8 Satellites Operati

NOTICE submitted by Goldberg Godles Wiener & Wright LLP

Milestone Notification and Request for Public Not

2014-08-18

This document pretains to SES-LIC-20100723-00952 for License on a Satellite Earth Station filing.

IBFS_SESLIC2010072300952_1058368

                                               LAW OFFICES
                            GOLDBERG, GODLES, WIENER & WRIGHT LLP
                                     1229 NINETEENTH STREET, N.W.
                                      WASHINGTON, D.C. 20036-2413
    HENRY GOLDBERG                                                                        (202) 429-4900
    JOSEPH A. GODLES                                                                      TELECOPIER:
    JONATHAN WIENER                                                                       (202) 429-4912
    LAURA A. STEFANI                                                                          e-mail:
    DEVENDRA (“DAVE”) KUMAR                                                             general@g2w2.com

    HENRIETTA WRIGHT
    THOMAS G. GHERARDI, P.C.
    COUNSEL

    THOMAS S. TYCZ*
    SENIOR POLICY ADVISOR
    *NOT AN ATTORNEY




                                             August 18, 2014

FILED ELECTRONICALLY

Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
The Portals Building
445 12th Street, S.W. TW-A325
Washington, D.C. 20554

                                  Re:     O3b Limited
                                          Eight Satellites Into Operation Milestone
                                          Notification
                                          Request for Informative Public Notice
                                          Call Sign E100088

Dear Ms. Dortch:

       On September 25, 2012, the Commission issued a license (the “Hawaii Gateway
License”) authorizing O3b Limited (“O3b”) to operate a gateway earth station located in
Hawaii to communicate with O3b’s non-geostationary satellite orbit (“NGSO”) space
stations. 1 The grant of O3b’s application for the Hawaii Gateway License was
conditioned on O3b posting a $2 million performance bond assuring compliance with
two FCC milestones, the first of which is that O3b launch and place its first NGSO space
station into operation within one year of grant, i.e., by September 25, 2013, 2 and the

1   See File No. SES-LIC-20100723-00952, Call Sign E100088.
2Hawaii Gateway License, condition 90047. The Commission’s rules establish five milestones for NGSO
systems; require NGSO licensees to post a $5 million performance bond covering the five milestones; and
provide that the bond amount may be reduced by $1 million each time a milestone is satisfied. See 47
C.F.R. §§ 25.164(b), 25.165(a)(1), and 25.165(d). O3b already had satisfied the first three milestones by the


August 18, 2014
Page 2

second and final of which is that O3b bring eight satellites into operation within three
years, six months of grant (i.e., by March 25, 2016). 3 O3b filed a copy of its bond with
the Commission on October 24, 2012. 4

        Pursuant to Sections 25.145(f)(iv), 25.164(b)(4), and 25.165(d) of the Commission’s
rules, 5O3b previously provided a certification that it had satisfied the first milestone on
July 3, 2013. The Commission issued an Informative Public Notice on July 31, 2014,
stating that O3b had met the first milestone to launch and place into operation the first
satellite in its NGSO satellite system.

       Pursuant to Sections 25.145(f)(iv), 25.164(b)(4), and 25.165(d) of the Commission’s
rules, 6
       O3b hereby provides the attached certification that it has satisfied the second and
final FCC milestone. O3b launched its first four satellites on June 25, 2013 and its second
four satellites on July 10, 2014. These eight satellites have been placed in their
authorized non-geostationary orbit, and in-orbit operation of the space stations has
been tested and found to be consistent with the terms of O3b’s authorization.7
Accordingly, O3b has brought eight satellites into operation, which satisfies the final
FCC milestone.

       O3b respectfully requests that the Commission issue an Informative Public
Notice confirming that O3b has met this milestone and that, in accordance with Section
25.165(d), the amount of O3b’s bond may be reduced by the remaining One Million
Dollars.




time the Hawaii Gateway License was issued. See Letter, dated April 23, 2012, from Brian D. Weimer,
counsel to O3b, to Marlene H. Dortch, Secretary, FCC, File No. SES-LIC-20100723-00952.
3   Hawaii Gateway License, condition 90047.
4   See File No. SES-LIC-20100723-00952.
5   47 C.F.R. §§ 25.145(f) (iv), 25.164(b)(4), and 25.165(d).
6   47 C.F.R. §§ 25.145(f) (iv), 25.164(b)(4), and 25.165(d).
7On August 15, 2014, the Commission granted special temporary authority giving O3b the flexibility to
operate up to two of its satellites as in-orbit spares. See FCC File Nos. SES-STA-20140814-00656, SES-STA-
20140814-00657, and SES-STA-20140814-00658.


August 18, 2014
Page 3

      Please direct any questions concerning this filing to the undersigned.

                                               Respectfully submitted,




                                               Joseph A. Godles
                                               Attorney for O3b Limited

cc:   Joslyn Read, O3b Limited


                                            CERTIFICATION



 1.   | am the Chief Architect of 03b Limited ("O3b"), which is the holder of an FCC gateway
      earth station license (the "Hawaii Gateway License"), Call Sign £100088, thatis subject to
      two milestone conditions. In July 2013, the Commission found that O3b had satisfied the
      first of the two conditions by launching and placing into operation the first satellite in its
      NGSO satellite system. O3b has now satisfied the second and final of the two milestone
      conditions, which is to bring eight 03b satellites into operation within three years, six
      months of grant (i.e., by March 25, 2016).


 2. The first four 03b satellites were launched on June 25, 2013, and the second four 03b
      satellites were launched on July 10, 2014. These eight satellites have been placed in their
      authorized non—geostationary orbit, and in—orbit operation of the space stations has been
      tested and found to be consistent with the terms of O3b‘s authorization. Accordingly, O3b
      has brought eight satellites into operation, which satisfies the second and final milestone
      condition of the Hawaii Gateway License.


3.    | declare under penalty of perjury that the foregoing is true and correct to the best of my
      knowledge.




                                                        Jim Mowat
                                                        Vice President and
                                                        Chief Architect


August 18, 2014



Document Created: 2014-08-18 14:15:25
Document Modified: 2014-08-18 14:15:25

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