Attachment Exhibit A

This document pretains to SES-STA-20100507-00569 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010050700569_815164

                                                                                    NewCom International, Inc.
                                                                                           Amazonas-2 STA
                                                                                                   Exhibit A

           EXHIBIT A – REASON FOR SPECIAL TEMPORARY AUTHORITY


        NewCom International, Inc. (“NewCom”), pursuant to Section 25.120(b)(3) of the
Commission’s Rules, 47 C.F.R. § 25.120(b)(3), hereby requests special temporary authority
(“STA”) for a period of 60 days to operate a 4.5 meter Ku-band antenna using the Amazonas-2
geostationary satellite at 61º west longitude (“Amazonas-2”) during the pendency of NewCom’s
permanent modification application to add the aforementioned satellite as a point of
communication to Call Sign E050018.1 Grant of this STA request will allow NewCom to better
support lifeline communications, including telemedicine and basic telephony services to remote
end users in rural Latin America, most of which have no alternative means of establishing cost
effective communications.

         NewCom operates a world class teleport facility in Miami, Florida, that for six (6) years
has provided communications to customers in underserved areas of the world.2 Most recently,
NewCom has undertaken the extraordinary task of extending duplex connectivity to over 1,000
remote satellite terminal sites in rural Colombia that have no other reliable transmission medium
for domestic or international communications.3 For these customers, NewCom’s service is
literally a lifeline to the rest of the world. Among other core applications, NewCom’s services in
Colombia and elsewhere support hospitals, humanitarian relief efforts and educational
institutions.

        This STA is needed because NewCom can no longer reliably provide lifeline
communications to Latin America and other remote parts of the Western Hemisphere using the
existing commercial fixed satellites visible from Miami, and must immediately implement a
redundant route using Amazonas-2’s extended Ku-band transponder payload to ensure that
mission critical applications have adequate bandwidth. In particular, the medical professionals
and humanitarian agencies that have come to heavily rely on NewCom’s service are urgently in
need of additional throughput to accommodate advanced telemedicine and logistical planning
applications. The ability to uplink in the extended Ku-band will free several underutilized
transponders on the Amazonas-2 capable of accommodating the applications of NewCom’s
medical and humanitarian end users. Although the Amazonas-2 is already on the FCC’s Foreign
Satellite Permitted List,4 this authority does not encompass the transponder pairings that transmit
space-to-earth in the conventional Ku-band between 11.7 and 12.2 GHz, but receive earth-to-
space transmissions in the extended Ku-band between 13.75 and 14.0 GHz.



1
        See FCC File No. SES-MFS-20100430-00497 (“NewCom Amazonas-2 Application”).
2
        See, e.g., FCC File No. SES-STA-20050112-00038 et al., describing NewCom’s extensive efforts to provide
        communications to hospitals and educational facilities in locations unserved by terrestrial infrastructure.
3
        See NewCom Awarded Expanded Role in Colombia Communications Project, The Link, Dec. 15, 2009,
        available at: http://www.newcom-intl.com/index.php/news/the-link-newsletter/59-newcom-awarded-
        expanded-role-in-colombia-communications-project.html (last visited May 3, 2010).
    4
        See FCC File No. SAT-PPL-20090806-00081.



                                                   Page 1 of 2


                                                                     NewCom International, Inc.
                                                                            Amazonas-2 STA
                                                                                    Exhibit A

         By way of reference, NewCom hereby incorporates the information and exhibits provided
in modification application SES-MFS-20100430-00497. The proposed operations pursuant to
grant of this STA request will comport with the parameters set forth in the aforementioned
application, including maximum EIRP per carrier, maximum EIRP density and maximum EIRP
density towards the horizon. An interference analysis demonstrates that NewCom’s proposed
operations will not affect U.S. Navy and National Aeronautics and Space Administration
facilities.5

        NewCom cannot accommodate the services it proposes to provide on the Amazonas-2
using alternative satellites. NewCom has explored purchasing transponder capacity from other
regional and international satellite operators with comparable coverage of the western
hemisphere. Despite a comprehensive search, NewCom has been unable to identify sufficient
transponder capacity to satisfy its lifeline customers’ urgent needs. Moreover, NewCom’s end
users are not served by reliable terrestrial facilities of any kind.

        Grant of this STA serves the public interest by mitigating the detrimental effect of the
ongoing capacity shortage in the fixed satellite industry on NewCom’s lifeline customers with
mission critical applications that cannot tolerate downtime or degradation of the transmission
service. Specifically, it will allow end users to operate telemedicine and other applications that
can no longer be properly supported by NewCom’s existing facilities and existing fixed satellite
systems. Grant is requested on or before May 31, 2010.




5
    See NewCom Amazonas-2 Application, Exhibit B.



                                             Page 2 of 2



Document Created: 2010-05-07 14:54:18
Document Modified: 2010-05-07 14:54:18

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