Dossier · informs positioning threads

US C-band spectrum & clearing economics

Revised 2026-08-24105 tracked data points7 open questions

Thesis

The upper C-band proceeding is primarily a balance-sheet event for SES (clearing costs vs incentive-payment proceeds vs transponder capacity loss), and only secondarily a D2D fight.

The CVR mechanic from the Intelsat acquisition sharpens this: SES splits net proceeds from the first 100 MHz 57.5/42.5 with legacy Intelsat shareholders but keeps 100% of anything cleared above 100 MHz — a pure incentive-capture logic would push SES to maximize clearing (every extra MHz above 100 is fully SES's), yet SES capped its own ask at 160 MHz, not 180. That gap is the real tell: capacity preservation outweighs even 100%-owned incremental incentive revenue past some threshold.

Falsifier trackerwhat would prove this wrong — and whether it has

Settled
(a) SES publicly advocating a larger clearing block, or accepting one without escalating compensation demands
FCC 26-46 was adopted 2026-07-22 at exactly 160 MHz (SES's own ask), published in the Federal Register 2026-07-31 and effective 2026-09-29 — the clearing amount is now fixed by the adopted order, and the FCC's own cost-benefit text rejected the higher-surplus 180 MHz option specifically to preserve one C-band transponder, confirming the capacity-preservation logic and concluding the proceeding in the thesis's favor; SES has filed no protest and advocating a larger block would cut against its own capacity interest

STATE OF PLAY

As of 2026-08-24, FCC 26-46 stands adopted and unprotested, 6 days from the Section 316 window closing

(2026-08-30) — re-checked this run, no protest and no new SES/SpaceX/OQ Technology filing in GN 25-59/18-122 since 07-14 (tracked series). SES's Transition Plan remains unfiled, against FCC 26-46's own firm November 5, 2026 deadline (open question 2).

A possible SES link to Intuitive Machines' $600M GEO order surfaced but stays unconfirmed

— 3 satellites, 30-month build, still-undisclosed customer, built via Lanteris (formerly Maxar, SES's prior C-band clearing vendor); a named analyst floated SES, unconfirmed by either party (tracked series).

The Clearinghouse selection remains the next active regulatory process, unchanged since 08-17

— the nine-member committee (incl. SES, Eutelsat) must convene by ~2026-09-29, name a clearinghouse by 2026-12-15 (structural dynamics); Summit Ridge Group's white paper and SES's own 25-157 ex parte both still 403-block on direct fetch. Auction 115's procedures comment period closed today, reply due 09-08; whether SpaceX bids stays contested (Entner yes, Farrar no, unchanged since 08-10 — open question 5).

Eutelsat and Telesat's posture is unchanged since 08-13

: both remain non-committal on new satellite orders even as Telesat's CEO gave the proceeding's first active clearing-plan statement; DISTRESS detail lives in dossiers/industry-consolidation.

STRUCTURAL DYNAMICS

Round-1 incentives dwarfed actual clearing costs. C-band 1.0's $9.7B incentive pool vastly exceeded SES+Intelsat's ~$1.6B clearing spend (tracked series) — a net-positive transfer, not cost reimbursement; SES's cost disclosures read as a negotiating floor, not an expected net outflow.
SES forwent CVR-favored upside to protect capacity. SES's Intelsat-acquisition CVR splits the first 100 MHz cleared 57.5% SES/42.5% legacy Intelsat shareholders but gives SES 100% above 100 MHz (tracked series); SES nonetheless capped its own ask at 160 MHz, not 180, per its 20-MHz-transponder rationale. FCC 26-46's full text confirms this in the FCC's own words: 180 MHz would have yielded higher surplus, yet the Commission rejected it to preserve "at least one transponder" (para. 29-31) — the clearest primary-text confirmation of the thesis to date.
FCC allocation and CVR split are separate axes. The FCC's 89/8/3% SES/Eutelsat/Telesat allocation and the CVR's 57.5/42.5/100% MHz-tranche split are different mechanisms (tracked series): the FCC divides its $6.3B pool by spectrum-encumbrance value, the CVR separately redistributes part of SES's share to legacy Intelsat shareholders. Nothing in FCC 26-46 maps one onto the other (open question 1).
Cost-per-MHz gap traces to new satellite builds, not markup. Round 2's cost implies roughly 4x round 1's realized per-MHz cost while the incentive per-MHz rate held roughly stable (tracked series): SES's cost ex parte shows satellite procurement is ~70% of the ~$3.75B total, and round 1 never required comparable satellite construction.
Winning bidders underwrite three separate, stacked cost streams. FCC 26-46 (paras. 114-140, tracked series) separates clearing-cost reimbursement (via the Upper C-band Clearinghouse) from the $6.3B incentive pool — the $4.0-5.0B aggregate cost estimate is drawn from SES's and Eutelsat's own ex parte filings, not an independent cross-check on SES's net capture (see superseded). A third stream, the radio altimeter retrofit rebate program (paras. 177-182), is funded the same way but not yet dollarized (draft categories due 2026-10-06) — all three streams are paid by Upper C-band auction winners, none by SES.
FCC and SES satellite-cost benchmarks diverge sharply. The FCC independently finds a 9-satellite build (SES up to 7, Eutelsat 2, Telesat 0) matching SES's own count, but at ~$203M/satellite vs. the ~$374M/satellite SES's own filing implies (tracked series) — the single most consequential open cost question (open question 2): reimbursement nearer the FCC benchmark risks a real ~$1.2B shortfall, resolved only once Teltrium's Cost Catalog and SES's now-dated (Nov 5) Transition Plan land. FCC 26-49 confirms a formal appeal path if it does (47 CFR § 27.1421(c)(2)-(3): Media Bureau review, then de novo ALJ review).
Cleared spectrum directly costs transponder capacity. Each MHz cleared is capacity SES/Intelsat lose for existing GEO video/data customers — SES's own 20 MHz/transponder threshold is the quantified mechanism behind the 160 MHz cap.
SpaceX's C-band ask fits a broader D2D strategy. SpaceX's C-band D2D ask stacks onto its separate EchoStar spectrum acquisitions (tracked series) — read-across to the EU COM(2026)311 contest. SES's own bundled inclusion in the same deferral clause is a distinct capacity ask, not a D2D pivot; the deferral survived unchanged into the adopted order.
Eutelsat's and Telesat's incentive shares are confirmed. Per the FCC's allocation table (tracked series): Eutelsat 8%/$504M, Telesat 3%/$189M vs. SES's 89%/$5.607B, over both operators' own proposed methodologies. Telesat's posture graduated from non-participation to active on its 08-13 earnings call, still without a new-satellite order. DISTRESS detail: dossiers/industry-consolidation.
FCC-26-47 preserves key GSO incumbent protections. The same meeting that constrained SES's C-band footprint also adopted FCC-26-47 (see superseded) — GSO-protective on the two questions most relevant to SES's fleet: it declined to narrow two-degree GSO spacing to US-facing operations only, and extended the default license term to 20 years. Renewal implications remain open in the FNPRM (open question 4).
Auction 115 proceeds dwarf the incentive pool. The sale of the 3,248 cleared licenses is analyst-estimated (TD Cowen, unverified; tracked series) at $30B-$75B, potentially 5-12x the $6.3B incentive pool — reframing, without reversing, the thesis: SES's cap at 160 rather than 180 MHz looks like a smaller sacrifice once the auction scale is visible.
The Clearinghouse selection process gives SES a direct seat. A nine-member committee (SES, Eutelsat, CTIA x2, CCA, NAB, NCTA, plus two aviation seats for the altimeter side) must convene by ~2026-09-29 and name the clearinghouse by 2026-12-15 (tracked series) — the FCC declined Summit Ridge's and SES's own bid for ongoing committee oversight of the clearinghouse, opting instead for 6-month stakeholder briefings.

POLITICAL & REGULATORY

Protest risk on FCC 26-46 remains narrow, window closing in days. The adopted order (2-1, Gomez dissenting only on tribal licensing) also resolved round-1's outstanding reconsideration petitions (tracked series) — round-1 litigation risk is closed. The Section 316 window closes 2026-08-30 with no protest filed through the latest pull; SES got its own requested terms, leaving little reason to protest.
Teltrium's ex parte exemption closes cost visibility, but not all of it. DA 26-783 keeps Teltrium's own vendor/stakeholder meetings ex parte-exempt until its Cost Catalog draft publishes (~2027-01-24); it doesn't bar public party filings, and Summit Ridge Group's 08-17 filing — the docket's first outside-party activity since adoption — is the exemption's first visible crack, not a breach of it (tracked series).
The FCC keeps building its own numbers. FCC 26-46 discarded both SES's and Eutelsat's submitted allocation methodologies (including a Eutelsat-commissioned Analysys Mason report) for a Commission-designed formula; DA 26-783 does the same on cost by hiring Teltrium. Relevant precedent for the 2 GHz MSS thread: a regulator dividing a fixed pool designs its own formula rather than deferring to operator-commissioned work.
FCC discretion operated only above the statutory floor. Congress set the floor (OBBBA, ≥100 MHz by July 2027) — the auction happens regardless of the incumbent-clearing fight; FCC discretion operated only on the margin above it and on compensation structure. The FCC's own cost-benefit text confirms it stopped exactly at SES's requested 160 MHz ceiling despite a higher-surplus 180 MHz alternative (structural dynamics).
Two separate SES dockets should not be conflated. Docket 25-157 (GSO reference-links/EPFD, SES filed again 08-14) runs on its own FR-set schedule independent of the July 22 meeting, distinct from SB Docket 25-306 (FCC-26-47's Part 100 rulemaking). Neither record shows SES filing on the narrow two-degree-spacing sub-question decided at FCC-26-47 para. 280.
Consumer groups backed D2D despite the FCC's deferral. Open Technology Institute and Public Knowledge publicly backed SpaceX's D2D carve-out request — the FCC declined regardless, and the deferral held through adoption; the first non-industry voice on record in this fight.
Auction 115's comment cycle is a separate political venue. Its own comment cycle (procedures due 2026-08-24/reply 09-08) asks how licenses get auctioned, distinct from FCC 26-46's closing protest window (was the clearing order lawful). SES has no direct stake (not an eligible bidder), but the auction's completion deadline is read-across context for how fast new licensees deploy against SES's cleared spectrum.
Space Bureau leadership change remains a watch item. Jennifer Gilsenan has been acting Space Bureau chief since 08-07 with no successor yet named to Jay Schwarz — a process-continuity item for the bureau reviewing SES's now Nov-5-dated Transition Plan.

IMPLICATIONS FOR SES

Thread: "US C-band spectrum reallocation" (priors.md). Balance-sheet relevance to SES now rivals IRIS². SES's confirmed gross incentive allocation is $5.607B, issuer-confirmed (tracked series); applying the CVR split proportionally by MHz (illustrative, not confirmed — open question 1) yields ≈$4.12B net before tax, ≈$3.7B illustrative-on-illustrative after the ~10% analyst-consensus tax rate SES has not itself guided. That net figure survives SES's own clearing cost because reimbursement and incentive payment are legally separate (structural dynamics); the remaining downside is a possible ~$1.2B uncompensated shortfall if Teltrium reimburses nearer the FCC's per-satellite benchmark than SES's own filed figure (open question 2). SES has already committed ~$1.6B toward satellite procurement, at risk only if under-reimbursed.

November 5, 2026 is now SES's nearest concrete action item: FCC 26-46's Transition Plan deadline (tracked series) forces the cost/scope detail this dossier's reconciliation gaps depend on. SES also holds one of nine seats on the Clearinghouse selection committee (structural dynamics) — direct process influence over the body that will certify its own reimbursement, though the FCC declined to make that oversight ongoing. Capital allocation is unchanged (≤3.0x net-debt/EBITDA policy, no M&A on the roadmap); FCC-26-47's retained GSO spacing rule and 20-year license term (structural dynamics) remain a modest offsetting positive for the legacy fleet. Auction 115 is not an SES cash event, but its $30B-$75B estimated proceeds (tracked series) underscore SES negotiated over a small slice of a much larger pie.

ANALYTIC STANCE

Trust hierarchy, established across runs:

Full primary-order text, directly read — the only reliable source for a long order's directional characterization, not just headline terms. On 07-30, FCC-26-47 read as "NGSO-favoring" from secondary press was wrong; primary text is GSO-protective on the two questions that matter to SES (see superseded).
5+-outlet convergent secondary quotation — reliable for occurrence and headline terms but not framing/thrust. Draft terms (07-05/07-11) and adopted-vote terms (07-23) both held up against later primary text.
Mirrored ECFS filing metadata over press claims about "who asked for what" — SES's titled filings (no D2D label) proved more reliable than press naming SES alongside SpaceX/OQ Technology in a bundled deferral clause.
WebSearch's synthesized-answer layer has twice produced a plausible but unverifiable figure (an Eutelsat/Telesat split, 07-17; an "Empresa"/"Hispasat" claim, 07-23) — neither was logged; treat synthesis as a lead only.

Farrar (tmfassociates.com) is now an engaged analyst voice, not just a dollar-total cross-validator (08-10, disconfirming on open question 5) — apply the same single-source caution given to Entner. docs.fcc.gov is reachable via the source mirror's fcc-docs scanner (sources/latest/fcc-docs/, populated since ~07-27) — check that path before treating docs.fcc.gov as blocked (503/timeout-blocked live fetch 07-05 through 07-23). CAVEAT 2026-08-24: mss-2ghz-spectrum's per-filing files.fcc.gov download-link workaround for a blocked ECFS filing does NOT generalize here — it works only via the single-ID ECFS lookup (needs an API key this environment lacks); the bulk q=SES search this dossier's mirror uses returns www.fcc.gov viewer links only, still genuinely blocked (SES's 25-157 ex parte, Summit Ridge's 25-59 paper).

Blind spots closed to date: full fcc-docs-index.json re-scans against scope keywords (not just already-cited documents) is standing practice — Auction 115 sat mirrored two weeks before this dossier opened it (08-07), missed on its AU-prefix docket type reading as boilerplate. Citing around a primary-text section is not the same as reading it — this dossier's own ~$3.5B reimbursement-vs-incentive self-reversal (08-04; superseded) came from citing FCC 26-46's incentive paragraphs for a week before reading the adjacent reimbursement section; read sections adjacent to a cited paragraph before cross-section arithmetic. An ECFS filing title alone doesn't identify which of a filer's like-named filings it is (08-08) — check body text or a primary press release. Most consequential self-catch: the 07-11 correction of priors.md's and four straight daily briefs' wrong "adopted July 1" claim (still a draft) — this dossier's own framing was correct throughout, worth naming since catching itself is a stronger signal than only ever finding others wrong.

Genuine uncertainty is now concentrated in two narrow, technical questions gated behind future events this dossier has no visibility into yet — the CVR-to-FCC-allocation mapping (open question 1, gated behind 2030/2031 disbursement) and how much of SES's satellite cost survives Teltrium's Cost Catalog review (open question 2, gated behind ~2027-01-24 finalization) — plus two demand-side questions (open questions 5 and 6) gated behind FCC Form 175 filings and the auction-comment cycle, not further reading of text already in hand.

OPEN QUESTIONS

1
How does the CVR's 57.5%/42.5% (first 100 MHz)/100% (remaining 60 MHz) split map onto the FCC's confirmed $5.607B SES allocation? FCC 26-46 allocates by operator and deadline, never by MHz tranche (structural dynamics); this dossier's own proportional estimate (≈$4.12B net, implications for SES) stays illustrative, not confirmed.
Resolves whenSES's own SEC/IR disclosure of the CVR payout, or any SEC filing quantifying it.
2
How much of SES's ~$2.62B satellite-cost line will Teltrium's Cost Catalog certify as reimbursable, given the FCC's own ~$203M/satellite benchmark runs roughly half of SES's implied ~$374M (structural dynamics) — a possible ~$1.2B shortfall?
Resolves whenSES's Transition Plan (due 2026-11-05); the Cost Catalog (due ~2027-01-24); Eutelsat/Telesat's own cost disclosures.
3
Will a Section 316 protest against FCC 26-46 be filed before the 2026-08-30 window closes? None filed as of the latest pull (tracked series), 6 days out; SES got its own requested terms, so standing to protest is unclear.
Resolves whenany Section 316 protest in GN 25-59/18-122 before 2026-08-30.
4
What renewal/replacement-expectancy rules will the FCC adopt for GSO stations under FCC-26-47's still-open FNPRM — processing-round status exchange, a 1-year "use it or lose it" proposal, multi-satellite- per-license renewal implications — bearing directly on SES's legacy GEO fleet at its now-20-year license term?
Resolves whenthe FNPRM comment cycle and eventual Order in SB Docket 25-306.
5
Is Entner's (Recon Analytics) claim that SpaceX will bid Auction 115 real evidence of intent, or single-analyst speculation? Farrar disconfirms (08-10, favoring EchoStar's CBRS spectrum instead); no primary SpaceX signal either way, and no new post from either analyst since.
Resolves whenany SpaceX FCC Form 175 filing in AU Docket 26-191.
6
Will Auction 115 complete by its statutory 2027-07-04 deadline, given bidding starts only 2027-04-27 — roughly ten weeks for a 3,248-license auction? OBBBA is silent on remedy for a missed deadline.
Resolves whenthe AU Docket 26-191 comment record (procedures closed 08-24, reply 09-08); any FCC contingency statement.
7
Is SES the undisclosed customer behind Intuitive Machines' $600M, 3-satellite GEO order (tracked series) — built via Lanteris (formerly Maxar), SES's prior C-band clearing vendor? A real lead (CEO declined to confirm/deny a C-band link), not yet a fact; if confirmed it's direct evidence toward SES's own disclosed satellite count (structural dynamics).
Resolves whenan SES or Intuitive Machines statement, or an FCC filing, naming the customer.

Tracked series

Complete append-only series — 105 readings, 3 Mar 2020 → 7 Aug 2026. Rows never change once added; the time series is the evidence base. Each row number is a permanent link — click it to copy a link straight to that reading.

#	Date	Metric	Value	Source
1	2026-06-18	SES ex parte ask	cap clearing at 160 MHz	brief 2026-07-04
2	2026-07-01	FCC draft order	160 MHz clearing (reported, unconfirmed)	brief 2026-07-04
3	n/a	SES+Intelsat clearing cost estimate	~$3.6B	brief 2026-07-04
4	2026-07-22	FCC Open Meeting vote	scheduled	brief 2026-07-04
5	2020-03-03	C-band 1.0 total incentive payments, 300 MHz, 5 operators (Intelsat/SES/Telesat/Eutelsat/Star One)	$9.7B total ⇒ $32.3M/MHz	WebSearch (Via Satellite/satellitetoday retrospective), 2026-07-05
6	2020-2023	C-band 1.0 SES+Intelsat realized clearing/relocation cost, 300 MHz	~$1.6B combined ⇒ $5.33M/MHz	WebSearch (satellitetoday), 2026-07-05 — NOTE: distinct from the $9.7B incentive-payment figure above; cost vs. payment are different numbers
7	n/a	Intelsat 2020-2023 accelerated relocation payments received	$4.87B ($1.20B Dec 2021 + $3.67B Dec 2023)	WebSearch (Inside Towers/SpaceNews), 2026-07-05
8	n/a	Round 2 CVR split, first 100 MHz tranche	42.5% legacy Intelsat shareholders / 57.5% SES	PRIMARYWebSearch (ses.com IR FAQ, advanced-television, satnews), 2026-07-05 — SECONDARY, not yet cross-checked against primary CVR agreement text
9	n/a	Round 2 remaining 60 MHz (160 total − 100 CVR tranche)	100% to SES	same sources
10	n/a	Round 2 first-100MHz total incentive pool, back-solved from reported "$1.3B = 42.5%" floor	≈$3.06B ⇒ ~$30.6M/MHz	derived (this dossier), 2026-07-05 — arithmetic: $1.3B / 0.425
11	2026-07-01	Draft order structure	143pp combined R&O + Order of Proposed Modification + Order on Reconsideration	WebSearch (lightreading/tlp.law), 2026-07-05
12	2026-07-01	Draft service-start dates	top-75 markets Dec 2030; remaining markets Jul 2031	WebSearch (lightreading), 2026-07-05 — draft-stage, not adopted
13	n/a	Statutory clearing floor	≥100 MHz by July 2027 (One Big Beautiful Bill Act)	WebSearch (lightreading/broadbandbreakfast), 2026-07-05
14	~2026-07-03/05	Draft order D2D/advanced-satellite-ops deferral, named requesters	SpaceX + OQ Technology confirmed; SES named by 2 outlets (Techtimes, Light Reading/Baumgartner) but absent from primary ECFS filing titles	PRIMARYWebSearch (lightreading, techtimes), 2026-07-05 — press convergence upgraded from 1 to 2 named-byline outlets; still not primary-confirmed
15	n/a	SpaceX EchoStar spectrum acquisitions (adjacent, not C-band)	AWS-4 + H-block $17B; AWS-3 $2.6B in stock	WebSearch (EchoStar IR, DCD, govconwire), 2026-07-05
16	2026-07-05 (ECFS pull)	SES filings in GN Docket 25-59, all-time	95 filings, 0 D2D-titled; filing types: NOTICE OF EXPARTE (cost/reimbursement/allocation/service-quality), COMMENT, REPLY TO COMMENTS	PRIMARYsources/latest/fcc-ecfs-cband-ses.json (PRIMARY, mirrored 2026-07-05T07:19:45Z)
17	2026-07-05 (ECFS pull)	OQ Technology filings in GN Docket 25-59, all-time	2 filings (COMMENT, 2026-01-05 and 2026-02-04); no ex parte	PRIMARYsources/latest/fcc-ecfs-oq-technology.json (PRIMARY, mirrored 2026-07-05T07:19:45Z)
18	2026-07-11 (ECFS pull)	SES/SpaceX/OQ Technology filings in GN 25-59, all-time	no new filings since 2026-06-22 (SES) across any of the three mirrored queries	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-07-11T06:26:07Z)
19	n/a	July 1 release status, reconfirmed	DRAFT Report and Order; formal Commission vote at July 22 Open Meeting — NOT adopted as of 2026-07-11	WebSearch (Davis Wright Tremaine, Light Reading, Advanced Television, broadbandbreakfast, TLP Law — convergent), 2026-07-11 — corrects "adopted July 1" framing that appears in priors.md and daily briefs 07-08 through 07-11
20	n/a	FCC disclosure practice	Commission will not release specific incentive/cost/rebate dollar figures until the July 22 vote itself	WebSearch (ad-hoc-news.de summary of FCC release), 2026-07-11
21	n/a	CVR terms, primary text located	42.5% Intelsat legacy shareholders / 57.5% SES of net proceeds from monetizing up to 100 MHz C-band downlink (3.98–4.2 GHz); CVRs terminate at earlier of full monetization or 7yr6mo post-closing	PRIMARYWebSearch locating SEC Form 424B3/F-4A text, sec.gov/Archives/edgar/data/1347408/ (direct fetch 403-blocked; snippet quotes contract language directly), 2026-07-11 — upgrades this figure from SECONDARY to PRIMARY-confirmed
22	n/a	SES technical rationale for 160 vs 180 MHz cap	clearing full 180 MHz leaves only 20 MHz C-band downlink — insufficient for a standard C-band transponder; degrades service to media/live-sports customers	WebSearch (advanced-television, broadbandbreakfast), 2026-07-11
23	n/a	SES self-disclosed clearing timeline	first 100 MHz clearable within 30 months given adequate incentives; additional 60 MHz requires +60 months (new hybrid satellites)	WebSearch (broadbandbreakfast), 2026-07-11
24	n/a	Eutelsat/Telesat named eligible incentive recipients	FCC draft names Eutelsat, SES, and Telesat as "eligible space station operators" for C-band cost reimbursement/incentive	WebSearch (ad-hoc-news.de citing FCC draft order), 2026-07-11
25	n/a	Eutelsat's own disclosed North America C-band clearing cost estimate	~$750M	WebSearch (ad-hoc-news.de), 2026-07-11
26	n/a	Farrar (tmfassociates.com) independent incentive estimate	~$5B to SES/Intelsat combined; ~$6B total across all eligible operators	WebSearch (search-indexed X commentary; direct blog fetch 403-blocked, no new dated post since 2026-06-29), 2026-07-11 — cross-validates this dossier's derived ≈$4.86B SES+Intelsat estimate (see IMPLICATIONS FOR SES)
27	2026-06-18 (ex parte, now readable)	SES cost ex parte, full line-item breakdown	Satellites (5 new hybrid Ku-band + 2 in-orbit backup, incl. procurement/launch/insurance/ground equip) $2.62B + terrestrial IRD/rain-fade network $777M + earth-station retrofits $93M + TT&C/uplink antennas $45M + program management $62M + contingency $150M ≈ $3.75B total	PRIMARYWebSearch (SatNews direct fetch, cross-confirmed via Light Reading and Communications Daily search-indexed snippets), 2026-07-17 — resolves OPEN Q3: satellite capex is ~70% of the total and is the primary driver of round 2's ~$22.5M/MHz vs round 1's ~$5.33M/MHz
28	n/a	SES capital already earmarked toward satellite procurement/US vendor contracts, ahead of the July 22 vote	~$1.6B	WebSearch (Light Reading), 2026-07-17
29	2026-07-15	FCC Sunshine Notice for the July 22 Open Meeting released	confirmed	WebSearch (multiple convergent sources), 2026-07-17 — corrects this dossier's and priors.md's "pre-Sunshine window closes ~July 17" framing; the ex parte-restricted quiet period for Sunshine-agenda items began 2026-07-15
30	2026-07-10 / 2026-07-14	SES FCC filings, existence/metadata only	Notice of Ex Parte (GN 25-59, meeting held 07-10) + Reply Comments (docket 25-157, GSO reference-links/EPFD implementation); substance unread	PRIMARYsources/latest/fcc-ecfs-cband-ses.json (PRIMARY, mirrored 2026-07-16); id_submission 26110015274 / 26110015888 — this run confirms docket 25-157 runs on its own FR-established comment schedule (comments 30d/reply 45d after the 2026-05-28 FR notice, ≈mid-July), fully independent of the July 22 Sunshine-restricted item, not just topically distinct
31	n/a	New Street Research (Ben Reitzes) independent total-incentive estimate	~$6B, "a reasonable assumption"	WebSearch, 2026-07-17 — second, non-Farrar named analyst voice cross-validating the ~$6B total
32	2026-07-16 (ECFS pull)	SES/SpaceX/OQ Technology filings in GN 25-59 and docket 25-157, all-time	no new filing since SES's own 07-14 filings	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-07-16T04:30:27Z) — Sunshine-restricted quiet period (opened 07-15) holding clean, 5 days ahead of the vote
33	2026-05 (approved) / 2027-11 (transfer target)	SpaceX-EchoStar $17B spectrum deal (AWS-4/H-block/unpaired AWS-3, 65MHz nationwide mid-band)	approved by FCC May 2026; full transfer targeted November 2027	WebSearch, 2026-07-17 — refines the prior undated "adjacent, not C-band" row; cross-consistent with dossiers/mss-2ghz-spectrum.md's SIRION-1/SpaceX-transfer "~Nov 2027" date
34	2026-07-22	FCC Upper C-band Report & Order — vote outcome	ADOPTED 2-1 (Carr, Trusty approve; Gomez approve-in-part/dissent-in-part), unchanged from July 1 draft: 160 MHz cleared at 3.98-4.14 GHz	WebSearch (SpaceNews, Via Satellite/satellitetoday, NewscastStudio, TV Tech — convergent, all dated 2026-07-22), 2026-07-23
35	2026-07-22	Adopted order docket number	FCC 26-46 (Report and Order, Order of Proposed Modification, and Order on Reconsideration)	WebSearch (TV Tech, satellitetoday), 2026-07-23 — first citable order number for this proceeding; full order text not yet released as of this run
36	2026-07-22	Adopted service-start dates	top-75 markets eligible Dec 31 2030; remaining markets eligible Jul 1 2031 — matches draft unchanged	WebSearch (TV Tech, satellitetoday), 2026-07-23
37	2026-07-22	Adopted incentive split, first 100 MHz	57.5% SES / 42.5% legacy Intelsat shareholders confirmed unchanged from CVR terms; SES also gets 100% of remaining 60 MHz	WebSearch (search-synthesized from TV Tech/broadbandbreakfast citing FCC 26-46), 2026-07-23 — exact dollar figures still NOT disclosed; FCC states final order will detail amounts (see next row)
38	2026-07-22	FCC disclosure practice, reconfirmed post-vote	incentive-payment dollar totals still undisclosed; FCC states total will be "roughly commensurate" with round 1's $9.7B but "less in aggregate" given smaller MHz cleared	WebSearch (satellitetoday, SpaceNews), 2026-07-23 — OPEN Q1 remains open even post-vote
39	2026-07-22	Commissioner Gomez partial dissent	dissented specifically over FCC declining a pre-auction tribal licensing window (Navajo Nation, Shoshone-Bannock Tribes, Tohono O'odham Utility Authority, National Coalition of Large Tribes had requested one) — not a dissent on SES/Intelsat economics or clearing amount	WebSearch (broadbandbreakfast headline + search-synthesized FCC.gov Gomez Statement page; direct fcc.gov fetch 503-blocked), 2026-07-23
40	2026-07-22	"Advanced satellite operations" deferral, adopted	survived unchanged from draft — SpaceX/SES/OQ Technology requests still deferred under the same bundled clause	WebSearch (Techtimes, dated 2026-07-22, quoting adopted order language directly), 2026-07-23 — fifth named outlet to quote this exact language, first to quote it post-adoption rather than pre-vote
41	2026-07-22	Same-meeting bundled action: "Space Modernization Order" (Part 100 licensing overhaul)	ADOPTED UNANIMOUSLY — replaces legacy Part 25 satellite/earth-station licensing; compresses review from "years" to "weeks/months"; widens scope of minor modifications not requiring prior authorization; explicitly excludes SpaceX's pending ~1M-satellite orbital-data-center application from the fast track (stays under old Part 25 review)	WebSearch (SpaceNews, Benzinga), 2026-07-23
42	n/a	Telesat's posture in the proceeding	reported not to have participated or raised concerns, unlike SES/Eutelsat's active filing record	WebSearch (satellitetoday), 2026-07-23 — not yet evidence of Telesat's incentive-split size, just its negotiating posture (OPEN Q2 unaffected)
43	2026-07-22 (ECFS pull)	SES/SpaceX/OQ Technology filings in GN 25-59 and docket 25-157, all-time	no new filing since SES's own 2026-07-14 filings — the quiet period held clean through the vote itself; no party "filing" accompanies a Commission vote	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-07-23T01:05Z)
44	2026-07-24	FCC 26-46 full order text, released	156pp (with appendices), GN Docket Nos. 25-59 and 18-122	PRIMARYFCC 26-46, docs.fcc.gov/public/attachments/FCC-26-46A1.pdf, mirrored sources/latest/fcc-docs/FCC-26-46.txt, read direct (dossier run 2026-07-30)
45	2026-07-24	Total incentive pool, confirmed	$6.3B ($4.914B Primary Transition Deadline PEAs / $1.386B Final Transition Deadline PEAs; 78% of $6.3B attributable to Primary-deadline PEAs)	PRIMARYFCC 26-46 para. 135-137, read direct (dossier run 2026-07-30)
46	2026-07-24	Per-operator incentive allocation, confirmed final	SES 89% = $5,607,000,000 ($4,373,460,000 primary/$1,233,540,000 final); Eutelsat 8% = $504,000,000 ($393,120,000/$110,880,000); Telesat 3% = $189,000,000 ($147,420,000/$41,580,000)	PRIMARYFCC 26-46 para. 138, allocation table, read direct (dossier run 2026-07-30) — resolves former OPEN Q1/Q2
47	2026-07-24	Allocation methodology, as adopted	value of spectrum each operator would encumber if it alone failed to clear timely, measured via an 8km non-interference buffer around each operator's Lower-C-band-Relocation-Coordinator-identified earth station antennas, valued at Lower C-band final-clock $/MHz-pop (B/C blocks); SES/Eutelsat's own proposals (incl. Eutelsat-commissioned Analysys Mason LyngSat-channel-count methodology) explicitly REJECTED	PRIMARYFCC 26-46 para. 137-138, read direct (dossier run 2026-07-30)
48	2026-07-24	Incentive valuation basis	8.5% WACC/discount rate (consistent with 2020 C-band R&O); calibrated $0.70/MHz-pop if full 160 MHz unavailable until Dec 30 2032 baseline; resulting $6.3B = value of accelerating access from that baseline	PRIMARYFCC 26-46 para. 134-136, read direct (dossier run 2026-07-30)
49	2026-07-24	Late-clearing incentive reduction schedule, Primary deadline	0% cut on-time; 7.5% at 1-30 days late; 15% at 31-60; 22.5% at 61-90; 30% at 91-120; 37.5% at 121-150; 45% at 151-180; 100% (full forfeiture) at 181+ days late. Missing Final deadline forfeits that tranche entirely plus risks cost-reimbursement loss/penalties	PRIMARYFCC 26-46 para. 139, read direct (dossier run 2026-07-30) — reduction pct increased from round 1's 5% first-tier cut to 7.5%
50	2026-07-24	FCC's own aggregate FSS transition cost estimate, all 3 operators	$4.0-5.0B undiscounted (PV $3.5-4.7B at 3-7% discount rates)	PRIMARYFCC 26-46 para. 17-18, read direct (dossier run 2026-07-30) — vs. SES's own single-operator $3.75B all-in figure; reconciliation gap, not yet resolved (OPEN Q)
51	2026-07-24	FCC's own per-new-satellite cost estimate	~$203M in 2026$ (inflated 27% CPI from round 1's $160M/satellite 2020 estimate)	PRIMARYFCC 26-46 para. 27 (Alternative B analysis), read direct (dossier run 2026-07-30) — vs. ~$374M/satellite implied by SES's own $2.62B/7-satellite line item; a second reconciliation gap
52	2026-07-24	Total new satellites required industry-wide, FCC finding	9 (SES up to 7, Eutelsat up to 2, Telesat 0) at an estimated $1.8B aggregate satellite cost	PRIMARYFCC 26-46 para. 27/1833, read direct (dossier run 2026-07-30) — cross-validates SES's own "5 new hybrid Ku-band + 2 in-orbit backups = 7" satellite count first logged 07-17
53	2026-07-24	FCC's own rejected-alternative analysis, 180 MHz option	would have produced HIGHER aggregate consumer/producer surplus than the adopted 160 MHz, but rejected because it "leave[s] only a 40 megahertz guard band" and the Commission found 160 MHz "the maximum amount of spectrum that could be reallocated while still maintaining at least one transponder for C-band FSS service"	PRIMARYFCC 26-46 para. 29-31 (Alternative C), read direct (dossier run 2026-07-30) — direct primary-text confirmation of THESIS's transponder-capacity-preservation logic
54	2026-07-24	Reconsideration/litigation procedural mechanics	Section 316 protest window = 30 days from Federal Register publication (not yet published as of 2026-07-30, per any source held); rules effective 60 days after FR publication; separately, this same order resolved 2020 C-band R&O's outstanding reconsideration petitions — Eutelsat, Intelsat License LLC, ITSO, Charter, Raytheon petitions DISMISSED/DENIED, AIA's GRANTED in part	PRIMARYFCC 26-46 para. 194, 198-201, read direct (dossier run 2026-07-30) — answers former OPEN Q3's procedural half
55	2026-07-26/27	SES/Eutelsat own confirmation of their FCC 26-46 incentive figures	SES: "Gross incentive payments of approximately $5.6 billion to SES are contingent on spectrum clearing within the transition deadlines" (ses.com, 07-27); Eutelsat: "incentive payments of $504 million (€443 million) pre-tax… expected during 2031" (Business Wire, 07-26)	PRIMARYses.com press release 2026-07-27; businesswire.com/news/home/20260726654737/en (both PRIMARY, issuer's own disclosure), via brief 2026-07-27T0930Z
56	2026-07-27	DA 26-783 — Upper C-band FSS transition Cost Catalog, ex parte modification	Bureau engaged contractor Teltrium Inc. to draft initial Cost Catalog; Teltrium's vendor/stakeholder meetings EXEMPT from ex parte disclosure until draft published for comment; Catalog must finalize within 6 months of FCC 26-46's release (~2027-01-24)	PRIMARYDA 26-783, docs.fcc.gov/public/attachments/DA-26-783A1.txt, mirrored sources/latest/fcc-docs/DA-26-783.txt, read direct (dossier run 2026-07-30)
57	2026-07-22/23 (adopted) / 2026-07-30 (full text read)	FCC-26-47 (Space Modernization for the 21st Century, SB Docket 25-306) — two-degree GSO spacing	Commission DECLINED its own proposal to narrow two-degree GSO spacing to US-facing operations only; retained current section 25.140 rule in full (incorporated into new §§100.230/278/279), plus the +/-0.05° station-keeping requirement	PRIMARYFCC-26-47 para. 280-281, mirrored sources/latest/fcc-docs/FCC-26-47.txt, read direct (dossier run 2026-07-30)
58	2026-07-22/23 (adopted) / 2026-07-30 (full text read)	FCC-26-47 — default license term	extended from 15 to 20 years for all GSO/NGSO space stations, earth stations and market-access grants (except statutorily-fixed terms e.g. DBS's 8yr); term now runs from date of grant, not in-orbit notification	PRIMARYFCC-26-47 para. 263-266, read direct (dossier run 2026-07-30)
59	2026-07-22/23 (adopted) / 2026-07-30 (full text read)	FCC-26-47 — GSO multi-satellite licensing	Order now permits more than one GSO space station to be authorized under a single license at one orbital location (previously one-satellite-per-license); FNPRM opens comment on how this affects renewal/replacement expectancy	PRIMARYFCC-26-47 para. 1625/1630, read direct (dossier run 2026-07-30)
60	2026-07-22/23 (adopted) / 2026-07-30 (full text read)	FCC-26-47 FNPRM — open GSO items, not yet decided	renewal vs. replacement expectancy framework for GSO (currently replacement-expectancy-only, no renewal expectancy); 1-year "use it or lose it" proposal for vacated GSO orbital locations/spectrum; secondary-market exchange of NGSO processing-round status; FSS earth-station antenna/off-axis EIRP performance-standard updates (SES Reply Comments cited at para. 1604/1610 opposing premature changes, alongside SIA/Telesat/SpaceX/Amazon Leo/CTIA/Verizon)	PRIMARYFCC-26-47 para. 380-392, read direct (dossier run 2026-07-30)
61	2026-07-27 (reported)	Eutelsat/Telesat satellite-order posture vs. SES, post-adoption	Eutelsat "still assessing the need to order satellites"; Telesat "had yet to determine whether any new satellites would be needed"; SES "actively negotiating contracts for the satellites and launches"	SpaceNews, 2026-07-27T2011Z, operator spokesperson quotes, via brief 2026-07-28T0340Z and dossiers/industry-consolidation.md (DISTRESS-angle detail lives there, not restated here)
62	2026-07-30 (checked)	FCC 26-46 Federal Register publication status	not yet published as of this run (no FR citation found in any mirrored or live-checked source) — Section 316 protest clock and 60-day effective-date clock both remain unstarted	dossier run 2026-07-30, cross-checked against sources/latest/fcc-docs-index.json and briefs 2026-07-27 through 2026-07-30 (no FR publication reported)
63	2026-07-31	FCC 26-46 Federal Register publication, confirmed	Document 2026-15598, 91 FR 48700-48750 (GN Docket Nos. 18-122, 25-59); effective date 2026-09-29; starts the 30-day Section 316 protest window (runs to 2026-08-30)	PRIMARYfederalregister.gov/documents/2026/07/31/2026-15598 (PRIMARY, live API-verified against publication_date/effective_date/document_number fields), via brief 2026-08-01T0342Z
64	2026-07-24 (para. 114-129, read in full 2026-08-04)	FCC 26-46 Transition Cost Reimbursement program, structure	new Upper C-band terrestrial licensees (auction winners) must reimburse eligible incumbents' "reasonable and necessary" transition costs via the Upper C-band Clearinghouse — a mechanism entirely SEPARATE from the $6.3B incentive-payment pool (paras. 130-140); lump-sum reimbursement option available; WTB delegated authority over Cost Catalog-based lump-sum amounts	PRIMARYFCC 26-46 paras. 114-126, read direct (dossier run 2026-08-04)
65	2026-06-18/2026-07 (ex parte filings) / 2026-07-24 (FCC estimate published)	FCC's own aggregate FSS transition cost estimate, sourcing confirmed	the $4.0-5.0B aggregate figure is sourced directly from SES's own June 18, 2026 ex parte and Eutelsat's June 10, 2026 ex parte cost filings (para. 127 cites both by name) — it is the REIMBURSEMENT program's estimate, not an independent FCC cost-benefit cross-check on SES's disclosed cost	PRIMARYFCC 26-46 para. 127, read direct (dossier run 2026-08-04) — corrects this dossier's own 07-30 framing of this figure as a separate "aggregate cost-benefit" cross-validation
66	2026-07-24 (para. 137, read in full 2026-08-04)	FCC's own rationale for rejecting a customer-count/earth-station metric as an INCENTIVE-allocation basis	explicitly because that metric "is more appropriately viewed as a proxy for the transition costs... and not for the relative contribution each operator will provide"; order states "all reasonable and necessary FSS C-band transition costs will be reimbursed through the Upper C-band transition cost reimbursement program"	PRIMARYFCC 26-46 para. 137, read direct (dossier run 2026-08-04) — the single clearest primary-text statement that cost reimbursement and incentive payment are legally and financially distinct
67	2026-07-30 (SES H1 2026 earnings call)	SES 2026 C-band capex guidance, primary	~€100-150M in 2026 (vs. ~€700M total 2026 capex guidance excluding C-band), explicitly "fully reimbursable over time"; CFO: "these costs are not expected to impact our long-term capital allocation, leaving the full amount of incentive payment as the potential economic benefit upon successful execution"	PRIMARYinbox/SES S.A._Earnings Call_2026-07-30T00_00_00_English.md (CFO prepared remarks), PRIMARY — issuer's own earnings call transcript
68	2026-07-30 (SES H1 2026 earnings call, Q&A)	SES CEO on Transition Plan filing timing and incentive to delay	"we absolutely want to clear it as quick as possible... there is no incentive for us to be later... we're supposed to submit the whole transition plan to FCC by the end of the year, which we will"; separately, SES will "set up the clearinghouse by the end of the year" (the reimbursement vehicle) ahead of the FCC-mandated mobile-operator auction "in the first half of 2027"	PRIMARYinbox/SES S.A._Earnings Call_2026-07-30T00_00_00_English.md (CEO Q&A), PRIMARY
69	2026-08-04 (checked)	SES Transition Plan (GN 25-59) filing status	still unfiled as of this run; a "SES Final Transition Plan.pdf" ECFS hit first surfaced 08-02 remains unresolved/unverified across four subsequent daily briefs (most likely the pre-existing 2021 Lower C-band plan, not asserted either way)	PRIMARYbriefs 2026-08-02 through 2026-08-04 (live ECFS/direct-check negatives); dossier run 2026-08-04
70	2026-08-04 (ECFS pull)	SES/SpaceX/OQ Technology filings in GN 25-59, all-time	no new filing since SES's own 2026-07-24 submissions — consistent with DA 26-783's Teltrium ex parte exemption keeping the reimbursement side of the docket quiet, not evidence of reduced activity	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored/fetched 2026-08-04T21:45:53Z)
71	2026-07-24 (released) / 2026-08-07 (read direct, first time)	Auction 115 — the terrestrial-license auction itself, previously untracked by this dossier	3,248 new flexible-use licenses in the 3.98–4.14 GHz band, licensed unpaired in eight 20-MHz blocks per PEA across 406 PEAs (CONUS + DC only; 406×8=3,248); bidding tentatively scheduled to commence April 27, 2027; this Public Notice itself seeks comment on bidding procedures, comment date 2026-08-24, reply 2026-09-08	PRIMARYDA 26-769, AU Docket No. 26-191, docs.fcc.gov/public/attachments/DA-26-769A1.pdf, mirrored sources/latest/fcc-docs/DA-26-769.txt, read direct in full (dossier run 2026-08-07) — mirrored and watchlist-flagged (`fcc-docs-index.json`) since 2026-07-24 but never surfaced by any brief or this dossier until this run, see ANALYTIC STANCE
72	2025-07-04 (OBBBA enactment)	Statutory deadline for Auction 115 completion	competitive bidding must COMPLETE — not merely commence — no later than 2 years after OBBBA enactment (July 4, 2025) = July 4, 2027; bidding starts April 27, 2027, leaving ~10 weeks to run a multi-round ascending-clock-plus-assignment auction across 3,248 licenses before the statutory deadline	PRIMARYDA 26-769 para. 1 (citing Pub. L. No. 119-21 § 40002(b)(2)), read direct; cross-confirmed phillipslytle.com summary (WebFetch, dossier run 2026-08-07)
73	2026-07-24	Auction 115 license/bidding-credit terms	15-year renewable license terms; small-business bidding-credit tiers ($55M/$20M avg. 5-yr gross revenue → 15%/25% credit), each capped at $25M/$10M per auction plus a $10M small-market (≤500k pop.) sub-cap; rural-service-provider credit 15%, capped $10M; AT&T, T-Mobile, and Verizon proposed as the auction's "nationwide providers" for the anti-collusion communications-prohibition rule	PRIMARYDA 26-769 paras. 6, 11–18, 33, read direct (dossier run 2026-08-07)
74	2026-07-24	Auction 115 floor-price formulas (reserve/opening prices, explicitly NOT value estimates)	proposed upfront payment: $0.015/MHz-pop (PEAs 1–50), $0.003 (51–100), $0.0015 (rest), min $500/20MHz block; proposed minimum opening bid: $0.03/$0.006/$0.003 per MHz-pop by the same tiers, min $1,000/block; no aggregate reserve price proposed	PRIMARYDA 26-769 paras. 19, 55–57, read direct (dossier run 2026-08-07) — FCC's own text: "minimum opening bid amounts... are not meant to predict the value of the spectrum"
75	2026-07-03 (dateline)	Analyst estimate, Auction 115 total proceeds	$30B–$75B range attributed to TD Cowen, driven by final spectrum allocation, FAA-related deployment-timeline risk, and whether SpaceX bids	WebSearch (techtimes.com, "FCC Sets Rules for $30B–$75B C-Band Auction, Blocks SpaceX Satellite Bid"), 2026-08-07 — SECONDARY; direct fetch of techtimes.com 403-blocked, figure not independently verified against any TD Cowen note itself; treat as a lead, not a confirmed figure (per this dossier's standing WebSearch-synthesis caution, ANALYTIC STANCE)
76	2026-08-03 (dateline)	Analyst speculation: SpaceX as a possible Auction 115 bidder	Roger Entner (Recon Analytics), on SpaceX's terrestrial-wireless ambitions: SpaceX "will now actively participate" in Auction 115, aiming to "win spectrum at auction and build a satellite- and terrestrial-hybrid network... from scratch" rather than acquire an existing carrier, "following the same strategy Musk has used for two decades of acquiring critical assets"	PRIMARYibtimes.co.uk, "SpaceX Won't Buy Verizon or AT&T: Analyst Says Elon Musk Will Build His Own Telco," read direct via WebFetch, dossier run 2026-08-07 — single-named-analyst forward-looking claim; no SpaceX filing exists yet in AU Docket 26-191 (comment window not open until 2026-08-24); does not reference the EchoStar-spectrum "femtocell" strategy SpaceX itself described on its 2026-08-04 earnings call (brief 2026-08-05T0958Z)
77	2026-07-30 (SES H1 2026 earnings call, Q&A)	SES CFO on round-2 incentive-payment tax rate	confirms Intelsat's C-band 1.0 tax rate on its own proceeds was "much lower" than SES's round-1 rate; SES itself has NOT guided a tax-rate figure for round 2 — the ~10% figure analysts use is the market's own consensus/midpoint assumption drawn from round-1 experience, not SES guidance ("SES hasn't guided really on this tax rate... the market is using the midpoint of that tax rate")	PRIMARYinbox/SES S.A._Earnings Call_2026-07-30T00_00_00_English.md (CFO Elisabeth Pataki + unnamed IR/exec on-call clarification), PRIMARY
78	2026-07-30 (SES H1 2026 earnings call, Q&A)	SES CEO on auction-vs-payment timing shift vs. round 1	confirms round-2 proceeds land later relative to the mobile-operator auction than round 1's ~1-year-post-auction start ("it's not 5 years, it's 4 years" to the Primary deadline); attributes the shift to the FCC's accelerated 70%-of-US-population-by-end-2030 clearing target plus a redesigned, more efficient expense-reimbursement process meant to minimize incumbents' financing/interest costs; separately confirms "the auction with the mobile operators" is expected "in the first half of 2027" — consistent with DA 26-769's April 27, 2027 tentative bidding start	PRIMARYinbox/SES S.A._Earnings Call_2026-07-30T00_00_00_English.md (CEO Adel Al-Saleh), PRIMARY
79	2026-08-07 (ECFS pull, filtered to proceedings 25-59/18-122)	SES/SpaceX/OQ Technology filings in GN 25-59, all-time	most recent SES filing actually tagged to docket 25-59 is 2026-07-14 (Reply Comments + Notice of Ex Parte) — this dossier's own prior rows (08-04 run) said "2026-07-24," which on this run's direct filter-check is not a docket-25-59-tagged SES filing (07-24's only hit in the mirror is an unrelated third-party comment in docket 26-131); precision correction, not a reversal of substance — no SES/SpaceX/OQ Technology filing in 25-59 since 07-14 either way, Teltrium ex parte-exemption quiet period continues	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-08-07T21:07:15Z), filtered directly on the `proceedings` field this run rather than assumed from query scope
80	2026-07-22 (filed) / 2026-07-29 (released)	Minor docket-hygiene item: prohibited Sunshine-period presentation	DA 26-791: a written presentation by one filer (Anura Lawson) reached GN 25-59/18-122 during the July 15–24 Sunshine Agenda quiet period; per 47 CFR § 1.1212(d) it is associated with, but not made part of, the docket record — a compliance footnote, not a substantive filing	PRIMARYDA 26-791, mirrored sources/latest/fcc-docs/DA-26-791.txt, read direct (dossier run 2026-08-07)
81	2023-08-10 (SES press release, read direct this run)	"SES Final Transition Plan.pdf" ECFS-hit identity, resolved	confirmed as SES's own completed LOWER C-band Transition Plan (2020 R&O, Dec 2023 Phase-II deadline, ~$2.99B accelerated relocation payments) — NOT a new Upper C-band GN 25-59 filing; SES's Upper C-band Transition Plan remains genuinely unfiled as of this run	PRIMARYses.com/press-release/ses-completes-fccs-c-band-transition-clearing-and-relocation-plan-us, read direct (dossier run 2026-08-08) — resolves the ambiguity this dossier's own 08-02/08-04 rows flagged but did not close
82	2026-08-07	FCC Space Bureau leadership transition	Jennifer Gilsenan named acting Space Bureau chief; Jay Schwarz (cut licensing backlog 43% in 2025, 15% further in 2026) prepares to retire, no successor named	brief 2026-08-08T0347Z, cross-checked this dossier run — process-continuity signal for the bureau that will review SES's still-unfiled Transition Plan, not yet a substantive one
83	2026-08-06 (adopted) / 2026-08-07 (released)	FCC-26-51 (ET Docket 26-169), "Unleashing Unlicensed Spectrum for Direct-to-Device" — checked and ruled out of scope	proposes opening Part 15 unlicensed bands (2.4/5.8 GHz, 200+ MHz) to D2D satellite use; a new SpaceX/OQ-Technology-adjacent D2D proceeding but on spectrum entirely distinct from Upper C-band GN 25-59/18-122 — NOT the resolution of FCC 26-46's deferred "advanced satellite operations" clause	PRIMARYFCC 26-51, docs.fcc.gov/public/attachments/FCC-26-51A1.pdf, mirrored sources/latest/fcc-docs/FCC-26-51.txt, read direct (dossier run 2026-08-08)
84	2026-08-07	FCC-26-52/FCC-26-54, watchlist false positives, confirmed	FCC-26-52 (Notice of Proposed Rulemaking, "Dish" hit) and FCC-26-54 (Third FNPRM, "C-band" hit) are Rural Health Care Program and USF/USAC administration rulemakings respectively; the C-band mention in FCC-26-54 is a single throwaway example sentence about LEO replacing backup links, no SES-relevant action	fcc-docs-index.json watchlist_hits, cross-checked against brief 2026-08-08T2130Z's own false-positive read (dossier run 2026-08-08)
85	2026-08-08 (ECFS pull, filtered to proceedings 25-59/18-122)	SES/SpaceX/OQ Technology filings in GN 25-59, all-time, reconfirmed	no new filing since SES's own 2026-07-14 submissions; no Section 316 protest found in any source this dossier holds, ~1 week into the 30-day window (closes 2026-08-30)	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-08-08T20:56Z), filtered directly on the `proceedings` field
86	2026-08-13 (Q2 2026 earnings call)	Telesat CEO on C-band clearing-plan status	"actively working to develop a plan to ensure that the spectrum is cleared prior to the transition deadlines in 2030 and 2031"; cites successful C-band 1.0 clearing as basis for confidence; declined to confirm a direct link between the new $120M term loan and C-band proceeds when asked	Telesat Q2 2026 earnings call (2026-08-13, CEO Dan Goldberg), via investing.com transcript (WebFetch, dossier run 2026-08-13) — SECONDARY, transcript not yet in inbox/; first active (vs. passive/non-participating) Telesat statement on clearing since FCC 26-46 adopted
87	2026-08-13 (disclosed)	Telesat US$120M secured term loan	4-year term, SOFR + margin, borrowed by a Telesat GEO Inc. subsidiary, "general corporate purposes"/GEO refinancing; CEO declined to characterize as C-band-proceeds-linked	Telesat Q2 2026 results release, globenewswire.com 2026-08-13 (WebFetch, dossier run 2026-08-13)
88	2026-08-10 (post date)	Farrar (tmfassociates.com), disconfirming read on SpaceX-Auction-115 speculation	arguing SpaceX's terrestrial small-cell buildout is more likely to target EchoStar's CBRS spectrum than Upper C-band, "which won't be available until 2031 (and isn't compatible with current phones)"	PRIMARYtmfassociates.com, "Musk's daily Starship problem…," 2026-08-10T17:47Z (sources/latest/tmfassociates.rss, PRIMARY analyst voice, read direct dossier run 2026-08-13) — bears on OPEN Q5, not independently corroborated or contradicted elsewhere
89	2026-08-13 (ECFS pull, filtered to proceedings 25-59/18-122)	SES/SpaceX/OQ Technology filings in GN 25-59, all-time, reconfirmed	no new filing since SES's own 2026-07-14 submissions; no Section 316 protest found, ~2 weeks into the 30-day window (closes 2026-08-30)	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-08-13T21:11Z), filtered directly on the `proceedings` field
90	2026-08-13 (checked)	`fcc-docs-index.json` re-scan for new C-band-tagged documents	none since the 08-07 FCC-26-51/52/54 batch already checked out (watermark DA-26-849/FCC-26-54); DA-26-835 (WRC-27 Advisory Committee NPRM, tagged "2 GHz" but not "C-band") read direct — concerns mmWave EESS/IMT bands only, no mention of 3.98-4.2 GHz, confirmed out of scope	PRIMARYfcc-docs-index.json (mirrored 2026-08-13T21:11:46Z) + sources/latest/fcc-docs/DA-26-835.txt, read direct (dossier run 2026-08-13)
91	2026-07-24 (para. 163/865; 47 CFR § 27.1412(e)), read direct 2026-08-18	Transition Plan statutory filing deadline, previously unread text	all three eligible space station operators (SES/Eutelsat/Telesat) must publicly file initial Transition Plans no later than November 5, 2026 — a firm regulatory deadline, sharper than CEO Al-Saleh's own "by end of year" guidance (07-30 call, [tracked series](#tracked-series))	PRIMARYFCC 26-46 para. 163, 865; 47 CFR § 27.1412(e); sources/latest/fcc-docs/FCC-26-46.txt, read direct (dossier run 2026-08-18)
92	2026-07-24 (para. 156-158/824-842), read direct 2026-08-18	Upper C-band Clearinghouse selection process, mechanics	9-member selection committee (SES, Eutelsat, CTIA x2, CCA, NAB, NCTA, plus A4A and AOPA for the altimeter-rebate side) must convene within 60 days of FR publication (~2026-09-29); must notify FCC of its clearinghouse choice by 2026-12-15 (fallback: drop 2 members, select by majority vote by 2027-01-15)	PRIMARYFCC 26-46 para. 156-158, read direct (dossier run 2026-08-18)
93	2026-07-24 (para. 170), read direct 2026-08-18	Relocation Coordinator selection committee, a separate process from the Clearinghouse	one representative per eligible operator (SES/Eutelsat/Telesat); convenes no later than October 1, 2026	PRIMARYFCC 26-46 para. 170, read direct (dossier run 2026-08-18)
94	2026-07-24 (para. 177-182/928-954), read direct 2026-08-18	Radio Altimeter Retrofit Rebate program — a third, distinct cost stream, previously untracked by this dossier	same Upper C-band Clearinghouse administers rebates to aircraft owners/operators (FAA's own forecast: 43,562 aircraft/62,810 altimeters) retrofitting under FAA's parallel rule, funded by Upper C-band auction winners — NOT part of the $6.3B incentive pool or the $4-5B FSS-cost estimate; draft rebate categories/dollar amounts out for comment by 2026-10-06, amounts not yet set; claims deadlines 2031-06-30 (first FAA deadline)/2035-04-30 (second)	PRIMARYFCC 26-46 para. 177-182, read direct (dossier run 2026-08-18)
95	2026-08-18 (dateline, unverified)	Press/analyst estimate, combined winning-bidder burden across all three Upper C-band cost streams	~$14-17B (incentive pool + FSS transition-cost reimbursement + altimeter rebates), attributed to Summit Ridge Group's own "Unofficial Guide to the Upper C-band Transition" (104pp/246 footnotes)	PRIMARYWebSearch (search-synthesized, SRG-attributed figure; SRG's own document text 403-blocked at ecfs.fcc.gov this run, not independently read), dossier run 2026-08-18 — SECONDARY, treat as a lead per this dossier's standing WebSearch-synthesis caution ([analytic stance](#analytic-stance))
96	2026-08-17 (ECFS pull)	New ex parte filer in GN 25-59/18-122, first new party since SES's own 07-14 filing	Summit Ridge Group LLC (author J. Armand Musey), Notice of Ex Parte attaching an "SRG Upper C-band White Paper v1.0" (dated 2026-08-12) and a 4-page "Core Brief" (2026-08-15) — SRG is an established repeat commenter already cited 10+ times in FCC 26-46's cost-reimbursement text (Comments + June 2, 2026 Ex Parte), where it unsuccessfully sought ongoing selection-committee oversight of the clearinghouse (FCC declined, opting for 6-month stakeholder briefings instead, para. 845-847)	PRIMARYsources/latest/fcc-ecfs-cband-ses.json (PRIMARY, mirrored 2026-08-18T20:46:20Z, id_submission 26110071818); filing PDFs themselves 403-blocked at ecfs.fcc.gov this run (dossier run 2026-08-18)
97	2026-08-17 (ECFS pull)	SES's own most recent FCC filing, any docket, reconfirmed	Notice of Ex Parte in docket 25-157 (GSO reference-links/EPFD), filed 2026-08-14 — the independent, non-25-59 docket this dossier already distinguishes ([political & regulatory](#political-regulatory)); still no new SES/SpaceX/OQ Technology filing in GN 25-59/18-122 itself since 07-14	PRIMARYsources/latest/fcc-ecfs-cband-ses.json (PRIMARY, mirrored 2026-08-18T20:46:20Z)
98	2026-08-18 (ECFS pull, filtered to proceedings 25-59/18-122)	Section 316 protest status, reconfirmed	none filed as of this run, 12 days short of the 2026-08-30 window close	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-08-18T20:46:20Z), filtered on the proceedings field
99	2026-08-14 (adopted 08-13, released 08-14)	FCC-26-55 (2026 Section 706 Report, GN Docket 25-223) — checked, largely out of scope	recaps FCC 26-46 (already-tracked facts) as evidence of Commission broadband progress; self-characterizes the order as making 160 MHz available "faster than stakeholders anticipated" — no new substantive C-band content, but a signal of low internal FCC appetite to revisit the order	PRIMARYFCC 26-55 para. 89, sources/latest/fcc-docs/FCC-26-55.txt, read direct (dossier run 2026-08-18)
100	2026-08-13 (announced) / 08-19 (detailed)	Intuitive Machines $600M GEO-satellite award, three spacecraft	30-month manufacture/delivery agreement, undisclosed customer; centerpiece of $920M Q2 2026 bookings, backlog reaches $1.8B (Commercial 49%/$882M, Civil Space 37%/$666M, National Security 14%/$252M); built via Lanteris Space Systems (Intuitive Machines' Jan 2026 acquisition of the former Maxar Space Systems)	PRIMARYSatNews, "Intuitive Machines Secures $600 Million Commercial GEO Satellite Award," 2026-08-19, read direct via WebFetch 2026-08-24; SpaceNews corroborates occurrence
101	2026-08-13 (earnings call)	Analyst question on Intuitive Machines' $600M customer, direct primary transcript	Deutsche Bank's Edison Yu asked on-call whether the contract relates to the FCC's Upper C-band reallocation; CEO Steve Altemus declined to confirm or deny ("I have that yet undisclosed... in the future we'll come out and give you a little more color")	brief 2026-08-19T0343Z, citing the Aug 13 earnings call directly
102	2026-08-17 (X post)	Analyst speculation naming SES as the likely Intuitive Machines customer	Peter B. de Selding (@pbdes, TIER-A per priors.md), citing SES's historical use of Intuitive Machines/Maxar for its prior C-band clearing round — explicitly unconfirmed by any SES or Intuitive Machines primary statement	brief 2026-08-19T0343Z, citing @pbdes 08-17 X post — SECONDARY, single-analyst speculation, not corroborated this run
103	2026-08-19/21 (ECFS pulls)	New filings in dockets 25-157/12-340/11-109, adjacent to but distinct from GN 25-59	SpaceX "Reference Link" ex parte (25-157, Aug 18/19) and a joint MSS-ATC-coexistence ex parte (12-340/11-109, Aug 21) — neither tagged to the Upper C-band proceeding itself; both content-blocked at fcc.gov/ecfs/document on this run's fetch attempts, same as SES's 25-157 filing and Summit Ridge's 25-59 white paper	PRIMARYsources/latest/fcc-ecfs-cband-ses.json (PRIMARY, mirrored 2026-08-24), id_submission 26110072093/26110072613; direct WebFetch/WebSearch attempts this run found no trade-press pickup of either
104	2026-08-24 (checked)	Section 316 protest status and GN 25-59/18-122 filing activity, reconfirmed	still none filed, 6 days short of the 2026-08-30 window close; no new SES/SpaceX/OQ Technology filing in GN 25-59/18-122 itself since 07-14	PRIMARYsources/latest/fcc-ecfs-cband-{ses,spacex,oq-technology}.json (PRIMARY, mirrored 2026-08-24), filtered on the proceedings field
105	2026-08-24 (checked)	Farrar (tmfassociates.com) and Rayal (frankrayal.com), disconfirming-evidence check	neither has published a new post since Farrar's 08-10 CBRS-vs-C-band read ([open question 5](#open-questions)) or Rayal's 07-27 post (not C-band-focused); no new analyst voice on Auction 115 or the SpaceX-bid question	sources/latest/tmfassociates.rss and frankrayal.rss, both live-checked 2026-08-24

Superseded

Earlier claims that evidence disproved — kept on record. 2 corrections documented.

believed 2026-07-23→overturned 2026-07-30
OLD CLAIM (believed 2026-07-23): "the same July 22 meeting... unanimously adopted a 'Space Modernization Order'... that favors NGSO constellation operators — compressed review timelines, fewer prior-authorization requirements for routine modifications... the pairing... is a directional signal about which business model the FCC's current posture favors at the margin." This was drawn entirely from secondary press (SpaceNews, Benzinga) at a point when FCC-26-47's own full text had not been read. OVERTURNED 2026-07-30: having read FCC-26-47's full text directly (sources/latest/fcc-docs/FCC-26-47.txt), the order is a mixed picture, not simply NGSO-favoring — and on the two structural questions with the clearest read-across to SES's own GEO fleet, it is GSO-incumbent- protective: the Commission explicitly declined to narrow the two-degree GSO spacing rule to US-facing operations only (retaining it in full over new-entrant objections), and extended the default GSO license term from 15 to 20 years. See STRUCTURAL DYNAMICS and IMPLICATIONS FOR SES for the corrected read. The general "streamlined licensing overall, and NGSO replacement rules loosened" observation still stands — only the "directionally favors NGSO at the margin" framing, stated without qualification, is corrected.
believed 2026-07-30→overturned 2026-08-04
OLD CLAIM (believed 2026-07-30): applying the CVR split proportionally by MHz to the FCC's confirmed $5.607B SES incentive allocation yields ≈$4.12B gross, "before the ~$3.75B all-in clearing cost SES itself has disclosed. That nets to roughly +$370M — still close to breakeven." This treated SES's disclosed clearing cost as a subtraction from the incentive payment. OVERTURNED 2026-08-04: FCC 26-46's own text (paras. 114-140, read in full this run) and SES's own CFO (H1 2026 earnings call, read this run from inbox/) both confirm that clearing-cost reimbursement (paid by new Upper C-band licensees via the Upper C-band Clearinghouse) and incentive payment (the $6.3B pool) are separate financial mechanisms — the FCC explicitly rejected an earth-station-count metric for allocating INCENTIVE shares because it is "more appropriately viewed as a proxy for the transition costs... [which] will be reimbursed through the Upper C-band transition cost reimbursement program" (para. 137). SES's own CFO independently confirmed 2026 C-band capex is "fully reimbursable over time" and "not expected to impact our long-term capital allocation, leaving the full amount of incentive payment as the potential economic benefit." SES's net capture is therefore much closer to the full ≈$4.12B illustrative figure than to "close to breakeven" — the real remaining downside is a possible shortfall (up to ~$1.2B) if Teltrium's Cost Catalog reimburses satellite costs nearer the FCC's ~$203M/satellite benchmark than SES's own ~$374M/satellite filed figure, not a blanket ~$3.75B net cost. See STRUCTURAL DYNAMICS and IMPLICATIONS FOR SES for the corrected arithmetic and revised OPEN Q2. This is the dossier's second self-reversal of its own prior stated claim (the first was FCC-26-47's directional characterization, above), and — like that one — it stems from finally reading a specific primary-text section (paras. 114-140) this dossier had cited around but not read in full on 07-30. (Dossier created 2026-07-05, refined 2026-07-11, 2026-07-17, 2026-07-23, 2026-07-30, 2026-08-04; the above are this dossier's two reversals of its own prior stated claims to date. Note: priors.md and daily briefs 07-08 through 07-11 separately asserted the July 1 rules were "adopted" — that claim is wrong per the 07-11 run's research, but it was never a claim this dossier itself made, so it is not a dossier-internal reversal; see CHANGELOG and the FOR RETRO note in the 07-11 run's PR. The 07-17 run's "pre-Sunshine window closes ~July 17" correction to "Sunshine Notice released 07-15" is a precision fix to this dossier's own prior framing, not a reversal of a stated fact. The 07-23 run's confirmation that the July 22 vote adopted every draft term this dossier tracked unchanged is, similarly, a confirmation rather than a reversal. The 07-30 run's finding that the FCC's own $5.607B gross SES figure came in ~44% higher than this dossier's prior ≈$3.5-4B derived estimate was not logged as a reversal either: that estimate was always explicitly flagged as this dossier's own unconfirmed derivation pending the FCC's real number. The 07-30 run's own "close to breakeven" net-of-cost conclusion, by contrast, WAS a stated claim — not a flagged placeholder — and its 08-04 overturning (see SUPERSEDED) is this dossier's second genuine reversal.)

Revision history

2026-08-29dossiers: audit sweep — fix wrong row mappings, convert missed citations51a3f46 ↗

2026-08-28dossiers: row-level citations comprehensively across all dossiersaa95527 ↗

2026-08-24dossier: 2 GHz MSS spectrum + US C-band spectrum — MSS supplement resolved as immaterial, Elveo sat-count confirmed at 320; C-band Intuitive Machines/SES lead surfacedbf013ea ↗

2026-08-18dossier: US C-band spectrum & clearing economics + Launch bottleneck — Summit Ridge/Clearinghouse-timeline depth added, NSSL Lane 1 provider-count and LM-7A/YF-100 self-correctionsa680d60 ↗

2026-08-16dossiers: full retroactive Wikipedia-style rewrite, all 10 dossiersbe37a91 ↗

2026-08-16dossiers: active/record principle + compress remaining active sections + retro budget audit74f7ec3 ↗

2026-08-16dossiers: compress State of Play to spec + add as-of labels1445d0d ↗

2026-08-16dossiers: add bold lead-in labels to Structural Dynamics / Political & Regulatory bullets40be2f5 ↗

2026-08-14dossiers: render bare falsifiers + a Settled/Moot state49a4273 ↗

2026-08-13dossier: c-band-spectrum deep-dive — Telesat clearing-plan intent, Farrar disconfirming CBRS argument3399ffe ↗

2026-08-08dossier: non-Western sovereign constellations + US C-band spectrum — quiet-cycle reconfirmation, prose-budget compaction, Transition Plan ECFS ambiguity resolved21d7143 ↗

2026-08-07dossier: iris2-spacerise + non-western-sovereign-constellations + c-band-spectrum — forced full-refresh deep-dive (partial batch)82ea264 ↗