Cover letter + New S

LETTER submitted by GCI Communication Corp.

Cover letter + New Spacecraft Chart (72219)

2019-07-22

This document pretains to SES-MOD-20181030-03744 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2018103003744_1809296

July 22, 2019

VIA IBFS

International Bureau
Federal Communications Commission
445 12th Street, NW
Washington, DC 20554


Re:       GCI Communication Corp.
          Supplement to Pending Earth Station Modification Applications

To Whom it May Concern:

GCI Communication Corp. (“GCI”) is the licensee of the C-Band fixed satellite earth stations (the
“Earth Stations”) listed on the attached spreadsheet. Due to a currently-utilized C-Band satellite
reaching end-of-life, GCI needs to move its operations to a different C-Band satellite in order to
continue providing services on its existing Earth Stations. GCI must transition these Earth Stations
to the new spacecraft beginning in September 2019.

To effect this transition, on October 30, 2018, GCI submitted modification applications for the
Earth Stations to modify the western limit of the satellite arc to permit operation on the new
satellite. 1 Such modifications should be considered to be a request to “correct the location or other
required data in the IBFS file,” which are specifically contemplated by the Filing Freeze PN. 2
However, in an abundance of caution, GCI also submitted waiver requests in conjunction with each
modification application.

GCI urges the FCC to act expeditiously to grant the pending applications listed in the attached
spreadsheet by no later than September 3, 2019.




1 GCI also corrected certain Earth Stations’ geographic coordinates for accuracy pursuant to GCI’s overall review of its
earth station licenses in connection with the Filing Freeze. For such Earth Stations, the modification application also
involves a change in the earth station’s geographic coordinates of more than +/- 1 second in latitude or longitude from
the filed coordinates. Pursuant to the Filing Freeze PN, the International Bureau specifically stated that the freeze “does
not extend to . . . modifications to correct location or other data required in the earth station file.” Accordingly, such a
modification is consistent with the Filing Freeze PN. However, GCI included a waiver request for such modifications as
well, in an abundance of caution, to ensure that its proposed changes are accepted by the Commission.
2 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”); see also International Bureau Announces 90-Day Extension of
Filing Window, to October 17, 2018, to file Applications for Earth Stations Currently Operating in 3.7-4.2 GHz Band; Filing Options
for Operators with Multiple Earth Station Antennas, GN Docket Nos. 17-183, 18-122, Public Notice, DA 18-639 (IB June 21,
2018); International Bureau Announces Two-week Extension of Filing Window for Earth Stations Currently Operating in 3.7-4.2 GHz
Band, GN Docket No. 18-122, DA 18-1061 (October 17, 2018).


      2550 Denali Street • Suite 1000 • Anchorage, Alaska 99503-2751 • 907-868-5600


Accordingly, and pursuant to discussions with FCC International Bureau Staff, GCI submits this
letter to supplement the pending applications listed in the attached spreadsheet. 3

Please direct any questions to the undersigned.




Kara Leibin Azocar
Regulatory Counsel, Federal Affairs
GCI Communication Corp.




3 While the majority of applications listed on the attached spreadsheet are modification applications, GCI has also
included a new license application and accompanying STA request for the Kotlik location, which is also a necessary
component of GCI’s transition to the new satellite. GCI will be providing additional information for this application in
a separate supplement.


Location         Callsign   File#                    Filed date    PN Date
Kotlik           E020088    SES-LIC-20190509-00583   5/9/2019      None
Kotlik           E020088    SES-STA-20190509-00582   5/9/2019      None
Selawik          E960454    SES-MOD-20181030-03708    10/30/2018   None
Buckland         E960451    SES-MOD-20181030-03710    10/30/2018   None
Dutch Harbor     E900261    SES-MOD-20181030-03712    10/30/2018   None
Kiana            E960458    SES-MOD-20181030-03714    10/30/2018   None
Shungnak         E960456    SES-MOD-20181030-03719    10/30/2018   None
Kobuk            E960457    SES-MOD-20181030-03724    10/30/2018   None
Point Hope       E960461    SES-MOD-20181030-03731    10/30/2018   None
Levelock         E960437    SES-MOD-20181030-03732    10/30/2018   None
Ambler           E960459    SES-MOD-20181030-03733    10/30/2018   None
Anaktuvuk Pass   E960394    SES-MOD-20181030-03734    10/30/2018   None
Atqasuk          E960398    SES-MOD-20181030-03736    10/30/2018   None
Kivalina         E960460    SES-MOD-20181030-03740    10/30/2018   None
Deering          E960452    SES-MOD-20181030-03744    10/30/2018   None
Kotzebue         E960386    SES-MOD-20181030-03745    10/30/2018   None
Kodiak           E890566    SES-MOD-20181030-03746    10/30/2018   None
Noatak           E960395    SES-MOD-20181030-03750    10/30/2018   None
Wainwright       E960393    SES-MOD-20181030-03754    10/30/2018   None



Document Created: 2019-07-22 11:34:25
Document Modified: 2019-07-22 11:34:25

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