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.


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                                                                           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.


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                                                                        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.




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

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