Chevak Letter (07222

LETTER submitted by GCI Communication Corp.

Chevak Letter (07222019)

2019-07-22

This document pretains to SES-LIC-20180608-01392 for License on a Satellite Earth Station filing.

IBFS_SESLIC2018060801392_1809826

July 22, 2019

VIA IBFS

International Bureau
Federal Communications Commission
445 12th Street, NW
Washington, DC 20554


Re:      GCI Communication Corp., Chevak Earth Station, License E180787
         Supplement to Pending License & STA Applications
         IBFS File Nos. SES-LIC-20180608-01392, SES-STA-20190404-00491


To Whom it May Concern:

Severe weather-related service disruptions to the microwave radio system located in Chevak, AK,
instigated GCI Communication Corp.’s (“GCI”) filing for a 60-day emergency STA on April 23,
2018 to immediately operate a C-Band fixed satellite earth station in this location (see IBFS File No.
SES-STA-20180423-00391 (filed April 23, 2018)) (“Initial STA”). GCI’s request was granted on
April 25, 2018.

On June 8, 2018, GCI filed an application for a license to operate a C-Band fixed satellite earth
station at Chevak, AK, Call Sign E020088 (the “License”) (see IBFS File No. SES-LIC-20180608-
01392 (filed June 8, 2018)) (the “License Application). GCI has been granted extensions of the
Initial STA, 1 and most recently filed an extension request on April 4, 2019, which remains pending
(see IBFS File No. SES-STA-20190404-00491) (the “STA Extension Application”) (the License
Application and STA Extension Application, collectively the “Applications”). GCI also submitted a
waiver request of the current filing freeze in conjunction with the Applications. 2 Pursuant to
discussions with FCC International Bureau Staff, GCI submits this letter to supplement the pending
Applications.




1 See IBFS File No. SES-STA-20180423-00391 (granted Apr. 25, 2018); IBFS File No. SES-STA-20180620-
01772 (granted July 31, 2018); IBFS File No. SES-STA-20180914-02716 (granted Sept. 21, 2018); IBFS File
No. SES-STA-20181119-03269 (granted Nov. 30, 2018); IBFS File No. SES-STA-20190128-00044 (granted
Feb. 8, 2019).
2See Temporary Freeze on Applications for New or Modified Fixed Satellite Service Earth Stations and Fixed Microwave
Stations in the 3.7-4.2 GHz Band, Public Notice, DA 18-398 (rel. Apr. 19, 2018).


      2550 Denali Street • Suite 1000 • Anchorage, Alaska 99503-2751 • 907-868-5600


GCI’s Critical C-Band Operations in Chevak

Grant of the requested Applications is necessary to provide important services to the rural Alaska
village of Chevak, including:

   •   Yukon Kuskokwim Health Corporation (YKHC)- Telehealth Services: Satellite data circuit
       supporting an internal/private point-to-point data network extension from YKHC
       Subregional Clinics. YKHC has health clinics in both Chevak and Hooper Bay (a
       subregional clinic), which GCI serves from this location. Uses of the satellite circuit likely
       include Voice-Over Internet Protocol (VoIP) calling, video teleconferencing,
       internal/private systems/records access, e-mail and other forms of communications.
   •   Kashunamiut School District in Chevak – Distance Learning Services: Satellite data circuit
       primarily supporting Internet access serving the Chevak school. Secondary access (not
       hosted by GCI but likely utilized by the school) via this Internet “pipe” include VoIP calling,
       video teleconferencing, internal/private systems/records access, etc.
   •   Lower Yukon School District (LYSD) – Distance Learning Services: Satellite data circuit
       primarily supporting Internet access serving the Hooper Bay school. Secondary access (not
       hosted by GCI but likely utilized by the school) via this Internet “pipe” include VoIP calling,
       video teleconferencing, internal/private systems/records access, etc.
   •   Federal Aviation Administration (FAA) – Federal Government Assistance: Satellite data
       circuits in both Chevak and Hooper Bay transport images from weather cameras to assist
       pilots in determining real-time local weather conditions throughout the state in an effort to
       reduce weather-related aviation incidents and last-minute changes to flight patterns.
   •   GCI’s Rural Wireless system: Satellite data circuit supporting GCI’s cellular/rural wireless
       system to provide wireless services in both Chevak and Hooper Bay, including wireless 911,
       subscriber authentication, voice trunking, wireless data, etc.
   •   Critical Long-Distance Voice Service: GCI offers Measured Toll Service (“MTS”) for
       consumers and businesses using the C-Band spectrum via trunking over the microwave radio
       system. For Chevak and Hooper Bay, this allows residents to contact state troopers and
       other emergency officials at all times via wireline 911 (for the Kusilvak or Kusilvac Census
       Area), but especially in critical situations.


Overview of Severe Weather in Chevak, AK

GCI’s C-Band earth station in the rural Alaskan village of Chevak is only used in circumstances
when the existing GCI TERRA C-Band microwave radio system experiences degraded service,
which cuts-off communications to approximately 2300 Alaskans in Chevak and Hooper Bay
(another rural Alaskan village served in tandem to the Chevak village). The microwave system is the
primary link to communications in these villages, supporting a variety of critical services described
above.

The GCI TERRA C-Band microwave radio system utilizes a mountaintop microwave repeater
location on Askinuk mountain. This site routinely experiences severe icing conditions the winter
and spring months. This severe icing has significantly damaged the microwave radio antennas and


waveguides , leading to link degradations and service outages. Below are two annotated pictures
(from 2018) showing the relative positions of the microwave radio antennas on this tower and the
links served from this site (Figure 1) and the type of severe icing that is common on the Askinuk
mountain tower (Figure 2). In an effort to account for the severe weather, GCI previously
reduced the height of the Askinuk tower by nearly 70-feet in order to reduce the risk of falling ice
and to minimize the damage that it causes to GCI’s microwave radio antennas and waveguides
however, despite this effort, GCI’s TERRA services are still severely impacted and disrupted.




               Figure 1: Askinuk Mt. Aerial Photo (Bing) w/ Deltanet/TERRA Inset (annotated)


               Figure 2: Askinuk Tower; Summer and Winter (3/15/2018) (annotated)



There are no Suitable Transmission Alternatives to the C-Band during the Chevak Winter
Season

GCI explored alternative methods of providing service to Chevak prior to seeking a waiver of the
Filing Freeze to file for an STA and license to operate on the C-Band. The result of this assessment
is that the C-Band is the exclusive means to provide telecommunications services into the remote


village of Chevak (and affecting approximately 2300 western Alaskans) when the severe weather
renders the microwave link unreliable, which has occurred consistently over the past two winters.

Alternative Satellite Bands: Prior to seeking the Initial STA, GCI initially intended to temporarily
operate in this area using flyaway Ku-Band VSAT stations, however these emergency deployments
proved unable to withstand the high wind and severe weather in this area of Alaska. As a general
matter, the currently available Ku- and Ka-band options are not realistic alternative options due to
(a) the limited lower link availability resulting from more challenging propagation conditions and
higher link margins required for Ku- or Ka-band fading; 3 (b) the prohibitively high cost associated
with replacing or upgrading ground segment equipment; and, (c) the lack of available Ku- or Ka-
band satellites having satisfactory coverage over the state of Alaska - in other words, there is not
enough capacity or coverage of Ku-band satellites to move all of the C-Band services and there is
minimal, if any, Ka-Band coverage in Chevak. For these reasons, the available alternative satellite
bands are not currently an option to replace GCI’s TERRA C-Band microwave radio system in
Chevak during episodes of severe icing.

Fiber: Utilizing existing or deploying new fiber is also not a suitable alternative for GCI’s services in
Chevak. The nearest location to Chevak that has existing fiber-optic facilities) is in Nome, AK,
which is hundreds of miles away from Chevak, and across the Bering Sea. The shortest distance
between Nome and Chevak includes both over-land and subsea components, making the route a
difficult one (financially, environmentally, reliably, etc.). To connect to that existing fiber would
require a new subsea fiber to be buried deep into hundreds of miles of arctic ocean floor and to lay
terrestrial fiber (either across the tundra or buried below the tundra), making the route a difficult one
(financially, environmentally, reliably, etc.). GCI investigated this possibility and realized that there
are significant challenges associated with such an effort that realistically prohibit such an effort.

    •   Deploying a new fiber along the coast would run over the Arctic tundra and would need to
        be safeguarded against damage caused by the complex and changing structure of permafrost,
        which can range in thickness from a single meter to many hundreds of meters. And, it
        would require permitting in a national wildlife refuge, which is generally not permitted. 4 In
        addition, uneven freezing and thawing at or near the surface can result in dramatic changes
        to landforms, such as ice wedges (i.e., growing cracks in the ground) and pingos (i.e., small
        hills that arise quickly due to subsurface pressures), which can damage buried fiber optic
        cable. 5


3 For instance, weather characteristics such as rain, snow, or fog may cause signal fade on these satellite
bands. This is especially concerning in Alaska, where snowfall could occur anytime from September to June,
and its natural attributes make it even more difficult to rely on other satellite bands.
4 Much of the land in rural Alaska is protected by numerous federal and state laws that limit human activity,

including the Alaska National Interest Lands Conservation Act, the National Wildlife Refuge System
Administration Act, the National Wildlife Refuge System Improvement Act of 1997, the Wilderness Act, the
Wild and Scenic Rivers Act, the Marine Mammal Protection Act, and the Arctic Refuge Comprehensive
Conservation Plan.
5 U.S. Fish & Wildlife Serv., Ice Wedges, Polygons, and Pingos,

https://www.fws.gov/refuge/arctic/permcycle.html (last visited July 17, 2019) (describing the process by


    •   A subsea fiber would be required to run hundreds of miles in the sea and would need to be
        safeguarded against additional elements, including ice and rough sea floors. 6

Both of these options are not viable alternatives in the instance that the Chevak station freezes up
and GCI must restore services in the middle of the Alaskan winter. In short, if it were feasible to
install fiber to serve Chevak, then GCI would have already done so.

Given the critical services being provided via C-Band in Chevak and the lack of alternatives methods
of serving this remote community, GCI urges the Commission to grant its waiver requests and
ultimately grant GCI a permanent C-Band earth station license in Chevak.

Please direct any questions to the undersigned.



Kara Leibin Azocar
Regulatory Counsel, Federal Affairs
GCI Communication Corp.

CC (via email):          Jennifer Gilsenen
                         Paul Blais
                         Kerry Murray




which the permafrost cycles through these changes); Nat’l Snow & Ice Data Ctr., All About Frozen Ground –
How Does Frozen Ground Affect Land? https://nsidc.org/cryosphere/frozenground/how_fg_affects_land.html
(last visited July 17, 2019) (describing how freezing and thawing in the Arctic can change the shape of the
land).
6Submarine fiber, particularly in Alaska’s cold and icy waters carries inherent risk. The more ice that
accumulates, the higher the probability of cuts to the fiber, resulting in decreased reliability.



Document Created: 2019-07-22 20:43:46
Document Modified: 2019-07-22 20:43:46

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