Re: OIA Docket No. 24-30; WAC-27 073, WRC-27 Agenda Item 9.2 – Support for View A

Dear Federal Communications Commission Office of International Affairs:

The Connect Everyone Coalition (CEC) is a broad-based coalition committed to educating the public and policymakers on the importance of using every tool in the connectivity toolbox to deliver fast, affordable broadband. Our members include consumer advocates, community organizations, technology groups, small businesses and public safety experts that support updating broadband strategies so unserved and underserved communities across our nation and world can fully benefit from advancements in connectivity, including low Earth orbit (LEO) satellite systems.

Modernizing space policy is an essential part of that work. WRC-27’s extensive satellite agenda presents an opportunity for the United States to shape an international environment that encourages investment, responsible innovation and broader access to connectivity. Maintaining American leadership requires an international framework that allows those capabilities to serve consumers. As innovation advances, spectrum rules must keep pace rather than become a bottleneck to deployment and improved service. Spectrum rules should safeguard existing connectivity service while allowing new technologies to be deployed to reach people whose connectivity needs remain unmet.

CEC applauds the Commission’s recent EPFD modernization efforts. That progress provides a foundation for further international reforms, where unnecessary restrictions continue to limit the capabilities of globally operating networks. Modern satellites, particularly the growing constellations of LEO satellites, are more adaptive to mitigate interference and should not be constrained by outdated rules.

CEC supports View A of the World Radiocommunication Conference Advisory Committee (WAC) recommendation addressing equivalent power-flux density (EPFD) limits under World Radiocommunication Conference 2027 (WRC-27) Agenda Item 9.2, which better balances protections of existing satellite services with efficient spectrum use.

View A provides a practical path forward by modernizing Article 22 interference limits that have remained unchanged for more than a quarter-century. Evidence-based protection standards reflecting how today’s networks operate can give LEO operators greater freedom to manage their networks globally while preserving safeguards against unacceptable interference to geostationary satellite services. Additional restrictions should be supported by a demonstrated protection need and evaluated against their effects on network operations and consumers.

It is vital to rapidly scale up consumers’ LEO broadband options to help close remaining connectivity gaps. Advancing this technology can bring reliable internet options to rural and remote communities, support small businesses beyond the reach of traditional infrastructure and provide another means of staying connected when other networks are damaged or unavailable.

CEC urges the Commission, in consultation with the Department of State and the National Telecommunications and Information Administration, to adopt View A as the U.S. position for WRC-27 and advocate for its approach in international preparations and negotiations. By bringing domestic space policy modernization experience to the world stage, the United States can demonstrate that strong service protections and technological advancement can coexist – and help shape a new era of space-enabled connectivity.

Sincerely,
Connect Everyone Coalition