Attachment Extension grant

This document pretains to SES-STA-20080129-00098 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2008012900098_619060

                                      Row 44 Inc. SES—STA—20080129—000
                                                                       98      18200800019 *




                                                                                                                   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:
Application for Renewal of STA (AeroSat Test) — 1/29/2008
 1. Applicant

           Name:        Row 44 Inc.                        Phone Number:                       818—706—3111

           DBA Name:                                       Fax Number:
           Street:      31280 Oak Crest Drive,Suite 5      E—Mail:                             agior@verizon.net


           City:        Westlake Village                   State:                              CA
           Country:     USA                                Zipcode:                            91361       —
           Attention:   Dr Arthur A Giordano




                                                        nal Bureau: % Arpask


2. Contact


             Name:         David S. Keir                       Phone Number:                         (202) 429—8970

             Company:      Leventhal Senter & Lerman PLLC       Fax Number:                          (202) 293—7783
             Street:       2000 K Street, N.W.                 E—Mail:                               dkeir@Isl—law.com
                           Suite 600
             City:         Washington                          State:                                 DC
             Country:      USA                                 Zipcode:                              20006       —
             Attention:    David S. Keir                       Relationship:                          Legal Counsel


(If your application is related to an application filed with the Commission, entereither the file number or the IB Submission ID of the related
application. Please enter only one.)
 3. Reference File Number SESSTA2007112101610 or Submission ID
 4a. Is a fee submitted with this application?
@ IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
y Governmental Entity        C Noncommercial educational licensee
G Other(please explain):

4b. Fee Classification    CGV — Fixed Satellite VSAT System
5. Type Request


gy Use Prior to Grant                             zy Change Station Location                         & Other


6. Requested Use Prior Date
      02/08/2008
7. CityAmbherst                                                           8. Latitude
                                                                          (dd mm ss.sh)    42   48    424    N


9. State   NH                                                              10. Longitude
                                                                           (dd mm ss.sh)     71   35     1746   W
11. Please supply any need attachments.
Attachment 1: Explanatory                         Attachment 2: Antenna Patterns                     Attachment 3: RadHaz Study


12. Description.   (If the complete description does not appear in this box, please go to the end ofthe form to view it in its entirety.)
     Row 44 seeks a 30—day extension of the STA originally granted on 12/10/2007,                                           and extended
     through 2/07/2008 on 1/03/2008,                  to allow it to operate a fixed aircraft Earth station at a
     terrestrial location            (See File Nos.         SES—STA—20071121—01610 and SES—STA—20080102—00005) .
    The purpose of this operation is to continue gathering critical data from the testing of




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is          @ Yos          y No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 ofthe 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
  John Guidon                                                                 CEO
           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.$. Code, Title 47, Section 503).


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DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
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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 LAW104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


12. Description

Row 44 seeks a 30—day extension of the STA originally granted on 12/10/2007,         and extended through
2/07/2008 on 1/03/2008,       to allow it to operate a fixed aircraft Earth station at a terrestrial
location     (See File Nos.   SES—STA—20071121—01610 and SES—STA—20080102—00005).    The purpose of this
operation is to continue gathering critical data from the testing of the antenna with respect to
future provision of aeronautical mobile satellite service.          Copies of the materials provided with
the original application,       as supplemented,   are provided as attachments to this extension request.


                                                                                        Row 44, Inc.
                                                                                        STA Request
                                                                                     November 2007




                                EXPLANATORY STATEMENT


         Row 44, Inc. ("Row 44") is seeking special temporary authority ("STA") for a 30—day
period to operate a fixed aircraft Earth station ("AES") at a terrestrial location. The purpose of
this operation is to test the terminal antenna for provision of commercial aeronautical mobile
satellite service ("AMSS"). This is intended to be a final step in preparation for filing, in the
near—term, of an application for a permanent AMSS license for remote AES units which will
function with an existing hub Earth station. Row 44 understands that, because AMSS is a
secondary allocation at Ku—band, both its STA operation and any permanent operation ultimately
licensed must operate on a non—interference basis with respect to primary users in the band, and
must accept any interference caused by these licensees. Because this is Row 44‘s first request
for FCC authorization, and to facilitate processing of this STA request, Row 44 is submitting as
an attachment to this Explanatory Statement a complete Form 312 and Schedule B providing
information about Row 44 and the complete technical details of its proposed STA operation.

       Row 44 plans to offer a commercial broadband Internet data service to passengers and
crew aboard commercial aircraft traveling in North American airspace, consistent with the
framework that the Commission has proposed in its AMSS rulemaking proceeding. See Service
Rules and Procedures to Govern the Use ofAeronautical Mobile Satellite Service Earth Stations
in Frequency Bands Allocated to the Fixed Satellite Service, 20 FCC Red 2906 (2005) ("AMSS
NPRM"). The service will include IP data services, IP voice and IPTV. The geostationary FSS
satellite to be accessed is Galaxy 10R located at 123° West Longitude. A single remote unit will
be located at the AeroSat Avionics facility in Amherst, New Hampshire, and will operate in
conjunction with an existing hub terminal at Germantown, Maryland licensed to HNS License
Sub, LLC (FCC Call Sign E000166). See Schedule B (location and contact information only is
provided therein for this licensed hub). Row 44 notes that its transmission will comply with
Section 25.209 of the FCC‘s rules (47 C.F.R. §25.209) and the uplink RF transmit power
density will not exceed —14 dBW/4 kHz, consistent with Section 25.134(a)(1) (47 C.F.R.
§25.134(a)(1).

       Grant of the requested authority will serve the public interest by permitting Row 44 to
continue its preparations to offer a new mobile broadband service that is needed by the public.
As the Commission noted in the AAASS NPRM, there is a growing demand from airline
passengers and crewfor real—time, in—flight broadband data transmission and other
communications capability. See AMSS NPRM, 20 FCC Red at 2908. Several companies are
already providing similar services using the same Ku—band spectrum for general aviation and
commercial airlines,‘ and this emerging marketplace will benefit from additional competition
from new entrants. Row 44‘s provision of AMSS will ultimately allow airline passengers to
access a full range of broadband data, voice, and video services, including high—speed Internet



‘ See Boeing Company, 16 FCC Red 22645 (IB/OET 2001); ARINC Inc., 20 FCC Red 7553 (IB/OET 2005).


                                               12—                                    Row 44, Inc.
                                                                                    STA Request
                                                                                  November 2007


access and interactive entertainment, and would also facilitate access by flight crews to important
weather updates and security information.

        Accordingly, Row 44 requests that the FCC grantit an STA on an expedited basis to
performthe static test described herein for a period of thirty days. Row 44 anticipates being able
to commence testing by December 1, 2007, and respectfully requests Commission action on this
application consistent with that timetable to the extent possible.



Document Created: 2008-01-31 15:26:05
Document Modified: 2008-01-31 15:26:05

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