
Rigid Space Spectrum Allocations Could Limit Productivity
The world is experiencing an industrial revolution in space, yet federal and international regulators are proposing rules that would further narrow the permissible uses of certain space spectrum bands. The space economy requires robust support, and restrictive spectrum allocations limits productivity and hinders development. Past Federal Communications Commission (FCC) action dictated that when spectrum is allocated to a single preferred use, bands can remain dormant if demand for that specific use fails to materialize. These rules prevent other operators from repurposing the spectrum for other uses. As the FCC and the International Telecommunication Union (ITU) develop new spectrum policies for space, they should preserve flexibility and avoid restricting bands to narrowly defined use cases. Otherwise, they risk repeating mistakes that have substantially reduced the productive use of spectrum resources.
A key example of reducing productivity by allocating spectrum bands for a specific use is the 2.5 GHz band. The FCC initially allocated this spectrum for educational television programming in 1963, and then later for educational broadband services. However, the FCC’s effort to anticipate the spectrum band’s most valuable use did not align with market realities, as demand for dedicated educational spectrum proved lower than expected. And even though educators barely used the 2.5 GHz band, the FCC’s allocation framework prevented others from accessing it, so its capacity lay untapped. More than 50 years later, the FCC finally adopted a more flexible framework for the band and it has since become a major artery of 5G coverage across the United States.
A similar outcome occurred with the 5.9 GHz band. In 1999, the FCC allocated the band for “Dedicated Short-Range Communications” (DSRC), an automotive technology intended to support the development of connected and intelligent transportation systems. Yet adoption did not occur at the scale that the FCC anticipated. While demand for the band remained limited, the allocation framework restricted alternative uses, reducing the spectrum’s overall productivity. Over two decades later, in 2020, the FCC reallocated portions of the 5.9 GHz band to support more efficient utilization.
These examples illustrate a broader challenge in spectrum policy. Efforts to identify the optimal use of a band in advance are often well-intentioned but face inherent uncertainty. Allocating spectrum for a specific purpose excludes alternative uses that may emerge as technologies and markets evolve. Over time, spectrum policy has generally moved toward greater flexibility. Regulators should avoid reversing that trend as they establish spectrum rules for space operations.
The FCC is considering proposals to open more spectrum for non-communications spacecraft. One proposal problematic proposal would add a “space operations service (SOS)” allocation to several existing commercial spectrum bands. While adding additional permissible services to a band increases its flexibility, the SOS allocation would itself only allow command and control of spacecraft in orbit, not all operations that meet technical rules. While Command and control operations are important, as the space ecosystem evolves, they may not be the only or the best use of SOS bands. The FCC risks creating more underutilized spectrum if it limits future use cases with today’s rigid allocation framework, just as it did with the 2.5 GHz and 5.9 GHz bands.
Similarly, the ITU is considering new space spectrum rules for operations on and around the moon. The 2027 World Radiocommunications Conference (WRC-27) will consider new spectrum allocations to support China and the United States establishing lunar outposts. Specifically, a “space research service” (SRS) allocation would limit the use of certain bands to scientific or technological research activities, under the assumption that research operations will constitute a significant share of lunar activity. However, if future commercial, industrial, or operational uses develop more rapidly than anticipated, the narrowly defined SRS allocation could limit the ability of spectrum resources to adapt to changing demand.
While allocating spectrum for specific space operations may prove effective in the near term, the history of the 2.5 GHz and 5.9 GHz bands suggests that highly restrictive allocations can become obstacles when technological developments or market conditions change. If SOS or SRS allocations are not adopted as broadly as expected, regulators will inevitably need to revisit those frameworks, which historically only happen after decades of reduced spectrum productivity.
As the FCC and the ITU consider new approaches to space spectrum governance, they should continue to prioritize flexibility wherever possible. Spectrum policies that accommodate a range of potential uses are far more effective at enabling new technologies and responding to evolving commercial activity. Preserving flexibility in space spectrum will help maximize the productivity of these resources and support the continued growth of the burgeoning space economy.
