises issues concerning RAS, we note that Resolution 
 
40 See Qualcomm Comments at 1 -2. 
41 We note that after WRC -19, the European Union modified its stricter limits stating that  “[t]he continued 
application of the current more stringent EU -harmonised protection limits in the single market would  provide greater 
protection of the EESS (passive) across the territory of the Union.  However  the application of protection limits in 
the Union that differed from those applied in the rest of the world, in particular by being more stringent may affect 
the degree of equipment availability and choice, which in turn may have a negative impact on equip ment costs and 
the scale of investments in high -capacity (5G) networks…” and concluded that “Decision (EU) 2019/784 should be 
amended in order to preserve the balance of Union policies on 5G deployment and the monitoring of the Earth’s 
atmosphere and surfa ce and to foster the Union’s role  as a leader in the global 5G ecosystem of equipment and 
services .”).  See EU Commission implementing Decision (EU) 2020/590 (24 April 2020) amending Decision (EU) 
2019/784 , at https://docdb.cept.org/download/167 .  
42 CORF Comments at 11.   IEEE neither support s nor rejects the WRC -19 limits but propose the alternative of 
supporting whichever limit allows for the least power to be emitted into the 23.6 -24.0 GHz band.   IEEE Comment s 
at 4.  IEEE  also argues it is necessary to understand  the filter roll -off characteristics of the equipment being used in 
order to calculate the  amount of power that would be transmitted by that equipment into a 200 MHz block  of the 
23.6-24.0 GHz  band , and therefore requests that the Commission delay making a decision on limits until the 
Commission has completed such an evaluation.   Id.  Assuming we adopt rules that will limit the amount of 
unwanted emissions into the EESS band, our licensees will be required to comply with those limits by any means 
necessary.  Although we invite commenters to provide information on filter roll -off chara cteristics, we see no need 
to delay this proceeding pending such information.  
43 CORF Comments at  9. 
44 AT&T  Reply  Comments  at 4; T-Mobile  Reply  Comments  at 6; CTIA  Reply  Comments  at 7. 
45 AT&T Reply Comments at 4.  
46 T-Mobile Reply Comments at 6.  
47 CTIA Reply Comments at 5.   Federal Communications Commission   FCC 23 -114  
 7 750 was limited to protection of EESS, and RAS is outside the scope of this proceeding.  W e also note 
that RAS observations that are protected under US74 historically have received a lower level of 
protection than EESS.48         
15. We propose to make any changes to the limits on emissions into the 23.6 -24.0 GHz band 
by amending our part 30 rules  and adding a footnote to the U.S. Table of Allocations .49  Since our part 30 
rules already contain a rule governing emissions limits,50 it appears to be appropriate to incorporate any 
changes we make in this proceeding into that rule.  CORF, CTIA, and T -Mobile all support incorporating 
any changes to our emissions limits into part 30 of the Commission’s rules.51  We seek comment on 
alternative approaches.  
B. Services Subject to Resolution 750 Unwanted Emissions Limits  
16. We propose to apply the Resolution 750 unwanted emissions limits to all mobile 
operations  (as defined in Parts 2 and 20 of the Commission’s rules )52 in the 24 GHz band, not just to IMT 
operations.  While WRC -19 only applied the unwanted emission s limits of Resolution 750 to IMT base 
stations and mobile stations , the Commission’s rules do not define IMT and do not require  that equipment 
complying with a particular technical standard be used in a band licensed under the UMFUS rules.  
Accordingly, attempting to treat non -IMT mobile operations differently than IMT mobile operations 
could cause confusion and difficulties with enforcing the limits.  We also do not see a technical 
justification for applying differ ent emissions limits to IMT and non -IMT mobile systems.  NTIA believes 
that device and deployment density, along with pointing angles toward the satellite, are the predominant 
factors in causing interference to the passive satellite sensors, and these factors are not unique to IMT but 
common to all mobile systems.53  Additionally , we note that NTIA, CORF, and various wireless industry 
commenters support applying any revised emissions limits to all mobile operations, while no commenter 
supports applying the Resolution 750 emissions limits to only IMT mobile operations.54  We seek 
comment on this proposal.   We also seek comment on  NTIA’s request that we apply  the Resolution 750 
unwanted emissions limits to fixed operations, including point -to-point and point -to-multipoint 
 
48 Compare United States Table of Allocations, 47 CFR § 2.106 (c)(74)  (“In the bands . . . 23.6 -24.0 . . . GHz, the 
radio astronomy service shall be protected from unwanted emissions only to the extent that such radiation exceeds 
the level which would be present if the offending station were operating in compliance with the  technical standards 
or criteria applicable to the service in which it operates.”) with id.  at (c)(246)  (“No station shall be authorized to 
transmit in the following bands. . .”).  
49 See Appendix A for the proposed rule text.  The proposed footnote would require that stations in the mobile 
service in the 24.25 -27.5 GHz band comply with the Resolution 750 emission limits.   
50 See 47 CFR § 30.203.  
51 See CORF Comment s at 12 ; CTIA Reply Comment s at 7-8; T-Mobile Reply Comment s at 1; see also Johnson & 
Lucas Congressional Letter at 2 (advocating that changes to the 24 GHz emissions limits be made through amend ing 
the Part 30 UMFUS rules ).  
52 See 47 CFR § 2.1 (“Mobile Service. A radiocommunication service between mobile and land stations, or between 
mobile stations.”) ; see also 47 CFR § 20.3 (“Mobile Service. A radio communication service carried on between 
mobile stations or receivers and land stations, and by mobile stations communicating among themselves, and 
includes: (a) Both one -way and two -way radio communications services ; (b) A mobile service which provides a 
regularly interacting group of base, mobile, portable, and associated control and relay stations (whether licensed on 
an individual, cooperative, or multiple basis) for private one -way or two -way land mobile radio co mmunications by 
eligible users over designated areas of operation; and (c) Any service for which a license is required in a personal 
communications service under part 24 of this chapter.”)  
53 NTIA Comments  at 11 . 
54 See NTIA Comment s at 11 ; CORF Comments at 13; CTIA Comment s at 6-7; Qualcomm Comment s at 1; T -
Mobile Comment s at 6; Johnson & Lucas Congressional Letter at 2 .  Qualcomm opposes the WRC limits and asks 
the Commission to maintain the existing –13 dBm/MHz OOBE standard, but to the extent the Commission will 
adopt the  WRC  limits, it asks that they apply only to mobile deployments.   Qualcomm Comments at 2.   Federal Communications Commission   FCC 23 -114  
 8 operations,55 though we acknowledge that WRC -19 did not study fixed deployments.  NTIA argues the 
Commission should apply the two -phased WRC -19 emissions limit timetable described below to fixed 
deployments.56  It asserts that fixed services that cannot comply with the WRC -19 OOBE limits, or that 
cannot meet the phased approach, should be constructed to operate with no greater than 0 degree antenna 
up-tilt to protect satellite operations.57  NTIA further submits that the applicability of OOBE limits to 
fixed deployments is an issue that could merit explicit study – perhaps jointly by the Commission and 
NTIA – to gain sufficient confidence to relax the rules for fixed services.58  CORF and IEEE also want all 
potential UMFUS operations, mobile and fixed, to be subject to enhanced OOBE standards.59 
17. We seek comment on whether it would be  necessary to apply emissions limits stricter 
than –13 dBm/MHz to fixed operations in the 24 GHz band.  Proponents of applying stricter limits as well 
as those arguing for maintaining the existing limits should provide specific technical data justifying the ir 
respective positions , as well as the costs and benefits  of applying stricter limits or of keeping the existing 
limits .60  We note that numerous  point -to-point microwave links deployed by non -federal and federal 
operators in the 21.2 -23.6 GHz band (which has propagation characteristics similar to the 24 GHz band 
and is immediately adjacent to the 23.6 -24.0 GHz passive band ) operate with the same unwanted 
emission s limits that apply under the UMFUS rules.61  We seek comment on whether these existing 
deployments have caused harmful interference to passive sensors in the 23.6 -24.0 GHz band, and on the 
likelihood that the tighter beams of fixed point -to-point systems will be detected by passive instruments in 
space.  We also seek comment on whether there are material differences between existing fixed point -to-
point systems and fixed point -to-point and point -to-multipoint systems that m ay be deployed in the 24 
GHz band  in the future and how such systems m ight impact emissions into the 23.6 -24.0 GHz band.  
Further, w e seek comment on NTIA’s alternative suggestions  of limiting the elevation angles of fixed 
deployments.62 
18. Finally, we seek comment on Ericsson’s and AT&T’s proposal that indoor small -cell 
systems be exempt from the Resolution  750 limits .63  We urge parties who support an exemption for 
indoor systems to includ e a technical justification for treating indoor small -cell systems differently.   We 
note that indoor systems normally run at lower power and should have less difficulty meeting the 
Resolution 750 limits.  Conversely , building attenuation would further reduce the likelihood of unwanted 
emissions in the 23.6 -24 GHz passive band  from indoor small cell transmitters.  
C. Timetable for Application of WRC -19 Limits   
19. We propose to apply the new Resolution 750 unwanted emissions limits on the 
timeframes adopted at WRC -19.  Under  this proposal , the first phase limits ( –33 dBW for base stations, –
 
55 Point -to-multipoint operations include transportable user equipment, where the user equipment is not intended to 
be used while in motion, but the equipment could be moved when not in operation.  See 47 CFR § 30.2.  
56 NTIA Comments  at 12.  
57 NTIA Comments  at 12.   NTIA further submits that the applicability of OOBE limits to fixed deployments is an 
issue that could merit explicit study —perhaps jointly by the Commission and NTIA —to gain sufficient confidence 
to relax the rules for fixed services.  Id. 
58 NTIA Comments  at 12.  
59 See CORF Comments  at 13; IEEE Comments  at 5; see also  Johnson & Lucas Congressional Letter at 2 
(advocating that the Commission should consider applying the WRC -19 OOB E limits to all fixed systems ).  
60 We note the arguments that the scientific community is unable to determine whether data has been corrupted by 
low-level interference.  See CORF Comments at 13 -14. 
61 See 47 CFR § 101.111(a)(2)(ii) ( “Attenuation greater than 56 decibels or to an absolute power of less than −13 
dBm/1MHz is not required. ”) 
62 See NTIA Comments at 12.  
63 Ericsson Comments at 5 -6; AT&T Reply Comments at 6 -7.  Federal Communications Commission   FCC 23 -114  
 9 29 dBW for mobile stations) would apply as of the effective date of the rules, and the second phase limits 
(–39 dBW for base stations, –35 dBW for mobile stations) would apply to all deployments after 
September 1, 2027.  AT&T, CTIA, Ericsson, Nokia, and T -Mobile support adopting the WRC limits on 
the timeframes adopted by WRC -19.64  We note that no party has alleged that there will be a problem 
complying  with the first phase limits or has asserted that existing deployments in the 24 GHz band would 
be constrained by such limits.  AT&T, Ericsson, and Nokia state they will have equipment that meets the 
interim Phase 1 standard, and that they are working on c ompliance with the 2027 standards, which will 
depend on advances in chipsets and significant research and development.65  CTIA asserts that licensees 
and manufacturers have relied on the WRC -19 decisions in developing equipment and planning 
deployment, and it notes that the  3rd Generation Partnership Project (3GPP) standards development 
organization is adopting these limits into its standards for equipment operating in the band based on the 
timeframes determined at WRC -19.66  We seek comment on this proposal.  
20. One of the tools that the Commission uses to ensure compliance with our technical rules 
is our equipment authorization program for RF devices, which is codified in part 2 of our rules.67  In 
general, and for 24 GHz band devices used for mobile services, RF devices must comply with the 
Commission ’s technical  and equipment authorization requirements before they can be imported into or 
marketed  in the United States .68  Because the unwanted emission limits for base stations and mobile 
stations will change after September 1, 2027 under our proposal, equipment certifications based on 
compliance with the first phase limits would expire on that date.  Any equipment remaining in the supply 
chain —i.e. in warehouses or in transit —would then be illegal to sell or install under our rules.  To 
minimize this issue , we seek comment on whether we should prohibit the grant of new equipment 
certifications for , or the importation of , equipment not complying with the phase two unwanted emission 
limits at a date prior to September 1, 2027.  For example, we could cease granting new equipment 
certifications  or permitting importation of equipment certified as complying w ith only the first phase 
limits after March 1, 2027 —six months before the  implementation of the second phase limits.   Adopting 
such a rule could help prevent equipment that does not comply with the phase two unwanted emission 
limits from being deployed after September 1, 2027.   We would expect equipment manufacturers and 
distributors to manage their inventories to comply with the rules that we adopt.   
21. IEEE asks that the U.S. apply the stricter Phase 2 standards on an accelerated schedule  
for new deployments and in 2027 for all deployments, consistent with  the European Union.69  We seek 
comment on the feasibility and appropriateness of accelerating the deadline for compliance with the Phase 
2 standards.  In that regard, we request that equipment manufacturers and 24 GHz licensees provide 
further information on timelines for mobile  equipment availability and system deployment.  As noted 
above, while equipment manufacturers are working on equipment that would comply with the Phase 2 
 
64 CTIA Comments  at 7; Ericsson Comments  at 4; Nokia Comments at 1 -2; T-Mobile Comments  at 5; AT&T Reply 
Comment s at 3-4. 
65 Nokia  states its equipment meets the current WRC limits and that it is devoting substantial resources to meet the 
stricter limits by, but not earlier than, September 1, 2027. Nokia Comments  at 1-2.  Likewise, Ericsson states it 
already designs its equipment to meet the current, phase 1 WRC -19 limits, but cannot guarantee meeting the stricter, 
phase 2 limits prior to September 202 7.  Ericsson Comments  at 4.  AT&T states its planning is designed to meet 
Phase 1, but Phase 2 is significantly more restrictive and will require research and development, arguing against 
accelerated deadlines.  AT&T Reply Comments  at 3-4. 
66 CTIA Comments  at 7. 
67 See 47 CFR  pt. 2, subpart J.  
68 See 47 CFR §§ 2.803, 30.201.  Part 30 transmitters used for fixed point -to-point microwave and point -to-
multipoint services do not require certification.  See also 47 U.S.C. § 302a(b) (stating that no person shall 
manufacture, import, sell, offer for sale, or ship device s or home electronic equipment and systems, or use device s, 
which fail to comply with regulations promulgated under the Act).  
69 IEEE Comments at 4 -5.  Federal Communications Commission   FCC 23 -114  
 10 standards, it is not clear that equipment meeting the Phase 2 standards would be widely available on an 
accelerated time frame.70  Furthermore, the Phase 2 standards anticipate ubiquitous deployment of mobile 
systems in the band, and it is not clear that widespread deployment of mobile systems will occur in the 
band before 2027.  We also note that licensees in the band in the U.S. w ill not be required to demonstrate 
buildout before 2029.71   
22. NTIA requests that the Commission incentivize early adoption of the 2027 WRC limits, 
assert ing that  the WRC limits are based on estimates of gradual 5G deployment, which is at odds with the 
United States’  national priority of rapid 5G deployment.72  Noting that rapid 5G deployment in a range of 
frequency bands covering high -band, mid -band, and low -band spectrum is a priority for many countries 
around the world, and that international 5G deployments are well underway, w e seek comment on 
NTIA’s request.  What incentives  would facilitate deployment of equipment that meets the Phase 2 
limits?73  Are there steps the Commission can take to encourage the development and deployment of 
equipment that meets the Phase 2 standards?  
23. NTIA urges, and AGU/AMS/NWA agrees, that base stations and user equipment 
modified or replaced after September 1, 2027, should comply with the post -2027 (e.g., –39 dBW) OOBE 
levels .74  CTIA argues this requirement is overly broad and would effectively prevent licensees from 
making any changes to existing deployments without purchasing and installing entirely new equipment; 
furthermore , it asserts the WRC -19 decision makes clear that the more stringent limits apply to equipment 
brought into use after September 2027, and that equipment brought into use before that date will continue 
to be subject to the initial emission s limits.75  T-Mobile notes that equipment can be “modified” in a 
number of insignificant ways, and thus, the Commission should only treat base station modifications that 
affect the emission s characteristics as “modifications.”76  In contrast, AGU/AMS/NWA recommends that 
all legacy equipment installed prior to 2027 that does not meet the more stringent limits should be given a 
sunset date of September 1, 2028, for retrofit or replacement to comply with the  Phase 2 limits .77  CTIA 
and AT&T respond that the Commission should not apply  a more stringent emission s limit to any 
equipment that is modified or replaced after September 2027 .78 
24. We seek comment on adopt ing a timetable that matches what was adopted at  WRC -19; 
i.e., deployments would be required to meet the first phase limits as of the effective date of any rules we 
adopt, and deployments after September 1, 2027 would be required to meet the stricter second phase 
limits .  We note the co ncern  that significant research and development will be required to meet the 2027 
deadline in the U .S.  We seek comment on rules for transitioning equipment deployed under the Phase 1 
 
70 See Ericsson Comments at 4; Nokia Comments at 2; AT&T Reply Comments at 4.  
71 See 47 CFR § 30.103 (buildout showing required with initial renewal application ten years after initial license 
grant).  Most 24 GHz licenses were issued in 2019; for example, 2,912 licenses were offered at 24 GHz in Auction 
102, out of which 29 bidders won a  total of 2,904 licenses.  See Auction of  24 GHz Upper Microwave Flexible Use 
Service Licenses Closes, Public Notice, 34 FCC Rcd 4294, 4294, para. 1 (OEA2019); see also Auctions of Upper 
Microwave Flexible Use Licenses for Next -Generation Wireless Services , Public Notice, 33 FCC Rcd 4103, 4105, 
para. 3 (OEA 2018)  (explaining that Auction 102 would offer 2,912 licenses in the 24 GHz band) .   
72 See NTIA Comments  at 9. 
73 See Johnson & Lucas Congressional Letter at 2 (advocating that the Commission consider all available incentives 
to encourage operators in the 24.25 -24.45 GHz or 24.75 -25.25 GHz bands to meet the -39 dBW/200 MHz standard 
in equipment they deploy prior to September 1, 2027 ). 
74 NTIA Comments at 10; AGU/AMS/NWA  Reply Comments at 5.  
75 CTIA Reply Comments  at 6. 
76 T-Mobile Reply Comments at 4.  
77 AGU/AMS/NWA  Reply Comments at 5.  
78 AT&T Reply Comments at 4 -5; CTIA Reply Comments at 3 -4.  Federal Communications Commission   FCC 23 -114  
 11 limits , including  the proposal of NTIA and others that parties modifying or replacing equipment after 
September 1, 2027 must meet the more stringent OOBE limit (e.g., –39 dBW) .79  We seek to understand 
what would constitute “replacement” or “modification” of equipment under such a proposal .  What sort of 
technical changes would constitute a “modification” for this purpose?   Would any alterations qualify, or 
only those which altered certain technical parameters, such as antenna height?  To the extent that parties 
are correct that the U .S. would be better served by having its equipment ecosystem meet stricter emissions 
limits by 2024 as is required in Europe,80 we seek comment on whether there are any steps we can take to 
facilitate early adoption of the 2027 limit.   Additionally, as noted above, we seek comment on whether a 
different implementation schedule would be appropriate for smaller entities and if so, what would be the 
related costs and benefits.   
D. Measurement of Unwanted Emissions  
25. Currently, the UMFUS rules permit equipment manufacturers the flexibility of 
demonstrating compliance with the out -of-band emissions limits by using either a TRP or conductive 
methodology when  obtaining equipment certification.81  To the extent that we adopt new emissions limits 
to protect passive sensors in the 23.6 -24.0 GHz band, w e propose to allow compliance with  the unwanted 
emission s limits for the 23.6 -24.0 GHz band to be demonstrated using TRP measurements, and we seek 
comment on whether to permit use of conductive power measurements as well .     
26. CTIA , Nokia , and AT&T  support the Commission permitting use of either TRP or 
conductive power methodologies to measure emissions ,82 while NTIA, AGU/AMS/NWA, and Ericsson 
argue that only TRP should be allowed , consistent with the rules  adopted at WRC -19.83  CTIA urges the 
Commission to allow for measurement of emissions either in terms of TRP or conductive power to 
provide manufacture rs the flexibility to determine the most feasible approach for a particular device 
without affecting compli ance with the established limits.84  Other commenters assert that the Commission 
should not permit the conductive power methodology to be used to measure emissions into the 23.6 -24.0 
GHz band.  NTIA suggests  that only TRP measurements should be permitted  because the Resolution 750 
unwanted emissions limits are based on the use of TRP and because  conductive power, while useful, is 
presently less understood than TRP.85  Ericsson adds that mobile terrestrial systems are increasingly 
relying on large arrays of active antenna elements in their design, and there are no physical connections to 
the antenna elements, making conductive power measurements unnecessary.86  Ericsson does not 
anticipate encountering any difficulties in performing TRP measurements on low signal levels in the 
24.25 -24.45 GHz and 24.75 -25.25 GHz bands in a controlled chamber environment, such as anechoic 
chambers, where reliable and repeatable po wer measurements can be taken at discrete sets of points from 
 
79 See Johnson & Lucas Congressional Letter at 2 (advocating that the Commission should clarify that base station 
and user equipment modified or replaced after September 1, 2027 , must comply with the more stringent post -2027 
OOBE limits ). 
80 In Europe, the initial focus on licensing has been the 26.5 -27.5 GHz band.  See, e.g., Global update on spectrum 
for 4G & 5G , Qualcomm Corporation, December 2020, available at https://www.qualcomm.com/media/documents/  
files/spectrum -for-4g-and-5g.pdf  at 11.  
81 See 47 CFR § 30.203.  
82 CTIA Comments at 7 -8; Nokia Comments at 2; AT&T Reply Comments at 5.  
83 See NTIA Comments at 12; Ericsson Comments at 3-4; AGU/AMS/NWA Reply Comments at 7; see also 
Johnson & Lucas Congressional Letter at 2 (advocating that the Commission  should require licensees to use TRP to 
measure compliance with these emission limits ). 
84 CTIA Comments at 7 -8. 
85 NTIA Comments at 12.  
86 Ericsson Comments at 3.   Federal Communications Commission   FCC 23 -114  
 12 all directions from the antenna.87  AGU/AMS/NWA recognize Ericsson’s support for TRP and state that 
permitting multiple measurement techniques would make it difficult for the scientific community to use 
the measurement data from licensees to determine if those emissions may be detrimental to passive 
sensing measurements.88  
27. We note that no party objects to including TRP measurements as an acceptable 
alternative. As the Commission stated in the Spectrum Frontiers proceeding, however, a TRP 
measurement of a device requires that EIRP measurements be made around a spherical surface 
surroundi ng the device for both polarizations, and as a result it can be time consuming and difficult.89  
Given the complexity of making TRP measurements, we seek comment on whether allowing equipment 
manufacturers to use conductive power or other measurement alternatives will result in the increased 
potential for harmful interference to occur to 23.6-24.0 GHz band passive sensors.  We also seek 
comment on whether equipment with accessible connections to make conductive power measurements 
has been manufactured or will likely be manufactured for use in this band.  To the extent that commenters 
advocate against use of conductive power m ethodology for measuring unwanted emissions into the 23.6 -
24.0 GHz band, we seek comment on how to distinguish its disallowance in this band from generally 
accepted use domestically and internationally in other bands.90                
E. Other Matters  
28. Marcus  & Jornet support adopting the WRC limits but ask the Commission to consider 
alternative antenna technologies or standards that they believe would protect passive sensing.   For 
example, they urge the Commission to entertain  waiver requests for alternative antenna  technologies that 
demonstrate that the resulting emissions will protect the passive satellites to the  limits stated in 
Recommendation ITU -R RS.2017 -0.91  We will consider waiver requests in accordance with our normal 
practice if a specific request is filed , and in light of the specific circumstances, and do not see the need to 
seek comment on such requests here .92   
29. Meanwhile , Choyu Networks offers a proposal for Real -time Geospatial Spectrum 
Sharing (RGSS) as a method to ensure the protection of EESS radiometers from interference while 
enabling adjacent and coincident radio frequency spectrum to be used for 5G/6G (or alternativ e) 
communication networks.93  While the concept has potential interest, Choyu Networks admits that further 
research would be necessary to develop even a proof of concept RGSS system.94  Accordingly, it would 
 
87 Ericsson Comments at 4.  
88 AGU/AMS/NWA Reply Comments at 7.  
89 Spectrum Frontiers 1st R&O , 31 FCC Rcd at 8120, para. 303; Tadahiro Watanabe et al., Total Radiated Power 
Measurement above 1 GHz with Partially -Spherical Scanning of a Probe , 2009 Proceedings of the Institute of 
Electronics, Information and Communication Engineers at 179 ( http://www.ieice.org/proceedings/EMC09/pdf/  
21R3 -3.pdf ).  As Ericsson has pointed out, this requires measurements to be made in a controlled environment, such 
as an anechoic or reverberation chamber .  Ericsson Comments at 3 -4. 
90  Resolution 750 specifies that the unwanted emissions for all other bands except for 23.6 -24.0 GHz should be 
measured at the antenna port —i.e., they are conductive power limits.  ITU Radio Regulations (2020), Resolution 
750 (Rev.WRC -19), Table 1,  Table 2  Vol. 3 at 519 -524 https://www.itu.int/en/myitu/Publications/2020/09/02/14/  
23/Radio -Regulations -2020 .  The Commission’s rules have traditionally specified out -of-band emissions limits in 
terms of conductive power and only permit TRP as an option in the UMFUS rules, which were adopted in 2016 and 
which also specify a conductive limit.   47 CFR § 30.203(a); Spectrum Frontiers 1st R&O ,  31 FCC Rcd at 8119 -21, 
paras. 301 -304. 
91 Marcus & Jornet Comments at 6.  
92 See 47 CFR § 1.925(b)(3).  
93 Choyu Networks Comments at 5 -11. 
94 Choyu Networks Comments at 10.   Federal Communications Commission   FCC 23 -114  
 13 appear to be premature to develop proposed rules based on an RGSS system at this time, but we seek 
comment on this alternative proposal.  
30. Digital Equity and Inclusion.   Finally, the  Commission, as part of its continuing effort to 
advance digital equity for all,95 including people of color , persons with disabilities, persons who live in 
rural or Tribal areas,  and others who are or have been historically  underserved, marginalized, or adversely 
affected by persistent poverty or inequality, invites comment on any equity -related considerations96 and 
benefits (if any) that may be associated with the proposals and issues discussed herein.  Specifically, we 
seek comment on how our proposals may promote or inhibit advances in diversity, equity, inclusion, and 
accessibility , as well the scope of the Commission’s relevant legal authority . 
IV. PROCEDURAL MATTERS  
31. Regulatory Flexibility Act .  The Regulatory Flexibility Act of 1980, as amended (RFA),  
requires that an agency prepare a regulatory flexibility analysis for notice -and-comment rulemaking 
proceedings, unless the agency certifies that “the rule will not, if promulgated, have a signi ficant 
economic impact on a substantial number of small entities.”  Accordingly, the Commission has prepared 
an Initial Regulatory Flexibility Analysis (IRFA) concerning potential rule and policy changes contained 
in this Notice o f Proposed Rulemaking .  The IRFA is set forth in Appendix B.  
32. Comment Period and Filing Requirements .  Pursuant to sections 1.415 and 1.419 of the 
Commission’s rules, 47 CFR §§ 1.415, 1.419, interested parties may file comments and reply comments 
on or before the dates indicated on the first page of this document.  Comments may be filed using the 
Commiss ion’s Electronic Comment Filing System (ECFS).  See Electronic Filing of Documents in 
Rulemaking Proceedings, 63 FR 24121 (1998).  
• Electronic Filers :  Comments may be filed electronically using the Internet by accessing the 
ECFS:  http://www.fcc.gov/ecfs/.  
• Paper Filers :  Parties who choose to file by paper must file an original and one copy of each 
filing.  
• Filings can be sent by commercial overnight courier, or by first -class or overnight U.S. Postal 
Service mail.  All filings must be addressed to the Commission’s Secretary, Office of the 
Secretary, Federal Communications Commission.  
• Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must 
be sent to 9050 Junction Drive, Annapolis Junction, MD 20701.  
• U.S. Postal Service first -class, Express, and Priority mail must be addressed to 45 L Street NE 
Washington, DC 20554.  
• Effective March 19, 2020, and until further notice, the Commission no longer accepts any hand or 
messenger delivered filings. This is a temporary measure taken to help protect the health and 
 
95 Section 1 of the Communications Act of 1934 as amended provides that the FCC “regulat [es] interstate and 
foreign commerce in communication by wire and radio so as to make [such service] available, so far as possible, to 
all the people of the United States, without discrimination on the basis of race, color, religion, national origin, or 
sex.”  47 U.S.C. § 151.  
96 The term “equity” is used here consistent with Executive Order 13985 as the consistent and systematic fair, just, 
and impartial treatment of all individuals, including individuals who belong to underserved communities that have 
been denied such treatment, such as Black, Latino, and Indi genous and Native American persons, Asian Americans 
and Pacific Islanders and other persons of color; members of religious minorities; lesbian, gay, bisexual, 
transgender, and queer (LGBTQ+) persons; persons with disabilities; persons who live in rural are as; and persons 
otherwise adversely affected by persistent poverty or inequality.  See Exec. Order No. 13985, 86 Fed. Reg. 7009, 
Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal 
Government (January 20, 2021).   Federal Communications Commission   FCC 23 -114  
 14 safety of individuals, and to mitigate the transmission of COVID -19.  See FCC Announces 
Closure of FCC Headquarters Open Window and Change in Hand -Delivery Policy, Public 
Notice, 35 FCC Rcd 2788, 2788 -89 (OS 2020), https://www.fcc.gov/document/fcc -closes -
headquarters -open -window -and-changes -hand -delivery -policy . 
33. People with Disabilities :  To request materials in accessible formats for people with 
disabilities (braille, large print, electronic files, audio format), send an e -mail to fcc504@fcc.gov or call 
the Consumer & Governmental Affairs Bureau at 202 -418-0530 (voice), 202 -418-0432 (TT Y). 
34. The proceeding this Notice initiates shall be treated as a “permit -but-disclose” proceeding 
in accordance with the Commission’s ex parte rules.   Persons making ex parte presentations must file a 
copy of any written presentation or a memorandum summarizing  any oral presentation within two 
business days after the presentation (unless a different deadline applicable to the Sunshine period applies).  
Persons making oral ex parte presentations are reminded that memoranda summarizing the presentation 
must (1) li st all persons attending or otherwise participating in the meeting at which the ex parte 
presentation was made, and (2) summarize all data presented and arguments made during the 
presentation.  If the presentation consisted in whole or in part of the prese ntation of data or arguments 
already reflected in the presenter’s written comments, memoranda or other filings in the proceeding, the 
presenter may provide citations to such data or arguments in his or her prior comments, memoranda, or 
other filings (speci fying the relevant page and/or paragraph numbers where such data or arguments can be 
found) in lieu of summarizing them in the memorandum.  Documents shown or given to Commission 
staff during ex parte meetings are deemed to be written ex parte presentation s and must be filed consistent 
with rule 1.1206(b).  In proceedings governed by rule 1.49(f) or for which the Commission has made 
available a method of electronic filing, written ex parte presentations and memoranda summarizing oral 
ex parte presentations,  and all attachments thereto, must be filed through the electronic comment filing 
system available for that proceeding, and must be filed in their native format (e.g., .doc, .xml, .ppt, 
searchable .pdf).  Participants in this proceeding should familiarize themselves with the Commission’s ex 
parte rules.  
35. Paperwork Reduction Act.  This document does not contain proposed information 
collection requirements subject to the Paperwork Reduction Act of 1995, Public Law 104 -13.  In addition , 
therefore, it does not contain any proposed information collection burden “for small business concerns 
with fewer than 25 employees,” pursuant to the Small Business Paperwork Relief Act of 2002, Public 
Law 107 -198, see 44 U.S.C. § 3506(c)(4).  
36. For further information contact Simon Banyai of the Wireless Telecommunications 
Bureau, Broadband Division, at 202-418-1443 or by e-mail to Simon.Banyai@fcc.gov .  
V. ORDERING CLAUSES  
37. Accordingly , IT IS ORDERED, pursuant to sections 4(i), 301, 302, 303(r), 308, 309 , and 
333 of the Communications Act of 1934, 47 U.S.C. §§ 154(i), 301, 302a, 303(r), 308, 309 , 333,  that this 
Notice  of Proposed Rulemaking is HEREBY ADOPTED  and is EFFECTIVE upon publication in the 
Federal Register .  Federal Communications Commission   FCC 23 -114  
 15 38. IT IS FURTHER ORDERED that  the Commission’s  Office of Managing Director , 
Reference  Information Center, SHALL SEND a copy of this Notice of Proposed Rulemaking , including 
the Initial Regulatory  Flexibility Analysis , to the Chief Counsel for Advocacy of the Small Business 
Administration.  
 
      FEDERAL COMMUNICATIONS COMMISSION  
 
 
 
 
      Marlene H. Dortch  
      Secretary   Federal Communications Commission  FCC 23 -114  
 
16 APPENDIX A  
 
Proposed Rules  
 
For the reasons discussed in the preamble, the Federal Communications Commission proposes to amend 
part 30 of Title 47 as follows:  
PART 2 – FREQUENCY ALLOCATIONS AND RADIO TREATY MATTERS; GENERAL 
RULES AND REGULATIONS  
1. The authority citation for part 2 continues to read as follows:  
AUTHORITY : 47 U.S.C. 154, 302a, 303, and 336, unless otherwise noted.  
2. Amend §  2.106 (a) by revising paragraph (a) pages 54 and 55  in the Table of 
Frequency Allocations and adding paragraph (c)( 146) to read as follows : 
§ 2.106   Table of Frequency Allocations  
(a) * * *  
 
* * * * * 
17 22-22.21  
FIXED  
MOBILE except aeronautical mobile   
5.149  22-22.21  
FIXED  
MOBILE except aeronautical mobile   
US342  
 22.21 -22.5 
EARTH EXPLORATION -SATELLITE (passive)  
FIXED  
MOBILE except aeronautical mobile  
RADIO ASTRONOMY  
SPACE RESEARCH (passive)   
5.149  5.532  22.21 -22.5 
EARTH EXPLORATION -SATELLITE (passive)  
FIXED  
MOBILE except aeronautical mobile  
RADIO ASTRONOMY  
SPACE RESEARCH (passive)   
US342  US532  
22.5-22.55  
FIXED  
MOBILE  22.5-22.55  
FIXED  
MOBILE   
US211  
22.55 -23.15  
FIXED  
INTER -SATELLITE  5.338A  
MOBILE  
SPACE RESEARCH (Earth -to-space)  5.532A  
 
5.149  22.55 -23.15  
FIXED  
INTER -SATELLITE  US145  US278  
MOBILE  
SPACE RESEARCH (Earth -to-space)  5.532A  
 
US342   
Satellite  
   Communications (25)  
Fixed Microwave (101)  
23.15 -23.55  
FIXED  
INTER -SATELLITE  5.338A  
MOBILE  23.15 -23.55  
FIXED  
INTER -SATELLITE  US145  US278  
MOBILE  
23.55 -23.6 
FIXED  
MOBILE  23.55 -23.6 
FIXED  
MOBILE   
Fixed Microwave (101)  
23.6-24 
EARTH EXPLORATION -SATELLITE (passive)  
RADIO ASTRONOMY  
SPACE RESEARCH (passive)   
5.340  23.6-24 
EARTH EXPLORATION -SATELLITE (passive)  
RADIO ASTRONOMY  US74  
SPACE RESEARCH (passive)   
US246   
24-24.05  
AMATEUR  
AMATEUR -SATELLITE   
5.150  24-24.05  
 
  
5.150  US211  24-24.05  
AMATEUR  
AMATEUR -SATELLITE   
5.150  US211   
ISM Equipment (18)  
Amateur Radio (97)  
24.05 -24.25  
RADIOLOCATION  
Amateur  
Earth exploration -satellite (active)   
5.150  24.05 -24.25  
RADIOLOCATION G59  
Earth exploration -satellite (active)  
  
5.150  24.05 -24.25  
Amateur  
Earth exploration -satellite (active)  
Radiolocation   
5.150   
RF Devices (15)  
ISM Equipment (18)  
Private Land Mobile (90)  
Amateur Radio (97)  
24.25 -24.45  
FIXED  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  24.25 -24.45  
FIXED  5.532AA  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  
RADIONAVIGATION  24.25 -24.45  
FIXED  
MOBILE  5.338A  5.532AB  
RADIONAVIGATION  24.25 -24.45  24.25 -24.45  
FIXED  
MOBILE   USxxx  
RF Devices (15)  
Upper Microwave  
   Flexible Use (30)  
Page 54  
   
18  
Table of Frequency Allocations                                                                                                                   24.45 -31.8 GHz (SHF/EHF)  Page 55  
International Table  United States Table  FCC Rule Part(s)  
Region 1 Table  Region 2 Table  Region 3 Table  Federal Table  Non-Federal Table   
24.45 -24.65  
FIXED  
INTER -SATELLITE  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  24.45 -24.65  
FIXED  5.532AA  
INTER -SATELLITE  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  
RADIONAVIGATION   
5.533  24.45 -24.65  
FIXED  
INTER -SATELLITE  
MOBILE   5.338A  5.532AB  
RADIONAVIGATION  
 
5.533  24.45 -24.65  
INTER -SATELLITE  
RADIONAVIGATION  
 
 
 
5.533   
RF Devices (15)  
Satellite  
   Communications (25)  
24.65 -24.75  
FIXED  
FIXED -SATELLITE  
   (Earth -to-space)  5.532B  
INTER -SATELLITE  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  24.65 -24.75  
FIXED  5.532AA  
INTER -SATELLITE  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  
RADIOLOCATION -SATELLITE  
   (Earth -to-space)  24.65 -24.75  
FIXED  
FIXED -SATELLITE  
   (Earth -to-space)  5.532B  
INTER -SATELLITE  
MOBILE   5.338A  5.532AB  24.65 -24.75  
INTER -SATELLITE  
RADIOLOCATION -SATELLITE (Earth -to-space)  
24.75 -25.25  
FIXED  
FIXED -SATELLITE  
   (Earth -to-space)  5.532B  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  24.75 -25.25  
FIXED  5.532AA  
FIXED -SATELLITE  
   (Earth -to-space)  5.535  
MOBILE except aeronautical  
   mobile  5.338A  5.532AB  24.75 -25.25  
FIXED  
FIXED -SATELLITE  
   (Earth -to-space)  5.535  
MOBILE   5.338A  5.532AB  24.75 -25.25  24.75 -25.25  
FIXED  
FIXED -SATELLITE (Earth -to-space)  
MOBILE  USxxx  
 
NG65   
RF Devices (15)  
Satellite  
   Communications (25)  
Upper Microwave  
   Flexible Use (30)  
25.25 -25.5 
FIXED   5.534A  
INTER -SATELLITE  5.536  
MOBILE   5.338A  5.532AB  
Standard frequency and time signal -satellite (Earth -to-space)  25.25 -25.5 
FIXED  
INTER -SATELLITE  5.536  
MOBILE  USxxx  
Standard frequency and time  
   signal -satellite (Earth -to-space)  25.25 -25.5 
Inter-satellite  5.536  
Standard frequency and time  
   signal -satellite (Earth -to-space)   
RF Devices (15)  
25.5-27 
EARTH EXPLORATION -SATELLITE (space -to-Earth)  5.536B  
FIXED   5.534A  
INTER -SATELLITE  5.536  
MOBILE   5.338A  5.532AB  
SPACE RESEARCH (space -to-Earth)  5.536C  
Standard frequency and time signal -satellite (Earth -to-space)  
 
 
5.536A  25.5-27 
EARTH EXPLORATION - 
   SATELLITE (space -to-Earth)  
FIXED  
INTER -SATELLITE  5.536  
MOBILE  USxxx  
SPACE RESEARCH (space -to-Earth)  
Standard frequency and time  
   signal -satellite (Earth -to-space)   
5.536A  US258  25.5-27 
SPACE RESEARCH  
   (space -to-Earth)  
Inter-satellite 5.536  
Standard frequency and time  
   signal -satellite (Earth -to-space)  
 
 
  
5.536A  US258  
27-27.5 
FIXED  
INTER -SATELLITE 5.536  
MOBILE   5.338A  5.532AB  27-27.5 
FIXED   5.534A  
FIXED -SATELLITE (Earth -to-space)  
INTER -SATELLITE  5.536  5.537  
MOBILE   5.338A  5.532AB  27-27.5 
FIXED  
INTER -SATELLITE  5.536  
MOBILE  USxxx  27-27.5 
Inter-satellite  5.536  
27.5-28.5 
FIXED 5.537A  
FIXED -SATELLITE (Earth -to-space)  5.484A  5.516B  5. 517A  5. 539 
MOBILE  27.5-30 27.5-28.35  
FIXED  
FIXED -SATELLITE (Earth -to-space)  
MOBILE   
RF Devices (15)  
Satellite  
   Communications (25)  
Upper Microwave  
   Flexible Use (30)  
Fixed Microwave (101)  
5.538  5.540  28.35 -29.1 
FIXED -SATELLITE (Earth -to-space)  
G165   NG527A   
RF Devices (15)  
Satellite  
   Communications (25)   Federal Communications Commission  FCC 23 -114  
19 * * * * * 
 
(C) * * * 
 
 
* * * * *  
 
(146) USxxx  In the bands 24.25 -24.45 GHz and 24.75 -27.5 GHz , the total radiated power (TRP) of 
emissions from stations in the mob ile service in any 200 MHz of the band 23.6 -24 GHz shall not exceed   
-33 dBW /200 MHz  for base stations and -29 dBW /200 MHz  for mobile stations, and for stations brought 
into use after September 1, 2027, TRP shall not exceed -39 dBW /200 MHz  for base stations and -35 
dBW /200 MHz  for mobile stations.  
 
* * * * *  
 
 
The authority  citation for part 30 continues to read as follows:  
 
AUTHORITY:  47 U.S.C. 151, 152, 153, 154, 301, 303, 304, 307, 309, 310, 316, 332, 1302 , 
unless otherwise noted . 
 
2. Amend § 30.203 by adding paragraph (d) to read as follows:  
§ 30. 203  Emission Limits.  
* * * * *  
 (d)   (1) In addition to the limits noted above, f or licensees operating mobile equipment  in the 
24.25 -24.45 GHz or 24.75 -25.25 GHz bands, the total radiated power of emissions in any 200 MHz of the 
23.6-24.0 GHz band  shall not exceed -33 dBW (for base stations) or -29 dBW (for mobile stations).  
(2) For mobile equipment placed in service after September 1, 2027, the total radiated 
power of emissions in any 200 MHz of the 23.6 -24.0 GHz band  shall not exceed -39 dBW (for base 
stations) or -35 dBW (for mobile stations).  
  Federal Communications Commission  FCC 23 -114  
20 APPENDIX B  
Initial Regulatory Flexibility Analysis  
 
1. As required by the Regulatory Flexibility Act of 1980, as amended (RFA),1 the 
Commission has prepared this Initial Regulatory Flexibility Analysis (IRFA) of the possible significant 
economic impact on a substantial number of small entities by the policies and rules proposed in this 
Notice of Proposed Rulemaking (NPRM ).  Written public comments are requested on this IRFA.  
Comments must be identified as responses to the IRFA and must be filed by the deadlines specified in the 
NPRM for comments.  The Commission will send a copy of th e NPRM , including this IRFA, to the Chief 
Counsel for Advocacy of the Small Business Administration (SBA).2  In addition, the NPRM  and IRFA 
(or summaries thereof) will be published in the Federal Register.3   
A. Need for, and Objectives  of, the Proposed Rules  
2. In the NPRM , the Commission  proposes to implement certain decisions regarding the 
24.25 -27.5 GHz band made in the World Radiocommunication Conference held by the International 
Telecommunication  Union (ITU) in 2019 (WRC -19).  Specifically, the Commission proposes to adopt the 
Resolution 750 limits , apply them to all mobile systems, and incorporate those limits into our part 30 
technical rules.  We also propose to adopt the WRC -19 timeframes for the Resolution 750 emissions 
limits.  Resolution 750 defines current unwanted emissions lim its, measured in terms of Total Radiated 
Power (TRP), for IMT base and mobile stations and a stricter set of emissions limits for the same stations 
that will become effective after September 1, 2027.  Consistent with Resolution 750, we propose to adopt 
the use of TRP to  measure  compliance with the unwanted emissions limits for the 23.6 -24.0 GHz band.   
The Commission seeks comment on these proposals and invites comment on alternative proposals and 
approaches such as applying Resolution 750 limits to fixed op erations or applying them on a more 
abbreviated timeframe, adopting stricter emission s limits, and permitting the use of condu ctive power to 
measure compliance with the unwanted emissions limits.  The Commission also seeks comment on 
equipment manufacturers’ capacity to meet the proposed timelines, and whether adoption of the 
Resolution 750 emissions limits would increase network deployment costs with the directive to 
commenters to quantify any additional costs that would be incurred and discuss what if any  impact there 
would be on service .  By adopting certain requirements consistent Resolution 750 and aligning them with 
part 30 of our rules, the Commission hopes to ensure t he protection of Earth Exploration Satellite Service  
(EESS) passive operations in the 23.6 -24.0 GHz band, which are critical for accurate climate monitoring 
and weather forecasting as well as for climatology science.  
B. Legal  Basis  
3. The proposed  action is authorized pursuant to sections 4(i), 301, 302, 303(r), 308, 309 , 
and 333 of the Communications Act of 1934, 47 U.S.C. §§ 154(i), 301, 302a, 303(r), 308, 309 , 333.  
C. Description and Estimate of the Number of Small Entities To Which the Proposed 
Rules Will Apply  
4. The RFA directs agencies to provide a description of, and, where feasible, an estimate of 
the number of small entities that may be affected by the proposed rules and policies, if adopted.4  The 
RFA generally defines the term “small entity” as having the same meaning as the terms “small business,” 
 
1 See 5 U.S.C. § 603.  The RFA, 5 U.S.C. §§ 601 -612, has been amended by the Small Business Regulatory 
Enforcement Fairness Act of 1996, (SBREFA) Pub. L. No. 104 -121, Title II, 110 Stat. 857 (1996).  
2 See 5 U.S.C. § 603(a).  
3 See id. § 603(a).  
4 See id. § 603(b)(3).   Federal Communications Commission  FCC 23 -114  
21 “small organization,” and “small governmental jurisdiction.”5  In addition, the term “small business” has 
the same meaning as the term “small business concern” under the Small Business Act.6  A “small 
business concern” is one which: (1) is independently owned and operated; (2) is not dominant in its field 
of operation; and (3) satisfies any additional criteria established by the SBA.7   
5. Small Businesses, Small Organizations, Small Governmental Jurisdictions .  Our actions, 
over time, may affect small entities that are not easily categorized at present.  We therefore describe here, 
at the outset, three broad groups of small entities that could be directly affected herein.8  First, while there 
are industry specific size standards for small businesses that are used in the regulatory flexibility analysis, 
according to data from the SBA’s Office of Advocacy, in general a small business is an independent 
business having fewer th an 500 employees.9  These types of small businesses represent 99.9% of all 
businesses in the United States which translates to 30.7 million businesses .10 
6. Next, the type of small entity described as a “small organization” is generally “any not -
for-profit enterprise which is independently owned and operated and is not dominant in its field.”11  The 
Internal Revenue Service (IRS) uses a revenue benchmark of $50,000 or less to delineate its annual 
electronic filing requirements for small exempt organizations.12  Nationwide, for tax year 2018, there 
were approximately 571,709 small exempt organizations in the U.S. reporting revenues of $50,000 or less 
according to the registration and tax data for exempt organizations available from the IRS.13 
7. Finally, the small entity described as a “small governmental jurisdiction” is defined 
generally as “governments of cities, counties, towns, townships, villages, school districts, or special 
districts, with a population of less than fifty thousand.”14  U.S. Census Bureau data from the 2017 Census 
 
5 See id. § 601(6).  
6 See id . § 601(3) (incorporating by reference the definition of “small -business concern” in the Small Business Act, 
15 U.S.C. § 632).  Pursuant to 5 U.S.C. § 601(3), the statutory definition of a small business applies “unless an 
agency, after consultatio n with the Office of Advocacy of the Small Business Administration and after opportunity 
for public comment, establishes one or more definitions of such term which are appropriate to the activities of the 
agency and publishes such definition(s) in the Feder al Register.”  
7 15 U.S.C. § 632.  
8 See 5 U.S.C. § 601(3) -(6). 
9 See SBA, Office of Advocacy, “What’s New With Small Business,” https://cdn.advocacy.sba.gov/wp -
content/uploads/2019/09/23172859/Whats -New -With -Small -Business -2019.pdf  (Sept. 2019).  
10 Id. 
11 5 U.S.C.  § 601(4).  
12 The IRS benchmark is similar to the population of less than 50,000 benchmark in 5 U.S.C § 601(5) that is used to 
define a small governmental jurisdiction. Therefore, the IRS benchmark has been used to estimate the number small 
organizations in this small entity description.  S ee Annual Electronic Filing Requirement for Small Exempt 
Organizations — Form 990 -N (e-Postcard), “Who must file, ” https://www.irs.gov/charities -non-profits/annual -
electronic -filing -requirement -for-small -exempt -organizations -form -990-n-e-postcard .  We note that the IRS data 
does not provide information on whether a small exempt organization is independently owned and operated or 
dominant in its field.  
13 See Exempt Organizations Business Master File Extract (EO BMF), “CSV Files by Region, ” 
https://www.irs.gov/charities -non-profits/exempt -organizations -business -master -file-extract -eo-bmf.  The IRS 
Exempt Organization Business Master File (EO BMF) Extract provides information on all registered tax -
exempt/non -profit organizations. The data utilized for purposes of this description was extracted from the IRS EO 
BMF data for Region 1 -Northeas t Area (76,886), Region 2 -Mid-Atlantic and Great Lakes Areas (221,121), and 
Region 3 -Gulf Coast and Pacific Coast Areas (273,702) which includes the continental U.S., Alaska, and Hawaii.  
This data does not include information for Puerto Rico.   
14 5 U.S.C. § 601(5).   Federal Communications Commission  FCC 23 -114  
22 of Governments15 indicate that there were 90,075 local governmental jurisdictions consisting of general 
purpose governments and special purpose governments in the United States.16  Of this number there were 
36,931 general purpose governments (county17, municipal and town or township18) with populations of 
less than 50,000 and 12,040 special purpose governments - independent school districts19 with enrollment 
populations of less than 50,000.20  Accordingly, based on the 2017 U.S. Census of Governments data, we 
estimate that at least 48,971 entities fall into the category of “small governmental jurisdictions.”21   
8. Wireless Telecommunications Carriers (except Satellite) .  This industry comprises 
establishments  engaged in operating and maintaining switching and transmission facilities to provide 
communications via the airwaves.  Establishments in this industry have spectrum licenses and provide 
services using that spectrum, such as cellular services, paging serv ices, wireless internet access, and 
wireless video services.22  The appropriate size standard under SBA rules is that such a business is small 
if it has 1,500 or fewer employees.23  For this industry, U.S. Census Bureau data for 2012 show that there 
were 967 firms that operated for the entire year.24  Of this total, 955 firms had employment of 999 or 
 
15 See 13 U.S.C. § 161.  The Census of Government is conducted every five (5) years compiling data for years 
ending with “2” and “7 .”  Census of Governments, https://www.census.gov/programs -surveys/cog/about.html  (last 
visited September 19, 2023 ).  
16 See U.S. Census Bureau, 2017 Census of Governments – Organization, Table 2. Local Governments by Type and 
State: 2017 [CG1700ORG02] .  https://www.census.gov/data/tables/2017/econ/gus/2017 -governments.html . Local 
governmental jurisdictions are made up of general purpose governments (county, municipal and town or township) 
and special purpose governments (special districts and independent school districts).  See also Table 2.  
CG1700ORG02 Table Notes_Local Governments by Type and State_2017  (providing the methodology for creating 
the table ). 
17 See id. At Table 5,  County Governments by Population -Size Group and State: 2017  [CG1700ORG05] .  
https://www.census.gov/data/tables/2017/econ/gus/2017 -governments.html . There were 2,105 county governments 
with populations less than 50,000.  This category does not include subcounty (municipal and township) 
governments.   
18 See id. At Table 6, Subcounty General -Purpose Governments by Population -Size Group and State: 2017 
[CG1700ORG06].  https://www.census.gov/data/tables/2017/econ/gus/2017 -governments.html .  There were 18,729 
municipal and 16,097 town and township governments with populations less than 50,000.  
19 See id.  At Table 10, Elementary and Secondary School Systems by Enrollment -Size Group and State: 2017 
[CG1700ORG10].   https://www.census.gov/data/tables/2017/econ/gus/2017 -governments.html .  There were 12,040 
independent school districts with enrollment populations less than 50,000.  See also Table 4.  Special -Purpose Local 
Governments by State Census Years 1942 to 2017 [CG1700ORG04], CG1700ORG04 Table Notes_Special Purpose 
Local Governments by State_Census Years 1942 to 2017  (providing the methodology for creating the table) . 
20 While the special purpose governments category also includes local special district governments, the 2017 Census 
of Governments data does not provide data aggregated based on population size for the special purpose governments 
category.  Therefore, only d ata from independent school districts is included in the special purpose governments 
category.  
21 This total is derived from the sum of the number of general purpose governments (county, municipal and town or 
township) with populations of less than 50,000 (36,931) and the number of special purpose governments – 
independent school districts with enrollment populations of less than 50,000 (12,040), from the 2017 Census of 
Governments – Organizations Tables 5, 6, and 10.  
22 See U.S. Census Bureau, 2017 NAICS Definition, “ 517312 Wireless Telecommunications Carriers  (except 
Satellite),” https://www.census.gov/naics/?input=517312&year=2017&details=517312 . 
23 See 13 CFR § 121.201, NAICS Code 517312 (previously 517210).  
24 See U.S. Census Bureau, 2012  Economic Census  of the United States , Table ID: EC1251SSSZ5, Information: 
Subject Series: Estab and Firm Size: Employment Size of Firms for the U.S.: 2012 , NAICS Code 517210, 
https://data.census.gov/cedsci/table?text=EC1251SSSZ5&n=517210&tid=ECNSIZE2012.EC1251SSSZ5&hidePrev
iew=false&vintage=2012 .  Federal Communications Commission  FCC 23 -114  
23 fewer employees and 12 firms had employment of 1,000 employees or more.25  Thus under this category 
and the associated size standard, the Commission estimates that the majority of wireless 
telecommunications carriers (except satellite) are small entities.  
9. Fixed Microwave Services.  Microwave services include common carrier,26 private -
operational fixed,27 and broadcast auxiliary radio services.28  They also include the Upper Microwave 
Flexible Use Service,29 the Millimeter Wave Service,30 and the Local Multipoint Distribution Service 
(LMDS),31 where licensees can choose between common carrier and non -common carrier status.32  The 
Commission has not yet defined a small business with respect to microwave services.  The closest 
applicable SBA category is Wireless Telecommunications Carriers (except Satellite) and the appropriate 
size standard for this category under SBA rules is  that such a business is small if it has 1,500 or fewer 
employees.33  For this industry, U.S. Census Bureau data for 2012 shows that there were 967 firms that 
operated for the entire year.  Of this total, 955 had employment of 999 or fewer, and 12 firms had 
employment of 1,000 employees or more.34  Thus under this SBA category and the associated standard, 
the Commission estimates that the majority of fixed microwave service licensees can be considered small.   
10. Satellite Telecommunications.  This category comprises firms “primarily engaged in 
providing telecommunications services to other establishments in the telecommunications and 
broadcasting industries by forwarding and receiving communications signals via a system of satellites or 
reselling satellite telecommunications.”35  Satellite telecommunications service providers include satellite 
and earth station operators. The category has a small business size standard of $35 million or less in 
average annual receipts, under SBA rules.36  For this category, U.S. Census Bureau data for 2012 show 
that there were a total of 275 firms that operated for the entire year. 37  Of this total, 299 firms had annual 
 
25 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  
26 See 47 CFR pt. 10, subpart I.  
27 Persons eligible under Parts 80 and 90 of the Commission’s rules can use Private -Operational Fixed Microwave 
services.  See 47 CFR Parts 80 and 90.  Stations in this service are called operational -fixed to distinguish them from 
common carrier and public fixed stations.  Only the licensee may use the operational -fixed station, and only for 
communications related to the licensee ’s commercial, industrial, or safety operations.  
28 Auxiliary Microwave Service is governed by parts 74 and 78 of Title 47 of the Commission’s rules.   Available to 
licensees of broadcast stations, cable operators, and to broadcast and cable network entities. Auxiliary microwave 
stations are used for relaying broadcast television signals from the studio t o the transmitter, or between two points 
such as a main studio and an auxiliary studio.   The service also includes TV pickup and CARS pickup, which relay 
signals from a remote location back to the studio.  
29 See 47 CFR pt. 30. 
30 See 47 CFR pt. 101, subpart Q.  
31 See 47 CFR pt. 101, subpart L.  
32 See 47 CFR §§  30.6, 101.1017.  
33 13 CFR §  121.201, NAICS Code 517210.  
34 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  
35 See U.S. Census Bureau, 2017 NAICS Definition, “517410 Satellite Telecommunications ,” 
https://www.census.gov/naics/?input=517410&year=2017&details=517410 . 
36 See 13 CFR §  121.201, NAICS Code 517410.  
37 See U.S. Census Bureau, 2012  Economic Census  of the United States , Table ID:  EC1251SSSZ4, Information: 
Subject Series: Estab and Firm Size: Receipts Size of Firms for the U.S. : 2012 , NAICS Code 517410, 
https://data.census.gov/cedsci/table?text=EC1251SSSZ4&n=517410&tid=ECNSIZE2012.EC1251SSSZ4&hidePrev
iew=false&vintage=2012 .  Federal Communications Commission  FCC 23 -114  
24 receipts of less than $25 million.38  Consequently, we estimate that the majority of satellite 
telecommunications providers are small entities.  
11. All Other Telecommunications .  The “All Other Telecommunications” category is 
comprised of establishments primarily engaged in providing specialized telecommunications services, 
such as satellite tracking, communications telemetry, and radar station operation.39  This industry also 
includes establishments primarily engaged in providing satellite terminal stations and associated facilities 
connected with one or more terrestrial systems and capable of transmitting telecommunications to, and 
receiving telecommunicat ions from, satellite systems.40  Establishments providing Internet services or 
voice over Internet protocol (VoIP) services via client -supplied telecommunications connections are also 
included in this industry.”41  The SBA has developed a small business size standard for “All Other 
Telecommunications,” which consists of all such firms with annual receipts of $35 million or less.42  For 
this category, U.S. Census Bureau data for 2012 show that there were a total of 1,442 firms that operated 
for the entire year.43  Of these firms, a total of 1,400 firms had annual receipts of less than $25 million and 
15 firms had gross annual receipts of $25 million to $49,999,999.44  Thus, the Commission estimates that 
a majority of “All Other Telecommunications” firms potentially affected by our actions can be considered 
small.  
12. Radio and Television Broadcasting and Wireless Communications Equipment 
Manufacturing.   This industry comprises establishments primarily engaged in manufacturing radio and 
television broadcast and wireless communications equipment.45  Examples of products made by these 
establishments are: transmitting and receiving antennas, cable television equipment, GPS equipment, 
pagers, cellular phones, mobile communications equipment, and radio and television studio and 
broadcasting equipment.”46  The SBA has established a small business size standard for this industry of 
1,250 employees or less.47  U.S. Census Bureau data for 2012 show that 841 firms operated in this 
industry in that year.48  Of that number, 828 establishments operated with fewer than 1,000 employees, 7 
establishments operated with between 1,000 and 2,499 employees and 6 establishments operated with 
 
38 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  
39 See U.S. Census Bureau, 2017 NAICS Definition , “517919 All Other Telecommunications ,” 
https://www.census.gov/naics/?input=517919&year=2017&details=517919 . 
40 Id. 
41 Id. 
42 See 13 CFR § 121.201, NAICS Code 517919.  
43 See U.S. Census Bureau, 2012  Economic Census  of the United States , Table ID: EC1251SSSZ4, Information: 
Subject Series - Estab and Firm Size: Receipts Size of Firms for the United States: 2012 , NAICS Code 517919 
https://data.census.gov/cedsci/table?text=EC1251SSSZ4&n=517919&tid=ECNSIZE2012.EC1251SSSZ4&hidePrev
iew=false . 
44 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  
45 See U.S. Census Bureau, 2017 NAICS Definition, “ 334220 Radio and Television Broadcasting and Wireless 
Communications Equipment Manufacturing, ” 
https://www.census.gov/naics/?input=334220&year=2017&details=334220 . 
46 Id. 
47 See 13 CFR § 121.201, NAICS Code 334220.  
48 See U.S. Census Bureau, 2012  Economic Census  of the United States , Table ID: EC1231SG2, Manufacturing: 
Summary Series: General Summary: Industry Statistics for Subsectors and Industries by Employment Size: 2012 
NAICS Code 334220, 
https://data.census.gov/cedsci/table?text=EC1231SG2&n=334220&tid=ECNSIZE2012.EC1231SG2&hidePreview=
false .  Federal Communications Commission  FCC 23 -114  
25 2,500 or more employees.49  Based on this data, we conclude that a majority of manufacturers in this 
industry is small.  
D. Description  of Projected Reporting, Recordkeeping , and Other Compliance  
Requirements for Small Entities  
13. The proposal in the NPRM to adopt the Resolution 750 emission s limits, emission s limit s 
measurement methodology and emission s limit s effective date timetable s will not impose any new 
reporting or recordkeeping requirements.  In assessing the cost of compliance for small entities, at this 
time the Commission is not in a position to determine whether, if adopted, the proposals in the NPRM  
will require small entities  to hire professionals to comply , and cannot quantify the cost of compliance 
with any of the potential rule changes that may be adopted.  Comments in response to  the Public Notice50 
that sought to develop a record on how the Commission should implement the emissions limits contained 
in Resolution 750 for the active services in the 24 GHz band that raised  concerns about increased costs if 
Resolution 750 emission s limits are adopted, have been tak en into consideration , and commenters have 
been asked to quantify these costs and specify the impact on service  in the NPRM .  We expect the 
comments we receive on our proposals to include information addressing costs, service impacts, and other 
matters of concern, which should help the Commission identify and evaluate relevant issues for small 
entities  including compliance costs and other burdens that may  result from the matters raised in the 
NPRM , before adopting final rules .     
E. Steps Taken to Minimize the Significant Economic Impact on Small Entities, and 
Significant Alternatives Considered  
14. The RFA requires an agency to describe any significant, specifically small business,  
alternatives that it has considered in reaching its proposed approach, which may include the following 
four alternatives (among others):  (1) the establishment of differi ng compliance or reporting requirements 
or timetables that take into account the resources available to small entities; (2) the clarification, 
consolidation, or simplification of compliance or reporting requirements under the rule for such small 
entities; (3) the use of performance, rather than design, standards; and (4) an exemption from coverage of 
the rule, or any part thereof, for such small entities.51   
15. Having data on the costs and economic impact of the proposals and approaches discussed 
in the NPRM  will allow the Commission to better evaluate options and alternatives for minimization , 
should there be a significant economic impact on small entities  if Resolution 750 emission s limits  and 
effective date timetables are adopted .  Accordingly, we expect to more fully consider the economic 
impact on small entities following our review of comments filed in response to the NPRM  which as 
mentioned above in Section D include s a request for comments on the costs and service impacts 
associated with adoption of Resolution 750 emission s limits.  Below we discuss actions taken and 
alternatives considered by the Commission relating to the proposals in the NPRM. 
16. Based on the record from the Public Notice  comments, our proposal to adopt Resolution 
750 emission s limits seems to strike the appropriate balance between protecting passive sensing satellite 
operations and facilitating use of the 24 GHz band.   The Commission could have developed and proposed 
its own emission limits and related requirements which may have included emissions limits that were 
stricter or not as strict as the Resolution 750 emissions limits.  The Commission could have also simply 
maintained th e existing rules.  As discussed in the NPRM however, many  of the industry participants 
support adoption of Resolution 750 emission limits to protect extremely sensitive passive satellite 
operations, facilitate the continued development and deployment of 5G in the U.S., promote international 
 
49 Id.  The available U.S. Census Bureau data does not provide a more precise estimate of the number of firms that 
meet the SBA size standard.  
50 See Office of Engineering & Technology and the Wireless Telecommunications Bureau Seek Comment on 
Emission Limits for the 24.25 -27.5 GHz Band , Public Notice, 36 FCC Rcd 7561  (OET WTB  2021) ( Public Notice ). 
51 5 U.S.C. §  603(c)(1) -(4).  Federal Communications Commission  FCC 23 -114  
26 harmonization, enable equipment manufacturers to provide globally marketable equipment, and to be 
consistent with U.S. policy relating to Radio Regulations.  T hus, th e synchronicity between the 
Resolution 750 emissions limits and the Commission's part 30 rules appears  to be the best course of 
action, although small entities that hold licenses subject to these rules may incur increased deployment 
costs to comply with the more stringent Resolution  750 emissions limits .  
17. In the alternative, if the Commission were to propose and adopt its own emissions limits , 
particularly if the emissions limits were stricter than both the existing emission limits and  Resolution 750 
emission limits, small entities could be subjected to  significantly  increased compliance costs  without any 
of the above -mentioned benefits .  Further, if the Commission were to propose and adopt less stri ngent 
emissions limit requirements or if we simply maintained the existing requirements, our rule s may not 
provide the necessary protections for passive sate llite operations to operate in the 24GHz band and might 
make it difficult for EESS to make observations free from harmful interference, thereby jeopardizing the 
accuracy of critical weather forecasting and climatology science data.  Instead, the Commission believes 
our proposal to adopt the Resolution 750 emission limits which were carefully considered and the product 
of extensive industry collaboration, is the right approach and any potential burdens are outweighed by the 
benefits of protecting passive observations in the 23.6 -24.0 GHz band, including imp rovements in 
weather forecasting.   
18. Finally, in addition to seeking comment on the costs and service impacts of the 
Commission's proposals, the NPRM  provides small entities the opportunity to submit comments on a wide 
range of issues relating to the proposed emissions limits including but not limited to comment on 
alternative limits, including the effect that any changes to existing limits would have on smaller entities ,  
comment on the schedule for adoption of any revised limits, including adjustments that should be made 
for smaller entities  to come into compliance , and comment on other  related matters that are not addressed 
in Resolution 750.  The Commission’s evaluation of the information it receives will shape the final 
alternatives it considers, the final conclusions it reaches , and any additional steps it takes to minimize any 
significant economic impact that may occur on small entities as a result of the final rules it promulgates in 
this proceeding.  
F. Federal Rules that May Duplicate, Overlap, or Conflict with the Proposed Rules  
19. None.  
 
 
  Federal Communications Commission  FCC 23 -114  
27 APPENDIX C  
List of Commenters  to Public Notice  
 
Comments  
The National Academy of Sciences, through its Committee on Radio Frequencies (CORF)  
CTIA  
Elliot Eichen, Ph.D. Principal, Choyu Networks  
Ericsson  
IEEE Geoscience and Remote Sensing Society  (IEEE)  
Mike Marcus and Josep Jornet  (Marcus & Jornet)  
Nokia  
National Telecommunications and Information Administration (NTIA)  
Qualcomm Incorporated (Qualcomm)  
T-Mobile USA, Inc. (T-Mobile)  
 
Reply Comments  
American Geophysical Union, American Meteorological Society, and National Weather Association  
(AGU/AMS/NWA)  
AT&T  
CTIA  
T-Mobile  
 
Ex Parte  
Letter from Eddie Johnson, Chairwoman and Frank Lucas, Ranking Member, Congressional Committee 
on Science, Space, and Technology  
Letter from American Geophysical Union, American Meteorological Society, National Weather 
Association , and University Corporation for Atmospheric Research  (AGU/AMS/NWA/UCAR)  
 
  Federal Communications Commission  FCC 23 -114  
28 STATEMENT OF  
CHAIRWOMAN JESSICA ROSENWORCEL  
 
Re:  Modifying Emissions Limits for the 24.25 -24.45 GHz and 24.75 -25.25 GHz Bands ; ET Docket 
No. 21 -186, Notice of Proposed Rulemaking (December 22, 2023)  
 
 Last month, I had the honor of being a part of the United States delegation at the World Radio 
Conference in Dubai.  At these conferences, the world gathers to discuss opportunities for the 
harmonization of spectrum and the growth of wireless markets.  Pr eparation for these discussions, which 
are held once every four years, requires a mix of Olympic energy and diplomatic skill.  The gatherings 
themselves take weeks and the resolutions that result have treaty -like effect, obligating member states to 
make ad justments to their domestic spectrum policies.   
 At the most recent conference, the United States was able to secure significant victories, clearing 
the way for further development of unlicensed and licensed airwaves.  To ensure that we reap the full 
benefit of these outcomes, however, two things are ess ential.   
First, it is essential that Congress reinstate spectrum auction authority for the Federal 
Communications Commission.  The expiration of this authority —for the first time in three decades —has 
tied our hands, constraining our ability to hold auctions and thr eatening our leadership in global wireless 
deployment.   
Second, it is essential that we honor the resolutions from this conference and past ones, including 
the World Radio Conference held four years ago in Sharm el -Sheikh.  Here, we take steps to implement 
specific policies from that last gathering by proposing  to align our rules for 5G mobile services in the 24 
GHz band with international protections for weather forecasting and climate research that takes place in 
adjacent bands.  It is worth noting that the world followed our lead in adopting mobile operations  in the 
24 GHz band.  Now with this rulemaking, we seek to fulfill our obligations in this band, and in doing so 
commit to strike the right balance between fostering mobile service and protecting resources for scientific 
research.    
I am grateful for the Commission team that led our work at the World Radio Conference in 
Dubai, just as I am for those who have taken on this duty at conferences in the past.  The demands on 
their time are extensive, the days they spend far from home are s ubstantial, and the commitment they 
have to serving the public interest is extraordinary.  
  Federal Communications Commission  FCC 23 -114  
29 DISSENTING STATEMENT OF  
COMMISSIONER BRENDAN CARR  
 
Re:  Modifying Emissions Limits for the 24.25 -24.45 GHz and 24.75 -25.25 GHz Bands ; ET Docket 
No. 21 -186, Notice of Proposed Rulemaking (December 22, 2023)  
 
Backwards.  When it comes to America’s leadership in wireless, the Biden Administration is 
moving backwards.  
Today’s Notice of Proposed Rulemaking is just one example.  In it, the FCC seeks comment on 
the Biden Administration’s request that the agency impose new restrictions on 24 GHz spectrum that 
licensees bought and paid for all the way back in 2019.  There is  no apparent reason for this U -turn.  
Indeed, while the Notice discusses several potential rule changes that may be necessary for purposes of 
conforming our rules with the results of the 2019 World Radio Conference (WRC -19), these particular 
Biden Administ ration requests are asks that were either rejected or never even studied at WRC -19.  Thus, 
WRC -19 provides no basis or justification for turning heel.  
What’s more, changing the rules of the game after an auction has already closed —years after in 
this case —is bad policy.  It undermines the reasonable, investment -backed expectations held by licensees 
and potential licensees alike.  And it injects uncertainty into the FCC’s spectrum auction process, which  
makes it harder to attract capital as well as innovators.  The FCC should be leading the world with clear, 
predictable, and reliable spectrum auctions.   
This decision is also disappointing because it comes at a point in time when the U.S. needs to 
start generating forward movement on spectrum.  Just last month, after three years of study, the Biden 
Administration released its much -anticipated National Spec trum Strategy.  Except, President Biden’s 
spectrum plan was missing one key ingredient: spectrum.  Indeed, the plan commits to freeing up exactly 
zero MHz of spectrum.  Instead, the Administration will continue to study the issue for years to come.   
The Biden Administration’s spectrum -less spectrum plan is a big miss because the rest of the 
world is not standing still.  The U.S. now ranks 13th out of 15 leading markets when it comes to the 
availability of licensed mid -band spectrum.  The U.S. now trai ls its peers by an average of almost 400 
MHz in licensed mid -band spectrum.  And the U.S. is now nearly 700 MHz behind China, according to 
some measures.   
This marks a complete 180 from just a few short years ago.  During the last Administration, the 
federal government worked to free up an unprecedented amount of spectrum for 5G and other next -
generation wireless services.  All told, our efforts freed up abo ut 6,000 MHz of spectrum for licensed 5G 
services in addition to thousands of MHz of spectrum for unlicensed use.  The Biden Administration  only 
plans to study less than 2,800 MHz.  In other words, the FCC moved more spectrum into the commercial 
marketplac e for consumer use from 2017 through 2020 than the Biden Administration plans to study —
and it is not even close.  
The U.S. needs to right the ship.  And it can start with (hopefully) rejecting the Biden 
Administration’s misguided request to claw back spectrum rights that the FCC auctioned off in 2019.  
And it can accelerate with the Biden Administration putting forwar d an actual spectrum plan that will 
improve connectivity and capacity for Americans.  
For my part, I cannot support this look backwards.  Accordingly, I dissent.   Federal Communications Commission  FCC 23 -114  
30 DISSENTING STATEMENT OF  
COMMISSIONER NATHAN SIMINGTON  
 
Re:  Modifying Emissions Limits for the 24.25 -24.45 GHz and 24.75 -25.25 GHz Bands ; ET Docket 
No. 21 -186, Notice of Proposed Rulemaking  (December 22, 2023)   
 
I respectfully dissent from this notice of proposed rulemaking (NPRM).  As stated in the 
introductory paragraph, it was intended to “implement certain decisions regarding the 24.25 -27.5 GHz 
band made in the World Radiocommunication Conference held by the I nternational Telecommunication 
Union (ITU) in 2019 (WRC -19).”  However instead of focusing only on those decisions made at WRC -
19, the item unnecessarily delves into seeking comment on after -the-fact proposals about out -of-band 
emissions that conflict with  the notice given to bidders in the 24 GHz auction that the Commission would 
not adopt limits that are significantly stricter than what was agreed to at WRC -19.   
The NPRM also seeks comment on applying emissions limits to fixed operations deployed in the 
band, all the while acknowledging that WRC -19 did not study fixed deployments.  Opening up these 
issues to question post -auction sets a bad precedent that could up end investments made by the bidders at 
auction.  It also disrupts the deployment of fixed and mobile services that have been deployed in the band 
since the conclusion of the auction that may have been based on assumptions that the Commission would 
adopt em ission limits consistent with WRC -19 Resolution 750.   
For these reasons, I respectfully dissent. Federal Communications Commission  FCC 23 -114  
31 STATEMENT OF  
COMMISSIONER ANNA M. GOMEZ  
 
Re:  Modifying Emissions Limits for the 24.25 -24.45 GHz and 24.75 -25.25 GHz Bands ; ET Docket 
No. 21 -186, Notice of Proposed Rulemaking (December 2 2, 2023)  
 
 Every decision made at a World Radiocommunication Conference (WRC) represents years of 
collaboration and hard work between federal agencies, the telecommunications industry, and our regional 
and international partners.  
Today, we propose to harmonize our domestic 24 GHz rules with the unwanted emission limits in 
Resolution 750 adopted at WRC -19, four years ago.  This step furthers our domestic and international 
goals – continued wireless innovation and protection of criti cal services that creates economic prosperity 
for American consumers and businesses, and global collaborations that reflect our leadership 
internationally.    
I look forward to working with all stakeholders to make the harmonization process a success.  
Thank you to the Federal Communications Commission team that led these efforts in 2019 and to 
the Wireless Telecommunications Bureau for taking on the next stage of the work.   
 