Reply To Comments by The Boeing Company in 25-59
The Federal Communications Commission is developing a Preliminary Cost Catalog to manage the transition of incumbent satellite services from the Upper C-band spectrum. Boeing recommends updating this catalog to account for the higher technical complexity and costs associated with hybrid satellites capable of operating in both C-band and Ku-band. Additionally, Boeing urges the inclusion of reimbursement provisions for spare and in-orbit protection satellites, citing their necessity for mitigating manufacturing delays and launch failures to ensure timely spectrum clearing. Industry stakeholders have previously demonstrated that procuring spare satellites is a standard risk-mitigation practice essential for maintaining service continuity during such complex transitions.
- Submission type
- REPLY TO COMMENTS
- Filers
- The Boeing Company
- Authors
- Bruce A. Olcott
- Law firms
- Jones Day
- Proceedings
- 25-59 Upper C-band (3.98 GHz to 4.2 GHz)
- Submitted
- Nov 9, 2026, 6:50 PM ET
- Disseminated
- Nov 10, 2026, 11:00 AM ET