About the RPC

Relocation Payment Clearinghouse LLC (“RPC LLC”) is the Relocation Payment Clearinghouse that administers the cost-related aspects of the transition of licensees in the 3.7-4.2 GHz band (C-band) mandated by the Federal Communications Commission (“FCC”). RPC LLC has contracted with CohnReznick LLP, one of the nation’s largest certified public accounting firms; Squire Patton Boggs (US) LLP, a global law firm; Intellicom Technologies, Inc., experts in satellite and communications; and Reed Strategy LLC, experts on cable and broadband technologies, to perform the duties of the RPC. Among its duties, the RPC collects and distributes payments for the C-band transition, administers the reimbursement fund, reviews claims for reimbursement of relocation costs, mitigates financial disputes among stakeholders, and administers the alternative dispute resolution process. RPC LLC uses information it receives solely for the purposes of administering the cost-related aspects of the C-band transition and may disclose such information to the FCC or other authorized parties pursuant to the requirements of the FCC’s 3.7 GHz Report and Order or other applicable laws.
To select the RPC, the FCC appointed a search committee composed of nine entities that the FCC found, collectively, reasonably represented the interests of stakeholders in the transition. On July 31, 2020, the search committee announced that it had unanimously selected CohnReznick LLP and subcontractors Squire Patton Boggs (US) LLP and Intellicom Technologies, Inc. (together, the CohnReznick Team) to serve as the RPC. On October 22, 2020, the FCC’s Wireless Telecommunications Bureau confirmed the search committee’s selection of the CohnReznick Team to serve as the RPC.

The C-band is a 500 megahertz (“MHz”) segment of spectrum from 3.7 to 4.2 gigahertz (“GHz”), which is now mostly used by fixed satellite companies to provide content to video and audio broadcasters, cable systems, and other content distributors. The FCC is requiring that incumbent licensees within the C-band clear existing services from the lower 300 MHz of the C-band (3.7–4.0 GHz), making it available for flexible use for wireless services. Existing satellite operations will be repacked and move into the upper 200 MHz of the band (4.0–4.2 GHz). Incumbent space station operators, incumbent earth station operators, and incumbent Fixed Service licensees will transition out of the 3.7–4.0 GHz band and will be reimbursed for their reasonable relocation costs.

Overlay licensees, which are the winning bidders in Auction 107, are responsible for funding C-band relocation expenses, as well as accelerated relocation payments, based on their winning share of bids in Auction 107. The RPC will calculate the pro rata share due from each overlay licensee and invoice and collect in a timely manner throughout the program to ensure adequate funding is available to reimburse reasonable relocation expenses incurred by incumbent space station operators, incumbent earth station operators, and eligible surrogates, as well as the costs of the RPC.

The RPC is responsible for collecting and reviewing relocation costs from eligible incumbent space station operators, incumbent earth station operators, and surrogates to determine whether the costs are reasonable and necessary for C-band relocation.

Claims Reimbursement Payments The RPC will distribute reimbursements to eligible incumbents after approving a claim.

Lump Sum Payments Instead of reimbursement for the reasonable relocation costs, an earth station operator may elect to accept a lump sum payment. The FCC-established deadline for submitting a lump sum election was September 14, 2020. The RPC is responsible for providing these lump sum payments to eligible earth station operators whose lump sum elections were accepted by the FCC.

Accelerated Relocation (Incentive) Payments To ensure speedy transition into the upper 200 MHz of the C-band, the FCC’s Report and Order (“R&O”) provides for accelerated relocation payments for incumbent space station operators that voluntarily relocate on an accelerated schedule and clear the lower 300 MHz of the C-band by the Accelerated Relocation Deadlines. The RPC is responsible for distributing accelerated relocation payments to eligible space station operators after FCC validation that accelerated clearing timelines have been met.

The RPC has established a dispute resolution process consistent with the FCC’s R&O and rules to resolve any disputes regarding costs and payments that arise in the course of band reconfiguration. The process provides fairness, transparency, flexibility, and due process. The dispute resolution process is designed to resolve disputes, as well as avoid disruption to program stakeholders and delays to the program.

The RPC will publish quarterly reports containing relevant C-band program information and progress, such as:

  • Status of reimbursement funds available for obligation;
  • Overlay licensee billings and collections;
  • Relocation costs reimbursed;
  • Certifications filed by incumbents;
  • Accelerated relocation payments distributed;
  • Disputes in-process and resolved; and
  • RPC fees and expenses.

As part of its Enterprise Risk Management framework, the RPC will design and implement internal controls adequate to ensure its operations maintain best practices to protect against improper payments and to prevent fraud, waste, and abuse in its handling of funds. The RPC’s internal controls processes will ensure that the written procedures, prepared using the Government Accountability Office’s Green Book as guidance, are followed as prescribed. The RPC will undergo an annual external audit of C-band collections and disbursements, including its own fees and expenses. The RPC will also engage an external auditor to conduct annual assessments of systems and controls to ensure comprehensive privacy and information security measures are utilized.

Questions?

If you have questions regarding the C-band Relocation program, contact the RPC