Background

Global spectrum allocations and other policies are harmonized through study cycles that culminate in rules adopted by the International Telecommunication Union (ITU) at World Radiocommunication Conferences (WRCs), which are held every four years. Member states negotiate binding regulations covering a wide range of radiocommunication issues, including how spectrum is allocated, assigned, and managed on a global scale.¹ The decisions reached at each WRC are codified in the ITU Radio Regulations, which carry the force of an international treaty, although individual countries retain the authority to adapt them for their own national regulatory frameworks.

While some countries, including the United States, often modify the regulations to reflect national priorities, many others incorporate the Radio Regulations directly into domestic law. As a result, the ITU Radio Regulations play a major role in shaping spectrum policy worldwide.

At WRCs, decisions are generally made by multinational consensus, although the host country often exercises significant influence over how the conference operates. China’s selection as host of WRC-27 has therefore raised concerns in Washington, where policymakers worry both about security issues and about the outcomes that could emerge from an unfriendly conference environment.²

Decisions reached at any given WRC are a product of years of preparatory work set in motion by previous conferences. Before each WRC, the Radiocommunication Assembly convenes to review and approve the technical standards, recommendations and questions developed by the ITU Radiocommunication Sector’s (ITU-R) specialized study groups, which consist of experts representing participating administrations.³ For WRC-27, the assembly will be held October 11-15 in Shanghai, immediately before the conference itself.

The agenda for each WRC includes not only final decisions on allocations and regulations but also an item establishing the agenda for the next conference and, in some cases, identifying preliminary issues for conferences further in the future. Because the WRC is the primary mechanism through which topics are formally placed on future agendas, moving a spectrum-allocation change or regulatory reform from initial proposal to final adoption often takes two conference cycles—eight years or more.⁴

The process is intentionally slow and deliberate, prioritizing international consensus over speed. Increasingly, however, both the length of the process and the ability of countries resistant to change to delay decisions on globally harmonized allocations and rules have frustrated regulators and innovative firms. This is particularly true for the Federal Communications Commission (FCC) and leading U.S. non-geostationary orbit (NGSO) satellite operators seeking to modernize regulations to keep pace with rapidly evolving technologies.

Following each WRC, a Conference Preparatory Meeting (CPM) assigns new agenda items to the relevant study groups.⁵ Those groups develop potential approaches to each item and identify additional areas requiring study. Their work feeds into a comprehensive CPM report that is finalized at a second meeting shortly before the next WRC. While the CPM seeks to reconcile competing approaches, the report may present multiple alternatives when consensus proves impossible.

The ITU also convenes a separate Plenipotentiary Conference every four years to establish the organization’s broader strategic direction, elect leadership, and address governance and membership issues. The next conference, PP-26, is scheduled for November 9–27, 2026, in Doha, Qatar.⁶

Like other member states, the United States participates in the WRC process both independently and through a regional bloc. In the Americas, that bloc is the Inter-American Telecommunication Commission (CITEL), one of six regional organizations that participate in WRC preparations.⁷ CITEL members have already begun meeting to discuss proposals and identify areas of agreement.

Regional consensus significantly increases the influence of proposals at the ITU and improves their chances of adoption. The ITU divides the world into three regions for spectrum-management purposes: Region 1 (Europe, Africa, and most of northern Asia), Region 2 (the Americas), and Region 3 (South Asia and Australasia).⁸ Because ITU rules permit some variation among regions, regional agreement is often essential to securing new allocations and regulatory changes.

Before the United States can advocate a position internationally, however, it must first navigate a complicated domestic process. Reaching a formal U.S. position requires reconciling two parallel tracks: one led by the National Telecommunications and Information Administration (NTIA), which represents federal government interests, and one led by the FCC, which represents private-sector and public-interest stakeholders. Those interests do not always align. Ultimately, the Department of State, informed by NTIA and FCC recommendations, finalizes U.S. positions and appoints an ambassador-level official to lead the U.S. delegation.

On the federal side, NTIA’s Office of Spectrum Management coordinates participation through the Interdepartment Radio Advisory Committee’s Radio Conference Subcommittee (IRAC RCS), which includes representatives from federal departments and agencies.⁹ The RCS develops preliminary government views and proposals. Once approved by the full IRAC, NTIA develops a final position and submits it to the FCC’s Office of International Affairs. Although the FCC is not a member of IRAC, it appoints a liaison to work with the RCS.

On the private-sector side, the FCC chair convenes the WRC Advisory Committee (WAC), which consists of industry representatives granted special government employee status for the duration of the process.¹⁰ The WAC is organized into four working groups covering maritime, aeronautical and radar services; mobile and fixed services; fixed-satellite service and regulatory matters; and mobile-satellite and space science services.

The full WAC typically meets four times per year. The current committee, whose chair and vice chair were announced in May 2024 and whose renewed charter applications were due in January 2026, held its fourth meeting in February 2026.¹¹ FCC staff also contribute technical and regulatory expertise through specialized bureaus and offices. Following each meeting, the FCC’s Office of International Affairs solicits public comment on WAC recommendations. The most recent comment cycle closed on March 6.¹² NTIA’s RCS also provides updates at WAC meetings, creating a regular point of coordination between the two processes.

Once the WAC completes its work, FCC and NTIA officials reconcile any remaining differences through their respective WRC coordinators. The resulting draft U.S. positions are transmitted to the Department of State. The State Department then submits approved proposals either to CITEL, if sufficient time remains for regional consideration, or directly to the ITU when deadlines require.¹³

CITEL’s Permanent Consultative Committee II (PCC.II) meets twice annually. Member states use those meetings to debate national proposals and consolidate them into regional positions that carry substantially greater weight at WRC than any individual country submission. In theory, the goal is straightforward: develop unified U.S. positions early enough to build coalitions and secure regional support before arriving at the conference. In practice, weaknesses in the process have repeatedly undermined that objective.

At WRC-23, many of those weaknesses were on full display. Critics argued that the United States appointed its delegation head too late, moved too slowly to reach consensus on key issues, and therefore found itself excluded from important negotiations because it lacked regional support and was advancing largely unilateral positions.¹⁴

These shortcomings were not isolated incidents. They reflect deeper structural problems that have appeared repeatedly across multiple WRC cycles.

Domestic coordination challenges, particularly between the FCC and the NTIA, have been a recurring concern for years. A 2019 Government Accountability Office (GAO) report found that the absence of a clear definition of “consensus” complicated efforts to reach agreement. Although the FCC and NTIA signed a new memorandum of understanding in 2022, they had previously operated under a decades-old framework.¹⁵ GAO testimony following WRC-19 further suggested that a highly public interagency dispute over several spectrum bands weakened the U.S. position and delayed submission of technical studies.¹⁶

The U.S. process will always be complex. Reconciling diverse and sometimes competing interests is unavoidable. But with WRC-27 approaching rapidly, critical satellite issues at stake, and an adversarial host nation, the United States cannot afford to repeat past mistakes.

Several areas deserve particular attention:

The United States has a long-standing practice of appointing delegation heads relatively late in the WRC process. Current FCC Commissioner Anna Gomez was appointed to lead the WRC-23 delegation only nine months before the conference, and her successor was appointed even later, after Gomez’s Senate confirmation required her to step aside.

This pattern should change. The delegation head plays a central role in building relationships across U.S. stakeholder groups, within CITEL, and with international partners. Late appointments shorten the time available to cultivate those relationships and reduce opportunities to develop expertise on both the technical issues and political dynamics involved.¹⁷

Although formal ambassadorial appointments may limit how early the State Department can act, prospective delegation heads can still be selected well in advance and begin attending meetings, building expertise, and developing coalitions. The administration’s recent appointment of an ambassador-at-large for cyberspace and digital policy may signal movement in this direction.

A core premise of U.S. preparation for WRC-27 should be support for modern, flexible spectrum-management policies that maximize the productive use of scarce spectrum resources.

The United States has undertaken a broad spectrum- and space-policy modernization effort in recent years that should serve as the foundation for its engagement at the ITU. Beginning with its 2023 spectrum-management policy statement, the FCC signaled a shift away from rigid, worst-case regulatory assumptions toward modern sharing frameworks based on real-world interference conditions, efficient protection criteria, and shared coordination responsibilities.¹⁸

Several recent FCC actions reflect this approach, including the agency’s 2023 and 2026 reforms governing spectrum sharing among NGSO systems and between NGSO and geostationary orbit (GSO) systems as well as proposals to streamline the licensing of satellite and terrestrial ground equipment operating in millimeter-wave bands.

The ITU Radio Regulations, by contrast, remain rooted in a command-and-control model that often relies on outdated assumptions, overprotects incumbents, limits spectrum capacity, and slows innovation. The United States should use the WRC-27 process to advocate a broader modernization of ITU rules consistent with its own evolving spectrum-management philosophy.

Success at the WRC depends on consensus—first domestically, then regionally, and finally internationally.

For the United States, that process begins with developing clear, technically supported positions through the FCC and NTIA. Although the current process has often worked, delays have sometimes prevented the United States from developing positions early enough to advance them through CITEL. Proposals that do not become regional submissions generally carry less influence at the ITU.

The United States should prioritize reaching decisions early enough for them to become CITEL proposals. Doing so requires identifying potential disagreements early, conducting technical studies where necessary, and ensuring that both industry participants and government agencies approach negotiations with a willingness to compromise in pursuit of broader national interests.

Satellite issues will be especially important at WRC-27. The United States has a strong interest in shaping global regulations that support innovation in a rapidly growing industry led by American firms. Consider broadband connectivity. Unlike terrestrial cellular providers, satellite operators deploy global systems that depend on worldwide customer bases and favorable regulatory treatment across multiple jurisdictions. ITU decisions regarding spectrum harmonization, power limits, and market access therefore have significant implications for the ability of U.S. satellite operators to deploy networks and compete globally.

For that reason, U.S.-led satellite providers are likely to face competing regulatory initiatives from countries seeking to strengthen domestic rivals. One notable example is the European Union’s proposed Space Act, which imposes requirements that appear designed to burden large non-European operators while protecting European competitors.¹⁹ Similar concerns arise from regulatory frameworks in Canada, Brazil, Japan, India, China, and elsewhere.²⁰ As the International Center for Law & Economics (ICLE) has observed, these policies can function as nontariff barriers that disadvantage foreign providers, shield less-efficient domestic operators from competition, reduce incentives to invest and innovate, and slow the deployment of new technologies and network capacity.²¹

Industry and government agencies should jointly identify the satellite-related agenda items that present the greatest risks to U.S. interests and make them the organizing focus of the U.S. preparatory effort. These include issues involving additional Earth station backhaul capacity, spectrum for direct-to-device (D2D) services, and the equivalent power-flux-density (EPFD) limits on co-frequency low-Earth orbit (LEO) system sharing with GSOs. Several of these issues are discussed in greater detail below.

The value of CITEL-backed proposals is widely recognized. In practice, however, the United States has sometimes arrived at CITEL meetings with underdeveloped positions that were unable to serve as the basis for regional coalitions.

Coalition-building is as much a diplomatic exercise as a technical one. Other Region 2 countries are far more likely to support U.S. proposals when the United States engages them early, listens to their concerns, and develops proposals they can confidently endorse.

Political considerations will also shape coalition-building at WRC-27. Some recent decisions by the Trump administration concerning tariffs and military actions may create additional diplomatic headwinds for U.S. negotiators. At the same time, many CITEL member states have demonstrated strong demand for the NGSO satellite services that would benefit from the ITU reforms discussed in this paper. That demand creates an opportunity.

The head of the U.S. delegation should begin building support as early as possible by strengthening relationships and socializing U.S. positions with counterparts across the region. Outreach should focus on fostering a shared understanding of both the benefits and the trade-offs associated with U.S. proposals on satellite issues. It could also include workshops and other convenings that help regulators and policymakers better understand the technical issues at stake and the perspectives of U.S. companies and experts.

As noted above, next year’s World Radiocommunication Conference is remarkable for its unprecedented focus on satellite and space issues. More than 80 percent of the tentative agenda items affect the rapidly growing LEO satellite sector, an industry in which U.S. companies currently hold a leading position.

The sections that follow examine four established agenda items of major importance to the LEO satellite industry. Before turning to those items, however, it is important to address a separate issue that, while not formally on the WRC-27 agenda, remains highly consequential to U.S. interests. The issue stems from unresolved debates at WRC-23 over the rules governing spectrum sharing between traditional geostationary orbit (GSO) satellites and the increasingly prevalent non-geostationary orbit (NGSO) systems, including LEO constellations.