Attachment Explanatory Stmt

This document pretains to SES-MFS-20190710-00898 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2019071000898_1785721

Global Eagle Telecom Licensing Subsidiary, LLC FCC Form 312 July 2019 Page 1 of 5 ATTACHMENT Description of Application for Modification of License 1.0 OVERVIEW Global Eagle Telecom Licensing Subsidiary, LLC (“Global Eagle”) seeks modification of its Ku- band Earth Stations Aboard Aircraft (“ESAA”) license (Call Sign E080100) for the purpose of adding an additional satellite point of communication – the SES-14 satellite (“SES-14”) located at 47.5° West Longitude. Global Eagle seeks this modification subject to all terms and conditions set forth in its current license and the operations proposed are otherwise consistent with the technical 1 specifications set forth in its current license. Operations using the additional satellites would use both the TECOM Ku-Stream (SAA/Remote 2) and QEST Q050000 (GSAA/Remote 3) antennas. The Form 312, Schedule B associated with this filing reflects only the addition of the SES-14 satellite and does not recapitulate all technical data contained in its current license. 2.0 ADDITIONAL POINT OF COMMUNICATION REQUESTED Global Eagle requests the addition of the SES-14 satellite that is authorized under Call Sign S2974 as a Ku-band Permitted List satellite for service to the United States (see FCC File No. SAT-PPL- 20160918-00093). The specific frequencies to be used on SES-14 satellite are registered with International Telecommunication Union by the administration of Brazil under the network identifier B-SAT-1W-2. Complete technical information regarding the SES-14 satellite was submitted to the FCC in the proceeding authorizing the satellite’s inclusion on the Ku-band Permitted List, which is cited in the foregoing paragraph. Global Eagle therefore simply requests that its existing ESAA license be updated to reflect use of SES-14 on a primary basis for ESAA operations in the 14-14.5 GHz and 11.7-12.2 GHz bands. The addition to the Global Eagle license of authority to communicate using SES-14 will provide additional near-term space segment capacity for Global Eagle’s ESAA network, thereby allowing it to provide greater system throughput and coverage for the provision of its in-flight Wi-Fi connectivity services to airline passengers on flights operating in the Eastern United States and between CONUS and Europe and the Caribbean. Global Eagle is concurrently seeking special temporary authority (“STA”) to permit it to operate using these same parameters on an expedited basis to begin service on or about July 17, 2019, 1 See Row 44 Inc., Call Sign E080100, FCC File No. SES-MFS-20180515-00624 (Sat. Div., granted 7/17/2018).

Global Eagle Telecom Licensing Subsidiary, LLC FCC Form 312 July 2019 Page 2 of 5 3.0 COORDINATION CERTIFICATION [47 C.F.R. §§ 25.227(b)(2) & 25.220(d)] Global Eagle’s intended operations are within the scope that SES S.A. has coordinated with the adjacent satellite operators within six degrees adjacent to SES-14 in either direction along the geostationary arc and should not cause harmful interference to any of these satellites operating in accordance with FCC's two-degree spacing policy. Exhibit A attached hereto provides copies of the coordination certification letter dated July 2, 2019 covering Global Eagle’s proposed operations using SES-14. Global Eagle is aware that multiple NGSO FSS systems have been authorized to provide service to the U.S. market using Ku-band spectrum. It is prepared to enter into discussions with these operators as service is launched in the United States to establish operating parameters that permit successful co-frequency sharing. Global Eagle would modify its operations if necessary to implement any coordination agreement reached. Global Eagle acknowledges that the Commission may condition the grant of any modified license issued to it upon a requirement that it ultimately complete such coordination. 4.0 TECHNICAL DATA, LINK BUDGETS AND PREDICTED COVERAGE AREAS [47 C.F.R. § 25.227(b)(4)] Exhibit B attached hereto includes representative link budgets and a depiction of the geographic coverage contours for operations using SES-14 at 47.5° W.L. 5.0 REVISED SPACECRAFT, FREQUENCY & BEAM COVERAGE [See Next Page]

Global Eagle Telecom Licensing Subsidiary, LLC FCC Form 312 July 2019 Page 3 of 5 Table 1: Spacecraft, Frequency & Beam Coverage Table (All Provide Some Coverage to U.S. Locations; * =Non-U.S., Permitted List Satellite) Beam Coverage Tx Rx Satellite Satellite Location Area (GHz) (GHz) Operator North America, AMC-1 130.9 W Central America and 14.05-14.47 11.7-12.2 Pacific North America, AMC-2 84.85 W Caribbean and North 14.05-14.47 11.7-12.2 Atlantic North America, Central America, AMC-3 72.0 W 14.05-14.47 11.7-12.2 Atlantic and Caribbean North America, Caribbean, Central AMC-9 83.0 W 14.05-14.47 11.7-12.2 America and North Atlantic North America, SES Central America, SES-1 101.0 W 14.05-14.47 11.7–12.2 Pacific and Caribbean North America, SES-10 67.0W Central America, 14.05-14.47 11.7-12.2 South Atlantic and Caribbean North America, SES-14 47.5 W North Atlantic and 14.05-14.47 11.7-12.2 Caribbean 10.7-10.95, North America, 10.95-11.2, Central America, SES-15 129.0 W 14.05-14.47 11.2-11.45, Caribbean and Pacific 11.45-11.7, 11.7-12.2 North America, 10.95-11.2, Central America, 11.2-11.45, IS-29E 50.0 W South America, 14.05-14.47 11.45-11.7, Intelsat North Atlantic and 11.7-12.2, Caribbean 12.2-12.5 North America, Eutelsat 115 WB* 114.9 W North Atlantic and 14.05-14.47 11.7-12.2 Pacific Ocean Eutelsat 11.2-11.45, Eutelsat 133 WA* 132.85 W North America and 14.05-14.47 11.45-11.7, Pacific 12.5-12.75 North America, Gulf Telesat Telstar 12 109.2 W of Mexico and 14.05-14.47 11.7-12.2 (Skynet) Caribbean

Global Eagle Telecom Licensing Subsidiary, LLC FCC Form 312 July 2019 Page 4 of 5 6.0 TELEPORT UPLINK LOCATIONS Table 2 Teleport Locations for Provision of Service within the United States Orbital Teleport Location(s) Satellite Site Operator Call Sign(s) Location AMC-1 130.9 W Holmdel, NJ GEE/MTN E160163 AMC-2 80.85 W N. Las Vegas, NV Hughes E940460 AMC-3 72.0 W Holmdel, NJ GEE/MTN E160163 AMC-9 83.0 W North Las Vegas, NV Hughes E940460 SES-1 101.0 W North Las Vegas, NV Hughes E940460 Level 3/ SES-10 67.0 W Steele Valley, CA E950202 Vyvx SES-14* 47.5 W Holmdel, NJ GEE/MTN E160163 SES-15 129.0 W South Mountain, CA SES E170139 IS-29E 50.0 W Holmdel, NJ GEE/MTN E160163 Eutelsat 115 WB* 114.9W Southfield (Detroit), MI Hughes E990170 Eutelsat 133 WA* 132.85 W Hawaii Pacific Kapolei, HI E010236 Teleport Telstar 12 109.2W South Jordan, UT LBiSat LLC E030342 * = Non-U.S.-licensed satellite included on Ku-band Permitted List

Global Eagle Telecom Licensing Subsidiary, LLC FCC Form 312 July 2019 Page 5 of 5 7.0 LICENSEE CERTIFICATION I, Simon McLellan, Chief Engineer of Global Eagle Entertainment, Inc. (“Global Eagle”), hereby certify that Global Eagle: (1) will continue to comply with the requirements of paragraphs (a)(6), (a)(9), (a)(10), and (a)(11) of Section 25.227 of the Commission’s Rules and the conditions of its existing license; and (2) has confirmed, as shown by the SES coordination letter submitted with this application, that the ESAA operations proposed herein are within coordinated parameters for adjacent satellites up to 6 degrees away on the geostationary arc. Simon McLellan Chief Engineer Global Eagle Entertainment, Inc. July 10, 2019


Document Created: 2019-07-10 16:10:30
Document Modified: 2019-07-10 16:10:30
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