Newsletter November 2, 2026

Wireless Roundup (November 2026)

November 2, 2026

Key Wireless Deadlines
Upcoming Meetings and Events
Cyber Corner
Other Wireless Developments

Key Wireless Deadlines

Input Requested for Initial Upper C-Band Transition Plans: On October 8, the Federal Communications Commission (FCC or Commission) released a Public Notice (PN or Notice) establishing GN Docket No. 26-289 as the official docket for Upper-C band transition plans. Space station operators are required to publicly file their plans in the docket on or before November 5, as stated in a previous Report and Order (R&O). Comments on these initial plans are due November 30.

Commission Releases Proposed Cost Catalog for Upper C-Band Transition Reimbursements: On September 30, the FCC issued a PN seeking comment on its Upper C-Band Transition Preliminary Cost Catalog. The cost catalog lists estimated ranges for relocation expenses that the Commission deems “presumptively reasonable,” as well as preliminary lump sum amounts for incumbent earth station operators that elect lump sum reimbursement rather than reimbursement for actual costs. Reply Comments are due November 9.

Commission Proposes to Expand D2D Communications Between Satellites and Unlicensed Devices: On August 7, the FCC issued a Notice of Proposed Rulemaking (NPRM) to permit kellyunlicensed devices operating under Part 15 rules to communicate with FCC-authorized satellites. Among other proposals, the Commission would authorize Earth-to-space transmissions from Part 15 devices in the 2400-2483.5 MHz and 5725-5850 MHz bands. The NPRM also requests comment on other bands that could support Earth-to-space or space-to-Earth communications, as well as on the appropriate licensing framework for Direct-to-Device (D2D) communications. Comments are due November 9. Reply Comments are due December 7.

FCC Invites Comment on Rebates for Retrofitting Radio Altimeters: On October 5, the FCC released a PN seeking input on a proposed rebate system for aircraft operators to update their radio altimeters as mandated by the Federal Aviation Administration (FAA). According to the Commission, these rebates will facilitate the introduction of terrestrial wireless services to the Upper C-band by accelerating the retrofitting timeline such that altimeters and wireless operations can coexist without interference. The Notice specifically requests comment on the rebate structure, including proposed categories and amounts and procedural guidance for administering the rebates. Reply Comments are due November 16.

Comments Welcomed on the Commission’s NHPA and ESA Frameworks: On October 1, the Commission released both a Report and Order updating their implementation of the National Environmental Policy Act (NEPA) and a Further Notice of Proposed Rulemaking (FNPRM) seeking input on their National Historic Preservation Act (NHPA) and Endangered Species Act (ESA) frameworks. Specifically, the FCC invites commenters to refresh the record on the definition of certain phrases within the frameworks and to offer suggestions on how to make environmental review processes more efficient. Comments are due November 18. Reply Comments are due December 3.

FCC Seeks Additional Comments on Part 100 Rules for Space and Earth Station Licensing: On July 23, the FCC issued a R&O and FNPRM adopting a new Part 100 to govern the licensing and operational rules of space and earth stations. These rules replace the previous licensing framework in Part 25 and update the application and review process, operational and technical requirements, and enforcement mechanisms. The FNPRM requests additional input on specific aspects of these rules, including, among other things, operational requirements for licensees, reporting and documentation obligations, the experimental license framework, requirements for connectivity between satellites and unmanned aircraft systems (UAS or drones), and secondary markets for licenses. Comments are due November 25. Reply Comments are due December 28.

Upcoming Meetings and Events

FCC Open Meeting: The next FCC Open Meeting is scheduled for November 19. Meeting details are available here. The agenda includes:

CISA Collaborative Cybersecurity Workshop: The Cybersecurity and Infrastructure Security Agency (CISA) is hosting an in-person Collaborative Cybersecurity Workshop in Southern California on November 10, which will discuss service offerings available to assist in building cyber resilient infrastructures.

Cyber Corner

NIST Releases Draft CSF Profile for Federal Agency O-RAN Deployment: On September 17, the National Institute of Standards and Technology (NIST) released for comment the initial public draft of NIST Interagency or Internal Reports 8623, Cybersecurity Framework (CSF) 2.0 Community Profile for Federal Agency Open Radio Access Network (O-RAN) Deployment. Comments are due November 2.
NIST Releases Draft of OT Security Publication: On September 21, NIST released the initial public draft of Special Publication (SP) 800-82 Revision (Rev.) 4, Guide to Operational Technology (OT) Security, which “provides guidelines for establishing secure [OT systems] while addressing [their] unique performance, reliability, and safety requirements.” Comments are due November 30.
CIRCIA Final Rule Submitted to OMB for Review: On October 1, CISA sent the draft final Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) rule to the Office of Management and Budget (OMB) for review. Once OMB completes its review, CISA can publish the item in the Federal Register and set an effective date.
FCC to Move Forward with U.S. Cyber Trust Mark Implementation: On October 27, the FCC released a PN seeking comment on implementation issues for the U.S. Cyber Trust Mark Internet of Things (IoT) labeling program, including labeling and post-market surveillance. Comments on the PN would be due 30 days after Federal Register publication and Reply Comments 45 days after publication. For detailed insights into these U.S. Cyber Trust Mark Implementation updates, see this recent Wiley Client Alert.
NIST Seeks Comment on ICT Risk Management Publication: On October 22, NIST released the initial public draft of Revision 1 to SP 800-221, Enterprise Impacts of Information and Communications Technology Risk: Governing and Managing ICT Risk Programs Within an Enterprise Risk Portfolio. Comments are due December 7.

Other Wireless Developments

FCC Enforces Covered List Component Rules by Banning Two Devices: Following the implementation of new restrictions on logic-bearing components made by entities on the Covered List on October 13, the FCC banned two products, a dashboard camera and a wireless video transmitter, that contained chips produced by HiSilicon, a subsidiary of Huawei. This action took place just a week after the new restrictions took effect, indicating the FCC’s commitment to facilitating compliance with the component rules. Some flexibility remains, however, as indicated by the FCC’s grant of the first hardware waiver for foreign-produced equipment that had authorization before the relevant product sector was added to the Covered List. For detailed insights into these Covered List updates, see this recent Wiley Client Alert.

Wireless Telecommunications Bureau Releases Selection Criteria for Upper C-Band Clearinghouse: As a part of the Upper C-Band R&O, the FCC authorized the creation of a clearinghouse to supervise the band transition. On October 9, the Wireless Bureau published the selection criteria and submission instructions for potential clearinghouse candidates. Candidates are instructed to submit their proposals no later than November 9.

Commission Proposes to Auction 25 MHz of Mid-Band Spectrum: On October 29, the FCC approved an FNPRM requesting comments on the Commission’s proposal to auction the 1675-1695 MHz and 2020-2025 MHz bands for commercial use. Depending on the results of an ongoing study by the National Telecommunications and Information Administration (NTIA), the proposed rule would reallocate the 1675-1695 MHz band on a co-primary basis for fixed and mobile services and on a secondary basis for mobile satellite service (MSS) for domestic supplemental coverage from space (SCS). Additionally, it would add a secondary MSS allocation for domestic SCS for the 2020-2025 MHz band. Comments and Reply Comments will be due 60 days and 90 days after publication in the Federal Register, respectively.

FCC to Seek Comment on Revised D2D Rules: On October 29, the FCC voted to approve an NPRM inviting stakeholders to weigh in on proposed changes to the SCS rules on direct-to-device (D2D) services in licensed spectrum. Among the revisions is a proposal to expand the number of bands in which SCS is authorized to thirteen bands and remove certain eligibility requirements for operators. Additional proposals include changes to D2D performance requirements and new rules that clarify and expand the authorized operation of UAS in SCS bands. Comments and Reply Comments will be due 60 days and 90 days after publication in the Federal Register, respectively.

FCC Approves Drone Use in 800 MHz Band: On October 29, the Commission adopted a Report and Order eliminating the cellular airborne use restriction in the 800 MHz Band, which prevented drone operations. This change will allow UAS command, control, communication, and payload operations across fifty megahertz of low-band spectrum. According to the Commission, this Report and Order is part of a larger effort to modernize UAS rules in support of American leadership in drone use and operations.

FCC Modernizes International Section 214 Framework: On October 29, the FCC approved a R&O and FNPRM addressing the rules applicable to international section 214 authorization holders and applicants. The R&O adopts new rules that the Commission states will bolster security for cross-border communications such as requiring international section 214 authorization holders and applicants to adhere to baseline cybersecurity practices and prohibiting the use of equipment and services on the FCC’s Covered List. The FNPRM seeks comment on additional regulatory obligations, including security measures for international section 214 authorization holders and applicants. The new rules adopted in the R&O will become effective 60 days after publication in the Federal Register, although certain of the requirements are subject to review by the Office of Management and Budget and will not become effective until after that review is complete. Comments on the FNPRM will be due 30 days and 60 days after publication in the Federal Register, respectively. For additional insight into the sweeping changes in the R&O and FNPRM, see this recent Wiley Client Alert.

Francesca Burke, a Law Clerk at Wiley Rein LLP, contributed to this newsletter.