The C000 segment was used for the EGA/VGA extension ROM. I'm guessing that using D000-EFFF would be unnecessary (because of the planar addressing squeezing 256kB of video memory into a 64kB address space), inconvenient (because the addresses wouldn't be contiguous - EGA and VGA were designed to coexist with either CGA or monochrome adapters in B000-BFFF) and (for VGA) insufficient - you'd still not have enough to map the entire 256kB of VRAM linearly. I also expect that IBM's engineers didn't want to take up all the extension ROM space because then it wouldn't be possible to add EMS cards, network cards, and whatever else ended up being mapped there. Though 192kB of write-only video memory in that space would be an interesting design!
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