What’s New in Wireless - March 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 recent actions to re-examine spectrum use in what is known as the C-band to determine whether it can be further used for commercial wireless services.

Regulatory Actions and Initiatives 

Spectrum

The FCC Initiates an Inquiry on the Upper C-band. On February 27, 2025, the FCC adopted a Notice of Inquiry, seeking comment on whether it should make some or all of the Upper C-band (3.98-4.2 GHz) available for more intensive use.  In particular, building on its prior decision in the 2020 C-Band Report and Order, the FCC seeks comment on whether the Upper C-band, in whole or in part, should be further repurposed for commercial wireless services and, if so, the amount of spectrum that should be made available and how.  The Commission also asks incumbent operators and users of the Upper C-band – principally broadcasters and media service providers – how the potential introduction of new services in the band would impact their operations and, if the band is repurposed, how they should be transitioned from it.  Finally, the Commission seeks comment on how repurposing the band would impact radio altimeters, which operate in the adjacent 4.2-4.4 GHz band.  The deadlines for submitting comments and reply comments are April 29 and May 29, 2025, respectively.

The FCC Takes Action to Start the AWS-3 Auction.  On the same day, the FCC adopted a Notice of Proposed Rulemaking (“NPRM”) proposing to update the service-specific rules for the AWS-3 spectrum bands (the 1695-1710 MHz, 1755-1780 MHz, and 2155-2180 MHz bands) by harmonizing the AWS-3 designated entity bidding credits with the bidding credits offered in more recent spectrum license auctions. The NPRM is the Commission’s first step in fulfilling its statutory obligation to initiate an auction of AWS-3 licenses by June 23, 2026, to provide funding for the FCC’s Secure and Trusted Communications Networks Reimbursement Program (“Reimbursement Program”).  The deadlines for submitting comments and reply comments are March 31 and April 14, 2025, respectively.

The FCC Provides Guidance on the 5.9 GHz Band. The FCC’s Wireless Telecommunications Bureau (“WTB”) and Public Safety and Homeland Security Bureau (“PSHSB”) released a Public Notice on February 11, 2025, to further support the deployment of connected car technologies that can assist with automotive safety.  Among other things, the Public Notice provides guidance to Intelligent Transportation System (“ITS”) licensees transitioning from Dedicated Short-Range Communications (“DSRC”)-based operations to Cellular Vehicle-to-Everything (“C-V2X”)-based technology in the upper 30-megahertz (5.985-5.925 GHz) portion of the 5.850-5.925 GHz band (the “5.9 GHz band”).  It also reinstates by waiver all roadside unit (“RSUs”) licenses that automatically terminated due to licensees’ failure to notify the FCC that they ceased operating in the lower 45-megahertz (5.850-5.895) portion of the 5.9 GHz band by July 5, 2022.  The Public Notice explains that while there were 82 DSRC-based ITS licensees that failed to make the certification, they likely did not have any operations in the lower 45-megahertz portion of the band and, without a waiver, they would be unable to deploy C-V2X, which would depress or delay use of the band as the FCC intended.  Accordingly, the licensees have an additional 90 days – i.e., until May 12, 2025 – to certify that they ceased operations on or before July 5, 2022.

The FCC Re-Authorizes 3.5 GHz Band Spectrum Access System Administrators.  On February 13, 2025, the FCC’s WTB and Office of Engineering and Technology released a Public Notice announcing that ANDREW, an Amphenol Company (formerly CommScope, Inc.), Federated Wireless, Inc., Google LLC, and Sony Corporation are each approved to continue operating as Spectrum Access System (“SAS”) administrators in the 3.5 GHz band (“SAS Administrators”) for an additional five-year term.  The Public Notice notes that two additional active SAS Administrators – Key Bridge Wireless and RED Technologies – do not require certification renewal at this time.

Wireless Networks and Equipment 

The FCC Extends the Deadline for IoT Cybersecurity Labeling Program Recommendations.  On March 4, 2025, the PSHSB granted UL LLC’s (“UL’s”) request to extend the deadline to submit recommendations of cybersecurity standards and testing procedures to be used to determine if products meet those standards for the FCC’s IoT Cybersecurity Labeling Program. As we previously reported, UL was selected as the Lead Administrator for the IoT Cybersecurity Labeling Program.  UL’s recommendations are now due May 3, 2025.

The FCC Grants Limited Relief to Rip-and-Replace Support Recipients.  The FCC’s Wireline Competition Bureau (“WCB”) released a Public Notice on February 21, 2025, conditionally granting, as it has in the past, 13 requests for an extension of the removal and replacement deadline for entities participating in the Reimbursement Program.  However, unlike past extensions, the WCB granted the extensions for only three months, even though the recipients (except for one, which requested three months) requested six-month extensions.  The WCB finds that three months is more reasonable in light of the additional funding that has been made available for the Reimbursement Program and the previous extensions most parties already received. The WCB also imposed an additional requirement that each of the recipients that sought a six-month extension must withdraw its six-month request and instead file a request for a three-month extension.  These new requests must be filed by March 10, 2025, or they will be denied. 

The FCC Limits Further Requests for Relief for Rip-and-Replace Support Recipients.  In addition, the WCB released a Public Notice outlining changes for future Reimbursement Program extension requests.  The WCB explained that with the recent funding authorized by Congress, Reimbursement Program recipients should be able to “move swiftly” to remove any remaining covered equipment or services from their networks.  As a result, requests for extensions should become “increasingly unnecessary” and will face greater scrutiny.  Moving forward, extension requests will be reviewed on a case-by-case basis and must include the specific obstacles faced by the recipient, how those obstacles affect the recipient’s ability to meet its deadline, steps taken to mitigate the impacts of the obstacles, and whether the recipient expects to meet a future deadline if an extension is granted.  The WCB notes that it expects future extension requests to be for less than six months. 

The FCC Reminds Providers About Their Annual Supply Chain Reports.  The WCB released a Public Notice on February 18, 2025, reminding certain advanced communications service providers of their obligation to file an annual supply chain report by March 31, 2025.  Providers must submit an annual supply chain report if they (i) certified that they had purchased, rented, leased, or otherwise obtained covered communications equipment and services in their most recent annual report (2023); or (ii) newly obtained covered equipment or services.  Reports must be filed in the FCC’s Supply Chain Portal, and they must cover information as of December 31, 2024. Providers that certified that they did not have any covered communications equipment or services in their 2023 annual reports are not required to file this year’s (2024) report (unless they obtained new covered equipment and services). 

Legislative Efforts

The Senate Introduces Bills to Valuate and Audit Federal Spectrum.  On February 27, 2025, Senator Lee introduced two bills that would require NTIA to assess federal spectrum use.  If enacted, the Government Spectrum Valuation Act would require NTIA to periodically estimate the value of spectrum assigned or allocated to federal entities.  The spectrum valuation would be based on the highest potential value of the spectrum if it were reallocated for licensed or unlicensed commercial wireless use.  The Government Spectrum Audit bill, if enacted, would require NTIA to audit spectrum assigned or allocated to federal entities and submit a report to Congress on the results of the audit.  Both bills are currently in committee. 

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