Attachment Freeze Waiver

This document pretains to SES-LIC-INTR2019-00816 for License on a Satellite Earth Station filing.

IBFS_SESLICINTR201900816_1637951

          REQUEST FOR WAIVER OF TEMPORARY FILING FREEZE


Arctic Slope Telephone Assoc Coop, Inc. (“ASTAC”) hereby petitions the
International 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. A waiver in this instance is appropriate as it will “serve
the public interest and not undermine the objectives of the freeze.

Previous applications have been submitted and accepted for filing, example
SES-LIC-20181031-03653, Call Sign E190040, requesting a waiver for the
temporary freeze in the 3.7 – 4.2 GHz Band.

A waiver is appropriate here as well, since ASTAC is facing unique
circumstances that warrant a deviation from the Filing Freeze and such
deviation will serve the public interest. ASTAC relies on the 3.7 - 4.2 GHz
band to provide communications services to rural Alaska.
Alaskan Ku-Band VSAT stations are geographically not available in all
markets, limiting broadband deployment opportunities. Access to Ka-Band
is lacking and none of the major Ka HTS operators are planning any new
satellites that will be able to serve Alaska in the next 5-7 years. Ka-Band is
not proven in Northern part of Alaska and not viable near or above the
Arctic Circle. The Ka-Band does not have the atmospheric penetration
capability of C-Band and is vulnerable to extended outages due to weather.

Allowing ASTAC to file and register for a new C-Band Earth Station would
permit ASTAC to continue to offer essential services to rural and remote
areas throughout Alaska. ASTAC has no reasonable alternative, as the C-
Band presents the only current economically viable option for providing
such communications services to these villages on a going-forward basis
as attempts to use microwave operations or the Ku-band have failed.
 ASTAC has a demonstrated need for this authorization to provide
necessary services now and in the future. Accordingly, for good cause
shown, ASTAC requests a waiver of the Filing Freeze, consistent with the
request for relief set forth herein, and any other such relief as the Bureau
may deem proper.



Document Created: 2019-03-20 15:18:06
Document Modified: 2019-03-20 15:18:06

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