Upper C-band Clearinghouse · dry run · FCC 26-46, GN Docket 25-59

What breaks at intake on day one.

The Upper C-band Clearinghouse operator is being chosen now: proposals are due Nov 9, 2026 and a selection is expected by about Dec 15. Whoever wins inherits two claim streams, lump sum elections from 2,603 earth station registrants and radio altimeter rebates on about 50,043 turbine aircraft. We ran every one of them through a claims engine before a single real claim exists, to measure what the operator will hit in its first week.

Written for the selection committee, the FCC Wireless Telecommunications Bureau and every bidder. Each number below has its method next to it and the script that produced it. No names of people or companies appear on this page.

801of 6,015 honest lump sum claims (one per site, filed exactly as the list reads) stop at intake: 790 for review, 11 rejected on list defects
$35.3Mof lump sums held in review on day one, from 246 registrants
6,108of 50,043 honest altimeter rebate claims (owner of record, 1 altimeter) stop at intake, $324.0M at the proposed amounts
6,109aircraft where any claim not filed in the trustee's own name is rejected without a trustee certification (6,036 carry TRUSTEE in the owner name)
0of 354 call signs accepted when the owner files under the licensee name in the FCC's own licensing system (ICFS) instead of the list name; 96 rejected outright
236call signs on the Nov 2025 list that are gone from the Oct 2026 list (surrendered or expired): a claim on any of them fails rule E1

The 2020 lesson

In the Lower C-band program the International Bureau reviewed 1,510 lump sum elections and denied 34 (DA 20-1421, Nov 30, 2020, Table of Lump Sum Elections). Reasons it named: missing certifications, leaving out antennas that were on the list, and claiming antennas that were not. 9 denials were marked antenna or quantity mismatch, 4 certification. Getting to 1,476 acceptances took rounds of staff requests, errata in ECFS and corrective filings in the licensing system. The same mismatches are already in the Oct 15, 2026 list, below, and this time the clearinghouse has to find them at intake.

Five intake scenarios, run on the full records

One ledger per scenario, claims validated in order, each accepted claim's keys recorded before the next one, through the same 24 rules the console runs (E1, E2, E3, E4, E5, E6, E7, E8, E9, E10, E11, A1, A2, A3, A4, A5, A6, A7, A8, A9, A10, A11, X1, INPUT).

ScenarioClaimsAcceptedReviewRejected
S1 Lump sum, honest: one claim per physical site, claimant = list registrant, all antennas at list quantities6,0155,21479011
S2 Altimeter, honest: every turbine aircraft, claimant = owner of record, 1 altimeter50,04343,9356,07533
S3 Lump sum filed under the ICFS licensee name where it differs from the list3850261124
S4 Lump sum filed by a former registrant (2020 or Nov 2025 list) for its old call sign9430105838
S5 Altimeter claim by the operator on a trustee-registered aircraft, no certification6,109006,109
$35.3Mlump sums in review after the honest run (S1), out of $189.5M not rejected. Engine time for all 6,015 claims: 217 ms.
$324Maltimeter rebates in review after the honest run (S2), out of $2.93B not rejected. Engine time for all 50,043 claims: 5,982 ms.

S1 and S2 are the floor: every claimant is the party of record and files exactly what the record says. S3 to S5 are the mistakes and gaps the records make likely. All five are constructed from real records; no Upper C-band claim has been filed yet. Amounts are the preliminary lump sums (DA 26-1049, single-feed or temporary fixed, no MVPD amount) and the proposed rebates (DA 26-1076).

firm error the record itself stops the claim as filed (12 findings)needs review a person has to look (26 findings)scale program size, no action by itself

Day one, with every claim honest

We filed one claim for every physical site on the Oct 15, 2026 list (6,015 claims, claimant = list registrant, every antenna at list quantities) and one claim for every turbine aircraft in the FAA registry snapshot (50,043 claims, claimant = owner of record), into one ledger, in order, through the console's own 24 rules. Nothing in these files is fraud. This is the floor of the review load before a single filer makes a mistake.

FindingCountClass
Lump sum claims accepted / review / rejectedEngine run in 217 mssource: engine.mjs5,214 / 790 / 11scale
Same dish under another call sign (E10): later claim at an already-claimed location428 call signs. Location = coordinates within about 11 m, or the same street and ZIP, filed under another call sign.source: engine.mjs444needs review
Registrant with a foreign-adversary interest holder on Form 323 (E11)Ontology obligation FCC-FAC-FLAG on the registrant; held for the GN Docket 25-166 attestation review. OFAC SDN matches: 0.source: engine.mjs239needs review
One street address filed under 2+ Site IDs (E6)77 call signs. Pay both only after confirming they are different antennas.source: engine.mjs162needs review
Antenna ID filed under 2+ Site IDs at one address (E4)The list repeats one antenna ID under several Site IDs at the same address, so a claim for the whole site cannot be matched; it must be filed per Site ID.source: engine.mjs7firm error
Site ID filed at two different street addresses (E4 / E5)4 claims rejected (the antenna sits at the other address) and 3 sent to review as partial elections. 3 such Site IDs on the list.source: engine.mjs + data.py7firm error
Altimeter claims accepted / review / rejectedEngine run in 5,982 mssource: engine.mjs43,935 / 6,075 / 33scale
Co-owners or fractional ownership on the registration (A11)2,298 co-owner names, 418 fractional with co-owners, 41 fractional only. One rebate per aircraft; designation on file.source: engine.mjs2,757needs review
Government registrant (A3)FAA type of registrant 5 (government). Eligibility check before payment.source: engine.mjs2,230needs review
Registration certificate issued after FCC 26-46 (Jul 24, 2026) (A10)Who paid for the retrofit, and did an earlier owner already claim it.source: engine.mjs1,944needs review
Airframe serial also under another N-number (A9)FAA DEREG file: the same manufacturer-model code and serial on another tail number.source: engine.mjs5needs review
Aircraft that left the registry, expired or changed owner after the Nov 5 snapshot (A8, A2)One-day drift between the Nov 5 snapshot and the Nov 6 FAA file: 16 no longer in MASTER, 27 owner name changed (16 enough to fail the name match), 14 new valid turbine registrations.source: engine.mjs + data.py33firm error

Who is the owner: names, FRNs and addresses that disagree

A clearinghouse matches the claimant to the record. The records do not agree with each other, and the 2020 program told owners to fix the FCC record before an election could be accepted.

FindingCountClass
Call signs whose ICFS licensee name differs from the list registrant106 of them are not even close (engine name score below 0.8). Claimants copy the name on their own FCC record.source: data.py354needs review
Owner files under the ICFS licensee name: call signs rejected / sent to review on the nameScenario S3: 385 site claims, 0 accepted. Rejections are names the engine cannot tie to the registrant or its control group.source: engine.mjs96 / 258firm error
Call signs whose registrant changed since the 2020 or Nov 2025 list339 changed in the last year. Changelog: 364 call signs got a new applicant name since Nov 14, 2025.source: data.py608needs review
Former registrant files for its old call sign: site claims rejected / reviewScenario S4: 642 former names across 607 call signs. Review = a former name close to the current one (rename, dba); rejected = a different entity.source: engine.mjs838 / 105firm error
One licensee FRN shared by 2+ list registrant names24 registrant names on those FRNs.source: data.py10needs review
One registrant name under 2+ FRNsThe FRN is the FCC's own entity key; two FRNs means two entities or a stale record.source: data.py43needs review
One registrant name with 2+ ICFS mailing addressesLatest ICFS filing applicant street + ZIP per call sign, compared across the registrant's call signs.source: data.py35needs review
Registrant names spelled 2+ ways on the listSame name after the engine's normalization (case, punctuation, LLC/Inc). 43 call signs. The all-or-none election has to cover every spelling.source: data.py18 (36 spellings)needs review
Near-duplicate registrant pairs on the listEngine name score 0.8 or more between two different names; 397 names, 943 call signs. Many are affiliates; some are one entity.source: data.py358needs review
Call signs with no licensee FRN in ICFSsource: data.py9needs review
FAA registrant names spelled 2+ waysValid US turbine registrations. Near-duplicate pairs (score 0.8+): 8,397.source: data.py449 (970 spellings)needs review

Antennas and sites: the 2020 denial class

In 2020 the Bureau denied 34 of 1,510 lump sum elections (DA 20-1421). The named reasons were missing certifications, leaving out antennas on the list, and claiming antennas not on the list; 9 of the 34 were marked antenna or quantity mismatch. These are the places on the Oct 15, 2026 list where the same mismatch is waiting.

FindingCountClass
Antenna IDs filed under 2+ Site IDs within one call sign21 call signs. An election that names the antenna ID without the Site ID cannot be matched to one antenna.source: data.py62firm error
Street addresses filed under 2+ Site IDs within one call sign84 call signs.source: data.py169needs review
Site IDs filed at 2+ different street addresses3 call signs.source: data.py3firm error
List rows with a quantity above 1Where count mistakes happen: one row, several dishes.source: data.py1,571 rows, 5,312 antennasscale
Dish locations under 2+ call signs (engine, rule E10)Engine co-location table (integrity.json): 269 locations, 718 call-sign sites, 1,748 antennas.source: build.py (integrity.json)269needs review
Same, recomputed from the raw list (transitive, per call-sign site)799 call-sign sites, 1,987 antennas; 102 locations with 2+ registrant names. Broader than the engine because it chains locations.source: data.py304needs review
Site ZIP outside the site state63 call signs, 137 antennas. USPS ZIP3 ranges per state.source: data.py96 rowsneeds review
Site ZIP blank174 call signs; 115 rows have no street.source: data.py215 rowsneeds review
Site coordinates in the wrong hemisphere17 call signs: latitude south or longitude east, which puts a contiguous-US dish outside the country.source: data.py28 rowsfirm error

Stale, surrendered and pending call signs

The list is a snapshot of ICFS on Oct 15, 2026. Elections come months later, and call signs keep moving.

FindingCountClass
Call signs on the Nov 2025 list that left the Oct 2026 listChangelog: 224 surrendered, 12 expired. 166 registrant names on the 2025 list have no call sign left.source: data.py236firm error
List call signs whose latest ICFS filing is a surrenderICFS fetched Nov 5, 2026. On the list, but the FCC record now shows a surrender of authorization: stop until confirmed.source: data.py4firm error
List call signs whose latest ICFS filing carries an expiration date already past19 more expire before the estimated election deadline (Mar 25, 2027); 282 in all before the final transition deadline. A renewal may sit in another filing, so this is review, not rejection.source: data.py80needs review
List call signs whose latest ICFS filing has not been acted onDraft, filed with payment received, or accepted for filing.source: data.py26needs review
Call signs in "pending" filing state on the list itselfDA 26-1126 FilingState column.source: data.py5 (13 antennas)needs review
ICFS records with no status at allsource: data.py8needs review
Turbine US registrations not in valid statusMASTER status codes other than V (M: 671, 25: 547, R: 134, N: 58 ...). A claim on any of them fails A1.source: data.py1,485firm error
Valid turbine registrations that expire before the Oct 31, 2034 second deadlineOf 50,029; 587 have no expiration date. Owner of record has to be re-checked at payment, not only at intake.source: data.py49,442scale

Trust registrations and one entity behind many names

FCC 26-46 pays second-deadline rebates to owners as determined by the FAA Aircraft Registry. For trust-registered aircraft the owner of record is a bank acting as trustee, not the operator who paid for the retrofit.

FindingCountClass
Turbine aircraft with TRUSTEE in the owner name (Nov 4 FAA file, our Nov 6 FCC filing)12.1% of 50,043. Reply comments in GN Docket 25-59 on DA 26-1076, filed Nov 6, 2026; altimeter_facts.py.source: pressure/filings/fcc-da-26-1076-altimeter-reply/altimeter_facts.py6,036scale
Same rule on the Nov 6 FAA file422 trustee names; 12.1% of 50,029. "TRUST" anywhere in the name: 6,106.source: data.py6,029scale
Operator claims on trustee aircraft without a certification (A2)Scenario S5: every aircraft the engine flags as trustee-registered (6,109; 73 of them are trust companies without the word TRUSTEE). All rejected: $404.7M at the proposed amounts.source: engine.mjs6,109firm error
The four largest trustee institutions: aircraft (name spellings)Trustee-named registrations and the distinct spellings each institution appears under. A name-match rule has to know every spelling.source: data.py1,748 (5) / 1,482 (17) / 660 (6) / 623 (7)scale
Registrant names holding 10+ turbine aircraft19,996 aircraft; 26 names hold 100+; the largest single name holds 1,716. 19,326 names hold one.source: data.py348scale
One street address behind 10+ aircraft registrant names2,147 names, 5,046 aircraft; the busiest address carries 157 names. One payee account across many claimants is what rule X1 is for.source: data.py67needs review
C-band registrant names with 10+ sitesThey hold 39.3% of 6,012 sites; 4 hold 100+; one name holds 126 call signs. 1,978 names hold one site.source: data.py71scale
Control units (control group or lone registrant) with 10+ sites2,768 sites. The largest spans 11 registrant names and 148 sites. The 2020 rule made an operator and its affiliates elect for all stations or none.source: engine.mjs75scale
Organizations in both programs (C-band registrant and aircraft owner)1,049 aircraft. One payee, two streams: the same bank-account check has to span both.source: data.py (ontology)25scale
Ontology parents with 2+ aircraft-owning subsidiaries201 aircraft (SUBSIDIARY_OF links). Sanction links or OFAC obligations on either stream's organizations: 0.source: data.py (ontology)5scale

Run your own list before the committee does

Bidders: put your intake design against the real records. Bureau staff: check a list revision before it is published. Upload a CSV of claims to the console's pre-check (up to 60,000 rows, nothing is recorded) and get every rule's result with the reason and the record it was compared against. The template and a sample batch are in the console.

curl -s "https://shop.tensorust.com/api/clearinghouse/batch?dry=1&detail=0" \
  -H "content-type: text/csv" --data-binary @claims.csv

Agents can call the MCP tool clearinghouse_precheck at shop.tensorust.com/api/mcp. To talk about a pilot on your own files: mattbusel@tensorust.com.

How we counted

  • Engine. The console's own validation code, compiled unchanged and run over the full list and registry in one ordered ledger per scenario (engine.mjs).
  • Records. Counts that do not need a claim come straight from the source files, not from the engine's derived data (data.py). Names are compared with the engine's normalization (case, punctuation, LLC/Inc suffixes) and its name score (0.8 or more is "close").
  • Firm vs review. Firm: the record proves the claim cannot be paid as filed (a call sign gone from the list, an antenna that cannot be tied to one Site ID, a registration no longer valid, a trustee aircraft claimed by someone else without a certification). Review: a pattern a person must resolve (two spellings that may be one entity, a ZIP outside the site's state, a name that differs between FCC systems).
  • Two counts that differ, both shown. Trust registrations: 6,036 with TRUSTEE in the owner name on the Nov 4 FAA file (the figure in our Nov 6 reply comments on DA 26-1076), the same rule on the Nov 6 file, and the engine's wider trustee flag. Co-location: the engine's per-site table (269) and a transitive recompute from the raw list.
  • Limits. Turbine engine is our proxy for a radio altimeter. Near-duplicate names are compared within blocks that share a distinctive word, so that count is a floor. ICFS "latest filing" dates can coexist with a renewal in another filing, so they are review only. The ontology control graph found no sanctions links on either stream.

Sources

  • FCC DA 26-1126, Updated Incumbent C-band Earth Station List, current as of Oct 15, 2026 (xlsx, alphabetical sheet and changelog vs Nov 14, 2025)
  • FCC DA 25-960 (Nov 14, 2025) and DA 20-1424 (2020) incumbent lists
  • FCC ICFS call sign records (status, licensee name, FRN, applicant address, latest filing), fetched Nov 5, 2026
  • FCC LMS Form 323 ownership reports (snapshot Aug 16, 2026) for control groups and foreign-adversary flags
  • FAA Releasable Aircraft Database: MASTER and DEREG files of Nov 6, 2026; the engine snapshot of Nov 5, 2026
  • Tensorust ontology control graph (HOLDS, OWNS, SUBSIDIARY_OF, MEMBER_OF, SANCTIONED links; OFAC-SDN, FCC-FAC-FLAG obligations)
  • FCC DA 20-1421 (Nov 30, 2020), DA 26-1049 preliminary Cost Catalog, DA 26-1076 proposed altimeter amounts, FCC 26-46

Built 2026-11-06. Full fact sheet with every number and its script: available on request.

Built on the FCC incumbent list (DA 26-1126, Oct 15, 2026), preliminary Cost Catalog (DA 26-1049), proposed rebate amounts (DA 26-1076) and the FAA Aircraft Registry. Tensorust LLC is not affiliated with the FCC, FAA or the Upper C-band Clearinghouse.