STA Narrative

0124-EX-ST-2015 Text Documents

Eutelsat America Corp.

2015-02-10ELS_158863

Eutelsat America Corp. ELS File No. 0124-EX-ST-2015 REQUEST FOR SPECIAL TEMPORARY AUTHORITY I. Introduction Pursuant to Section 5.61 of the Commission’s regulations, 47 C.F.R. § 5.61, Eutelsat America Corp. (“EAC”) hereby requests special temporary authority (“STA”) to exhibit, demonstrate, and test the operational characteristics of its earth station terminals manufactured by the Kathrein Group (“Kathrein”), a Germany-based manufacturer of communications equipment and technology. Operations will occur (i) on the rooftop of EAC’s Washington, DC office; and (ii) at various customer facilities across the United States. STA is sought for a six- month period. The Commission previously approved EAC’s request to operate these terminals in the C-band; the instant request for STA seeks only to operate these same terminals in the conventional Ku-band.1 II. Description of Operations and Public Interest Statement EAC is an indirect subsidiary of Eutelsat S.A., a leading global satellite operator in Europe. Eutelsat S.A. operates a network of 34 geostationary satellites providing near-global coverage to a variety of industries. EAC, as Eutelsat S.A.’s American subsidiary, was established to serve the North American market, offering a wide range of broadband and data solutions to support both government and commercial customers. EAC submits the instant application in order to support the continued testing, exhibition, and small-scale demonstration of two new earth station terminals offered by its corporate parent, Eutelsat S.A.: the Kathrein CS 80 and the Kathrein CS 120. These innovative terminals incorporate technology whereby an electronic feed – a unique low-noise block downconverter (the “Smart LNB”) – is connected to a traditional direct-to-home (“DTH”) antenna with an embedded transmitter.2 The transmitter is based on an open standard and takes advantage of a narrowband return link, optimized for short transmissions of IP packets with low duty cycle. This technology – designed by Eutelsat – allows service providers partnered with Eutelsat to provide interactive applications for consumers, including push video on demand, pay-per-view, social TV, multiscreen viewing, personal subscription management and live show participation. The Smart LNB terminal is precisely the kind of innovative technology that the Office of Engineering & Technology is tasked to foster and support. This application is very similar to a recent grant of Special Temporary Authority and an Experimental License permitting EAC to test the LNB terminals both in its Washington, DC offices and at customer facilities nationwide.3 Building upon its successful demonstrations at the NAB Show in Las Vegas, NV, its Washington, DC offices, and various customer facilities, EAC 1 See File No. 0249-EX-ST-2014, granted April 1, 2014; see also File No. 0434-EX-PL-2014 (granted July 28, 2014) (the “Eutelsat Experimental Grants”). 2 See Exhibit A for a picture of the Smart LNB-enabled terminals. 3 See the Eutelsat Experimental Grants. SMRH:204043080.1 -1-

Eutelsat America Corp. ELS File No. 0124-EX-ST-2015 seeks to expand its ability to exhibit, demonstrate, and test the characteristics of the Smart LNB terminals by operating the terminals in the conventional Ku-band. These expanded operations will allow EAC increased flexibility to conduct additional long-term testing of the operational characteristics of the Smart LNB terminals, as well as the opportunity to demonstrate and exhibit the terminals to a larger audience of potential customers. As described above, EAC seeks to expand upon its initial experimental testing by undertaking merely one additional step: testing the smart LNB terminal’s operational capacity in the conventional Ku-band. Pursuant to its previous STA and experimental license, EAC has confirmed the operational characteristics of the Smart LNB terminal in the C-band. In order to expand the footprint and deployment of the smart LNB terminal, Eutelsat seeks to use this antenna in conjunction with its existing fleet of Ku-band satellites. As it has pursuant to the terms of its initial STA and Experimental License, EAC will coordinate with all necessary parties prior to operation of the Smart LNB terminals. At all times, testing will be conducted under the close supervision of EAC personnel. In addition, EAC plans to promptly modify its existing experimental authorization to add this Ku-band connectivity. The public benefits of these new terminals are numerous and a matter of record with the Commission. As a result of this cutting-edge technology, Smart LNB terminals will allow broadcasters to operate an ecosystem of linear television and other “connected TV” services via satellite. Additionally, it will allow broadcasters in the future to extend their service offerings to new domestic applications. The Smart LNB terminals are consumer-grade devices, intended as cost-effective solutions to provide millions of users with advanced, in-home interactive services based wholly on a satellite infrastructure. III. Test Frequencies and Coordination EAC seeks to transmit using the specific frequency range identified below: Frequency Range (MHz) Band 14.0 – 14.5 GHz Conventional Ku-band Uplink This frequency band is designated on a co-primary basis for use by the fixed-satellite services (“FSS”).4 Satellite-based connectivity for both the CAS 80 and CAS 120 terminals will be provided by the Eutelsat 113WA satellite (f/k/a “Satmex 6”), which is on the Commission’s Permitted Space Station List.5 The Satmex 6 satellite is authorized to provide service in this requested band.6 EAC will take all actions necessary to avoid causing interference to licensed users in the Ku- band, and will comply with any and all conditions imposed by the Commission. 4 See 47 C.F.R. § 2.106. 5 See FCC File No. SAT-PPL-20060329-00030, call sign S2695 (granted Aug. 4, 2006). 6 Id. SMRH:204043080.1 -2-

Eutelsat America Corp. ELS File No. 0124-EX-ST-2015 IV. Stop Buzzer and Contact Information The “Stop Buzzer” contact at EAC is Vince Walisko, who will be available 24 hours per day, 7 days per week to cease operations should any reports of harmful interference be received. Vince Walisko can be reached at: (202) 448-9667 (mobile) (202) 559-4336 (landline) vwalisko@eutelsatamerica.com (email) For any questions regarding this application, please contact: Brian D. Weimer Sheppard Mullin Richter & Hampton LLP 202-469-4904 (phone) 202-218-0020 (fax) bweimer@sheppardmullin.com (email) V. Conclusion For the reasons set forth above, EAC respectfully requests that the Commission expeditiously grant the requested STA in order to facilitate its continued development and implementation of innovative, consumer-oriented antenna terminals. SMRH:204043080.1 -3-


Document Created: 0400-04-27 00:00:00
Document Modified: 0400-04-27 00:00:00
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