NAB is warning the FCC that another major repurposing of satellite spectrum could disrupt the behind-the-scenes infrastructure many radio stations rely on to receive network programming and other audio feeds. In comments in the FCC’s upper C-band proceeding, NAB urges the commission to auction only the minimum amount required by statute and to build strong protections so broadcasters are not forced into service interruptions or large, unfunded equipment changes.
Under federal law, the FCC must auction at least 100 MHz of upper C-band spectrum in the 3.98–4.08 GHz range by July 2027. The FCC has floated a larger auction that could reach 180 MHz, extending to 4.16 GHz, and wireless interests have pushed for even more. NAB’s filing argues that upper C-band is a core resource for satellite program contribution and distribution used by broadcasters, and that its importance has increased since the lower C-band transition earlier this decade.
NAB says the FCC should cap any auction at the required 100 MHz to reduce the risk of “material disruption” to broadcast services. If the FCC proceeds beyond that amount, NAB argues the transition should not be financed by broadcasters. Instead, it says costs should be borne by auction winners, reflecting the idea that those who benefit from new spectrum access should pay for the changes imposed on incumbent users.
The group also presses for more predictable, faster reimbursement mechanics. In the previous lower C-band transition, many broadcaster earth stations needed filtering, repointing, and modest equipment upgrades, and the process included standardized reimbursement assumptions. NAB cites reports from users who experienced long reimbursement delays, and it asks for a system that avoids leaving incumbents out of pocket for extended periods, including the possibility of significant upfront funding.
NAB argues that a forced move of broadcast services out of C-band entirely, such as into Ku-band, would be far more expensive and operationally complicated than a tighter repack within C-band. It says a C-band earth station required to shift to Ku-band might need construction of a second earth station to maintain dual illumination during transition, and it estimates such relocation costs could exceed $400,000 in some cases.
The filing also flags adjacent-band interference risk to radio altimeters, which operate at 4.2–4.4 GHz. NAB argues that limiting terrestrial operations to below 4.080 GHz by auctioning only 100 MHz would reduce interference risk and could lower the need for altimeter replacements. Overall, NAB’s message is that the FCC should treat broadcast satellite distribution as critical infrastructure, with a deliberate timeline, enforceable protections, and a cost model that does not shift the burden onto local stations.