Attachment Narrative/Waiver Req

This document pretains to SES-RWL-20190809-01041 for Renewal on a Satellite Earth Station filing.

IBFS_SESRWL2019080901041_1837538

NewCom International, Ltd. Call Sign E040267, File Nos. SES-MOD-20110418-00472, SES-MOD-20181017-03612, SES-RWL-______________ Renewal of License Aug. 9, 2019 Additional Information and Request for Waiver NewCom International, Ltd., requests renewal of the above-referenced license to ensure continuing authorization for operations at its Miami, Florida earth station, call sign E040267. Pursuant to Section 1.3 of the Commission’s rules, 47 C.F.R. § 1.3, NewCom requests a waiver of the requirement of Section 25.121(e) of the Commission’s rules, 47 C.F.R. § 25.121(e), that an application for renewal of a fixed satellite service (“FSS”) earth station license be filed “no later than 30 days[] before the expiration date of the license.” The FCC may waive any provision of its rules, in whole or in part, for “good cause shown,” 47 C.F.R. § 1.3. Here, the above-referenced license covers multiple satellite earth station hub antennae located at NewCom’s Miami teleport. These antennae provide a vital link through which NewCom and its affiliates provide vital communications services to numerous customer terminals in remote locations throughout the hemisphere, including cruise ships, offshore oil platforms, and isolated terrestrial sites. In many cases, terrestrial communications networks do not reach these locations, meaning that NewCom’s remote terminals provide its customers with their primary link to global communications networks and services. NewCom would have great difficulty maintaining these services after August 13, 2019, if it were to lose the use of the teleport antennae covered by this license. NewCom inadvertently overlooked the need to renew this license because it is in the process of consolidating its teleport operations at this Miami site from the Houston teleport operated by its affiliate, SpeedCast Communications, Inc. (“SpeedCast”). Indeed, this very license is currently the subject of a pending application to add new terminals being relocated from the Houston teleport, making renewal of this license all the more vital to the continuity of service to NewCom and SpeedCast customers. Should the renewal remain pending on the expiration date of the license, August 13, 2019, this waiver will also avoid any doubt that NewCom’s renewal application is “proper and timely” for purposes of Section 1.62(a)(1) of the Commission’s rules, which provides authority NewCom to continue operating these earth stations after the expiration date of the license, while the renewal is pending.1 1 47 C.F.R. § 1.62(a)(1) (providing that “[w]here there is pending before the Commission at the time of expiration of license any proper and timely application for renewal of license with respect to any activity of a continuing nature . . . , such license shall continue in effect without further action by the Commission until such time as the Commission shall make a final determination with respect to the renewal application”).


Document Created: 0300-09-07 00:00:00
Document Modified: 0300-09-07 00:00:00
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