Attachment Higher Ground Letter

This document pretains to SES-LIC-20150616-00357 for License on a Satellite Earth Station filing.

IBFS_SESLIC2015061600357_1099407

                                                                            2 3 0 0 N S T R E E T, N W
                                                                            SU ITE 700
                                                                            W ASHINGTON, DC 20037
                                                                            TEL    202.783.4141
                                                                            FA X   202.783.5851
                                                                            W W W .W BKL AW .C O M

                                                                            ADAM D. KR INSKY
                                                                            202.383.3340
                                                                            AKRINSKY@ WBKLAW.COM



August 14, 2015

BY EFILE

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

Re:    OET File No. 0124-EX-ML-2015
       IBFS File No. SES-LIC-20150616-00357 (Call Sign E150095)

Dear Ms. Dortch:

Pursuant to 47 C.F.R. § 1.65, Higher Ground LLC (“Higher Ground”), by its counsel, provides
the following additional information with respect to its above-referenced applications for an
experimental license modification and a blanket earth station license.

Higher Ground is committed to ensuring that its interference protection regime for C-band point-
to-point operations accounts for all point-to-point operational fixed licensees, operational fixed
applicants operating pursuant to pre-authorization construction, and temporary fixed licensees.
To that end, Higher Ground has entered an agreement with a frequency coordinator that will
enable it to incorporate temporary fixed licensees’ locations of operation into its database and
establish protection zones for those temporary fixed operations, even if such location information
is not submitted to the Universal Licensing System database. This arrangement will serve to
provide Higher Ground with notification of existing and future temporary fixed locations that
may be near SatPaq devices intending to operate under either experimental authority or the
proposed blanket earth station authorization.

For purposes of the experimental modification application, Higher Ground also proposes to
provide notice of its intent to operate SatPaq devices to the nearby point-to-point operational
fixed licensees, operational fixed applicants operating pursuant to pre-authorization construction,
and temporary fixed licensees. Such notification will include a 24/7 point-of-contact with
capability to control SatPaq operations.

Higher Ground is eager to promptly gain modified experimental authority so that it can prepare
to engage in expanded SatPaq testing in early Fall 2015, prior to the foliage changes on the East


August 14, 2015
Page 2

Coast. This will permit Higher Ground to assess SatPaq operations under diverse conditions.
Under its existing experimental license, Higher Ground has conducted SatPaq testing in the
authorized Palo Alto, California area and limited SatPaq testing for a short period in the
authorized Jackson, California area. Higher Ground is ready to expand its testing to additional
locations and seeks prompt action on its pending experimental modification application to allow
this to happen.

Please direct any additional questions regarding this matter to the undersigned.

                                                 Sincerely,



                                                 /s/ Adam D. Krinsky
                                                 Adam D. Krinsky
                                                 Counsel to Higher Ground LLC

cc:    Stephen Buenzow (FCC WTB)
       Nnake Nweke (FCC OET)
       Paul Blais (FCC IB)



Document Created: 2019-04-21 10:34:28
Document Modified: 2019-04-21 10:34:28

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