NRAO FCC Comments

Along with many other groups and individuals, NRAO regularly comments on FCC Notices of Proposed Rule Making (NPRM). Below is an archive (updated quarterly) of the most recent NRAO FCC comments and reply comments. The FCC's Electronic Comment Filing System (ECFS) can be utilized to do a more targeted search for NRAO FCC comments, if desired.

Click on the title below to view the associated document.

Date Received Title Summary
06 Jul 2026 Reply Comments of the NRAO on Petition for Rulemaking of Teradar, Inc. NRAO's second comment in Docket RM-12021 raises objections to Teradar's FCC petition for terahertz imaging devices at 300-320 GHz. It rebuts Teradar's atmospheric-absorption argument (based on standard atmospheric conditions that are not appropriate for the dry high-altitude sites where submm astronomy occurs), notes 296-325 GHz is absent from WRC-27's device studies under Agenda Item 1.8, and cites 76-77 GHz where similar mitigation promises failed to stop interference to radio astronomy from vehicular radars as a warning. NRAO maintains that a rulemaking is premature without compatibility studies and while Agenda Item 1.8 (WRC-27) is pending.
13 May 2026 Comments of the NRAO on Petition for Rulemaking of Teradar, Inc. NRAO filed public comments regarding Docket No. RM-12021. The proceeding addresses a Petition for Rulemaking by Teradar, Inc. seeking to amend Part 15 of the FCC rules to permit unlicensed operation of Terahertz imaging devices in the 300–320 GHz frequency band. The comments focus on evaluating potential radio frequency interference (RFI) from high-frequency active sensing and imaging devices operating in the 300–320 GHz range to ensure protection for passive radio astronomy observations in adjacent or overlapping spectrum bands.
04 May 2026 Comments of the NRAO on Petition for Rulemaking of Qualcomm, Inc. NRAO’s comments on Qualcomm’s proposed Sidelink service warn that Crosslink could cause significant interference to radio astronomy in the 1.675–1.695 GHz and 5.35–5.47 GHz bands, with required separation distances of roughly 100 km or more. NRAO argues that commercial use should not be allowed to interfere with observations and requests minimum-distance geo-fencing for non-safety use, along with additional protections within the National Radio Quiet Zone.
30 April 2026 Comments of the NRAO on Spectrum Abundance for Weird Space Stuff (NPRM) NRAO's FCC comments on spectrum for "novel/emergent" space activities urge better alignment of allocations, but oppose authorizing transmissions in passive radio-astronomy bands and a proposed 2320–2345 MHz allocation, which would interfere with VLBA/VLA geodetic VLBI observations used for Earth orientation and satellite tracking. NRAO asks the FCC to require coordination with radio astronomy operators before authorizing new uses in these bands.
12 January 2026 Comments of the NRAO on Upper C-band (3.98–4.2 GHz) (NPRM) NRAO’s comments on the FCC’s proposed rules for the 3.98–4.2 GHz Upper C-band emphasize the importance of this spectrum for radio astronomy and note that observations occur regularly at the VLA and VLBA. NRAO supports improved coordination with wireless operators to prevent receiver overload and increased noise, suggesting that its existing near-real-time data sharing could facilitate cooperative spectrum use. It also asks the FCC to provide incentives for operators that coordinate with observatories and reduce coverage where necessary.
07 January 2026 Comments of the NRAO on Space Modernization for the 21st Century (NPRM) NRAO’s comments on the FCC’s “Space Modernization for the 21st Century” proposal generally support reorganizing the satellite licensing rules but call for stronger safeguards for radio astronomy. NRAO asks the FCC to retain detailed application narratives and technical information, limit fast-track licensing and waivers, ensure public access to current satellite data and ephemerides, and better account for radio astronomy in coordination procedures. It also urges the FCC to assess the optical and visual impacts of space activities, including large satellite constellations and other potentially disruptive operations.
05 January 2026 Comments of the NRAO on Space Bureau and Wireless Telecommunications Bureau accept for filing application of SpaceX requesting NGSO MSS authorization and supplemental coverage from space authorization and seek comment on Waivers NRAO argues that SpaceX’s proposed satellite operations could cause harmful interference to radio astronomy, particularly in the critical 42–42.5 GHz and 92–114 GHz bands. It questions whether SpaceX can meet interference limits, calls for detailed technical analysis before granting W-band waivers, and asks how exposed radio telescopes—especially in Arizona—will be protected.

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