On November 9, AMSAT filed comments with the Federal Communications Commission (FCC) on a proposal to let unlicensed devices communicate directly with satellites in two bands shared with the amateur and amateur-satellite services. AMSAT asked the Commission to keep the new satellite uplinks out of the 2400-2450 MHz amateur-satellite segment and not to add a satellite downlink allocation in the 2.4 GHz band.The Notice of Proposed Rulemaking (NPRM), “Unleashing Unlicensed Spectrum for Direct-to-Device” (ET Docket No. 26-169, FCC 26-51), was adopted August 6 and released August 7. It would allow devices certified under Part 15 of the FCC’s rules, such as Wi-Fi and Bluetooth equipment, to transmit to authorized satellites in the 2400-2483.5 MHz and 5725-5850 MHz bands. A new footnote to the Table of Frequency Allocations, NG36, would permit mobile-satellite service uplinks in both bands on an unprotected, non-interference basis. Devices would remain within the existing Part 15 limits of up to 4 watts EIRP, although the FCC asks whether different limits are warranted for satellite links. The 902-928 MHz band, included in the draft released in July, was dropped before adoption.The NPRM proposes no rules for satellite downlinks, but it asks whether they should be permitted at 5725-5850 MHz and whether a downlink allocation should be added at 2400-2483.5 MHz. It also proposes to confirm that Part 15 devices may be used inside spacecraft, seeks comment on their use during spacewalks and for links between spacecraft, and asks whether limits are needed on unintended radio emissions from satellite electronics.In the United States, the amateur service is primary at 2400-2417 MHz and secondary at 2417-2450 MHz and across 5725-5850 MHz. The amateur-satellite service may operate at 2400-2450 MHz in both directions on a non-interference basis and has a secondary downlink allocation at 5830-5850 MHz.In its 20-page filing, AMSAT said it does not oppose innovation in direct-to-device connectivity, but noted that the 2400-2450 MHz segment has hosted amateur satellite links for decades, from the S-band downlinks of AO-40 and AO-51 to the 2400-2410 MHz uplink of the QO-100 geostationary transponder. It described the 5830-5850 MHz segment as an important option for higher-rate microwave downlinks. The comments explain that amateur satellite links are often weak-signal links with margins that may be only a few decibels.Terrestrial Part 15 emissions generally arrive from directions that a ground station’s antenna attenuates while tracking a satellite, but a co-frequency satellite in or near the antenna’s main beam may be received at high gain. For a reference ground station with a 60 cm dish, AMSAT’s technical appendix finds a difference of about 35 dB between the signal level an illustrative consumer downlink would need and the level that would protect the amateur receiver. AMSAT called this a serious warning about compatibility at 2400-2450 MHz rather than a complete sharing study, and said the whole 2400-2483.5 MHz band should be excluded from any downlink framework absent a convincing demonstration of compatibility.On the uplink side, AMSAT noted that links to orbit could favor outdoor, skyward transmissions, while many Wi-Fi and Bluetooth links today operate indoors or below maximum power. Its bounding calculations show that a single device at the maximum permitted power spectral density could approach the interference allowance of a narrowband transponder channel on a low Earth orbit amateur satellite passing overhead, and that roughly 10 to 30 co-channel devices transmitting skyward at full power at once could raise the satellite receiver’s noise floor by about 3 dB in 1 MHz. Calling these figures stress tests rather than forecasts, AMSAT asked the Commission to require realistic aggregate interference studies that treat amateur satellite receivers as victims.Among other things, AMSAT asked the Commission to:• Add no satellite downlink allocation at 2400-2483.5 MHz, and issue a further notice with specific rule text and technical analysis before adopting downlink rules in any band.• Exclude the 5830-5850 MHz amateur-satellite downlink segment from any 5725-5850 MHz downlink framework, or protect it with limits based on the needs of amateur ground stations.• Allow no increase in Part 15 power, antenna gain, or emission limits for transmissions to satellites, and cap direct-to-device earth stations at 36 dBm (4 watts) EIRP.• Revise footnote NG36 to bar operations under it from causing harmful interference to, or claiming protection from, the amateur and amateur-satellite services; to include those technical limits; and to confine the 2.4 GHz uplink allocation to 2450-2483.5 MHz, where there is no amateur allocation.• Require an individual license or U.S. market access grant for every satellite operating under the new framework, a public point of contact for interference reports, prompt investigation and mitigation of harmful interference, and a public database of authorized operations.• Apply radiated emission limits at least as strict as the Part 15 Class B limits, as an initial benchmark, to unintended emissions from spacecraft in bands used by the amateur-satellite and passive services, measured before launch, with stricter narrowband or aggregate limits where needed.• On the last point, AMSAT noted that the reported unintended emissions, at 40-70 MHz and 110-188 MHz, overlap the 50-54 MHz amateur band and the 144-146 MHz amateur-satellite band, including the 145.8-146.0 MHz segment that carries ARISS downlinks and the downlinks of amateur and university satellites. Its analysis found that a Class B-level limit offers substantial protection against a single spacecraft’s emissions but cannot by itself guarantee protection against narrowband emissions from large constellations.AMSAT supported confirming that Part 15 devices may be used inside spacecraft, citing the long-standing use of crew Wi-Fi and Bluetooth devices aboard the International Space Station alongside ARISS. It urged greater caution about spacewalk and spacecraft-to-spacecraft use of 2400-2450 MHz, where no hull shields amateur satellites sharing the band.***For More Information***The FCC NPRM (FCC 26-51) is available at: https://docs.fcc.gov/public/attachments/FCC-26-51A1.pdfAMSAT’s comments are available at: https://www.fcc.gov/ecfs/document/26110084235/1Reply comments are due December 7, 2026, and may be filed at https://www.fcc.gov/ecfs/Source AMSAT News Service (ANS) https://mailman.amsat.org/hyperkitty/list/ans@amsat.org/thread/UDSS7CEAZYFTPBPOT2INZ3COVHPWJLKD/