Attachment SuppStmnt

SuppStmnt

LETTER submitted by On behalf of Applicant

Supplementary Information regarding earth station operation

2008-04-15

This document pretains to SES-LIC-20080411-00456 for License on a Satellite Earth Station filing.

IBFS_SESLIC2008041100456_635623

"€TRMP & RETURN M Davis Wright Tremaine LLr ANCHORAGE BELLEVUE LOS ANGELES NEW YORK PORTLAND SAN FRANCISCO SEATTLE SHANGHALT WASHINGTON, D.C. CHRISTOPHER A. FEDELI SsUITE 200 TEL (202) 973—4200 DIRECT (202) 973—4274 1919 PENNSYLVANIA AVE NW FAX (202) 973—4499 chrisfedeli@dwt.com WASHINGTON, DC 20006 www .dwt.co m | FILED/ACCEPTED April 15, 2008 APR 1 5 2008 Via Hand Delivery Federal Communications Commission Office of the Secretary Marlene H. Dortch, Secretary Federal Communications Commission 445 12"" Street, SW Washington, DC 20554 Re: Supplemental Statement in Support of STA Request (File No. ' SES—STA—20080313—00298) and New License Request (File No. SES—LIC— 20080411—00456) Dear Ms. Dortch: Discovery World Television, Inc. ("Discovery"), through undersigned counsel, hereby provides the following supplemental information in support of the above—referenced pending applications for Special Temporary Authority ("STA") and for new licensing of a transmit— receive satellite earth station link ("Earth Station"). Although the Earth Station in question had been frequency—coordinated and properly licensed with the Commission, through an apparent administrative oversight Discovery did not timely file a request for renewal of the license in October 2007. Due to this oversight Discovery had no knowledge that Commission authorization for this Earth Station was no longer in effect until very recently. As a result, Discovery, in good faith and under the belief that it was entitled _ to operational authority under the Commission‘s rules, continued operations over this Earth Station. Following an internal license review, Discovery learned that this Earth Station authorization had expired and that no renewal application had been filed. At this time, Discovery immediately analyzed alternative means to send the video programming signals of Discovery‘s television networks for ultimate distribution to certain affected viewers and

Ms. Marlene H. Dortch > fi.i. April 15, 2008 Page 2 determined that continued use of the previously—licensed Earth Station link as proposed in the instant STA and new license request was the only way to achieve this task without subjecting viewers to potential extended blackouts of Discovery‘s programming. Specifically, Discovery determined that construction of new facilities or re—routing of this communications traffic to a different link would require an extended period of time during which there would be a significant risk that certain of Discovery‘s viewers would lose the ability to watch its programming, and so continued operations over the previously—licensed Earth Station link. Discovery then immediately sought to recoordinate the Earth Station transmit—receive link and filed an STA request with the Commission on March 13, 2008, followed by a new license application on April 11, 2008. Discovery has received no complaints of interference due to its operation of the link during this time, and the frequency coordinator has now reconfirmed that no such harmful interference exists. Discovery wishes to operate the Earth Station in full compliance with the Commission‘s rules, and believes that a prompt grant of the STA and new license requests is consistent with the public interest in light of the imminent loss of signal to Discovery‘s viewers which would occur without continued operation. Discovery has taken immediate steps to ensure that such an inadvertent failure to renew a license on file with the Commission does not occur in the future. Specifically, Discovery has now designated multiple responsible persons each with specific procedures to monitor all of Discovery‘s FCC authorization expirations and renewal dates to ensure redundancy in Discovery‘s future FCC licensing compliance. Indeed, it was as a result of Discovery‘s internal review that this issue and the need for improved compliance procedures was uncovered. Discovery wishes to confirm its commitment to ensure compliance with the Commission‘s rules and to work closely with Commission staff as it processes these appllcatlons as well in future applications and other pending matters. Should you have any questions, please do not hesitate to contact me. Respgctfull yours, Christopher A. Fedeli co: Mr. Scott Kotler


Document Created: 2019-04-19 19:40:05
Document Modified: 2019-04-19 19:40:05
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