Welcome to The Perihelion Moment, a monthly briefing on FCC and spectrum developments in TMT, satellite, and frontier space brought to you by Perihelion Strategies. Each issue covers what the Commission (or other relevant authorities) is doing, why it matters, and what it means for the people building and investing in this space. This is meant to start a dialogue, so feel free to email me about topics you’d like to see covered (ross@perihelionstrategies.com).

This month: all the messy drama in the Direct-to-Device (D2D) world and the FCC’s related proposal, views on the prospects and scope of a potential ban on foreign-produced optical transceivers, and what to watch in November.

Setting Up Satellite Situationships

While TPM often covers the FCC’s expansion into national security, with this month’s new D2D proposal, the agency finds itself in Judge Judy’s seat brokering a soapy love triangle between cell phones, cell towers, and satellites. Freeing up the bands listed above for D2D is only part of the equation.

The other part is figuring out who gets to pair up. Cell phones have longstanding relationships with Verizon, AT&T, and T-Mobile, but some attractive alternatives have entered the picture (e.g., SpaceX, AST SpaceMobile, and Lynk Global).

Also, consider the fraying relationship between T-Mobile and SpaceX. In 2025, they launched T-Satellite, using Starlink satellites to eliminate dead zones in rural and remote areas. But now T-Mo has scrubbed Starlink’s name from T-Satellite’s webpage and is forming a new satellite venture with Verizon and AT&T.1

Meanwhile, their custody battle is heating up. Earlier this month, SpaceX struck back by buying T-Mobile’s old 800 MHz spectrum from Grain Management (pending FCC approval), and is reportedly putting more pressure on the big three by talking to Crown Castle (and possibly other companies) about plans to access 80,000 terrestrial cell sites.

Enter the FCC.

Under the existing framework, a satellite company that wanted to do direct-to-cellular needed a lease from someone holding relevant spectrum rights across massive regions like the full continental United States, which typically meant one of the big three.

This month’s draft NPRM would loosen this framework. Instead of leases, satellite and terrestrial operators could strike more flexible arrangements and certify them to the Commission. Instead of having to span the continent, D2D providers could get carte blanche to draw their own boundaries.

Stated differently, the Commission is inviting open relationships.2

While much attention will go toward what this means for mega-constellations, tower companies, and the big three, your author is more interested in second-order effects: whether a more flexible framework gives smaller carriers and regional spectrum holders something new to sell.

We’ll have to see whether the new challengers can spice things up.

Bad Optics?

Don’t worry. Back to FCC national security adventures. The Commission may soon regulate an obscure but pivotal component of AI data centers known as optical transceivers.

In essence, optical transceivers translate data between servers and fiber-optic cables. There are three main tiers: 800G (widely deployed), 1.6T (ramping now), and 3.2T (late-2020s next generation).

While some security experts are skeptical, proponents of the ban believe optical transceivers could be exploited to steal data, install malware, or disrupt critical infrastructure.

This sets up a game of limbo in multiple respects.

First, the timing is in limbo. Rumors of a ban have circulated for months, and there’s a legislative proposal behind it, but optical transceivers still haven’t hit the Covered List. Depending on who you ask, it could happen later this year, early next, or not at all.3

Second, assuming a ban occurs, the question becomes how low do you go?

According to Morgan Stanley analysis from earlier this month, the administration may draw the line by putting 3.2T on the Covered List. If a ban has to happen, 3.2T is the line markets would find easiest to swallow: it avoids ripping and replacing 800Gs, leaves the 1.6T ramp largely intact, and gives U.S. industry several years to scale 3.2T output.

Although a ban would likely cover “foreign-produced” optical transceivers, the real target is Chinese vendors, which account for 66% of the global supply.

While this might seem like a boon for U.S. optical transceiver companies, the ultimate outcome may be up to Beijing instead of Washington. China produces 70% of the world’s indium—an essential input for the lasers used in high-speed optical transceivers—and could easily retaliate by tightening its export controls. The million-dollar question is how quickly and economically U.S. producers could adjust.

The U.S. and China are locked in a race for AI supremacy. The fastest way to grow U.S. capacity is by relying on global supply chains that include Chinese components. But that same interdependence could undermine the security of the AI systems U.S. companies are rushing to build. It’s a problem far easier to name than to solve.

If you’re a hyperscaler, data-center developer, optical supplier, or investor in the AI infrastructure stack, now might be a good time to join me in doing some lower back stretches.4

What to Watch in November

Nothing like Federal Register stuffing. Gobble gobble.

• November 5. Double trouble. Reply comments are due in the FCC’s equipment authorization proceeding (ET Docket No. 21-232) examining where the Covered List regime goes next, considering software and firmware rules and more granular bills of materials. Also due: initial Upper C-band transition plans (GN Docket No. 25-59) covering how eligible operators would repack services, migrate customers, modify earth stations, and potentially launch new satellites to clear spectrum ahead of the auction.

• November 16. Comments are due on the FCC’s reevaluation of how 911 emergency-service obligations should apply to evolving network architectures (PS Docket No. 26-197). D2D and LEO constellations make the question of who must provide 911 access more interesting than it sounds at first blush.

• November 18-19. In another surprising love triangle, Trump, Xi, and possibly Putin may meet at the APEC summit in Shenzhen. Watch for new White House signals on Chinese technology restrictions. If optical transceivers get swept in, query how much transition time industry will get.

• November 25. Comments are due on the FCC’s Space Modernization FNPRM (SB Docket No. 25-306). Buried inside: advance notice for rendezvous and proximity operations, trackability rules that reach cislunar space, and 20-year license renewals for satellites kept alive by servicing spacecraft. Have at it, Weird Space Stuff folks!

See you next time.

About

Ross Slutsky is the founder of Perihelion Strategies, Limited (PSL), an independent FCC regulatory strategy and intelligence firm that helps operators and investors understand what the FCC is doing, engage it effectively, and position themselves to win at the moments that determine outcomes. Before founding PSL, Ross spent time at the Commission, in big law, and in-house at a leading global satellite operator. In his downtime he enjoys film, family activities, and flying trapeze.

The Perihelion Moment is published monthly by Perihelion Strategies, Ltd. Nothing here is legal, financial, or investment advice.

4

Fun fact. In 1991, Dennis Walston set the limbo world record by passing under a 6-inch bar.

The FCC is about to do something it hasn’t done since American Idol’s premiere in 2002 - revisit its Ultra-wideband (UWB) rules.1

Makes sense. The rules are really old, much has changed, and if there’s one point of consensus, it’s that the current regime is a huge pain. Parties seeking to deploy UWB tech struggle to fit in existing categories and comply with testing and measurement procedures. Incumbents get stuck tracking and responding to numerous waiver proceedings.

However, there’s a reason the FCC punted on this for so long; the 2002 UWB rulemaking was one of the nastiest spectrum fights of all time. It made Ligado look like people joining hands and singing Kumbaya.

So what exactly is UWB?

It’s a regulatory construct referring to devices occupying a large amount of spectrum at once (generally at least 500 MHz of bandwidth).

This pulls in a wide variety of technologies like smart door locks, parking garage spot trackers, tech for SWAT teams to see through walls, and sensors that show exactly where an NFL ref was when he made a bad call. It also has major potential for healthcare, logistics, and spatial computing, where it can map a room and its contents within a centimeter.

Here’s how it works. Think about transmitter power like ordering pancakes at IHOP. A conventional transmitter is relatively high power in a relatively narrow slice of spectrum: a dense dollop of butter in the middle of your pancake. Alternatively, a UWB transmitter is low power dispersed across a much wider band: the same butter spread over the whole thing.

In the view of UWB proponents, a little butter everywhere never hurt anybody. In the view of others, spreading butter where you’ve already poured IHOP Butter Pecan Syrup2 is too rich for your blood, especially when that spectrum supports safety-of-life systems like GPS, aviation, and search and rescue. Who is correct is a tough question that gives me heartburn.

While there isn’t time or space to review all the major implications of the UWB NPRM, I’ll leave you with three tasty questions to chew on as the proceeding continues:

• What is a toy?

  • The Commission asks numerous questions about this, and rightfully so. The most obvious example of where this line gets blurry is with drones, but there are plenty of other questions to consider such as aggregate interference, scope of eligibility, preferred channels, and indoor vs. outdoor use. Commenters looking to persuade the Commission on any of these points would do well to articulate clear technical and operational limiting principles.

• What is an AI device?

  • The Commission also asks whether AI-enabled sensing systems need their own UWB device category. The item references agentic AI and physical AI applications, and seems to implicitly ask whether robotic or other autonomous devices using UWB to map their surroundings, navigate, and act should really be regulated the same way as door locks or AirTags. Should adaptive devices get more flexibility because they can sense the RF environment, or tighter limits because they can operate with less human intervention? Not simple questions.

• Where can you take UWB?

  • On paper, the NPRM seems open to modifying the ban on UWB operation on ships, aircraft, and satellites. It asks open ended questions about allowances for cruise ships, offshore platforms, inland water operations, and drone navigation and landing. However, the actual rule proposal in Appendix A would prohibit operation “onboard an aircraft, a ship not within inland waters, or a satellite.3 So parties who want to move that line shouldn’t just assume the FCC is onboard, and may benefit from proposing geofencing, channel, or altitude conditions that would make partially lifting the ban administrable for the agency.

Thanks for reading. I accept tips in the form of pancakes. If you have any real questions about understanding or participating in this proceeding, book a free consult with Perihelion Strategies.

3

Proposed revised § 15.521(a).

Welcome to The Perihelion Moment, a monthly briefing on FCC and spectrum developments in TMT, satellite, and frontier space brought to you by Perihelion Strategies. Each issue covers what the Commission (or other relevant authorities) is doing, why it matters, and what it means for the people building and investing in this space. This is meant to start a dialogue, so feel free to email me about topics you’d like to see covered (ross@perihelionstrategies.com).

This month: the FCC’s new Spectrum Abundance Further Notice, expanded opportunities in the FCC’s Weird Space Stuff proceeding, updates on a few key proceedings, and what to watch in October.

Spectrum Abundance II: More Abundance

Shortly after this issue is published, on September 30th, the FCC will vote on a second push in its Spectrum Abundance proceeding featuring one order and two further notices of proposed rulemaking (“FNPRMs”) that would unlock extensive spectrum for satellite use.

Though it’s already fall, we’re still far from Thanksgiving, which might explain the abundance of parties fighting and pleading over the final text of the item. Below are some fun details to mull over with cider.

First Order of Business

The draft order opens the 12.7 and 42 GHz bands for satellite use, amplifying broadband capacity for users at home, on ships, and on planes, while setting forth a plan to eventually reduce the protections enjoyed by certain legacy broadcast and cable TV stakeholders. Notably, SpaceX, the Commercial Space Federation (CSF), and the Open Technology Institute sought to get NGSO operators access to the 52 GHz band, so worth watching to see if that changes in the final item.

FNPRM 1: Satellite Spectrum for All Seasons

Among other things, the first FNPRM looks to free up more spectrum for satellites in the Ku-, Ka-, and D-bands.

Each of these bands has their own advantages and disadvantages. Ku is good for pushing signals through when it’s raining but a bit limited in how much data it can carry. Ka can carry more data than Ku but doesn’t fare quite as well in bad weather.

D is seldom used because while it can carry insane amounts of data, it’s very bad at dealing with Mother Nature.

The item looks to open a massive amount (138.25 gigahertz) in and above the D-band spectrum. The main driver of this is probably SpaceX, which wants to use D-band spectrum as part of a broader plan to expand capacity for AI-powered devices in a 100,000-satellite constellation. We’ve heard bold promises about millimeter wave (“mmW”) spectrum before.1 It will be interesting to see what comes of this.

Weird Space Stuff Part Two

Now the fun part. People are now doing all kinds of crazy things in space - developing pharmaceuticals, building gas stations, creating multi-tenant payload warehouses, designing private space stations, etc.

Back in March, the FCC launched the Weird Space Stuff (WSS) proceeding (their title, not mine) to accommodate these operations by giving them greater flexibility to operate in existing categories and also potentially creating one or more dedicated secondary spectrum allocations.

A key proposal was to allow SiriusXM to lease its 2320-2345 MHz band spectrum to some of these parties, and potentially extend leasing to adjacent bands.2

Presently, the Further Notice considers allowing WSS to operate in the 2360-2395 MHz, 13.25-13.4 GHz, and 100-300 GHz bands. 2360-2395 MHz could potentially support emergent space operations but needs coordination with flight testing stakeholders. 13.25-13.4 GHz could enable heavier-duty comms for things like private space stations and docking systems. And, despite its limitations, with bespoke equipment 100-300 GHz spectrum could be a game-changer.

This is a brave new world, and parties building and deploying WSS applications have a real chance to shape the rules to their benefit.

Updates

NextNav. Busy month full of tailwinds and headwinds. A major alliance urged the FCC to push forward the alternative PNT NPRM; NextNav successfully field tested its 5G PNT tech exhibiting robust location accuracy results; and the company hired a new VP of government affairs. However, a new coalition formed opposing NextNav’s proposal; another alliance asked the FCC to reinstate the 900 MHz band in the unlicensed D2D proceeding; and a separate party claimed NextNav’s field test used artificially low power levels and hence understated the interference risks.

Equipment Authorization. On September 22, Frank Pallone (D-NJ) and Brett Guthrie (R-KY) introduced a bill that would empower Congress and the Department of Commerce to add technologies or equipment that pose a national security threat to the Covered List. It also sets up greater congressional oversight of related FCC activities. We’ll see if it gains any steam after midterms.

CSF Petition for Rulemaking. We promised you a fight and you’re getting one. Many parties weighed in, with rocket companies seeking various reforms and greater transparency in coordination, defense and aviation interests seeking to protect their operations, CSF and SpaceX doubling down, and AFTRCC both inviting dialogue on improving the existing framework and understandably defending itself. Though there’s consensus on the need for change, in many cases the agreement stops there.

What to Watch in October

Next month, a few dates that go bump in the night:

• October 13. New rules take effect that close a loophole in the equipment authorization process - parties can no longer incorporate into their devices any logic-bearing hardware components made by Covered List entities if the device itself is of a type that a Covered List entity would be barred from getting authorized. These rules are moving fast and might haunt inattentive operators.

• October 19. Responses are due for a Space Systems Command request for ideas on spacecraft that can launch on short notice and quickly close on a target for rendezvous, proximity operations, and docking missions for FY 2029 and beyond. A key skeletal outline of desired Space Force capabilities.

• October 21. DARPA will close its request for proposals for spacecraft electric propulsion systems capable of operating on air, water, or mixtures incorporating elements like nitrogen or hydrogen. So still a few weeks to brew up something for those of you with a cauldron at home.

• Beetlejuice. Always good to watch this month, but don’t say it three times.

About

Ross Slutsky is the founder of Perihelion Strategies, Limited (PSL), an independent FCC regulatory strategy and intelligence firm that helps operators and investors understand what the FCC is doing, engage it effectively, and position themselves to win at the moments that determine outcomes. Before founding PSL, Ross spent time at the Commission, in big law, and in-house at a leading global satellite operator. In his downtime he enjoys film, family activities, and flying trapeze.

The Perihelion Moment is published monthly by Perihelion Strategies, Ltd. Nothing here is legal, financial, or investment advice.

1

Your author is old enough to remember industry promising that 5G millimeter wave tech would result in the world below. (It did not.)

Admittedly, though, satellites with clear lines of sight are a different play than physically obstructed terrestrial wireless systems. While it’s had some value in fixed wireless and other limited deployments, if someone truly cracks mmW, they will make a fortune.

Welcome to The Perihelion Moment, a monthly briefing on FCC and spectrum developments in TMT, satellite, and frontier space brought to you by Perihelion Strategies. Each issue covers key things the Commission (or other relevant authorities) is doing, why they matter, and what it means for the people building and investing in this space. This is meant to start a dialogue, so feel free to email me about topics you’d like to see covered (ross@perihelionstrategies.com).

This month’s focus: the FCC’s new Space Launch Spectrum Public Notice, a forthcoming fight between airspace and outer-space interests, further FCC expansion into nat sec industrial policy, and what to watch in September.

We’re off to see the Chairman

On August 25, the FCC released a Public Notice (DA 26-887) seeking comment on ensuring spectrum access for space launch activities.

This item comes less than a week after the White House released a presidential memorandum (NSPM-17) seeking to increase U.S.-based launches to at least a thousand per year (aka 5x more annual launches). Several things worth noting.

First, this isn’t a new issue - in recent years, the FCC has worked on opening several spectrum bands to support space launches, though often on a secondary basis (i.e. lower quality access than incumbent users). Also worth noting this is just a Public Notice and isn’t immediately proposing new rules.

Second, the item takes a wide lens by asking not only about spectrum access for rockets, but also for uncrewed surface vessels (USVs) and uncrewed aircraft systems (UAS) that support the launches.

USVs are things like the autonomous spaceport drone ships that recover rocket boosters at sea and haul them back to land. Drones tie up loose ends (e.g., rocket and pad inspections, post-launch damage surveys, and perimeter patrols).

Opening Bell

Third, at the bitter end, the Public Notice seeks comment on a petition by the Commercial Space Federation (RM-12025) asking the FCC to revisit spectrum sharing rules for plane, missile, and drone flight testing in the 1435–1535 MHz, 2360–2395 MHz, and 5091–5150 MHz bands. The Public Notice characterizes the petition as “[advocating] for increased efficiency within the existing coordination process.”

That line is a masterclass in understatement. The petition asks the Commission to completely cut the existing coordinator, the Aerospace and Flight Test Radio Coordinating Council (AFTRCC), out of the coordination process and shift to a light touch, database-centric approach.

CSF does not mince words, and says AFTRCC “monopolizes access to spectrum… and [has] begun to introduce obstacles that exemplify an antiquated, sclerotic process” contrary to Congressional and FCC objectives.

The timing is noteworthy. Many petitions for rulemaking collect dust for years. This one got folded into a live proceeding three weeks after filing. How this plays out remains to be seen, but it has all the makings of a major fight between rocket launch companies and aviation/defense primes.

In the words of the late great Apollo Creed, ding ding.1

Now Hiring

There’s been a lot of press lately about the Covered List turning the FCC into a national security agency, and rightfully so. It enables the administration to quickly and categorically ban foreign produced technologies in critical industries that contain radio frequency components - such as drones, robots, and inverters.2 Moreover, Reuters has reported a potential ban on imported optical transceivers (a key data center input), and there’s broader speculation that IoT modules, medical devices, and smart meter technology could soon follow.

The FCC’s Office of Engineering and Technology (OET) is responsible for implementing Covered List bans, which is ironic given it used to be best known for having developed hands-off rules that enabled permissionless innovation and gave birth to WiFi and Bluetooth.

OET is a small office with far more engineers than lawyers. But the Commission is now planning to expand OET’s policymaking division by hiring three “national security attorneys… to help write the regulations governing the Covered List” and “generally protect national security in the equipment authorization program.”

This is a major investment by the agency and a clear signal to the market - more rules are coming.

What to Watch in September

Some fun reg dates to ease your back to school blues:

• September 4. Comment due date for the DOJ and DHS interim final rules implementing the SAFER SKIES Act, which lets state and local law enforcement do the thing most of the Communications Act was designed to prevent - cause deliberate radio interference.

• September 14. It’s when comments are due on the Space Launch Spectrum PN discussed above - including the Commercial Space Federation’s petition coming for AFTRCC. Worth watching whether CSF expands its ask in wake of NSPM-17, how the opposition responds, and whether DoW or NTIA weigh in on this. Replies are due the 24th.

• September 8. Comments close in the equipment authorization docket (ET Docket 21-232) that expands component coverage, and it’s also the due date for reply comments on the Upper C-band auction proceeding (GN Docket 25-59).

About

Ross Slutsky is the founder of Perihelion Strategies, Limited (PSL), an independent FCC regulatory strategy and intelligence firm that helps operators and investors understand what the FCC is doing, engage it effectively, and position themselves to win at the moments that determine outcomes. Before founding PSL, Ross spent time at the Commission, in big law, and in-house at a leading global satellite operator. In his downtime he enjoys film, family activities, and flying trapeze.

The Perihelion Moment is published monthly by Perihelion Strategies, Ltd. Nothing here is legal, financial, or investment advice.

Welcome to The Perihelion Moment, a monthly briefing on FCC and spectrum developments in TMT, satellite, and frontier space brought to you by Perihelion Strategies. Each issue covers what the Commission (or other relevant authorities) is doing, why it matters, and what it means for the people building and investing in this space. This is meant to start a dialogue, so feel free to email me about topics you’d like to see covered (ross@perihelionstrategies.com).

This month: the FCC's new Unlicensed Direct to Device item, a hidden opportunity for ISAM, Covered List expansions with implications for satellite and space manufacturers, and what to watch in August.

Loosening the Bands: Inside the FCC's New Unlicensed D2D Item

On July 16, the FCC released a draft NPRM focused on opening up frequencies in the 902-928 MHz,1 2400-2483.5 MHz and 5725-5850 MHz bands for use by unlicensed devices.

This item opens the door for satellites to not just connect to cellular enabled devices, but also to the vast ecosystem of consumer electronics and industrial applications that do not operate in cellular frequencies and instead use unlicensed technologies like Bluetooth and Wi-Fi.

It specifically proposes to enable comms from Earth-to-space in all three bands but to only allow operations from space-to-Earth in the 5 GHz band. Worth noting that these bands are already heavily utilized for unlicensed operations, which means it’s a logical choice for unlicensed D2D, but WISPA, the trade association representing fixed wireless internet providers has already filed in opposition, citing interference risk, and resistance regarding the 5 GHz downlink segment is highly likely.

For those who have been tracking the FCC NextNav proceeding (a separate, contentious FCC proceeding about opening new spectrum for 5G and supplemental GPS services), it’s interesting that the FCC identified the 900 MHz band for unlicensed D2D, though it’s not clear what impact that will have on NextNav’s proposal for modified co-channel operations.2 For its part, NextNav has expressed theoretical support for Unlicensed D2D but is understandably playing defense.

But there is other completely unrelated fun stuff buried in this item. Namely, the FCC is (1) proposing to allow unlicensed operations inside spacecraft, and (2) asking about how it could enable unlicensed operations outside of spacecraft.

ISAM Loading

It makes sense that the Commission is closer to finalizing rules for inside spacecraft than for outside of them. Spectrum operations inside a spacecraft are largely contained within the spacecraft without causing interference to satellite communications. Most of the signal gets blocked from going outside due to the exterior shielding on the spacecraft that is designed to protect astronauts from space-based radiation.

But the more nascent and economically significant opportunity the Commission is teeing up relates to ISAM - In-space Servicing, Assembly, and Manufacturing.

These are the growing segments of the space economy that aren’t centered around satellite communications. This is about tugging things between different orbits, creating specialized pharmaceutical compounds and fiberoptic cables that can only be built in microgravity environments, setting up in-space gas stations, and building private space stations.

According to the Commission, it also refers to “space objects and celestial bodies, and in transit between these regimes” which means it’s not just about systems in orbit but also potentially lunar and martian operations.

Right now, there is a shortage of available spectrum - both licensed and unlicensed, that can be reliably used for ISAM operations. The Commission is working to fill that void - on the licensed side in the Weird Space Stuff proceeding (a topic for another day), and on the unlicensed side in this proceeding.

This is complicated - unlike inside a shielded spaceship, if not properly operated, spectrum used in the vacuum of space can travel vast distances, interfere with other services, and raise thorny treaty issues.

So the FCC is in an exploratory phase, asking questions like which frequencies would make the most sense, how much power would they need to operate, and what types of applications would communicate between different spacecraft.

Part of what makes this exciting is that it is a blank slate. The rules are totally up for grabs, and the companies that show up now with technical comments describing their actual operational needs are the ones most likely to shape what gets adopted.

Tightening the (Supply) Chain: The FCC Closes the Component Part Loophole

If the Unlicensed D2D item was like a pizza party for the space tech industry, this month’s supply chain tightening actions were more like a colonoscopy.

On July 22, the FCC adopted a Third Report and Order expanding its national security review of components as part of its equipment authorization regime. The most critical change is that a device can no longer receive FCC authorization if it contains a "logic-bearing hardware component," meaning a chip, module, or other programmable element produced by a banned entity like Huawei or ZTE, even if a completely unrelated, uncontroversial company assembled everything else. The test the Commission adopted is simple to describe, but painful to implement: if the banned entity had made the whole device, would it be prohibited? If yes, a device with just their chip inside it is prohibited too.

This closes what the Commission referred to as the “component part loophole,” and it shifts the compliance question from “who made this device” to “who made the digital device components inside the chip,” which is a much harder question for manufacturers utilizing globally sourced supply chains to answer.

The Commission also formally pulled online marketplaces like Amazon and eBay into its enforcement net, requiring verified FCC IDs at the point of sale and rejecting Section 230 defenses; expect litigation there.

A companion Further Notice, issued alongside the Order, previews where this goes next: software and hardware bills of materials, extending the same component-level logic to software and firmware, and a U.S.-based liable party requirement. Comments are due 30 days after Federal Register publication.

Separately, on July 28, the Commission added foreign-produced humanoid and quadruped robots and foreign-produced power inverters to the Covered List, extending its national security reach well beyond telecom hardware and into robotics and grid equipment.

For anyone in the satcom hardware business who hasn’t yet mapped their chip-level supply chain, the clock on that exercise just started ticking. Speaking of which…

What to Watch in August

• Keep the FCC’s August 6 Open Meeting on your radar.3 It’s when the Commission votes on Unlicensed D2D, so we’ll get a vote on a final version and also see if Carr makes any remarks sending signals to the ISAM industry upon adoption.

• Also worth tracking: NextNav’s proposal has been parked at OMB for interagency review since March, with a House Appropriations rider in the mix trying to block any funding for a 900 MHz rulemaking. Will it finally get to come out and play during the August recess?

• And a smaller note given this issue’s equipment security theme: DARPA’s Lift Challenge, a $6.5 million heavy-lift drone competition tied to the Pentagon’s Drone Dominance push, runs August 2-9, a reminder that the same UAS ecosystem facing tighter Covered List scrutiny is also being pushed hard to scale capabilities.

About

Ross Slutsky is the founder of Perihelion Strategies, Limited (PSL), an independent FCC regulatory strategy and intelligence firm that helps operators and investors understand what the FCC is doing, engage it effectively, and position themselves to win at the moments that determine outcomes. Before founding PSL, Ross spent time at the Commission, in big law, and in-house at a leading global satellite operator. In his downtime he enjoys film, family activities, and flying trapeze.

The Perihelion Moment is published monthly by Perihelion Strategies, Ltd. Nothing here is legal, financial, or investment advice.