Attachment Explanatory Stmt

This document pretains to SES-MOD-20171002-01094 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017100201094_1284096

Row 44 Inc. FCC Form 312 October 2017 Page 1 of 5 ATTACHMENT Description of Application for Modification of License 1.0 OVERVIEW Row 44, Inc. (“Row 44”) seeks modification of its Ku-band Earth Stations Aboard Aircraft (“ESAA”) license (Call Sign E080100) for the purpose of adding Telstar 12 at 109.2° W.L. (“T12”) as an additional point of communication. Row 44 seeks this modification subject to all terms and conditions set forth in its current license1 and the operations proposed are otherwise consistent with the technical specifications set forth in its current license. Operations using T12 would use both the TECOM Ku-Stream (SAA/Remote 2) and QEST Q050000 (GSAA/Remote 3) antennas. The Schedule B reflects only the additional point of communication, and does not recapitulate the technical data contained in its current license. 2.0 ADDITIONAL POINT OF COMMUNICATION REQUESTED T12 is a U.S.-licensed satellite under Call Sign S2462 (FCC File No. SAT-MOD-20160513-00050), licensed to Skynet Satellite Corporation, a U.S. subsidiary of Telesat Canada. It is currently operating pursuant to a Canadian ITU registration at the 109.2° W.L. orbital location. The addition to the Row 44 license of authority to communicate using T12 will provide additional near term space segment capacity for Row 44’s ESAA network, thereby allowing it to provide improved coverage for the provision of its in-flight Wi-Fi connectivity services to airline passengers on flights operating over North America, the Gulf of Mexico and parts of the Caribbean Sea. Row 44 is concurrently seeking special temporary authority (“STA”) to permit it to commence service immediately using its SAA antenna (Remote #2) for communication via T12. 3.0 COORDINATION CERTIFICATION [47 C.F.R. § 25.227(b)(2)] Row 44’s intended operations are within the scope that Telesat has coordinated with the adjacent satellite operators, and should not cause harmful interference into adjacent satellites operating in accordance with FCC's two-degree spacing policy. Exhibit A attached hereto is a copy of the September 21, 2017 coordination certification letter covering Row 44’s proposed operations using T12. In the event that a Ku-band NGSO FSS system is launched in the future, Row 44 would enter into coordination with the NGSO FSS system operator to establish operating parameters that permit successful co-frequency sharing, and would modify its operations as necessary to effect any coordination agreement reached. Row 44 acknowledges that the Commission may condition the grant of any modified license issued to it upon a requirement that it complete such coordination at the appropriate time. 1 See Row 44 Inc., Call Sign E080100, FCC File No. SES-MFS-20170221-00188 (Sat. Div., granted July 20, 2017).

Row 44 Inc. FCC Form 312 October 2017 Page 2 of 5 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 T12 at 109.2 W.L. 5.0 REVISED SPACECRAFT, FREQUENCY & BEAM COVERAGE [See Next Page]

Row 44 Inc. FCC Form 312 October 2017 Page 3 of 5 Table 1: Spacecraft, Frequency & Beam Coverage Table (All Provide Some Coverage to U.S. Locations) Beam Coverage Tx Rx Satellite Satellite Location Area (GHz) (GHz) Operator North America, AMC-1 129.15 W Central America 14.05-14.47 11.7-12.2 and Pacific North America, AMC-2 84.85 W Caribbean and 14.05-14.47 11.7-12.2 North Atlantic North America, Central America, AMC-3 72.0 W 14.05-14.47 11.7-12.2 Atlantic and Caribbean SES North America, Caribbean, Central AMC-9 83.0 W 14.05-14.47 11.7-12.2 America and North Atlantic North America, Central America, SES-1 101.0 W 14.05-14.47 11.7–12.2 Pacific and Caribbean North America, Central America, SES-10 67.0W 14.05-14.47 11/7-12.2 South Atlantic and Caribbean 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 Eutelsat North America, 114.9 W North Atlantic and 14.05-14.47 11.7-12.2 Eutelsat 115WB* Pacific Ocean North America, Telesat Telstar 12 109.2 W Gulf of Mexico 14.05-14.47 11.7-12.2 (Skynet) and Caribbean * = Non-U.S.-licensed satellites included on Ku-band Permitted List

Row 44 Inc. FCC Form 312 October 2017 Page 4 of 5 7.0 TELEPORT UPLINK LOCATIONS Table 2 Teleport Locations for Provision of Service within the United States Orbital Teleport Location(s) Site Satellite Call Sign(s) Location Operator AMC-1 129.15 W Holmdel, NJ GEE/MTN E160163 AMC-2 80.85W N. Las Vegas, NV Hughes E940460 AMC-3 72.0 W Holmdel, NJ GEE/MTN E160163 AMC-9 83.0W North Las Vegas, NV Hughes E940460 SES-1 101.0W North Las Vegas, NV Hughes E940460 Level 3/ SES-10 67.0W Steele Valley, CA E950202 Vyvx IS-29E 50.0 W Holmdel, NJ GEE/MTN E160163 Eutelsat 114.9W Southfield (Detroit), MI Hughes E990170 115WB* Telstar 12 109.2W South Jordan, UT LBiSat LLC E030342 * = Non-U.S.-licensed satellites included on Ku-band Permitted List

Row 44 Inc. FCC Form 312 October 2017 Page 5 of 5 7.0 LICENSEE CERTIFICATION I, Simon McLellan, Chief Engineer of Row 44, Inc. (“Row 44”) and Global Eagle Entertainment, Inc. (“Global Eagle”), hereby certify that Row 44/Global Eagle 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. s/ Simon McLellan Simon McLellan Chief Engineer Row 44, Inc., a subsidiary of Global Eagle Entertainment, Inc. October 1, 2017


Document Created: 2017-10-01 21:30:03
Document Modified: 2017-10-01 21:30:03
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