What’s New in Wireless - December 2025

The wireless industry has revolutionized the way we connect, from facilitating teleworking, distance learning, and telemedicine to allowing the American public to interact virtually in almost all other aspects of their daily lives. Leading policymakers – federal regulators and legislators – are making it a top priority to ensure that the wireless industry has the tools and resources it needs to keep pace with this evolving landscape. This blog provides monthly updates on actions by federal regulatory bodies responsible for communications policy and Congressional efforts to support wireless connectivity. And this month we highlight the FCC’s initiative to make additional mid-band spectrum available for 5G and 6G services. 

Regulatory Actions and Initiatives 

Spectrum

The FCC Proposes to Repurpose the Upper C-band. On November 21, 2025, the Commission adopted a Notice of Proposed Rulemaking (“NPRM”) that proposes to make at least 100 megahertz, and as much as 180 megahertz, of the 3.98-4.2 GHz band (the “Upper C-band”) available for commercial wireless services. The Commission’s action is consistent with the One Big Beautiful Bill Act (“OBBBA”), which directs the Commission to auction this spectrum by July 4, 2027. Because the Commission previously transitioned the 3.7-3.98 GHz band (the “Lower C-band”) to commercial wireless use, the NPRM proposes to repurpose and use much of the same framework that was utilized for that transition, including by applying the existing service rules applicable to the Lower C-band to any newly authorized terrestrial wireless operations in the Upper C-band, offering incentive payments for accelerated clearing of the spectrum, and establishing an approximate timeline for clearing the band in five and a half years. In the news release about the adoption of the item, the Commission stated that the NPRM represents “a critical step toward releasing a large swath of mid-band spectrum for America’s innovators.” Chairman Carr also noted in this release that “President Trump has been clear that America is going to lead the world in next-generation technologies” and that his proposal “aims to maximize the amount of [Upper C-band] spectrum available for 5G and 6G services.” Comments and reply comments on the NPRM are due January 5, 2026, and February 3, 2026, respectively.

The FCC Asks About Upper C-band Incumbents. Following the Public Notice released in September, on which we previously reported, the Space Bureau released a Public Notice on November 19, 2025, to make certain corrections to its list of Upper C-band earth stations that were previously found to be incumbent earth stations for purposes of the earlier transition of the Lower C-band. This updated list, which is current as of November 14, 2025, reflects changes made to the list of incumbent earth stations released on March 3, 2023, including, in most cases, the removal of inactive antennas and the surrender of authorizations as well as other ministerial updates. A changelog is also included. The Space Bureau reminds incumbent earth station operators that they must keep their registrations up to date at the Commission, which will help facilitate the transition of the Upper C-band. 

The FCC Clarifies the Schedule for the Pending Appeal in the Lower C-band. In addition to the actions above, the FCC’s ALJ issued an Order Revising Pleading Deadlines in the de novo review of the Relocation Payment Clearinghouse’s partial denial of Anuvu Licensing Holdings, LLC’s (“Anuvu’s”) C-band reimbursement claim, on which we previously reported. The Order clarifies that the hearing proceeding is no longer suspended and sets the following new deadlines:

• Enforcement Bureau’s Response Case was due November 21, 2025
• Anuvu’s Reply Case is due December 19, 2025
• Requests for additional written submissions and for oral hearing or argument are due January 9, 2026

The FCC Sets a New Pleading Cycle for SpaceX and EchoStar’s Amended Applications. In response to several new and amended filings made by Space Exploration Technologies Corp. (“SpaceX”) to its applications to acquire certain spectrum licenses from EchoStar Corporation (“EchoStar”), the FCC’s Wireless Telecommunications Bureau (“WTB”) and Space Bureau released a Public Notice tolling the original pleading cycle for the parties’ transaction. As we previously reported, SpaceX’s original filings included applications to assign EchoStar’s AWS-4 and H Block wireless licenses and earth station licenses to SpaceX. SpaceX’s amended filings now also included the assignment of EchoStar’s AWS-3 licenses to SpaceX. On November 25, 2025, the Bureaus released this Public Notice to announce that they have found the amended applications to be acceptable for filing and that the pleading cycle for filings on the transaction will be as follows:

• Petitions to Deny Due: December 15, 2025
• Oppositions Due: December 29, 2025
• Replies Due: January 8, 2026

The FCC Seeks Comment on SpaceX’s Application to Provide Supplemental Coverage from Space Services Using EchoStar’s Spectrum. Related to the applications above, the WTB and Space Bureau released this Public Notice to announce that they have accepted for filing an application (as amended) filed by SpaceX for authority to operate a new non-geostationary orbit (“NGSO”) system to provide supplemental coverage from space (“SCS”) services, conduct mobile-satellite service (“MSS”) operations, and perform related fixed-satellite service (“FSS”) and telemetry, tracking, and control operations (“TT&C”). In particular, SpaceX seeks authority to provide SCS using the 2000-2025 MHz band, H Block, and AWS-3 spectrum that it will receive from EchoStar (in addition to the PCS G Block spectrum it leases from T-Mobile). SpaceX also seeks authority to provide MSS outside of the U.S. – using, among others, the L-band – and to perform FSS backhaul and TT&C in various frequency bands. In connection with its application, SpaceX requests several waivers. The pleading cycle on the application and waiver requests is as follows:

• Comments/Petitions to Deny Due: January 5, 2026
• Response to Comments/Oppositions to Petition Due: January 15, 2026
• Replies to Responses/Oppositions Due: January 22, 2026

The FCC Reminds Incumbents in the 3.5 GHz Band to File for Protection. On November 20, 2025, the WTB, Office of Engineering and Technology (“OET”), and Space Bureau released a Public Notice reminding operators of grandfathered FSS earth stations that are entitled to protection from Citizens Broadband Radio Service (“CBRS”) users – including those in the 3.6-3.7 GHz band and TT&C stations in the 3.7-4.2 GHz band – of their annual December 1 registration requirement. After January 1, 2026, registrations that have not been completed may be deactivated or deleted, and the site will no longer merit protection by the Spectrum Access System administrators.

NTIA Launches Mission LA 2028. NTIA announced that it has launched Mission LA 2028, which it describes as a project that will “demonstrate the groundbreaking potential of early 6G technologies.” NTIA explained that, through this industry-led initiative, stakeholders will “plan, fund, and show the proposed 6G demos at the Summer Olympics” in LA. It added that interested parties should contact NTIA at [email protected] to receive more information about how to participate and that interested parties should submit a signed Letter of Intent by January 30, 2026. 

The FCC Establishes a Pleading Cycle for its Proposed Changes to Millimeter Wave Spectrum. The NPRM on which we previously reported that seeks comment on a range of proposals to facilitate more intensive use of the Upper Microwave Flexible Use Service bands, including the 24 GHz, 28 GHz, upper 37 GHz, 39 GHz, 47 GHz, and 50 GHz bands, was published in the Federal Register on December 3, 2025. Accordingly, comments and reply comments will be due January 2, 2026, and February 2, 2026, respectively. 

Wireless Networks, Equipment, and Infrastructure

The FCC Solicits Comments on Airspan’s Revised Petition for Use of Spectrum in the 3 GHz Band. On November 21, 2025, the WTB and OET released a Public Notice seeking comment on a revised petition for waiver filed by Airspan Networks, Inc. (“Airspan”) that seeks a waiver of the Commission’s out-of-band emission (“OOBE”) limits for the 3.45 GHz band. In the revised petition, Airspan argues that the devices included in its request conform to all OOBE requirements for the CBRS band, so the objections regarding CBRS OOBE relief that were filed against Airspan’s original petition are no longer relevant. Airspan also clarifies that its revised petition does not seek the ability to operate in the 3.45 GHz band on a standalone basis, which is consistent with a waiver that was granted to Ericsson in the FCC’s Ericsson Waiver Order. Comments and reply comments on Airspan’s revised petition are due December 22, 2025, and January 5, 2026, respectively.

The FCC Reminds Rip-and-Replace Support Recipients About Their Quarterly Status Update Deadline and Updates its Guidance. On November 25, 2025, the FCC’s Wireline Competition Bureau released a Public Notice reminding all rip-and-replace support recipients of their obligation to file a status update with the FCC by December 29, 2025. Support recipients are under the continuing obligation to file status updates every 90 days until they file their final certification.

The FCC Establishes a Pleading Cycle for its Proposals to Streamline Wireless Infrastructure Deployment. The NPRM seeking comment on ways to accelerate the buildout of wireless infrastructure was published in the Federal Register on December 1, 2025. As we previously reported, the NPRM seeks comment on steps the FCC could take to prevent or limit the ability of state and local permitting regulations to prohibit (or have the effect of prohibiting) deployment of wireless infrastructure facilities and whether the FCC should implement alternative dispute resolution procedures or an accelerated “rocket docket” process to facilitate the resolution of permitting disputes. Comments and reply comments on the FCC’s proposals will be due December 31, 2025, and January 15, 2026, respectively.

The FCC Establishes a Pleading Cycle for its Proposals to Permit the Jamming of Contraband Phones. The Third Further Notice on which we previously reported that proposes to permit the use of jamming solutions to prevent the use of contraband wireless devices in correctional facilities was published in the Federal Register on November 26, 2025. Comments and reply comments on the FCC’s proposals will therefore be due December 26, 2025, and January 12, 2026, respectively.

Legislative Efforts

Senate to Hold FCC Oversight Hearing. The Senate Commerce, Science, and Transportation Committee will hold a hearing on December 17, 2025 at 10:00 am to conduct oversight of the FCC. Each of the FCC commissioners will testify.

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