BEFORE THE
Federal Communications Commission
Washington, D.C.
| In the Matter of | ||
| Upper C-band (3.98-4.2 GHz) | GN Docket No. 25-59 |
Comments of
Thomas A. Schatz
President
Citizens Against Government Waste
on
Upper C-band (3.98-4.2 GHz)
December 17, 2025
Citizens Against Government Waste (CAGW) is a private, nonprofit, nonpartisan organization dedicated to educating the American public about waste, fraud, abuse, mismanagement, and inefficiency in government. On behalf of the more than 1.2 million members and supporters of CAGW, I offer the following comments and recommendations regarding the Upper C-band (3.98-4.2 GHz) proceeding (GN Docket No. 25-59).
Section 40002 of the One Big Beautiful Bill Act (OBBBA) provided the Federal Communications Commission (FCC) with spectrum auction authority and mandated that the FCC and the National Telecommunications and Information Administration work cooperatively to create a spectrum pipeline of at least 800 MHz of spectrum by 2034, including 500 MHz from federal bands, and 300 MHz from other bands, including 100 MHz in the upper C-band by 2027.[1]
The importance and value to the taxpayers of providing the FCC with spectrum auction authority cannot be overstated. CAGW’s 2019 report on the importance of finding and auctioning spectrum to help spur the development and deployment of 5th generation (5G) mobile networks noted that, “Spectrum is unlike any other public asset in terms of its value and strategic importance for the future of the economy and national security.”[2] The report also spotlighted the benefits of using the C-band spectrum for 5G deployment opportunities and recommended that it be auctioned by the FCC, including the benefit to taxpayers in auctioning this spectrum. While estimates of the value of the auction were between $15-$60 billion depending on how much of the band was included, the first phase of the auction conducted in 2020 set a record with $80.9 billion.[3]
Due to concerns about interference with other spectrum bands, other users of the band who were not included in the original relocation, and how that interference could impact public safety, 180 MHz of C-band spectrum remained for other uses. Whether the FCC will be able to auction 100 MHz or the full 180 MHz of spectrum in the upper channels will depend on how much spectrum can be vacated by incumbent users, which include fixed satellite services (FSS) that provide communications links for aeronautical communications, secure data transmissions for banking and financial services; data communications; distance learning; emergency and disaster response; environmental monitoring; government and military communications; internet connectivity; maritime communications; mobile backhaul; radio broadcasting; telemedicine; telephony, and television broadcasting, and Fixed Service (FS) operations, which “is defined as a radiocommunications service between specified fixed points” usually referring to “terrestrial microwave radio systems operating above 960 MHz in a point-to-point or point-to-multipoint configuration used to haul high volumes of data,” and can be used as studio transmitter links; backhaul for public telecommunications networks; news gathering video; supervisory control and data acquisition; and interconnections for internal data network for corporate, health, or educational purposes.[4] As with the previous C-band auction, incumbents currently using the band will need to be fully reimbursed for all relocation costs like reconfiguration or the purchase of new equipment that will be compatible with the new spectrum allocation.
CAGW supports the FCC’s auction of additional C-band spectrum and urges the commission to include in the final NPRM the maximum reimbursement amount to relocate incumbents by considering the cost of their existing investments in the current band, the value of the spectrum they will be required to relinquish, and providing them with adequate time to upgrade their equipment to utilize the new spectrum bands where they will be relocated.
Thank you for your consideration of CAGW’s comments on this proceeding.
[1] Public Law No. 119-21, One Big Beautiful Bill Act, H.R. 1, 119th Congress, House, 2025, https://www.congress.gov/bill/119th-congress/house-bill/1.
[2] Deborah Collier and Tom Schatz, “The Race to 5G: Protecting Taxpayers through Spectrum Auctions,” Citizens Against Government Waste (CAGW), 2019, https://www.cagw.org/race-to-5g/.
[3] Rachel Jewett, “C-Band Auction Sets Record, Grossing $81B in Phase One,” Via Satellite, January 19, 2021, https://www.satellitetoday.com/government-military/2021/01/19/c-band-auction-sets-record-grossing-81m-in-phase-one/.
[4] SatNow, “What is Fixed Satellite Service (FSS)?” February 12, 2025,https://www.satnow.com/community/what-is-fixed-satellite-service-fss; Government of Canada, “Overview of the Fixed Service,” January 30, 2025, https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/licences-and-certificates/fixed-service.