The FCC's Upper C-Band Transition Plan Rule Is Live. Three Satellite Filings Will Set the Bill for Bidders.

The FCC thinks each satellite operator will need 2,720 hours to write one document [1]. That’s the government’s paperwork estimate for an Upper C-band transition plan, and the requirement to file one became effective on October 29, after the Office of Management and Budget signed off in September [1].

The plans are due November 5 [1]. Only three companies have to write one. What they put in them is the first real number anyone bidding in next year’s auction will see.

What changed this week

The FCC adopted its Upper C-band order on July 22 and published it July 31 [5]. Most of it took effect September 29, but more than a dozen sections that collect information were held back pending OMB review [5]. On October 29 the FCC announced that one of them, the transition plan rule at 47 CFR 27.1412(e), is now in force [1].

The rule asks for a lot. Each eligible space station operator has to list every satellite that needs repacking, how many new satellites it would launch and why, the before-and-after frequencies for each customer, the number and location of earth station antennas that receive its signals, and a timeline [1]. Earth stations left out of a plan can be handed to a Relocation Coordinator, who can assign them to an operator or write an individual plan [1].

Three days earlier, the Wireless Telecommunications Bureau set up GN Docket No. 26-289 for the plans and set comments for November 30 [2]. The same day it published the criteria for picking the Upper C-band Clearinghouse, the third party that will review every reimbursement claim and run the aircraft rebates [3]. Proposals are due November 9, and the selection committee must name its pick by December 15 [3].

Also on October 26: notice that Harold Feld, on behalf of Public Knowledge and others, has asked the FCC to reconsider the order. Oppositions are due November 10, replies November 20 [4]. The notice doesn’t describe the arguments [4].

How we got here

Congress set the clock. Section 40002 of Public Law 119-21 told the FCC to complete an auction “not later than 2 years after the date of enactment of this Act for not less than 100 megahertz in the band between 3.98 gigahertz and 4.2 gigahertz” [9]. The law was signed July 4, 2025 [9].

The FCC went past the minimum. It is auctioning 160 megahertz at 3.98-4.14 GHz, keeping 4.14-4.16 GHz as a guard band and packing the satellites into 4.16-4.2 GHz [5]. The upper band joins the existing Lower C-band in a single 3.7 GHz Service [5]. Auction 115 will offer 3,248 licenses, eight 20-megahertz blocks in each partial economic area, with bidding tentatively starting April 27, 2027 [6].

Satellites have to be out of 4.0-4.16 GHz by December 30, 2030, in the top 75 markets and by June 30, 2031, everywhere else in the contiguous U.S. [1]. The earlier date isn’t arbitrary. It matches the FAA’s first deadline for retrofitting airliner radio altimeters, which operate just above the band at 4.2-4.4 GHz [1, 8]. The FAA’s rule says the new altimeters “must withstand interference from wireless signals in neighboring spectrum bands” [8]. Part 121 carriers and larger foreign carriers must comply by December 30, 2030; most other aircraft by October 31, 2034 [8].

What the winners will owe

This section is opinion, built on the FCC’s own figures.

If you build on licensed mid-band spectrum, through fixed wireless, a private network partner or an MVNO deal, the license price is the start of the cost. Upper C-band licensees inherit three separate bills:

• Relocation costs. Winners pay incumbents’ “reasonable and necessary” costs of moving, split mostly by each winner’s share of gross winning bids [5]. The FCC’s first estimate is $4 billion to $5 billion, and it adds a warning: “We again caution that this is an estimate only, and new terrestrial wireless licensees in the Upper C-band will be responsible for the entire allowed costs of relocation, including those costs that exceed this estimated range” [5].
• Incentive payments. $6.3 billion for clearing on time, allocated 89 percent to SES ($5.607 billion), 8 percent to Eutelsat ($504 million) and 3 percent to Telesat ($189 million) [5]. Miss the primary deadline and the primary-deadline payment shrinks by 7.5 percentage points per 30 days late, falling to zero after 180 days [5].
• Aircraft rebates. Winners fund set-amount rebates for eligible aircraft owners doing the FAA retrofit. The FCC estimates $3.83 billion to $5.71 billion, with a $3.5 billion cap for the group on the 2034 deadline [5]. Draft categories were published October 19 [7].

Add those up and a bidder is looking at roughly $14 billion to $17 billion in obligations before paying for the spectrum, by this column’s arithmetic. Only the incentive figure is fixed. The relocation number gets its first real test on November 5, which is why the transition plans matter more than their page count suggests. The FCC’s total annual burden estimate for the whole information collection is 104,160 hours and $540,000 across 3,003 respondents [1]. That’s cheap paperwork for documents that will move billions of dollars.

I’d also watch the rebate design. The FCC chose fixed amounts per aircraft category, not actual cost, partly to prevent fraud and keep the program manageable [7]. That’s a legible choice. It also means whoever lands in the wrong category bears the difference. Foreign-registered operators and altimeter makers get nothing directly, and the FCC says manufacturers will benefit “indirectly through operation of the relevant supply chain” [5].

The device rules are the part product teams will feel

Two technical decisions reach past the carriers.

First, the order raises the power limit for mobile and portable devices from 1 watt to 2 watts EIRP across 3.7-4.14 GHz [5]. Commenters had asked for 4 watts to improve in-home fixed wireless gear; the FCC said it would go “out of an abundance of caution” with the smaller step after cable and CBRS operators raised interference worries near the 3.7 GHz edge [5]. If you design or certify fixed wireless CPE, that’s a new ceiling. If you run CBRS gear, the FCC said CBRS commenters had not presented “any specific analysis” of harm [5]. I wrote about the band below this one earlier this month; the power decision touches its upper edge.

Second, buildout. In the 2020 Lower C-band rules, IoT and fixed point-to-point deployments could help a licensee meet its coverage obligations. Not here. The FCC declined alternative requirements for IoT or fixed links, “nor will we consider private internal operations in demonstrating buildout compliance” [5]. Licensees must reach 45 percent of the population a year after their transition deadline and 80 percent after five years, or lose the license area automatically [5]. A carrier can still lease capacity for your private network. It just won’t get coverage credit for it, which tells you whose use cases this band was built for.

Base stations get a split out-of-band limit into the altimeter band: either -28.4 dBm/MHz EIRP or -46 dBm/MHz conducted, the option CTIA proposed [5]. Lower C-band networks have voluntarily held to -48 dBm/MHz conducted since 2023, so the FCC expects no practical change for them [5].

What I’m watching

• November 5. The three transition plans in GN Docket No. 26-289, and whether their cost estimates land inside the FCC’s $4 billion to $5 billion range [2, 5]. Comments close November 30 [2].
• The reconsideration petition. Oppositions are due November 10 [4]. The FCC has said that, given the pre-auction timeline, “extensions will not be considered” [5].
• December 15. The clearinghouse pick, followed by a Bureau notice seeking comment on whether it meets the criteria [3].