What’s New in Wireless - September 2025

Mintz - Technology, Communications & Media Viewpoints

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 upcoming spectrum policy symposium held by the National Telecommunications and Information Administration (“NTIA”) in Washington, DC.

Regulatory Actions and Initiatives

Spectrum

NTIA to Host Spectrum Policy Symposium. NTIA has announced that it will host a spectrum policy symposium from 9:30 am to 12:30 pm ET on September 10, 2025, “to publicly announce its spectrum policy.” The symposium will be held in person at the Ronald Reagan Building and International Trade Center in Washington, DC, as well as webcast on NTIA’s spectrum policy symposium webpage. While an agenda has not yet been made available, invited speakers include members of the FCC, Executive Branch, and “leading wireless and satellite companies.”

Waiver of 3.45 GHz Band Spectrum Aggregation Limit Granted The FCC’s Wireless Telecommunications Bureau (“WTB”) released a Memorandum Opinion and Order on August 21, 2025, granting AT&T and FTC Management Group, Inc. – which have entered into long-term de facto transfer leasing arrangements for 3.45 GHz, AWS-1, and AWS-3 spectrum in South Carolina – a waiver of the spectrum aggregation limit that prevents licensees from holding more than 40 megahertz of 3.45 GHz band spectrum for four years after auction. The WTB found that a waiver would serve the public interest because it would put this spectrum to immediate use and would not result in competitive harm because there are other competitors in the markets at issue. Moreover, the aggregation limit has largely served its intended purpose and is set to expire in only four and a half months.

End of the C-band Transition Announced. On August 20, 2025, the C-band Relocation Payment Clearinghouse (“RPC”), which was tasked with overseeing the transition of the 3.7-4.2 GHz band – known as the C-band – from satellite use to commercial wireless services, filed its final certification attesting to the WTB that the RPC has completed all final administrative activities and ceased operations. The WTB subsequently released a Public Notice announcing that the C-band transition relocation cost reimbursement program is now complete.

Wireless Networks, Equipment, and Infrastructure

NTIA Releases Reports on Receivers. NTIA released two reports on August 12, 2025, that it commissioned from MITRE on receiver characteristics. The first report – titled “Receiver Interference Immunity: Issues and Recommendations” – discusses, among other things, how certain FCC proceedings have resulted in increased attention to mitigating receiver performance issues. Those proceedings include use of the C-band for 5G services and the impact of those services to airborne radio altimeters as well the ongoing dispute between Ligado and the GPS industry about the use of Ligado’s spectrum for commercial wireless services. The second report – titled “Best Practices for Designing Interference-Resilient RF Receiving Systems” – is principally intended for federal employees involved in the procurement of RF receiving systems and includes recommended best practices for designing interference-resilient receiving systems.

“Bad” Labs Rules Now Effective. The FCC’s Report and Order adopting rules that prohibit the use of any Telecommunications Certification Body, test lab, or laboratory accreditation body owned by, controlled by, or subject to the direction of a “prohibited entity” – i.e., “bad labs” – in the FCC’s equipment authorization process was published in the Federal Register on August 7, 2025, making the rules effective September 8, 2025. However, the rules will not yet have a practical impact on the FCC’s equipment authorization process because the reporting and certification requirements that would enable the Commission to verify whether an applicant has used a “bad lab” require approval by the Office of Management and Budget under the Paperwork Reduction Act before they can become effective, which has not yet occurred.

Pleading Cycle Established for Emergency Alert Systems. The FCC’s Notice of Proposed Rulemaking on its Emergency Alert System and Wireless Emergency Alerts was published in the Federal Register on August 26, 2025. As we previously reported, the FCC seeks to evaluate the goals of the systems, whether the systems are achieving those goals, and the steps the FCC should take to modernize the systems. Comments and reply comments on the FCC’s proposals will be due September 25 and October 10, 2025, respectively.

Pleading Cycle Established for Disaster Information Reporting System (“DIRS”). The FCC’s Third Further Notice of Proposed Rulemaking and Order on Reconsideration on DIRS was published in the Federal Register on September 2, 2025. As we previously reported, the FCC proposes to streamline and simplify DIRS reporting requirements for wireless service providers and others. It also proposes to eliminate DIRS reporting requirements for resellers and mobile virtual network operators. Comments and reply comments on the FCC’s proposals are due October 2 and November 3, 2025, respectively.

The FCC Reminds Rip-and-Replace Support Recipients About Their Quarterly Status Update Deadline and Updates its Guidance. On August 29, 2025, the FCC’s Wireline Competition Bureau (“WCB”) released a Public Notice reminding all rip-and-replace support recipients of their obligation to file a status update with the FCC by September 30, 2025. Support recipients are under the continuing obligation to file status updates every 90 days until they file their final certification. The WCB also separately released a Public Notice announcing that it has updated its Frequently Asked Questions and User Guides for the rip-and-replace program.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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