Attachment Hughes - Grant in pa

Hughes - Grant in pa

DECISION submitted by IB, FCC

grant in part in defer

2018-03-20

This document pretains to SAT-LOA-20170621-00092 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017062100092_1359373

**CRANT J PART / Derer in PBRT x« ggi ::n%ozct?oscsf o012¢ File#_SBT—LOB—20170621—000982 Call Sign S3OF7 GrantDate_O03/20/1% (or other identificr) Approved by OMB 3ee ‘ TermDates 5€€ h PP 306}6—067§ From _condifions qy conditions Date & Time Filed: Jun 21 2017 3:47:10:846PM reau Appraved: File Number: SAT—LOA—20170621—00092 + in part, corth_ Stepfieh 3. Dual) Callsign/Satellite ID: $3017 conditions Chie?f,Sedeilite Policg Bevich APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS FCC Use Only FCC 312 MAIN FORM FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description ofthis application to identify it on the main menu: HNS ISW Application 1—8. Legal Name of Applicant Name: Hughes Network Systems, LLC Phone Number: 301—428—5893 DBA Name: Fax Number: 301—428—2818 Street: 11717 Exploration Lane E—Mail: jennifer.manner@echostar.com City: Germantown State: MD Country: USA Zipcode: 20876 = Attention: Jennifer A. Manner

ATTACHMENT TO GRANT Hughes Network Systems, LLC IBFS File Nos. SAT—LOA—20170621—00092 & SAT—AMD—20170908—00128 IBFS File No(s): SAT—LOA—20170621—00092 GRANT IN PART/ : SAT—AMD—20170908—00128 DEFER IN PART— Licensee/Grantee: Hughes Network Systems, LLC (Hughes) With Conditions Call Sign: S3017 > Satellite Name: HNS—95W (also known as Jupiter 3) Orbital Location: 95.2° W.L. (required station— (+/— 0.05 degrees east—west station—keeping) keeping tolerance) Administration: United States of America Nature of Service: Fixed—Satellite Service (FSS) International Bureau Satellite Division Scope of Grant: Grant of authority to construct, deploy, and operate a geostationary orbit (GSO) space station providing fixed—satellite service. Consideration of Hughes‘s request for operations in the 50.4—51.4 GHz frequency band and associated waiver is deferred." Previous Grant(s): N/A — Service Area(s): North, South, and Central America. See IBFS File No. SAT—AMD—20170908—00128, Schedule S Tech Report, HNS 95W isoline contour.gxt Frequencies: 18.3—18.8 GHz (space—to—Earth) 18.8—19.3 GHz (space—to—Earth) (limited to operations outside the United States and possessions) 19.7—20.2 GHz (space—to—Earth) 27.5—28.0 GHz (Earth—to—space) 28.1—28.6 GHz (Earth—to—space) 29.3—29.9 GHz (Earth—to—space) 29.992—29.996 GHz (Earth—to—space) 40.0—42.0 GHz (space—to—Earth) 47.2—50.2 GHz (Earth—to—space) Telemetry, tracking, & command center frequencies: 19.705 GHz (space—to—Earth) 19.707 GHz (space—to—Earth) 29.993 GHz (Earth—to—space) 29.995 GHz (Earth—to—space) 1 In comments, The Boeing Company (Boeing) requested that the Commission avoid any action that may be viewed as favoring GSO FSS systems over non—geostationary (NGSO) FSS systems in the frequency bands between 37.5 and 52.4 GHz and that we condition grant on compliance with the outcome of WRC—19 Agenda Item 1.6 and any corresponding domestic regulations subsequently adopted. Boeing Comments at 5 (filed Nov. 13, 2017). In reply comments, Boeing further requested that Hughes be required to incorporate sufficient margin in its link budgets to address the range of protection criteria that could ultimately be adopted at WRC—19. Boeing Reply at 3 (filed Dec. 8, 2017). In an ex parte filing Boeing clarified that, with regard to its first point, "the need for NGSO system applications to protect GSO systems does not justify disparate processing of NGSO system applications on anything less than an expeditious basis." Boeing Ex Parte (filed Jan. 9, 2018). We address this point only by noting that the Commission has no policy of processing NGSO applications less expeditiously than GSO applications. Regarding Boeing‘s requests related to WRC—19 Agenda Item 1.6, we decline to include the requested conditions. Given that no limits have yet been adopted and it is not certain that limits will be adopted, we find that it would be premature to require Hughes to maintain certain margins in its link budget at this time. As with any license, Hughes will be required to comply with any relevant rule changes that we may adopt in the future. Page 1 of 5

ATTACHMENT TO GRANT Hughes Network Systems, LLC IBFS File Nos. SAT—LOA—20170621—00092 & SAT—AMD—20170908—00128 Unless otherwise specified herein, operations under this grant must comport with the legal and technical specifications set forth by the applicant or petitioner and with Federal Communication Commission‘s rules not waived herein. This grant is also subject to the following conditions: 1. Hughes must prepare the necessary information, as may be required, for submission to the International Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due diligence, and notification process of this space station, in accordance with the ITU Radio Regulations. Hughes will be held responsible for all cost—recovery fees associated with ITU filings. No protection from interference caused by radio stations authorized by other administrations is guaranteed unless coordination and notification procedures are timely completed or, with respect to individual administrations, coordination agreements are successfully completed. Any radio station authorization for which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments of other administrations. See 47 CFR § 25.111. In connection with the provision of service in any particular country, Hughes is obliged to comply with the applicable laws, regulations, rules, and licensing procedures of that country. Hughes must operate the HNS—95 W space station at the 95.2° W.L. orbital location in compliance with all existing or future coordination agreements for this location. Hughes must maintain the HNS—95 W space station within an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees of the 95.2° W.L. orbital location. Operations of the HNS—I5 W space station and associated earth stations must comport with the applicable uplink and downlink limits in 47 CFR § 25.140(a)(3) of the Commission‘s rules, unless Hughes coordinates any non—conforming operations with the operations of U.S.—licensed geostationary orbit space stations within 6 degrees of the 95.2° W.L. orbital location. Non—conforming operation must also be coordinated with respect to those operations of non—U.S.—licensed space stations within 6 degrees of 95.2° W.L. involving approved communications with U.S.—licensed earth stations. - Operations in the 18.3—19.3 GHz and 19.7—20.2 GHz frequency bands must complete coordination w1th U.S. Federal systems, in accordance with footnote US334 to the United States Table of Frequency Allocations, 47 CFR § 2.106, prior to being used. Operations in the 18.3—19.3 GHz and 19.7—20.2 GHz bands must be in accordance with any signed coordination agreement reached between Hughes and U.S. Federal operators. Two weeks prior to the start of any operations in the 18.3—19.3 GHz or 19.7—20.2 GHz bands, Hughes must provide contact information for a 24/7 point of contact for the resolution of any harmful interference to Jimmy Nguyen, Email: Jimmy.Nguyen@us.af.mil. The power flux—density (PFD) at the Earth‘s surface produced by the emissions from the HNS—9I5W space station, in the 18.3—19.3 GHz, 19.7—20.2 GHz, and 40.0—42.0 GHz frequency bands (space—to—Earth), must not exceed the applicable power flux—density limits contained in sections 25.138(a)(6), 25.140(a)(3)(iii), . and 25.208, and in Article 21 of the ITU Radio Regulations. Operations of the HNS—95 W space station in the 18.8—19.3 GHz (space—to—Earth) frequency band must not cause harmful interference to, or claim interference protection from, primary NGSO FSS systems licensed in the United States. Hughes must terminate operations immediately upon notification of harmful interference. No later than sixty days before the scheduled initial launch of each NGSO FSS satellite system licensed in the United States to operate in the 18.8—19.3 GHz (space—to—Earth) frequency band, Hughes must either: (1) notify the Commission in writing when an agreement has been reached with the NGSO satellite system operator, or (2) seek and obtain the Commission‘s approval of a modification of this license including detailed technical demonstrations of how Hughes will protect the NGSO FSS satellite system. If neither condition is met, Hughes must cease operations in the 18.8—19.3 GHz frequency band pursuant to this license until such time as compliance is demonstrated. Page 2 of 5

ATTACHMENT TO GRANT Hughes Network Systems, LLC IBFS File Nos. SAT—LOA—20170621—00092 & SAT—AMD—20170908—00128 10. Operations of the HNS—95 W space station in the 27.5—28.35 GHz (Earth—to—space) frequency band are secondary with respect to Upper Microwave Flexible Use Service (UMFUS) operations, except for FSS operations associated with earth stations authorized pursuant to 47 CFR § 25.136, and will comply with any determinations set forth in the Spectrum Frontiers Proceeding (GN Docket 14—177). 11. The 29.25—29.5 GHz band is designated for uplinks for FSS systems using geostationary satellites and for feeder uplinks for Mobile Satellite Systems using non—geostationary orbit satellites on a co—primary basis. Communications between U.S.—licensed earth stations and the HNS—95W space station in the 29.3—29.5 GHz band must comply with section 25.258 of the Commission‘s rules. 47 CFR § 25.258. 12. In accordance with footnote US211 to 47 CFR § 2.106, Hughes is urged to take all practicable steps to protect radio astronomy observations in the adjacent bands from harmful interference from its operations in the 40.0—42.0 GHz band. ' 13. Operations of the HNS—95 W space station in the 40.0—40.5 GHz frequency band mustbe successfully coordinated with Federal Space Research Service (SRS) facilities, pursuant to Recommendation ITU—R $SA.1396, "Protection Criteria for the Space Research Service in the 37—38 GHz and 40.0—40.5 GHz Bands." 14. Operations in the 47.2—48.2 GHz band must provide interference protection to the fixed and mobile services, except as authorized pursuant to 47 CFR § 25.136. 15. Any future grant of earth station licenses for operations with the HNS—95 W space station will be subject to the following condition, unless the condition is satisfied prior to such license grant: in the 48.94—49.04 GHz band, operations must be coordinated with radio astronomy stations operating on a co—primary basis in this band. 47 CFR § 2.106, footnote US342. 16. Any future grant of earth station licenses for operations with the HNS—95 W space station will be subject to the following condition: Hughes‘s earth station emissions into the 50.2—50.4 GHz band must comport with the limits contained in ITU—R Resolution 750 (REV. WRC—15) and/or footnote US156 to section 2.106 of the Commission‘s rules, 47 CFR §2.106, footnote US156, including any future revisions of footnote US156 to section 2.106. Such revisions may be introduced either because of modifications that may be approved by WRC—19 to Resolution 750, or as a result of a Commission rulemaking proceeding, independent of any ITU deliberation. 17. Prior to commencing operations with the HNS—95W space station, Hughes must file with the Commission the information required by section 25.172 of the Commission‘s rules, 47 CFR § 25.172. 18. This grant is based on a finding of compliance with section 25.114(d)(14)(i)—(iv) of the Commission‘s rules, 47 CFR § 25.114(d)(14)(i)—(iv), regarding design and operational strategies that will be used to mitigate orbital debris. Hughes states in its application that it has not yet selected a spacecraft manufacturer, and therefore its orbital debris mitigation plan is forward—looking." Upon finalization ofits space station design and prior to initiation ofservice, Hughes must seek and obtain the Commission‘s approval of a modification containing an updated description of the orbital debris mitigation plans for its system. 19. Hughes request for a waiver of section 25.114(c)(4)(vii) of the Commission‘s rules, 47 CFR § 25.114(c)(4)(vii), IS GRANTED. In response to a request from the Commission for additional information regarding its application, Hughes provided a revised isoline diagram and amended its Schedule S accordingly." We find that this showing, along with the other technical information provided with its application, is sufficient to support a waiver. > Hughes Application, Revised Technical Exhibit at 24—27. Although it appears that since filing its application Hughes has selected a spacecraft manufacturer, until the design is finalized Hughes‘s orbital debris mitigation plan remains prospective. 3 IBFS File No. SAT—AMD—20170908—00128, Schedule S Tech Report. Page 3 of 5

ATTACHMENT TO GRANT Hughes Network Systems, LLC IBFS File Nos. SAT—LOA—20170621—00092 & SAT—AMD—20170908—00128 20. Hughes request for a waiver of footnote NG165 section 2.106 of the Commission‘s Rules IS DISMISSED as MOOT. GSO operations in this band are permitted on a secondary basis. 47 CFR § 2.106. | 21. Hughes request for a waiver of section 25.156(d)(5) of the Commission rules, 47 CFR § 25.156(d)(5), IS DISMISSED as MOOT.* Section 25.156(d)(5) stated that in bands where the Commission has not adopted frequency—band specific service rules it will not consider applications for GSO—like operation after it has granted an application for NGSO—like operation in the same band, and vice versa, unless and until the Commission establishes NGSO/GSO sharing criteria for that frequency band. However, the Commission recently eliminated section 25.156(d)(5) in a rulemaking* and those rules are now in effect making a waiver of the rule unnecessary. 22. Hughes request for a waiver of the NGSO FSS Cut—off deadline for applications in the V—band IS DISMISSED as MOOT. By its own terms the application deadline of which Hughes requested a waiver applied only to NGSO FSS systems.© Consequently the HNS—95 W space station, a GSO—like system, was not covered by the filing deadline making a waiver unnecessary. 23. Hughes‘s request for a waiver of the application processing rules of sections 25.156(d)(3) and (4) of the Commission‘s rules, 47 CFR § 25.156(d)(3)—(4), IS DISMISSED as MOOT. Section 25.156(d)(3) requires the Commission to consider applications covering multiple service bands as separate applications |. for each band. As all the frequency bands requested by Hughes are addressed in this grant, no waiver of section 25.156(d)(3) is necessary. Section 25.156(d)(4) requires that applications for feeder—link authority be treated as an application separate from associated service bands. However, as an FSS system HNS—95 W by definition does not have feeder links‘ making waiver of section 25.156(d)(4) unnecessary. 24. Hughes must post a surety bond in satisfaction of 47 CFR §§ 25.165(a)(2) & (b) no later than April 19, 2018, and thereafter maintain on file a surety bond requiring payment in the event of a default in an amount, at minimum, determined according to the formula set forth in 47 CFR § 25.165(a)(2); and Hughes must launch the space station, position it in its assigned orbital location, and operate it in accordancewith the station authorization no later than March 20, 2023, 47 CFR § 25.164(a). This authorization will be null and void automatically, without further Commission action if Hughes fails to comply with any of these requirements. Failure to comply with the milestone requirement of 47 CFR § 25.164(a) will also result in forfeiture of Hughes‘s surety bond. By April 3, 2023, Hughes must either demonstrate compliance with its milestone requirement or notify the Commission in writing that the requirement was not met. 47 CFR § 25.164(f). 25. The license term for the HNS—I5W space station is 15 years and will begin on the date that Hughes certifies to the Commission that HNS—I5W has been successfully placed into orbit and its operations fully conform to the terms and conditions of this authorization. Hughes is directed to file its certification of commencement of operation with the Commission within five business days of HNS—I5W being placed into operation at the 95.2° W.L. orbital location. * In its waiver request, Hughes also references section 25.157(e)(1) of the Commission‘s rules, 47 CFR § 25.157(e). Hughes Application, Narrative at 13, note 60. To the extent that Hughes intended to request waiver of this rule, we note that such a waiver is unnecessary as by its terms section 25.157 applies only to NGSO—like systems and not to a GSO—like system like HNS—95W. 5 Update to Parts 2 and 25 Concerning Non—Geostationary, Fixed—Satellite Service Systems and Related Matters, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Red 7809, 7821—22, para. 39 (2017). © Cut—offEstablishedfor Additional NGSO—Like Satellite Applications or Petitions for Operations in the 37.5—40.0 GHz, 40.0— 42.0 GHz, 47.2—50.2 GHz, and 50.4—51.4 GHz Bands, Public Notice, 31 FCC Red 11957 (IB 2016). 7 47 CFR § 25.103. Page 4 of 5

ATTACHMENT TO GRANT Hughes Network Systems, LLC IBFS File Nos. SAT—LOA—20170621—00092 & SAT—AMD—20170908—00128 ‘Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned. This action is taken pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as amended, 47 U.S.C. § 309(h). Action March 20, 2018 Date: Term Dates From: see conditions To: see conditions Approved: Stephen J. Chief, Satellite Policy Branch Page 5 of 5

9—16. Name of Contact Representative Name: Jennifer A. Manner Phone Number: 301—428—5893 Company: Hughes Network Systems, LLC Fax Number: 301—428—2818 Street: 11717 Exploration Lane E—Mail: jennifermanner@echostar.com City: Germantown State: MD Country: USA Zipcode: 20876 — Attention: Jennifer A. Manner Relationship: Same CLASSIFICATION OF FILING 17. Choose the buttonnext to the b. classification that applies to thisfiling for @ b1. Application for License of New Station both questions a. and b. Choose only one (N/A) b2. Application for Registration of New Domestic Receive—Only Station for 17a and only one for 17b. (N/A) b3. Amendment to a Pending Application (N/A) b4. Modification of License or Registration a. (N/A) b5. Assignment of License or Registration (N/A) al. Earth Station (N/A) b6. Transfer of Control of License or Registration @ a2. Space Station (N/A) b7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite e b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States g74 b10. Replacement Satellite Application — no new frequency bands g4 b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined processing) £3 b12. Petition for Declaratory Ruling to be Added to the Permitted List (N/A) b13. Other (Please specify)

17¢. Is a fee submitted with this application? @ IfYes, complete and attach FCC Form 159. IfNo, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114). <3 Governmental Entity {74 Noncommercial educational licensee C Other(please explain): 17¢. Fee Classification BNY — Space Station (Geostationary) 18. If this filing is in reference to an existing station, enter: (a) Call sign of station: Not Applicable 19. If this filing is an amendment to a pending application enter: (a) Date pending application was filed: (b) File number of pending application: Not Applicable Not Applicable

TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply: E a. Fixed Satellite D b. Mobile Satellite D c. Radiodetermination Satellite D d. Earth Exploration Satellite D e. Direct to Home Fixed Satellite D £f. Digital Audio Radio Service D g. Other (please specify) 21. STATUS: Choose thebutton next to the applicable status. Choose 22. If earth station applicant, check all that apply. only one. Not Applicable C Common Carrier @ Non—Common Carrier 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these facilities: 4 Connected to a Public Switched Network C Not connected to a Public Switched Network @ N/A 24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s). D a. C—Band (4/6 GHz) D b. Ku—Band (12/14 GHz) E c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: 18300 Frequency Upper: 51400 (Please specify additional frequencies in an attachment)

TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. (N/A) a. Fixed Earth Station (N/A) b. Temporary—Fixed Earth Station (N/A) c. 12/14 GHz VSAT Network (N/A) d. Mobile Earth Station | @ e Geostationary Space Station. o f Non—Geostationary Space Station ) g Other (please specify) 26. TYPE OF EARTH STATION FACILITY: Not Applicable PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that Not Applicable apply.) ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental C Yes g No impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of the Commission‘s rules, 47 C.F.R. §§ 1.1308 and 1.1311, as an exhibit to this application. A Radiation Hazard Study must accompany all applications for new transmitting facilities, major modifications, or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station services are not required to respond to Items 30—34.

29. Is the applicant a foreign government or the representative of any foreign government? q3 Yes 30. Is the applicant an alien or the representative of an alien? C Yes O.No fod N/A 31. Is the applicant a corporation organized under the laws of any foreign government? «y Yes GN() @ N/A 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by _ «y Yes GNO @ N/A aliens or their representatives or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than «y Yes @ N/A one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 34. If any answerto questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATIONS

35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules? @ Yes { No IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents. 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license @ Yes ONO revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances. 37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling C Yes @ No the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an explination of circumstances. 38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, y Yes @, No guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of competition? IfYes, attach as an exhibit, an explanation of circumstances 39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending C Yes @No matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.

40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names, address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of beneficiaries. Also list the names and addresses of the officers and directors of the Filer. 41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is Yes g; No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes. / 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United. States? IfYes, ; Yes @ No answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No, proceed to question 43. 42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has coordinated or is in the process of coordinating the space station?

43. Description. (Summarize the nature of the application and the services to be provided). (If the complete description does not appear in this box, please go to the end of the form to view it inits entirety.) Appl icant seeks aut hority to l aunch and operate a geostationary orbit <Ka—band and & V— band satel lite at the nom nal 95 WL. orbital 1| ocati on. © Narrative 43a. Geographic Service Rule Certification @ A By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic coverage requirements specifiedin 47 C.F.R. Part 25. { B By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements. & C By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not feasible as a technical matter to do so, or that, while technically feasible, such services would require so many compromises in satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis demonstrating this claim are attached. ’ CERTIFICATION The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.

44. Applicant is a (an): (Choose the button next to applicable response.) «3 Individual g7y Unincorporated Association C3 Partnership C3 Corporation C» Governmental Entity @ Other (please specify) Limited Liability Company 45. Name of Person Signing 46. Title of Person Signing Jennifer A. Manner _ Senior Vice President, Regulatory Affairs 47. Please supply any need attachments. 1: Technical Exhibit 2: 3: WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503). 10

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fce.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507. 11


Document Created: 2018-03-22 16:42:49
Document Modified: 2018-03-22 16:42:49
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