On December 22, 2025, the Federal Communications Commission's Space Bureau issued a public notice (DA 25-1045) that, on its face, reads as procedural housekeeping: it seeks 'to refresh the record on proposed rules to permit the use of additional frequency bands for non-geostationary orbit (NGSO) Fixed Satellite Service (FSS) satellites to communicate with Earth Stations in Motion (ESIMs).' Comments were due January 21, 2026. But the docket numbers attached to that notice, IB Docket Nos. 17-95 and 18-315, tell a more interesting story than the brief text. This proceeding has been pending long enough that the Commission no longer trusts its own record, and the in-motion connectivity market has changed so fast that the only responsible thing to do is ask the industry to file fresh evidence before the rules are written.
Earth Stations in Motion are exactly what the name says: satellite terminals that operate while moving. They sit on the bellies and tails of commercial aircraft, on the superstructures of ships, and increasingly on trucks, buses and other land vehicles. ESIMs are the technical foundation of in-flight Wi-Fi, maritime broadband, and the emerging market for always-connected mobility on the ground. Historically, ESIM rules were written around geostationary satellites, where the terminal points at a fixed spot in the sky and the engineering problem is keeping that pointing stable as the platform pitches and rolls. NGSO systems change the problem fundamentally: the satellite is also moving, fast, across the sky, so the terminal must track a target that is itself in motion while the platform underneath it moves too.
Why 'additional frequency bands' is the operative phrase
The heart of this proceeding is spectrum access. ESIMs already operate in certain Ku- and Ka-band segments, but NGSO operators want to serve in-motion terminals across additional bands to get more capacity and more flexibility in how they route traffic. Each candidate band carries its own coordination problem, because ESIMs are inherently mobile and can wander into geographies and pointing geometries that complicate interference protection for incumbent services. A fixed earth station's interference environment can be characterized once and licensed; a terminal on a 747 crossing oceans and a terminal on a freighter in a crowded shipping lane present a moving, statistical interference picture that the rules must bound without strangling the service.
That is precisely why the Commission is refreshing rather than simply deciding. The original proposals in dockets 17-95 and 18-315 were developed when the NGSO broadband landscape looked very different. Since then, large LEO constellations have moved from paper filings to operational fleets serving real aviation and maritime customers, the terminal hardware has shifted toward electronically steered flat panels that track fast-moving satellites without mechanical gimbals, and the volume of in-motion traffic has grown by orders of magnitude. A rule built on the older record risks being obsolete the day it is adopted. By soliciting updated technical and market data, the Bureau is making sure the band designations, power limits, and coordination obligations reflect the systems that actually fly today.
The regulatory anchor is 47 CFR Part 25, the satellite rules, where ESIM operations and NGSO licensing both live. Part 25 already contains the framework for ESIMs communicating with GSO and, more recently, NGSO satellites; this proceeding extends that framework into new spectrum. The practical effect of a favorable rule would be to let an aircraft or a ship pull more bandwidth from a LEO constellation by drawing on a wider pool of frequencies, which translates directly into faster in-flight and maritime broadband and more headroom as passenger demand grows.
What is at stake for the connectivity market
For the airlines and cruise operators buying connectivity, more available bands mean their satellite partners can deliver higher throughput per platform and serve denser cabins without the link saturating. For the NGSO operators, it is a question of competitive positioning: the constellation that can legally serve in-motion terminals across the most spectrum, with the cleanest coordination rules, can win the lucrative mobility contracts that are among the highest-value markets in satellite broadband. In-flight and maritime customers pay premiums that residential broadband cannot match, which is why aviation and maritime ESIM access is strategically prized.
The coordination tension is real and the incumbents will press it. Terrestrial services and other satellite operators that share the candidate bands will want assurance that a global fleet of moving terminals will not raise the aggregate interference floor in their bands. ESIM rules typically respond with geographic exclusion zones, elevation-angle constraints, automatic transmit-power control tied to the link geometry, and database-driven coordination that shuts a terminal down when it strays into a protected region. The refreshed record is where the parties will argue over how tight those constraints must be, and tightness is the trade-off: stricter coordination protects incumbents but can carve holes in coverage precisely where mobile platforms travel.
The deeper signal in this notice is institutional. When the Commission refreshes a record rather than ruling on the existing one, it is acknowledging that the pace of the NGSO market has outrun its own deliberative cycle. Dockets opened in 2017 and 2018 are being revisited because the world they described, of mostly-paper NGSO constellations and GSO-centric ESIMs, has been replaced by operational LEO fleets serving real moving customers. For anyone tracking where satellite broadband revenue is actually going, the in-motion segment is the answer, and the additional bands at issue in IB Dockets 17-95 and 18-315 are the spectrum that will determine how much of that demand the constellations can actually carry. The refreshed comment window has closed, but the resulting rules will set the ceiling on in-motion capacity for years.