Attachment Frequency Coordinati

This document pretains to SES-LIC-20181031-03653 for License on a Satellite Earth Station filing.

IBFS_SESLIC2018103103653_1565842

TelAlaska Cellular, Inc. FRN: 0003740768 REQUEST FOR WAIVER OF TEMPORARY FILING FREEZE By this application, TelAlaska Cellular, Inc. (“TelAlaska”) hereby petitions the International Bureau (the “Bureau”) to waive the temporary freeze on the filing of new applications for fixed- satellite service (“FSS”) earth station licenses in the 3.7-4.2 GHz Band (the “Filing Freeze”). 1 A waiver in this instance is appropriate as it will “serve the public interest and not undermine the objectives of the freeze.” 2 Section 1.925 of the FCC rules empowers the Commission to waive specific requirements of its rules upon request if (a) the underlying purpose of the rule would not be served or would be frustrated by the application of the rule, and a waiver would serve the public interest; or (b) unique or unusual circumstances are presented such that it would be inequitable, unduly burdensome or contrary to the public interest to enforce the rule, and the applicant has no reasonable alternative. 3 A waiver is appropriate here because TelAlaska is facing unique circumstances that warrant a deviation from the Filing Freeze and such deviation will serve the public interest. 4 Providing mobile and broadband service to Alaska is particularly challenging. Such 1 TelAlaska’s discovery of the need for a request for waiver to accompany its application for a new C-Band Earth Station arose during the project planning phase. See 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, 90 Day Window to File Applications for Earth Stations Currently Operating in 3.7-4.2 GHz Band, Public Notice, DA 18-398 (rel. Apr. 19, 2018) (“Filing Freeze PN”). 2 Id. at 3. 3 47 C.F.R. §1.925(b)(3). 4 Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990); WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972). 1


Document Created: 2018-10-31 17:56:34
Document Modified: 2018-10-31 17:56:34
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