Attachment Exhibit D

This document pretains to SES-MOD-INTR2018-05791 for Modification on a Satellite Earth Station filing.

IBFS_SESMODINTR201805791_1530387

Exhibit D Description of Application Pursuant to 47 C.F.R. §25.117(c), Ligado Networks Subsidiary LLC (“Ligado”) hereby requests authority to modify the earth station license that is the subject of this application (the “License,” call sign E930124) to reflect the pending change in orbital location of MSAT-2 (call sign AMSC-1) from its current position at 103.3°WL to a new location at 106.5°WL. Ligado is simultaneously filing with the Commission applications under §25.114(c) to (1) modify Ligado’s license for MSAT-2 to authorize operation at the new orbital location1 and (2) modify Ligado’s license for its mobile earth terminals (call sign E980179) to reflect the new orbital location. MSAT-2 is expected to be relocated from its current orbital position to 106.5ºWL in September/October 2018.2 To date, and as authorized by the Commission and ISED, the primary TT&C and feeder link earth stations that communicate with the MSAT-2 satellite are located in Allan Park, Ontario. Ligado will continue operating these earth stations to communicate with MSAT-2 in exactly the same way after relocation to the new orbital location. The earth station in Reston, Virginia that is the subject of this application is currently used as a backup facility in the event 1 See File No. SAT-MOD-20180912-00070 (filed Sept. 12, 2018). To the extent necessary, Ligado incorporates by reference the technical information submitted in that proceeding relevant to the relocation of MSAT-2. As noted in that filing, because 106.5°WL is an orbital location under Canadian authority, Ligado filed an application on August 20, 2018 with Innovation, Science & Economic Development (“ISED”) Canada to establish telemetry, tracking and command (“TT&C”) communications with MSAT-2 and will soon file a further application to operate the satellite’s service and feeder links from that location. Ligado has requested that the Commission indicate to ISED that it consents to relocating MSAT-2 to bring back into use the orbital location at 106.5°WL. 2 Ligado has already received authorization from the Commission to drift MSAT-2 to the new location pursuant to its recent application for Special Temporary Authority. See FCC File No. SAT-TA-20180810-00061 (granted Aug. 28, 2018). The details of that application are incorporated by reference. 1

facilities in Allan Park cannot be used or communication from a U.S. located earth station is otherwise required. Ligado will continue operating this earth station to communicate with MSAT-2 on a backup basis in exactly the same way after relocation to the new orbital location. An updated Schedule B has been filed with this application, and an updated Schedule S reflecting the relocation of the satellite and associated technical changes related to the L-Band operations of the satellite is being provided with the modification to Ligado’s license for MSAT- 2 mentioned above. This application does not request authorization for new frequencies or any other change in the currently authorized earth station parameters defined in the License. As such, as required by the Commission’s rules,3 Ligado hereby certifies that all other information related to this earth stations operations and not addressed in this application has not changed. Grant of the application will facilitate the relocation of MSAT-2, without interference or harm to other operators, resulting in MSAT-2 being better accommodated in a fully coordinated orbital location and providing future certainty for backup MSS operations. Accordingly, modifying the License is in the public interest. For all of these reasons, Ligado submits that the Commission should grant this application for the modification of the License to reflect the relocation of MSAT-2. 3 See 47 C.F.R. § 25.117(c). 2

Technical Certification I, Maqbool Aliani, Senior Vice President of Spectrum Standards & Technology for Ligado Networks Subsidiary LLC, certify under penalty of perjury that: I am the technically qualified person with overall responsibility for preparation of the technical information contained in this application. I am familiar with the requirements of Part 25 of the Commission’s rules, and the information contained in the application is true and correct to the best of my knowledge and belief. /s/ Maqbool Aliani Dated: September 12, 2018


Document Created: 2018-09-12 16:07:58
Document Modified: 2018-09-12 16:07:58
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