Attachment extension of STA

extension of STA

OTHER submitted by Space Imaging

extension of STA (ses-sta-20050411-00414)

2005-06-07

This document pretains to SES-STA-20050607-00695 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005060700695_435499

E970270    SES—STA—20050607—00695       18200500121;
Space Imaging LLC




                                                                                                            Approved by OMB
                                                                                                                    3060—0678

                                    APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



  APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
  Request for Extension of Special Temporary Authority
    1. Applicant

              Name:         Space Imaging LLC            Phone Number:                303—254—2151

              DBA Name:                                  Fax Number:                  303—254—2214

              Street:       12076 Grant Street           E~—Mail:                     ssmith@spaceimaging.com


              City:         Thornton                     State:                       CO
              Country:       USA                         Zipcode:                     80241       —3102
              Attention:    Mr Scott Smith




                                                                                      rie#s SES— STA— 20050607 — 00 6 457


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                                                                                      From LHl              To: _


                   FEDERAL COMMUNICATIONS COMMISSION
                          WASHINGTON, D.C. 20554

                                             June 9, 2005



STA No:         SES—STA—20050607—00695
Call Sign:      E970270

    1)       Space Imaging LLC (Space Imaging) is authorized to receive remotely—sensed data
             and imagery from Indian—licensed ResourceSat—1 in the 8072.5—8177.5 MHz and
             8247.5—8352.5 MHz bands with bandwidths of 105 MHz, in accordance with the
             terms, conditions, and technical specifications set forth in its application, this
             attachment and the Commission‘s Rules.

   2)        All expenses for operation shall be at Space Imaging‘s own risk.

   3)        Harmful radio interference shall not be caused to any other lawfully operated radio
             station and satellite, and operation shall cease immediately upon notification of
             interference. Complaints of all radio interference shall be forwarded immediately to the
             Commussion, in writing.


2. Contact


             Name:         Raymond G. Bender, Jr.               Phone Number:                         202—776—2758

             Company:      Dow, Lohnes & Albertson, plic        Fax Number:                           202—776—2222

             Street:        1200 New Hampshire Ave., NW.        E—Mail:                               RBender@DowLohnes.com


             City:         Washington                           State:                                 DC

             Country:      USA                                  Zipcode:                              20036       —6802

             Attention:                                         Relationship:                          Legal Counsel


3. Reference File Number SESMOD2004060700810

 42. Is a fee submitted with this application?
@ If Yes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C Governmental Entity         {y Noncommercial educational licensee
C Other(please explain):

4b. Fee Classification    CGX — Fixed Satellite Transmit/Receive Earth Station

5. Type Request


@ Use Prior to Grant                              C Change Station Location                           O Other



6. Requested Use Prior Date
      06/12/2005
7. CityFairbanks                                                           8. Latitude
                                                                           (dd mmss.sh)     64   47    40.0   N


9. State   AK                                                              10. Longitude
                                                                           (dd mmss.sh)      147    32   13.0   W

11. Please supply any need attachments.
Attachment 1: Public Interest Ex                  Attachment 2:                                     Attachment 3:


12. Description.   (Ifthe complete description does not appearin this box, please go to the end of the form to view it in its entirety.)
    This application seeks an extension of an existing Special Temporary Authority                                             (STA)
     initially issued on April 12,                 2005,    authorizing Space Imaging‘s earth station at
     Fairbanks, Alaska,           to communicate          (on a receive—only basis)                with India‘s ResourceSat—1
    remote—sensing satellite during the pendency of an FCC Form 312 license modification




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is             Yes        g No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name of Person Signing                                                 15. Title of Person Signing
  S. Scott Smith                                                             Executive VP, Satellite Access Systems

           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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collection has been assigned an OMB control number of 3060—0678.

THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


12. Description

This application seeks an extension of an existing Special Temporary Authority         (STA)   initially
issued on April 12,      2005, authorizing Space Imaging‘s earth station at Fairbanks, Alaska, to
communicate       (on a receive—only basis)   with India‘s ResourceSat—1 remote—sensing satellite during
the pendency of an FCC Form 312 license modification application to add this satellite as a point
of communication.


                                                                                    Space Imaging LLC
                                                                                STA Extension Request
                                                                                           Attachment 1
                                                                                             Page 1 of 3



                      Request of Space Imaging LLC for Extension of
                               Special Temporary Authority


        Space Imaging LLC ("Space Imaging") hereby requests an extension of an
existing Special Temporary Authorization ("STA") to permit Space Imaging to continue
to receive remotely—sensed imagery data from India‘s ResourceSat—1 satellite at Space
Imaging‘s earth station in Fairbanks, Alaska (Call Sign E970270). Grant of this STA
extension will serve the public interest by allowing Space Imaging to continue current
operations and customer service pending FCC action on Space Imaging‘s FCC Form 312
license modification application which seeks permanent authority to communicate with
the ResourceSat—1 satellite.

        L.       Background

       On June 7, 2004, Space Imaging filed a license modification application on FCC
Form 312 to add the ResourceSat—1 satellite as a new point of communication (on a
receive—only basis) at the Fairbanks earth station (File No. SES—MOD—20040607—00810).
That underlying application remains pending at this time.‘

       On March 24, 2005, Space Imaging filed an STA application for authority to
communicate with the ResourceSat—1 satellite during the pendency of its application for
permanent authority. As the Commission is aware, the National Telecommunications
and Information Administration ("NTIA") cleared the proposed STA operations prior to
the Commission‘s initial STA grant. Moreover, Space Imaging observed in its initial
STA request that no objections had been filed with respect to Space Imaging‘s underlying
FCC Form 312 license modification application following public notice of that
application. On April 12, 2005, the Commission granted Space Imaging‘s STA
application for a term of sixty (60) days, /.e., until June 12, 2005, and the current STA
therefore is due to expire on June 12, 2005.

        Because the Commission has not yet acted on Space Imaging‘s FCC Form 312
license modification application, and the STA authorizing communications with
ResourceSat—1 is about to expire, Space Imaging is hereby seeking an extension ofits
STA so that there will be no interruption to Space Imaging‘s current remote—sensing
operations and customer service.

        IL.      Grant of this STA Extension Will Serve the Public Interest

        The STA extension requested herein will serve the public interest. Indeed, the
grant of an extension is necessary and appropriate for the same reasons the Commission

‘ Space Imaging also filed, on June 7, 2004, a separate FCC Form 312 license modification application to
receive remotely—sensed imagery data from the ResourceSat—1 satellite at another Space Imaging carth
station in Norman, Oklahoma, and that application also remains pending.


                                                                                    Space Imaging LLC
                                                                                 STA Extension Request
                                                                                         Attachment 1
                                                                                              Page 2 of3


found the initial STA request to be justified. We will not repeat in detail each of the
supporting facts and circumstances set out in the earlier STA request, but those factors
may be summarized as follows:*

         First, Space Imaging needed immediately to commence communications with
ResourceSat—1 as the designated replacement satellite for Indian remote—sensing satellites
IRS—1C and IRS—1D. Space Imaging had been communicating with each of those
satellites pursuant to prior FCC authorizations. However, as explained in the earlier STA
application, the IRS—1C satellite is no longer able to provide service in North America,
and Space Imaging therefore was forced to discontinue communications between its U.S.
ground stations and the IRS—1C satellite. Considering Space Imaging‘s reliance on the
two Indian remote—sensing satellites (IRS—1C and IRS—1D), the loss of IRS—1C service
represented a 50 percent reduction in earth coverage capacity. Moreover, the IRS—1D
satellite had begun experiencing anomalies and the satellite‘s deterioration has adversely
affected the quality of service provided to Space Imaging by that satellite. For these
reasons, it was critical for Space Imaging immediately to commence communications
with ResourceSat—1 as the designated replacement satellite for IRS—1C and IRS—1D.

        Second, the ResourceSat—1 satellite has vastly improved data quality over the
previously—authorized Indian satellites IRS—1C and IRS—1D, and the commencement of
service with this new satellite afforded new and improved remote—sensing applications
for commercial and government users alike.

       Third, for reasons explained in the earlier STA application, the commencement
of communications with ResourceSat—1 helped to foster ongoing cooperation and
harmonious relations between the U.S. and Indian interests (both commercial and
government) in the field of remote—sensing.

        Finally, these STA operations have been cleared with NTIA and no technical
issues prevented a grant of this relatively straightforward receive—only proposal, nor do
any technical issues prevent an extension of this STA. Space Imaging further noted that a
grant of the STA would address Space Imaging‘s immediate need to commence
communications with the ResourceSat—1 satellite, while at the same time permitting the
Commission to address any remaining processing issues surrounding Space Imaging‘s
FCC Form 312 license modification application in the ordinary course.

         Each ofthese public interest factors supports an STA extension to permit Space
Imaging to continue receiving remotely—sensed imagery data from the ResourceSat—1
satellite at its Fairbanks, Alaska earth station. Moreover, grant of an STA extension will
avoid interruption of critical remote—sensing satellite services on which Space Imaging
and its commercial and government customers have come to rely.


* The facts and circumstance supporting the initial STA were set out in Attachment 1 to Space Imaging‘s
prior STA application filed March 24, 2005.


                                                                      Space Imaging LLC
                                                                    STA Extension Request
                                                                             Attachment 1
                                                                                Page 3 of 3


      Considering the foregoing, Space Imaging respectfully submits that grant of this
STA extension request would serve the public interest.

       In accordance with Section 25.120 of the rules, a copy of this request for STA
extension is being forwarded to the Commission‘s Columbia Operations Center in
Columbia, Maryland.



Document Created: 2005-06-09 09:41:58
Document Modified: 2005-06-09 09:41:58

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