Attachment ExplanatoryStatement

This document pretains to SES-MOD-20190523-00789 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2019052300789_1695575

Attachment FCC Form 312 May 2019 EXPLANATORY STATEMENT REGARDING THE C-BAND APPLICATION FREEZE The application to which this statement is attached is not subject to the freeze on C-band downlink band applications (3700 to 4200 MHz) that was announced on April 19, 2018. The FCC Public Notice announcing the freeze made clear that “modifications to correct location or other data required in the earth station file” were exempt from the freeze. See FCC Public Notice, “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,” DA 18-398, GN Docket Nos. 17-183, 18-122, slip op. at 3 (released April 19, 2018). The stated exception would definitively extend to data such as the geographic coordinates, street address, correct emissions designator and updated contact information. In the attached application, only the information required to report the necessary updates and corrections is provided; all other information contained in the current authorization remains the same. This application also includes information concerning additional antennas located at the site. It is not as plain whether this updated information falls squarely within the stated exception for “correct” information. In this instance, however, there is good cause for either accepting this additional corrected information under the stated exception or, alternatively, for waiving the freeze for good cause shown and accepting the updated information at this time. First, the “modification” of the registration does not arise from any affirmative change in operations but is simply an effort to correct the underlying authorization to include receive-only antennas that have been operational at this site for many years. During the filing window, the site was identified as one where an FCC receive-only registration already existed and therefore did not require an entirely new filing to register and protect the site. Second, consistent with its modification of or refiling for other previously-registered receive-only sites during the 2018 filing window, Sinclair believes that it is important for the Commission’s IBFS database to include complete information on the scope of receive-only use at each such location. There is a substantial operational difference between a site that has just one receive-only antenna pointed at a single satellite and a site that has multiple receive-only antennas pointed at different elevation angles at satellites ranging across the visible geostationary arc. Notably, the updated information provided here does not expand the footprint of the site, but simply provides full information regarding the nature of the operations. Accordingly, the public interest will be served by accurately including this information in the registration for each affected site so that the broad scope of current use can be taken into consideration both in the Commission’s ongoing C-band rulemaking proceeding and in any future coordination or band clearing efforts undertaken pursuant to rules adopted in that proceeding. Accordingly, to the extent required, the Bureau should waive the freeze to accept this updated information.


Document Created: 2019-05-23 15:53:05
Document Modified: 2019-05-23 15:53:05
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