Hughes 4.2.19 Expart

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Hughes Network Systems, LLC

Ex Parte

2019-04-02

This document pretains to SAT-AMD-20170908-00128 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2017090800128_1642246

April 2, 2019

By Electronic Filing

Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re:    Use of Spectrum Bands Above 24 GHz For Mobile Radio Services, Fifth Report and
Order, GN Docket No. 14-177; Hughes Network Systems, LLC, File Nos. SAT-LOA-20170621-
00092, SAT-AMD-20170908-00128 & SAT-MOD-20190212-00011

Dear Ms. Dortch:

         Pursuant to 47 C.F.R. § 1.1206, Hughes Network Systems, LLC (together with its
affiliates, “Hughes”) submits this ex parte letter summarizing its phone call with Tom Sullivan,
Jim Schlicting, Troy Tanner, Jennifer Gilsenan and Jose Albuquerque, all of the International
Brueau, on April 2, 2019, regarding the above-captioned proceedings. During the call, the
undersigned, Jennifer A. Manner, Senior Vice President, Regulatory Affairs expressed Hughes’s
support for the public draft of the Spectrum Frontiers Fifth Report and Order that is scheduled to
be considered during the April 2019 Federal Communications Commission Open Meeting.1 In
particular, Hughes supports the Commission’s intent to adopt rules for Fixed-Satellite Service
operations in the 50.4-51.4 GHz (“50 GHz”) band.2

       As noted in the draft Fifth Report and Order, several satellite operators, including
Hughes, have space station applications pending before the Commission that seek authority to
operate in the 50 GHz band. 3 The Commission has deferred action on this portion of the
applications “until sharing between terrestrial and satellite operations in the band, as well as
other uses of the band, are addressed in the context of the Spectrum Frontiers Proceeding.”4 The
50 GHz band is of particular importance to Hughes because it is constructing its Jupiter 3 space


1
 Use of Spectrum Bands Above 24 GHz For Mobile Radio Services, Fifth Report and Order, GN Docket
No. 14-177, FCC-CIRC1904-02 (Mar. 22, 2019) (“Fifth Report and Order”).
2
    Id. ¶¶ 8-12.
3
 Id. ¶ 11. See also Hughes Network Systems, LLC, Stamp Grant, IBFS File Nos. SAT-LOA-20170621-
00092 & SAT-AMD-20170908-00128 (Mar. 20, 2018).
4
 See O3b Limited, Request for Modification of U.S. Market Access for O3b Limited’s Non-Geostationary
Satellite Orbit System in the Fixed-Satellite Service and in the Mobile-Satellite Service, Order and
Declaratory Ruling, 33 FCC Rcd 5508, ¶ 32 (2018).


station and the associated gateway locations, all of which seek to operate in the 50 GHz band. 5
With the planned 2021 launch of the Jupiter 3 space station, Hughes will deliver high speed
broadband service, with speeds over 100 Mbps, to the United States and help bring the United
States to the forefront of 5G development.6

        The Commission has taken the critical step of placing the Fifth Report and Order on the
tentative agenda for the April 2019 Open Meeting.7 Importantly, the Commission recognizes in
the Fifth Report and Order that satellite “operators in this co-primary service seeking to proceed
with system development need this degree of regulatory certainty and should not have to wait
while the more complex issues associated with UMFUS licensing are addressed and resolved.”8
Hughes urges the Commission to adopt the Fifth Report and Order and to take swift action on
the Jupiter 3 FSS space station application and pending modification as well as the associated
gateway earth station. Decisive Commission action on Hughes’s applications will ensure the
timely delivery of much needed broadband capacity over the United States and help to propel the
United States forward in the race to 5G.

          Please direct any questions regarding this matter to the undersigned.

                                                    Respectfully submitted,




                                                    /s/ Jennifer A. Manner
                                                    Jennifer A. Manner
                                                    Senior Vice President, Regulatory Affairs

cc:       Umair Javed




5
 Hughes Network Systems, LLC, File Nos. SAT-LOA-20170621-00092, SAT-AMD-20170908-00128 &
SAT-MOD-20190212-00011; HNS License Sub, LLC, File Nos. SES-LIC-20170807-00876 et seq.
Hughes’s proposed use of the 50 GHz band is consistent with the rules included in the draft Fifth Report
and Order and no oppositions were filed in response to the space station or earth station applications.
6
  U.S. Dep’t of Commerce & Office of Science and Technology Policy-The White House, Driving the
Space Commerce Through Effective Spectrum Policy, at 6 (Mar. 2019), https://www.commerce.gov/-
sites/default/files/2019-03/DrivingSpaceCommerce.pdf. In addition, the European Union has highlighted
that satellites are part of the 5G solution for years. See European Commission, Research & Standards,
https://ec.europa.eu/digital-single-market/en/research-standards (last visited Mar. 26, 2019); European
Commission, 5G Vision: The 5G Infrastructure Public Private Partnership: the next generation of
communication networks and services, at 9 (Feb. 2015), https://5g-ppp.eu/wp-
content/uploads/2015/02/5G-Vision-Brochure-v1.pdf.
7
    News Release, FCC, FCC Announces Tentative Agenda for April Open Meeting (Mar. 22, 2019).
8
    Fifth Report and Order ¶ 11.


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Document Created: 2010-01-01 00:00:00
Document Modified: 2010-01-01 00:00:00

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