The FCC Moves to Replace Part 25 and Clear 160 MHz of Upper C-Band — and Rewrites the Rules Every Operator Files Under
A draft order released 1 July 2026 and set for an FCC vote on 22 July would swap the Part 25 satellite-licensing regime for a new Part 100 'assembly line,' and auction 160 MHz of upper C-band at 3.98–4.14 GHz. The proceeding rewrites the filing rules and reallocates the band SES uses for U.S. distribution.
What happened
On 1 July 2026 the FCC released a draft order, teed up for a vote at its 22 July open meeting, that would replace the long-standing Part 25 space and Earth-station rules with a new Part 100 — described by Chairman Carr as moving 'from bespoke reviews to a consistent, predictable, and objective assembly line.' The rewrite revises processing rounds, license terms, surety-bond requirements, public-notice windows, and the scope of minor modifications operators can make without prior authorization, and adds space-situational-awareness data-sharing obligations.
The same July agenda carries a second order to auction 160 MHz of upper C-band at 3.98–4.14 GHz — spectrum SES uses for U.S. television and content distribution. Paired with the earlier C-band clearing, the FCC frames the result as a 440 MHz 'super band' of mid-band spectrum, with incentive payments for satellite operators and an auction targeted for 2027. The draft rejects requests from SpaceX, SES, and QQ Technology to carve out portions for satellite direct-to-device use.
Why it matters for dispute formation
A licensing-regime rewrite is the deepest kind of spectrum signal: it changes the rules under which every future filing, modification, and dispute is judged. Processing rounds decide who competes against whom; surety bonds and license terms decide who forfeits and when; the line between a minor modification and a new authorization decides what an operator can do without opening a fresh proceeding. When the framework itself moves, the record that governs a decade of disputes is reset in a single order.
The upper C-band clearing layers a valuation and transition fight on top. A second reallocation of the band SES relies on raises the same questions the first C-band clearing did — who controls the rights, how incentive payments are structured, how transition costs are borne — but now inside a consolidated SES/Intelsat balance sheet and against a refused D2D carve-out. For spectrum and regulatory teams, the work is to read the draft against current authorizations, model the clearing's effect on band value and service continuity, and track how the Part 100 transition treats pending filings and existing license conditions.
Who's exposed
Exposed as the operator whose 3.98–4.14 GHz upper C-band supports U.S. content distribution and now faces a second clearing; the value of the band, the transition mechanics, and any incentive payments turn on the order's terms.
Exposed as the primary users of the licensing regime the Part 100 rewrite reshapes — processing rounds, license terms, surety bonds, and modification rules that govern how constellations are authorized and updated.
Exposed as operators whose requests to reserve upper C-band for satellite direct-to-device operations the draft rejects; the refusal fixes the band as terrestrial and sets the coordination baseline.
Exposed as the downstream users of C-band content distribution and the prospective winners of a 'super band' of cleared mid-band spectrum, with transition timing and cost allocation to be set by the order.
The historical parallel · First FCC C-band reallocation & accelerated-clearing payments (2020)
The FCC's first C-band clearing for 5G turned on multibillion-dollar accelerated-relocation payments, and Intelsat and SES fought over how to split them — a dispute that ran through Intelsat's bankruptcy. It established that a satellite operator's value can sit in its spectrum and slot rights as much as its fleet, and that clearing terms are intensely contestable. A second upper C-band clearing runs the same playbook, now against a merged SES/Intelsat and a licensing regime being rewritten underneath it.
What to watch
- Whether the 22 July vote adopts Part 100 as drafted and how pending Part 25 applications transition to the new regime.
- The upper C-band clearing structure — incentive-payment terms for SES and others, transition timeline, and the 2027 auction rules.
- How the rejected direct-to-device carve-out requests (SpaceX, SES, QQ Technology) resurface in later proceedings.
- Surety-bond, license-term, and minor-modification changes and their effect on how constellations are authorized and updated.
Sources
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Get the Intelligence BriefFor general information only; not legal advice, and no attorney–client relationship is formed through this article. Company names appear because the companies are exposed to a public development — not as a statement of wrongdoing or a predicted outcome. Figures are as reported by the linked sources.