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FCC Filings·

Comment by ARRL, The National Association for Amateur Radio in 26-169

The Federal Communications Commission proposed authorizing unlicensed direct-to-device Earth-to-space communication in the 2400-2483.5 MHz and 5725-5850 MHz bands using existing Part 15 technical rules. The National Association for Amateur Radio contends that applying current terrestrial regulations to satellite communication is inadequate due to the higher average radiated power and outdoor operation of direct-to-device devices. ARRL emphasizes that 158.5 MHz of the proposed spectrum is already allocated to Amateur Radio and Amateur Satellite services, creating a risk of destructive interference. The organization recommends that the Commission issue a Further Notice to establish specific technical requirements or exclude amateur satellite subbands to ensure non-interference.

Submission type
COMMENT
Filers
ARRL, The National Association for Amateur Radio
Authors
David R. Siddall
Law firms
DS LAW PLLC
Proceedings
26-169 Unleashing Unlicensed Spectrum for Direct-to-Device
Submitted
Nov 9, 2026, 11:34 PM ET
Disseminated
Nov 10, 2026, 11:00 AM ET