Attachment Explanatory Stmt

This document pretains to SES-AMD-20170414-00395 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2017041400395_1205254

Row 44 Inc. FCC Form 312 April 2017 Page 1 of 5 Attachment Description of Amendment to Application for Modification of License 1.0 OVERVIEW Row 44, Inc. (“Row 44”) submits this amendment to the currently pending modification application (FCC File No. SES-MFS-20170221-00188) regarding its Ku-band Earth Stations Aboard Aircraft (“ESAA”) license (Call Sign E080100) for the purposes of adding SES-10 (“SES-10”) at 67 W.L. as an additional point of communication. Row 44 seeks these modifications subject to all terms and conditions set forth in its current license1 and the operations proposed are consistent with the technical specifications set forth in Schedule B of the pending modification application. Operations using SES-10 would use both the TECOM Ku-Stream (SAA/Remote 2) and QEST Q050000 (GSAA/Remote 3) antennas. The Schedule B reflects only the changed or additional information relevant to this amendment, and does not recapitulate the technical data supplied in the underlying application. 2.0 ADDITIONAL POINT OF COMMUNICATION REQUESTED The addition to the Row 44 license of authority to communicate using SES-10 will provide replacement capacity for AMC-3, which was previously used at this location pursuant to Row 44’s existing license, and AMC-6, which has been used since December 2016 at this location under Special Temporary Authority, thereby allowing Row 44 to continue offering in-flight Wi-Fi connectivity to airline passengers on flights operating over North America. The Commission has granted a request to place SES-10 (S2950) on the Ku-band Permitted Space Station List (SAT-PPL- 20160117-00005), and complete technical information for this space station is therefore a matter for record before the Commission. Row 44 anticipates seeking special temporary authority to permit it to commence service using SES-10 in the near future. 3.0 COORDINATION CERTIFICATION [47 C.F.R. § 25.227(b)(2)] Row 44’s intended operations are within the scope that each operator of the requested target satellites has coordinated with the adjacent satellite operators, and should not cause harmful interference into adjacent satellites operating in accordance with FCC's two-degree spacing policy. Exhibit A attached hereto is a copy of the April 11, 2017 SES coordination certification letter covering Row 44’s proposed operations using SES-10. In the event that a Ku-band NGSO FSS system is launched in the future, Row 44 would enter into coordination with the NGSO FSS system operator to establish operating parameters that permit 1 See Row 44 Inc., Call Sign E080100, File No. SES-MFS-20150928-00635 (Sat. Div., granted August 19, 2016).

Row 44 Inc. FCC Form 312 April 2017 Page 2 of 5 successful co-frequency sharing, and would modify its operations as necessary to effect any coordination agreement reached. Row 44 acknowledges that the Commission may condition the grant of any modified license issued to it upon a requirement that it complete such coordination at the appropriate time. 4.0 TECHNICAL DATA, LINK BUDGETS AND PREDICTED COVERAGE AREAS [47 C.F.R. § 25.227(b)(4)] Exhibit B attached hereto includes representative link budgets and a depiction of the geographic coverage contours for operations using SES-10 at 67 W.L. 5.0 REVISED SPACECRAFT, FREQUENCY & BEAM COVERAGE [See Next Page]

Row 44 Inc. FCC Form 312 April 2017 Page 3 of 5 Table 1: Spacecraft, Frequency & Beam Coverage Table (All Provide Some Coverage to U.S. Locations) Beam Coverage Tx Rx Satellite Satellite Location Area (GHz) (GHz) Operator North America, AMC-1 129.15 W Central America 14.05-14.47 11.7-12.2 and Pacific North America, AMC-2 84.85 W Caribbean and 14.05-14.47 11.7-12.2 North Atlantic North America, Central America, AMC-3 72.0 W 14.05-14.47 11.7-12.2 Atlantic and Caribbean SES North America, Caribbean, Central AMC-9 83.0 W 14.05-14.47 11.7-12.2 America and North Atlantic North America, Central America, SES-1 101.0 W 14.05-14.47 11.7–12.2 Pacific and Caribbean North America, Central America, SES-10 67.0W 14.05-14.47 11/7-12.2 South Atlantic and Caribbean North America, 10.95-11.2, Central America, 11.2-11.45, IS-29E 50.0 W South America, 14.05-14.47 11.45-11.7, Intelsat North Atlantic and 11.7-12.2, Caribbean 12.2-12.5 Eutelsat North America, 114.9 W North Atlantic and 14.05-14.47 11.7-12.2 Eutelsat 115WB* Pacific Ocean * = Non-U.S.-licensed satellites included on Ku-band Permitted List = Satellite previously authorized for SAA antenna (Remote #2) at a different orbital location = Points of Communication Currently Authorized for SAA antenna (Remote #2)

Row 44 Inc. FCC Form 312 April 2017 Page 4 of 5 7.0 TELEPORT UPLINK LOCATIONS Table 2 Teleport Locations for Provision of Service within the United States Orbital Teleport Location(s) Site Satellite Call Sign(s) Location Operator Woodbine, VA (until May 2017) SES E900448 & E140054 AMC-1 129.15 W Holmdel, NJ (from May 2017) Hughes E160163 Woodbine, VA (until May 2017) SES E900448 & E140054 AMC-2 80.85W N. Las Vegas, NV (from May 2017) Hughes E940460 AMC-3 72.0 W Holmdel, NJ GEE/MTN E160163 AMC-9 83.0W North Las Vegas, NV Hughes E940460 SES-1 101.0W North Las Vegas, NV Hughes E940460 Level 3/ SES-10 67.0W Steele Valley, CA E950202 Vyvx IS-29E 50.0 W Holmdel, NJ GEE/MTN E160163 Eutelsat 114.9W Southfield (Detroit), MI Hughes E990170 115WB* * = Non-U.S.-licensed satellites included on Ku-band Permitted List

Row 44 Inc. FCC Form 312 April 2017 Page 5 of 5 7.0 LICENSEE CERTIFICATION I, Simon McLellan, Chief Engineer of Row 44, Inc., hereby certify that Row 44, Inc. will continue to comply with the requirements of paragraphs (a)(6), (a)(9), (a)(10), and (a)(11) of Section 25.227 of the Commission’s Rules and the conditions of its existing license. s/ Simon McLellan Simon McLellan Chief Engineer Row 44, Inc. April 12, 2017


Document Created: 2017-04-12 14:51:50
Document Modified: 2017-04-12 14:51:50
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