Attachment Narr and Exhibits

This document pretains to SES-MFS-20160824-00738 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2016082400738_1147300

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Gogo LLC ) File No. SES-MOD-___________ ) Call Sign E120106 Modification to Blanket License for ) Operation of Ku-Band Transmit/Receive ) Earth Stations Aboard Aircraft ) MODIFICATION Gogo LLC (“Gogo”) hereby requests a modification of its blanket license to operate Ku-band transmit/receive earth stations aboard aircraft (“ESAAs”) on domestic and international flights. 1 Gogo requests that the Commission modify the Gogo ESAA License by adding the following spacecraft as authorized points of communication: Intelsat 20; Intelsat 29e; Intelsat 33e; Intelsat 907; AMC-3; AMC-21; and ASTRA 4A. A narrative description of the relevant changes is provided here, and Gogo is attaching an FCC Form 312 and Schedule B that identify the new points of communication and provide technical parameters for the ESAA operations. Supplemental technical information and copies of relevant coordination letters are attached as well. Pursuant to Section 25.117(c) of the Commission’s rules, Gogo is providing herein information that is changing as a result of the 1 See Call Sign E120106, File No. SES-MFS-20151022-00735, granted June 30, 2016 (the “Gogo ESAA License”). A pro forma assignment of the Gogo ESAA license to Gogo’s affiliate AC BidCo LLC (“AC BidCo”) has been approved by the Commission but has not yet been consummated. See File No. SES-ASG-20160714-00659, granted July 19, 2016. Gogo requests that upon consummation of the assignment, the Commission continue to process this modification application but replace Gogo with AC BidCo as the applicant.

modification. Gogo certifies that the remaining information provided in support of the Gogo ESAA License has not changed. 2 I. ADDITIONAL SATELLITES Gogo requests modification of its license to add the Intelsat 20; Intelsat 29e; Intelsat 33e; Intelsat 907; AMC-3; AMC-21; and ASTRA 4A satellites as points of communication for the Gogo ESAA network pursuant to the provisions of Section 25.227(a)(2) and (b)(2). As discussed below, each of the requested satellites is eligible for authority for use with the Gogo ESAA network. Updated tables listing the satellites to be used and the associated ground stations are provided in Annex 2 hereto. Intelsat 20: Intelsat 20 is a U.S.-licensed satellite positioned at the 68.5° E.L. orbital location, 3 and complete technical information regarding the satellite is therefore already on file with the Commission. 4 Gogo seeks authority to use Intelsat 20 capacity for ESAA operations on a primary basis in conventional Ku-band uplink spectrum, 14-14.5 GHz, and on an unprotected basis in the 10.95-11.2 GHz and 11.45-11.7 GHz downlink spectrum, consistent with the Commission’s orders in the ESAA proceeding 5 and with the terms of the satellite 2 For the Commission’s convenience, Gogo has attached as Annex 1 hereto a table listing the information required pursuant to Section 25.227 of the Commission’s rules and providing a cross-reference to the necessary information. 3 See Intelsat License LLC, Call Sign S2847, File No. SAT-LOA-20111024-00208, grant- stamped July 26, 2012. 4 Gogo has already commenced ESAA operations with Intelsat 20 pursuant to a grant of Special Temporary Authority. See Gogo LLC, File No. SES-STA-20160624-00610, granted June 30, 2016. 5 Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14-14.5 GHz Frequency Bands, Notice of Proposed Rulemaking and Report and Order, IB Docket Nos. 12-376 & 05-20, 27 FCC Rcd 16510 (2012) (“ESAA Order”); Second Report and Order and Order on 2

license. Gogo also seeks authority to use Intelsat 20 capacity for ESAA operations on a nonconforming basis in the 12.5-12.75 GHz downlink spectrum. Intelsat 20 will provide coverage of the Middle East. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of Intelsat 20 is included in Annex 3. Intelsat 29e: Intelsat 29e is a U.S.-licensed satellite positioned at the 50° W.L. orbital location, 6 and complete technical information regarding the satellite is therefore already on file with the Commission. Gogo seeks authority to use Intelsat 29e capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 10.95-11.7 GHz downlink spectrum, consistent with the ESAA Decisions and with the terms of the satellite license. Intelsat 29e will provide coverage of the United States. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of Intelsat 29e is included in Annex 3. Intelsat 33e: Intelsat 33e is a U.S.-licensed satellite positioned at the 60° E.L. orbital location, 7 and complete technical information regarding the satellite is therefore already on file with the Commission. Gogo seeks authority to use Intelsat 33e capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 10.95-11.2 GHz and 11.45-11.7 GHz Reconsideration, IB Docket No. 12-376, 29 FCC Rcd 4226 (2014) (“ESAA Second Order,” and with the ESAA Order, the “ESAA Decisions”). 6 See Intelsat License LLC, Call Sign S2913, File No. SAT-LOA-20130722-00097, grant- stamped May 21, 2015. 7 See Intelsat License LLC, Call Sign S2939, File No. SAT-LOA-20150327-00016, grant- stamped Feb. 25, 2016. 3

downlink spectrum, consistent with the ESAA Decisions and with the terms of the satellite license. Gogo also seeks authority to use Intelsat 33e capacity for ESAA operations on a nonconforming basis in the 12.5-12.6 GHz downlink spectrum. Intelsat 33e will provide coverage of Africa, Asia, and Europe. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of Intelsat 33e is included in Annex 3. Intelsat 907: Intelsat 907 is a U.S.-licensed satellite positioned at the 27.5° W.L. orbital location, 8 and complete technical information regarding the satellite is therefore already on file with the Commission. Gogo seeks authority to use Intelsat 907 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and on an unprotected basis in the 10.95-11.2 GHz and 11.45-11.7 GHz downlink spectrum, consistent with the ESAA Decisions and with the terms of the satellite license. Intelsat 907 will provide coverage of the East Pacific. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of Intelsat 907 is included in Annex 3. AMC-3: AMC-3 is a U.S.-licensed satellite positioned at the 67° W.L. orbital location, 9 and complete technical information regarding the satellite is therefore already on file with the Commission. Gogo seeks authority to use AMC-3 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum, consistent with the Commission’s ESAA Decisions and with the terms of the satellite license. 8 See Intelsat License LLC, Call Sign S2411, File Nos. SAT-LOA-20000119-00025 & SAT- MOD-20020918-00183, Memorandum Opinion Order and Authorization, 15 FCC Rcd 15460 (2000). 9 See SES Americom, Inc., Call Sign S2162, File No. SAT-MOD-20111220-00243, grant- stamped June 28, 2012. 4

AMC-3 will provide coverage of Mexico. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of AMC-3 is included in Annex 3. AMC-21: AMC-21 is a Gibraltar-licensed satellite positioned at the 124.9° W.L. orbital location. The Commission placed AMC-21 on the Permitted Space Station List for operations at this location in the conventional Ku-band, 10 and complete technical information regarding the satellite is therefore already on file with the Commission. Gogo seeks authority to use AMC-21 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and the 11.7-12.2 GHz downlink spectrum, consistent with the Commission’s ESAA Decisions and the satellite’s authorization. AMC-21 will provide coverage of the United States. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of AMC-21 is included in Annex 3. ASTRA 4A: ASTRA 4A is licensed by Sweden and positioned at the 4.8° E.L. orbital location. ASTRA 4A is not on the Permitted Space Station List, but its licensing administration, Sweden, is a member of the World Trade Organization (“WTO”). Accordingly, under the Commission’s DISCO II market access framework, there is a presumption that allowing the satellite to communicate with U.S.-licensed earth stations for services covered by the WTO Basic Telecommunications Agreement will serve the public interest. 11 10 See SES Satellites (Gibraltar) Limited, Call Sign S2676, File Nos. SAT-ASG-20080609- 00120 & SAT-PPL-20080929-00203, grant-stamped Aug. 6, 2008. 11 See Amendment of the Commission’s Policies to Allow Non-U.S. Licensed Space Stations providing Domestic and International Service in the United States, Report & Order, 12 FCC Rcd 24094, 24112, ¶ 39 (1997) (“DISCO II”). 5

Gogo seeks authority to use ASTRA 4A capacity for ESAA operations on a primary basis in the 14-14.25 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum, consistent with the Commission’s ESAA Decisions. Gogo also seeks authority to use ASTRA 4A capacity for ESAA operations on a nonconforming basis in the 12.2-12.75 GHz downlink spectrum. ASTRA 4A will provide coverage of Europe. A letter confirming that operation of the Gogo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of ASTRA 4A is included in Annex 3. In addition, Annex 4 contains technical materials regarding the proposed Gogo operations with ASTRA 4A, including a coverage map, link budgets, and an orbital debris mitigation statement. II. COORDINATION AND SPECTRUM SHARING MATTERS Attached as Annex 3 pursuant to Section 25.227(b)(2) of the Commission’s rules are copies of letters confirming that Gogo’s proposed ESAA operations are consistent with the coordination agreements between the satellites discussed above and operators of adjacent spacecraft. Furthermore, Gogo’s operations with the additional satellites will conform to the terms of the agreements between Gogo and the National Aeronautics and Space Administration and the National Science Foundation, as required by the Gogo ESAA License. 12 III. WAIVER REQUESTS Gogo seeks limited waivers of the Commission’s rules in connection with its request to add satellites as authorized points of communication for the Gogo ESAA network. Specifically, Gogo seeks a waiver of the Table of Allocations for its proposed operations in the 12.2-12.75 GHz spectrum and a waiver of orbital debris mitigation requirements for ASTRA 4A, 12 Gogo ESAA License, Special and General Provisions, Condition 90057. 6

which cannot fully vent propellants and/or relieve pressure vessels at end of life. Grant of these waivers is consistent with Commission policy: The Commission may waive a rule for good cause shown. Waiver is appropriate if special circumstances warrant a deviation from the general rule and such deviation would better serve the public interest than would strict adherence to the general rule. Generally, the Commission may grant a waiver of its rules in a particular case if the relief requested would not undermine the policy objective of the rule in question and would otherwise serve the public interest. 13 Section 2.106: Gogo requests waiver of the Table of Allocations in Section 2.106 of the Commission’s rules to permit use of downlink spectrum in the 12.2-12.75 GHz band range for ESAA operations. Gogo proposes to use capacity in part or all of this spectrum range on the following spacecraft: Intelsat 20; Intelsat 33e; and ASTRA 4A. Prior to adoption of the ESAA decisions, the Commission granted waivers for downlink operations in the 11.7-12.2 GHz conventional Ku-band downlink spectrum “based upon either a showing that the proposed AMSS downlink transmissions will not exceed the 10 dBW/4 kHz limit for routine processing in Section 25.134(g)(2) of the Commission’s rules or proof that adjacent satellite operators have consented to the operations.” 14 ESAA operators were also permitted to use extended Ku-band frequencies for ESAA downlinks pursuant to the same rationale. 15 The Commission has recognized that “terminals on U.S.-registered aircraft may 13 PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted). 14 See, e.g., Panasonic Avionics Corporation, Application for Authority to Operate Up to 50 Technically Identical Aeronautical Mobile-Satellite Service Aircraft Earth Stations in the 14.0- 14.4 GHz and 11.7-12.2 GHz Frequency Bands, Order and Authorization, 26 FCC Rcd 12557 (IB and OET 2011) at ¶ 11. 15 See Row 44 Inc., File No. SES-MFS-20100715-00903, Call Sign E080100, Attachment at 3 (requesting expansion of the waiver of Section 2.106 that Row 44 was granted for conventional Ku-band downlinks to cover the proposed use of the 11.45-11.7 GHz band), granted Dec. 23, 2010. 7

need to access foreign satellites while traveling outside of the United States (e.g., over international waters), and therefore may need to downlink in the extended Ku-band in certain circumstances.” 16 The Commission’s ESAA Decisions modified the Table of Allocations to permit ESAA operations in the conventional Ku-band, as well as in the 10.95-11.2 GHz and 11.45- 11.7 GHz segments of the extended Ku-band. The Commission acknowledged that ESAA operators may also wish to use other downlink spectrum, particularly for reception of transmissions from space stations with little or no U.S. coverage. 17 Although the Commission had not requested comment on changing the allocation status of this downlink spectrum, it specifically contemplated that access to such spectrum could be granted “on a case-by-case basis under Part 25 licensing rules.” 18 For example, the Commission has authorized Gogo and other ESAA providers to receive signals in the 12.2-12.75 GHz band. 19 Consistent with these past rulings, Gogo requests a waiver of the Table of Allocations to permit its terminals to receive transmissions from the ASTRA 4A spacecraft in the 12.2-12.75 GHz band; from the Intelsat 33e spacecraft in the 12.5-12.6 GHz band; and from the Intelsat 20 spacecraft in the 12.5-12.75 GHz band. None of these spacecraft is proposed to be used in U.S. airspace. As noted above, the satellite operators that will provide capacity to Gogo have coordinated the ESAA operations with satellites within six degrees. Authorizing Gogo to 16 Service Rules and Procedures to Govern the Use of Aeronautical Mobile Satellite Service Earth Stations in Frequency Bands Allocated to the Fixed Satellite Service, IB Docket No. 05-20, Notice of Proposed Rulemaking, 20 FCC Rcd 2906 (2005) at ¶ 18 (footnote omitted). 17 See ESAA Order at n.43. 18 Id. 19 See, e.g., Gogo Blanket License, Section B (authorizing use of the 12.2-12.75 GHz band); Panasonic Avionics Corporation, File No. SES-MFS-20150609-00349, Call Sign E100089, granted June 30, 2016 (the “Panasonic ESAA Grant”), Section B (authorizing use of the 10.7- 12.75 GHz band). 8

receive signals from these satellites will not alter the technical characteristics of the satellites’ operations in any way, and therefore will not create harmful interference to other authorized users of the spectrum. Furthermore, Gogo will not claim interference protection from such authorized users. Under these circumstances, grant of a Section 2.106 waiver is justified to permit use of the 12.2-12.75 GHz band for downlinks as part of the Gogo ESAA network. Section 25.283(c): Section 25.283(c) specifies requirements relating to venting stored energy sources at the spacecraft’s end of life. Specifically, the rule provides that upon completion of a satellite’s mission, “a space station licensee shall ensure, unless prevented by technical failures beyond its control, that all stored energy sources on board the satellite are discharged, by venting excess propellant, discharging batteries, relieving pressure vessels, and other appropriate measures.” 20 Gogo requests any necessary waiver of this requirement in connection with its request to communicate with the ASTRA 4A satellite, an in-orbit spacecraft that was not designed to allow complete venting at end of life. ASTRA 4A is a Lockheed Martin A2100 model spacecraft. As described in more detail in the attached Orbital Debris Mitigation Statement, the oxidizer tanks on the ASTRA 4A spacecraft were sealed following completion of the launch phase and will therefore retain residual pressure when the spacecraft is retired. Given the spacecraft design, it is physically impossible to vent the oxidizer tanks in order to comply with Section 25.283(c). Under Commission precedent, grant of a waiver is warranted. In a number of cases involving various spacecraft models with similar limitations, the Commission has waived Section 25.283(c) to permit launch and operation of spacecraft that do not allow for full venting of pressure vessels at end of life, based on a finding that modifying the space station design at a 20 47 C.F.R. § 25.283(c). 9

late stage of construction would pose an undue hardship. 21 In the case of ASTRA 4A, which is currently in-orbit, there is no question of bringing the satellite into compliance with the rule. The Commission has expressly recognized this, finding a waiver of Section 25.283(c) to be justified for in-orbit spacecraft that cannot satisfy the rule’s requirements. For example, in a decision involving the AMC-2 satellite, which is a Lockheed Martin A2100 design like ASTRA 4A, the Commission waived Section 25.283(c) on its own motion, observing that venting the spacecraft’s sealed oxidizer tanks “would require direct retrieval of the satellite, which is not currently possible.” 22 The same practical obstacle is present here. Because ASTRA 4A is already in orbit, it cannot be modified to enable full venting of residual pressure. Given this reality, a waiver is clearly warranted. 21 See, e.g., EchoStar Satellite Operating Corp., File No. SAT-LOA-20071221-00183, Call Sign S2746, grant-stamped Mar. 12, 2008, Attachment at ¶ 4 (granting a partial waiver of Section 25.283(c) for AMC-14, a Lockheed Martin A2100 model spacecraft, on grounds that requiring modification of satellite would present an undue hardship); DIRECTV Enterprises LLC, File No. SAT-LOA-20090807-00086, Call Sign S2797, grant-stamped Dec. 15, 2009, Attachment at ¶ 4 (same for DIRECTV 12, a Boeing 702 model spacecraft); PanAmSat Licensee Corp., File Nos. SAT-MOD-20070207-00027, SAT-AMD-20070716-00102, Call Sign S2237, grant-stamped Oct. 4, 2007, Attachment at ¶ 7 (same for Intelsat 11, an Orbital Sciences Star model spacecraft). 22 File No. SAT-MOD-20101215-00261, Call Sign S2134, grant-stamped Mar. 8, 2011, Attachment at ¶ 4. See also XM Radio Inc., File No. SAT-MOD-20100722-00165, Call Sign S2616, grant-stamped Oct. 14, 2010, Attachment at ¶ 2 (waiving Section 25.283(c) for XM-4, a Boeing 702 model spacecraft, because “modification of the spacecraft would present an undue hardship, since XM-4 is an in-orbit space station and venting XM-4’s helium and xenon tanks would require direct retrieval of the satellite, which is not currently possible”). 10

IV. CONCLUSION Gogo respectfully requests that the Commission modify the Gogo ESAA License to reflect the changes described herein. Respectfully submitted, GOGO LLC By: /s/ William J. Gordon______ Of Counsel William J. Gordon Karis A. Hastings VP, Regulatory Affairs SatCom Law LLC Gogo LLC 1317 F Street, N.W., Suite 400 111 North Canal Street Washington, D.C. 20004 Chicago, IL 60606 Tel: (202) 599-0975 Tel: (202) 870-7220 Dated: August 24, 2016 11

ANNEX 1: Table of Information Required by Section 25.227 Section 25.227 Requirement Citation to Information Provided 25.227(a)(1)(ii) & As Gogo has demonstrated, both ESAA antennas will maintain a pointing 25.227(a)(1)(iii) error of less than or equal to 0.2° between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna and will automatically cease transmission within 100 milliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna exceeds 0.5°, and transmission shall not resume until such angle is less than or equal to 0.2°. See File No. SES-AMD- 20120731-00709, Technical Appendix, Section 2.2.4; File No. SES-MFS- 20140801-00625, Technical Annex, Section 1.3. 25.227(a)(4) & N/A: no use of a contention protocol is proposed. 25.227(b)(5) 25.227(a)(5) & The 24/7 point of contact information remains the same. The phone number 25.227(b)(6) is +1 866-943-4662 and the e-mail address is noc@gogoair.com. The street address is: Gogo Network Operations Center, 111 North Canal Street, Chicago, IL, 60606, as specified in Form 312 Schedule B, Items E2-E9. 25.227(a)(15) Gogo certifications are in Annex 5 attached. 25.227(b)(2)(i), Target satellite operator certifications are in Annex 3 attached. (ii) & (iii) 25.227(b)(2)(iv) Gogo has previously demonstrated that its system will comply with coordination agreements and requirements to cease emissions. 1 25.227(b)(4) The ESAA network will operate in U.S. airspace, foreign airspace, and in the airspace over international waters. Coverage areas for the specific satellites to be used in the ESAA network are described in the table found in Annex 2 attached. Contours for the Intelsat 20; Intelsat 29e; Intelsat 33e; Intelsat 907; AMC-3; and AMC-21 satellites are already on file with the Commission. A coverage map for ASTRA 4A is included in Annex 4. 25.227(b)(7) Gogo certifications are in Annex 5 attached. 25.227(b)(8) No change to previously filed Radiation Hazard analyses. 25.227(c) Gogo’s coordination agreement with NASA was filed February 1, 2013 in File Nos. SES-LIC-20120619-00574 et al. 25.227(d) Gogo’s coordination agreement with NSF was included as Amendment Exhibit B in File No. SES-AMD-20120731-00709. 1 Gogo’s initial showing with respect to these requirements referred to the iDirect satellite modem used as part of the antenna control system. In the future, Gogo may incorporate modems from other manufacturers, but the antenna system will continue to function in the same way to ensure compliance with applicable coordination agreements and shut-off requirements. 1

ANNEX 2: Updated Spacecraft and Teleport Tables Use in US Satellite Satellite Location Beam Coverage Area Tx (GHz) Rx (GHz) airspace? Operator AMC-1 129.15W North America 14-14.5 11.7-12.2 Yes AMC-3 1 67W Mexico 14-14.5 11.7-12.2 Yes AMC-21 124.9W United States 14-14.5 11.7-12.2 Yes ASTRA 11.7-12.2; 4.8E Europe 14-14.25 No 4A 12.2-12.75 SES-1 101W North America 14-14.5 11.7–12.2 Yes SES SES-4 22W Europe 14-14.5 12.5-12.75 No 10.95-11.2; East Atlantic Ocean 14-14.5 No 11.45-11.7 SES-6 40.5W 10.95-11.2; West Atlantic Ocean 14-14.5 Yes 11.45-11.7 Galaxy 91W North America 14-14.5 11.7-12.2 Yes 17 North and South America IS-14 45W 14-14.5 11.7–12.2 Yes excludes Brazil IS-18 180E South Pacific 14-14.5 12.25-12.75 No Northeast Pacific 14-14.5 12.25-12.75 Yes Northwest Pacific IS-19 166E Australia 14-14.5 12.25-12.75 No Southwest Pacific 10.95-11.2; IS-20 68.5E Middle East 14-14.5 11.45-11.7; No 12.5-12.75 Brazil 14-14.5 11.7–12.2 No Intelsat IS-21 58W South Atlantic Ocean 14-14.5 11.45–11.7 No Mobility from Mideast to IS-22 72.1E 14-14.5 12.25–12.5 No Japan and to Australia 10.95-11.7; IS-29e 50W United States 14-14.5 Yes 11.7-12.2 10.95-11.2; 11.45-11.7; IS-33e 60E Africa, Asia, and Europe 14-14.5 No 11.7-12.2; 12.5-12.6 10.95–11.2; IS-904 60E Spot 1 - Western Russia 14-14.5 No 11.45-11.7 10.95–11.2; IS-907 27.5W East Pacific 14-14.5 Yes 11.45-11.7 1 This satellite is only used for communications with the ThinKom antenna system. 2

Tx Rx Use in US Satellite Satellite Location Beam Coverage Area (GHz) (GHz) airspace? Operator Eutelsat 115WB 114.9W North America 14-14.5 11.7-12.2 Yes (Satmex 7) Eutelsat Central and South 117WA 116.8W 14-14.5 11.7-12.2 Yes Eutelsat America (Satmex 8) 10.95-11.2; North Pacific and E172A 2 172E 14-14.5 11.45-11.7; No Northeastern Russia 12.2-12.75 10.95-11.2; Africa 14-14.5 11.45-11.7; No T-11N 37.5W 12.5-12.75 Telesat Atlantic 14-14.5 11.45-11.7 No T-18 138E Asia 14-14.5 12.2–12.75 No 11.45-11.7; JCSAT-2B 154E South Pacific 14-14.5 Yes 12.25-12.75 JSAT JCSAT-5A2 132E Japan 14-14.5 12.25-12.75 No 10.95-11.2; 183E Yamal 300K North Pacific Ocean 14-14.5 11.45-11.7; Yes (177W) 12.5-12.75 Gazprom Space 10.95-11.2; Systems Yamal 401 90E Russia 14-14.5 11.45-11.7; No 12.5-12.75 Asiasat 7 105.5E China 14-14.5 12.25-12.75 No AsiaSat 2 These satellites are only used for communications with the Aerosat antenna system. 3

Satellite Teleport Location FCC Call Sign AMC-1 Woodbine, MD E900448 AMC-3 Perris, CA E940448 AMC-21 Woodbine, MD E900448 ASTRA 4A Betzdorf, Luxembourg N/A SES-1 Woodbine, MD E920698 Bristow, VA E020071 SES-4 Bristow, VA E000696 SES-6 Betzdorf, Luxembourg N/A Galaxy 17 Atlanta, GA ATL-K26 E990214 ATL teleport ATL-C06 E940333 IS-14 ATL teleport ATL-K15 E090093 IS-18 Napa teleport NAP-K22 E990224 Perth, Australia N/A IS-19 Napa teleport NAP-K31 E980460 Napa teleport NAP-C30 E980467 IS-20 Fuchsstadt, Germany N/A Rio de Janeiro, Brazil N/A IS-21 Mobility: MTN teleport MTN-K02 E030051 IS-22 Kumsan, Korea N/A IS-29e Hagerstown, MD E030103 Fuchsstadt, Germany N/A IS-33e Moscow, Russia N/A IS-904 Moscow, Russia N/A IS-907 Hagerstown, MD E030103 Eutelsat 115WB Brewster, WA E120043 (Satmex 7) Eutelsat 117WA Brewster, WA E060416 (Satmex 8) E172a Khabarovsk, Russia N/A T-11N Aflenz, Austria N/A T-18 China (City TBD) N/A JCSAT-2B Kapolei, HI E010236 JCSAT-5A Yokohama, Japan N/A Yamal 300K Brewster, WA BRW-05C E120043 Yamal 401 Moscow, Russia N/A Asiasat 7 Beijing, China N/A 4

ANNEX 3: Satellite Company Letters 5

6

INTELSAT. Envision. Connect. Transform May 16, 2016 Federal Communications Commission International Bureau 445 12th Street, SW. Washington, D.C. 20554 Re: Engineering Certification of Intelsat for Is—2%e Satelite To Whom It May Concern: This letter confirms that Intelsat is aware that Gogo LC ("Gogo") is planning to seek a modification to its blanket authorization (the "Modification Application") from the Federal Communications Commission ("FCC") to operate two types of Ku band transmitfeceive earth stations aboard aircraft ("ESAAs"), Call Sign E120106. Amongother changes, the Modification Application will seek authority for Gogo‘s ESAA terminals to communicate with the 15—2%e satelite at 50° WL. under the current ESAA rules including Section 25.227 Based upon the representations made to Intelsat by Gogo concerning the contents ofits Modification Application: * INTELSAT acknowledges that the proposed operation of the Gogo ESAA terminals has the potential to create harmful interference to satelite networks adjacent to 15—2%e that may be unacceptable * Intelsat certifies that the proposed use of the ESAA transmit/receive terminals at the power density levels specified by: Gogo are consistent with existing coordination agreements to which INTELSAT is a party with all adjacent satelite operators within +/— 6 degrees of orbital separation from I5—2%e. * If the FCC authorizes the operations proposed by Gogo, Intelsat will include the power density levels specified by Gogo in all future satelite network coordination with other operators of satelites adjacentto 15—2%e. TAlA~ Armand Kadrichu Senior Technical Advisor, Spectrum Strategy inTeusat 7900 Tysons One Place, McLean, VA 221025972 T+1 703—559—7525. Ma1 202—445—4377 armand kadrichu@intelsat.com Intebat Coporation 7900 Tsons One Mac, Mclean, VA 22102:5972 USA wwrwintesatcom T +1 703—550—6200

INTELSAT. Envision. Connect. Transform May 16, 2016 Federal Communications Commission International Bureau 445 12th Street, SW. Washington, D.C. 20554 Re: Engineering Certification of Intelsat for Is—33e Satelite To Whom It May Concern: This letter confirms that Intelsat is aware that Gogo LC ("Gogo") is planning to seek a modification to its blanket authorization (the "Modification Application") from the Federal Communications Commission ("FCC") to operate two types of Ku band transmitfeceive earth stations aboard aircraft ("ESAAs"), Call Sign E120106. Amongother changes, the Modification Application will seek authority for Gogo‘s ESAA terminals to communicate with the 15—33e satelite at 60° EL. under the current ESAA rules including Section 25227 Based upon the representations made to Intelsat by Gogo concerning the contents ofits Modification Application: * INTELSAT acknowledges that the proposed operation of the Gogo ESAA terminals has the potential to create harmful interference to satellite networks adjacent to Is—33e that may be unacceptable, * Intelsat certifies that the proposed use of the ESAA transmit/receive terminals at the power density levels specified by Gogo are consistent with existing coordination agreements to which INTELSAT is a party with all adjacent satelite operators within +/— 6 degrees of orbital separation from Is—33e * If the FCC authorizes the operations proposed by Gogo, Intelsat will include the power density levels specified by Gogo in all future satelite network coordination with other operators of satelites adjacent to 15—33¢. Sincerely, OM Armand Kadrichu Senior Technical Advisor, Spectrum Strategy inteusat 7900 Tysons One Place, McLean, VA 221025972 T+1 703—559—7525 M +1 202—445—4377 armand kadrichu@intelsat.com Inteat Coporation 7900 Trsons One Hac, Metean, VA 22102:5972 USA wwrwintesatcom T +1 703—550—6200

INTELSAT. Envision. Connect. Tansform May 16, 2016 Federal Communications Commission International Bureau 445 12th Street, SW Washington, D.C. 20554 Re: Engineering Certification of Intelsat for 15—907 Satellite To Whom It May Concern: This letter confirms that Intelsat is aware that Gogo LC ("Gogo") is planning to seek a modification to its blanket authorization (the "Modification Application") from the Federal Communications Commission ("FCC") to operate two types of Ku band transmitfeceive earth stations aboard aircraft ("ESAAs"), Call Sign E120106. Amongother changes, the Modification Application will seek authority for Gogo‘s ESAA terminals to communicate with the 15—907 satelite at 27.5° WL. under the current ESAA rules including Section 25.227 Based upon the representations made to Intelsat by Gogo concerning the contents ofits Modification Application: * INTELSAT acknowledges that the proposed operation of the Gogo ESAA terminals has the potential to create harmful interference to satellite networks adjacent to 15—907 that may be unacceptable. * Intelsat certifies that the proposed use of the ESAA transmit/receive terminals at the power density levels specified by: Gogo are consistent with existing coordination agreements to which INTELSAT is a party with all adjacent satelite operators within +/— 6 degrees of orbital separation from 15—907 * if the FCC authorizes the operations proposed by Gogo, Intelsat will include the powerdensity levels specified by Gogo in all future satelite network coordination with other operators of satelites adjacentto 15—907. Sincerely, QuA| Armand Kadrichu Senior Technical Advisor, Spectrum Strategy inteusat 7900 Tysons One Place, Mclean, VA 221025972 T+1 703—559—7525 M +1 202—445—4377 armandkadrichu@intelsat.com Inteat Coporaion 7900 Tsons One Mac, Mclean, VA 22102:5972 USA wanwinteatcom T +1 703—550—6200

SES* Federal Communications Commission International Bureau 445 12" Street, S.W. Washington, D.C. 20554 United States 4 August 2016 Subject: Engineering Certification of SES for the AMC—3 satellite To whom it may concern, This letter confirms that SES is aware that Gogo LLC (‘Gogo‘), licensed by the Federal Communications Commission (‘FCC®) as Gogo LLC, is planning to file an application seeking a modification to its blanket authorization (the *Modification Application") to operate Ku—band Earth Stations Aboard Aircraft (‘ESAA") transmitreceive terminals (Call Sign E120106) pursuant to ITU RR 5.504A and Section 25.227 of the Commission‘s rules, on domestic and international flights. Among other changes, the Modification Application will seek authority for Gogo‘s ESAA terminals to communicate with the AMC—3 satelite at 67°W.L., under the current ESAA rules, including Section 25.227. Based upon the representations made to SES by Gogo concerning how it will operate on AMC—3 according to its letter dated 2 August 2016: * SES acknowledges that the proposed operation of the Gogo ESAA terminals has the potential to create harmful interference to satellite networks adjacent to AMC—3 that may be unacceptable. * SES certifies that it has completed coordination as required under the FCC‘s rules and that the power density levels specified by Gogo are consistent with existing coordination agreements to which SES is a party with all adjacent satellite operators within +/— 6 degrees of orbital separation from AMC—3. * If the FCC authorizes the operations proposed by Gogo, SES will include the power density levels specified by Gogo in all future satelite network coordination with other operators of satellites adjacent to AMC—3. Yours Sincerely, Vice President Spectrum Development & Management Americas

SES* Kimberly M. Baum Vice President Spectrum Management & Development, Americas Federal Communications Commission International Bureau 445 12th Street, S.W. Washington, D.C. 20554 10 August 2016 Subject: Engineering Certification of SES for the AMC—21 Satellite To whom it may concern, This letter confirms that SES is aware that Gogo LLC (‘Gogo") is planning to file an application seeking a modification to its blanket authorization (the "Modification Application") from the FCC to operate Ku—band Earth Stations Aboard Aircraft (‘ESAA") transmit/receive terminals (Call Sign E120106) pursuant to ITU RR 5.504A and Section 25.227 of the Commission‘s rules, on domestic and international flights. Among other changes, the Modification Application will seek authority for Gogo‘s ESAA terminals to communicate with the AMC—21 satellite at 124.9° W.L., under the current ESAA rules, including Section 25.227. Based upon the representations made to SES by Gogo concerning how it will operate on AMC—21 according to its letter dated August 8, 2016 for ThinKom 2Ku antennas and August 10, 2016 for Aerosat HR6400 antennas: * SES acknowledges that the proposed operation of the Gogo ESAA terminals has the potential to create harmful interference to satellte networks adjacent to AMC—21 that may be unacceptable. * SES certifies thatit has completed coordination as required under the FCC‘s rules and that the power density levels specified by Gogo are consistentwith any existing coordination agreements to which SES is a party with adjacent satelite operators within +/— 6 degrees of orbital separation from AMC—21. * If the FCC authorizes the operations proposed by Gogo, SES will include the power density levels specified by Gogo in all future satellite network coordination with other operators of satellites adjacent to AMC—21. Yours Sincerely, Kimberly M. Baum SES Americom, Inc. Tel. +1 609 987 4000 1129 20th St NW #1000 Fax +1 609 987 4517 Washington, DC 20036 kimberly.baum@ses.com USA www.ses.com

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ANNEX 4: ASTRA 4A Coverage Map, Link Budgets, and Orbital Debris Mitigation Statement 13

Ku band: ECEE (EU) beam EIRP SES* Contours Shown sire reavg 527. Beampeak s 5 s «o as ar 4 as as Notes ‘Te adjacent plot shous the ~]| measured pertormance ofa tpicat satelitetransponder. Perfomance iferences should be expected between indivual ransponders Elevation Angles are shown at 0,5 and 10 Degrees

ASTRA 4A Link Budgets AeroSat Antenna Forward Link Budget Return Link Budget Hub Betzdorf, Terminal Ku Luxembourg Required Eb/No 3.5 dB Required Eb/No .9 dB Modulation 2-PSK Modulation 4-PSK Info Rate 1.03 KMps Info Rate 22.74 Mbps FEC Rate .5 FEC Rate 0.41 Carrier Spacing 1.3 Carrier Rolloff 1.2 Carrier Spreading 0.0 Satellite SFD @ 0 -91.7 dBW/m2 Satellite SFD @ 0 -79 dBW/m2 dB/K dB/K Transponder Atten 11.0 dB Transponder Atten 13 dB Transponder ID 4.224/4.224 Transponder ID 4.306/4.306 Hub Transmit Aircraft Transmit Frequency 17.77 GHz Terminal Satellite G/T 6.1 dB/oK Frequency 14.2 GHz Antenna Diameter 9.0 m Satellite G/T 2.3 dB/oK Carrier EIRP 75.33 dBW Antenna Diameter 0.74 m Ant. Input PFD -25.67 dBW/4kHz Carrier EIRP 42.7 dBW Path Loss 209 dB Ant Input PFD -13.3 dBW/4kHz Atm/Point/Pol Loss 0.5 dB Path Loss 207.0 dB Aircraft Receive Atm/Point/Pol Loss 0.7 dB Terminal Hub Receive Frequency 12.52 GHz Frequency 12.7 GHz Satellite EIRP 52.8 dBW Satellite EIRP 50 dBW Downlink PFD@ 13.41 dBW/4kHz Downlink PFD@ -12.7 dBW/4kHz Beam Center Beam Center Receive Gain 29 dBi Hub G/T 38.4 dB/oK Terminal G/T 11.7 dB/oK Path Loss 206.2 dB Path Loss 206 dB Other Losses 0.8 dB Other Losses 0.7 dB Transponder Transponder Total OPBO 4.4 dB Total OPBO 1 dB Carrier OPBO 38.8 dB Carrier OPBO 1 dB C/No Thermal Up 66.0 dB-Hz C/No Thermal Up 100.5 dB-Hz C/No Thermal Dn 71.3 dB-Hz C/No Thermal Dn 77 dB-Hz C/Io Total 83.3 dB-Hz C/Io Total 86.3 dB-Hz C/No+Io 64..8 dB-Hz C/No+Io 76.6 dB-Hz Add”l Link Margin 1.2 dB Add’l Link Margin 1.0 dB % BW per cxr 3.7 % % BW per cxr 100 % % Power per cxr 0.04 % % Power per cxr 100 % Xpdr BW Alloc 2.67 MHz Xpdr BW Alloc 33 MHz 15

ASTRA 4A Link Budgets ThinKom Antenna Forward Link Budget Return Link Budget Hub Betzdorf, Terminal 2Ku Luxembourg Required Eb/No 3.5 dB Required Eb/No 1.7 dB Modulation 2-PSK Modulation 4-PSK Info Rate 1.03 KMps Info Rate 22.74 Mbps FEC Rate .5 FEC Rate 0.41 Carrier Spacing 1.3 Carrier Rolloff 1.2 Carrier Spreading 2.0 Satellite SFD @ 0 -91.7 dBW/m2 Satellite SFD @ 0 -80.8 dBW/m2 dB/K dB/K Transponder Atten 11.0 dB Transponder Atten 4.0 dB Transponder ID 4.224/4.224 Transponder ID 4.306/4.306 Hub Transmit Aircraft Transmit Frequency 17.76 GHz Terminal Satellite G/T 6.1 dB/oK Frequency 14.2 GHz Antenna Diameter 9.0 m Satellite G/T 4.1 dB/oK Carrier EIRP 75.33 dBW Antenna Diameter 0.74 m Ant. Input PFD -25.67 dBW/4kHz Carrier EIRP 41.7 dBW Path Loss 209 dB Ant Input PFD -13.3 dBW/4kHz Atm/Point/Pol Loss 0.2 dB Path Loss 207.6 dB Aircraft Receive Atm/Point/Pol Loss 0.4 dB Terminal Hub Receive Frequency 12.52 GHz Frequency 12.7 GHz Satellite EIRP 51 dBW Satellite EIRP 50 dBW Downlink PFD@ 13.41 dBW/4kHz Downlink PFD@ -12.7 dBW/4kHz Beam Center Beam Center Receive Gain 33 dBi Hub G/T 38.4 dB/oK Terminal G/T 6.1 dB/oK Path Loss 206.2 dB Path Loss 206 dB Other Losses 0.8 dB Other Losses 0.7 dB Transponder Transponder Total OPBO 4.4 dB Total OPBO 1 dB Carrier OPBO 38.8 dB Carrier OPBO 1 dB C/No Thermal Up 66 dB-Hz C/No Thermal Up 100.5 dB-Hz C/No Thermal Dn 71.3 dB-Hz C/No Thermal Dn 77 dB-Hz C/Io Total 85.6 dB-Hz C/Io Total 86.3 dB-Hz C/No+Io 64..8 dB-Hz C/No+Io 76.9 dB-Hz Add”l Link Margin 1.2 dB Add’l Link Margin .6 dB % BW per cxr 3.7 % % BW per cxr 100 % % Power per cxr 0.04 % % Power per cxr 100 % Xpdr BW Alloc 2.67 MHz Xpdr BW Alloc 33 MHz 16

5E5* This document contains the information required under Section 25.114(d)(14) ofthe Federal Communications Commission‘s Rules for the ASTRA 4A satellite operating at 4.8° E.L. Spacecraft Hardware Design: SES has assessed and limited the amount of debris releasedin a planned manner during normal operations of ASTRA 4A. No debris is generated during normal on—station operations, and the spacecraft will be in a stable configuration. On—station operations require station keeping within the +/— 0.05 degree E—W and N—S control box, thereby ensuring adequate collision avoidance distance from other satellites in geosynchronous orbit. In the event that co—location within the same stationkeeping volume ofthis and another satellite is required, use of the proven Inclination—Eceentricity (I—E) separation method can be employed. This strategy is presently in use by SES to ensure proper operation and safety of multiple satellites within one orbital box. SES has also assessed and limited the probability ofthe space station becoming a source of orbital debris by collisions with small debris or meteoroids that could cause loss ofcontrol and prevent post—mission disposal. SES requires that spacecraft manufacturers assess the probability of micrometeorite damage that can cause any loss of functionality. This probability is then factored into the ultimate spacecraft probability of success. Any significant probability of damage would need to be mitigated in order for the spacecraft design to meet the required. probability of success of the mission. The design of the spacecraft locates all sources ofstored energy within the body of the structure, which provides protection from small orbital debris. Steps have been taken to limit the effects of any collisions through shielding, the placement of components, and the use of redundant systems. Minimizing Accidental Explosions: SES has assessed and limited the probability of accidental explosions during and after completion of mission operations. As part of the Safety Data Package, an extensive analysis is completed by the spacecraft manufacturer,reviewing each potential hazard relating to accidental explosions. A matrix is generated indicating the worst— case effect, the hazard cause, and the hazard controls available to minimize the severity and the probability of occurrence. Each subsystem is analyzed for potential hazards, and the Safety Design Package is provided for each phase ofthe program running from design phase, qualification, manufacturing and operational phase of the spacecraft. Also, the spacecraft manufacturer generates a Failure Mode Effects and Criticality Analysis for the spacecraft to identify all potential mission failures. The risk of accidental explosion is included as part of this analysis. This analysis indicates failure modes, possible causes, methods of detection, and compensating features ofthe spacecraft design. The design of the ASTRA 4A spacecraft is such that the risk of explosion is minimized both during and after mission operations. In designing and building the spacecraft, the manufacturer took steps to ensure that debris generation will not result from the conversion of energy sources on board the satellite into energy that fragments the satellite. All propulsion subsystem pressure

5E5* vessels, which have high margins ofsafety at launch, have even higher margins in orbit, since use of propellants and pressurants during launch decreases the propulsion system pressure. Burst tests are performed on all pressure vessels during qualification testing to demonstrate a margin of safety against burst. Bipropellant mixing is prevented by the use ofvalves that prevent backwards flow in propellant and pressurization lines. All pressures, including those of the batteries, are monitored by telemetry. At the end of operational life, after the satellite has reached its final disposal orbit, on—board sources ofstored energy will be depleted or secured, and the batteries will be discharged. However, at the end of ASTRA 4A‘s operational life, there will be oxidizer remaining in the tanks that cannot be vented. Following insertion ofthe spacecraft into orbit, the spacecraft manufacturer permanently sealed the oxidizer tanks by firing pyrotechnic valves. This is a design feature ofthe Lockheed A2100 series spacecraft that cannot now be changed or remedied. Information regarding the residual oxidizer in the tanksis as follows: Item Total Pressure [bar] Temp. [deg C] Total Mass [kg] Volume [1] Oxidizer(in two 657 19 21.5 12 interconnected tanks) The oxidizer tanks are well shielded, and the residual pressure in the tanks will be well below their maximum rating. The oxidizer in the tanks is MON—3 (N204 with 3% NO2). In addition to the oxidizer,the tanks include helfum pressurant, which has a residual mass of approximately 1.9 kg. Given the tank temperature, the majority ofthe residual oxidizer (over 8 liters) is in a liquid form. Accordingly, the pressure results above reflect the combined pressure ofthe helfum gas and the vapor pressure from the oxidizer that is in gas form, using a tank volume of approximately 649 liters (657 liters less the 8 liters occupied by the liquid oxidizer). Safe Flight Profiles: SES has assessed and limited the probability ofthe space station becoming a source of debris by collisions with large debris or other operational space stations. Specifically, SES has assessed the possibility of collision with satellites located at, or reasonably expected to be located at, 4.8° E.L. or assigned in the vicinity ofthat location. Regarding avoidance ofcollisions with controlled objects, in general, if a geosynchronous satellite is controlled within its specified longitude and latitude stationkeeping limits, collision with another controlled object (excluding where the satellite is collocated with another object) is the direct result of that object entering the allocated space. At 4.8° E.L., ASTRA 4A operates at an offset from SES‘s SES—5 satellite operating at the nominal 5.0° E.L. During regular operation there are no other satellites assigned to or reasonably

5E5* expected to be located at 4.8° E.L. or to nearby orbifal Tocations such that there would be an overlap with the stationkeeping volume of ASTRA 4A at 4.8° E.L. SES uses the Space Data Center ("SDC") system from the Space Data Association to monitor the tisk ofclose approach of its satellites with other objects. Any close encounters (separation of less than 10 km) are flagged and investigated in more detail. If required, avoidance maneuvers are performed to eliminate the possibility ofcollisions. During any relocation, the moving spacecraft is maneuvered such that it is at least 30 km away from the synchronous radius at all times. In most cases, much larger deviation from the synchronous radiusis used. In addition, the SDC system is used to ensure no close encounter occurs during the move. When de—orbit of a spacecraft is required, the initial phase is treated as a satellite move, and the same precautions are used to ensure collision avoidance. Post—Mission Disposal: Post—mission disposal of the satellite from operational orbit will be accomplished by carrying out maneuvers to a higher orbit. The upper stage engine remains part ofthe satellite, and there is no re—entry phase for either component. Post—mission disposal ofthe satellite from operational orbit will be accomplished by carrying out maneuvers to a higher orbit. The fuel budget for this operation is included in the satellite design. SES plans to maneuver ASTRA 4A to a disposal orbit with a minimum perigee of 258 km above the normal operational altitude. This proposed disposal orbit altitude is based on the following calculation pursuantto § 25.283 of the Commission‘s Rules. Area of the satellite (average aspect area): 54 m* Mass of the spacecraft: 2261.4 kg CR (solar radiation pressure coefficient): 0.98 Therefore the MinimumDisposal Orbit Perigee Altitude, as calculated under the IADC formula is: 36.021 km + (1000 x CR x A/m)= 36,044 km, or 258 km above the GSO are (35,786 km) SES intends to reserve 5.3 kg of fuel in order to account for post—mission disposal of ASTRA 4A. SES has assessed fuel gauging uncertainty and has provided an adequate margin of fuel reserve to address the assessed uncertainty. a2

ANNEX 5: Gogo Certifications Gogo LLC (“Gogo”), in support of the foregoing application to modify the Gogo ESAA License, hereby certifies as follows: 1. Gogo’s target space station operators have confirmed that Gogo’s proposed ESAA operations over international waters are within coordinated parameters for adjacent satellites up to 6 degrees away on the geostationary arc. 2. Gogo will comply with the requirements contained in paragraphs (a)(6), (a)(9), (a)(10), and (a)(11) of Section 25.227 of the Commission’s rules, 47 C.F.R. § 25.227. By: /s/ Timothy Joyce Timothy Joyce VP of RF Engineering Gogo LLC August 24, 2016 20


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