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OTI and Public Knowledge submitted joint comments urging the Federal Communications Commission to propose changes that make all of the Upper C-band (3.98-4.2 GHz) available for more intensive licensed and shared use. The Commission can achieve this through a combination of consolidating Fixed Satellite Service (FSS) incumbents—enabling a new flexible use allocation in the lower portion of the band—and by authorizing shared use by mobile satellite services in the upper portion of the band to the greatest extent feasible.

They emphasize these proposals;

• While a reallocation and auction of at least 100 megahertz is required by law, the Commission has the discretion to protect the tens of millions of American households that continue to rely on FSS in the Upper C-band for high-quality video programming and other content to local broadcast stations, cable headends, and radio stations.
• While unique circumstances may have justified mandatory “acceleration payments” to satellite incumbents six years ago, these justifications are either nonexistent or unpersuasive today.
• If the Commission decides to auction more than 100 megahertz, this additional sub-band should be auctioned at the county level in 10 megahertz blocks and at the same lower power level that characterizes Priority Access Licenses (PALs) in the Citizens Broadband Radio Service (CBRS).
• The Commission should determine the extent to which additional satellite service—and in particular direct-to-device mobile satellite service—can coexist and share the top portion of the band that is not auctioned for terrestrial mobile services.

Along with other groups, OTI also submitted comments in support of a concurrent Tribal Licensing Window (TLW) as part of the Commission's reorganization and auction of the Upper C-Band.

They share these reasons as to why:

• Tribal spectrum windows deliver concrete and durable public-interest benefits—and the Upper C-Band is uniquely positioned to extend those benefits.
• A concurrent TLW is fully compatible with the Commission’s statutory auction obligations and operational timelines.
• A TLW would not meaningfully affect auction inventory or bidder value.
• The absence of a Tribal Licensing Window in the Lower C-Band auction does not constitute a precedent for declining to adopt one here.