Attachment STA Request

This document pretains to SES-STA-20100514-00597 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010051400597_816794

REQUEST FOR SPECIAL TEMPORARY AUTHORITY Pursuant to Section 25.120 of the Federal Communications Commission’s (“FCC”) rules, STM Networks, LLC (“STM Networks”), a wholly-owned subsidiary of STM Group, Inc. (“STM Group”) hereby requests Special Temporary Authority (“STA”) to operate Domestic Fixed Satellite Service VSAT Network license E070026 (the “Station”) as proposed in its modification of license application filed contemporaneously with this STA request. A copy of that application is attached. STM Networks’ system is used to provide broadband Internet, voice and data services, via satellite, to non-profit and charitable organizations, commercial users and government users where satellite service is the only means of communication except for marine radio. Many of these users are located in maritime areas, war zones or sites of natural disasters and no other broadband services are available or STM Networks’ service is the only available affordable service. For example, STM Networks is currently providing broadband service to the U.S. military in support of the war in the Middle East and to relief workers in Haiti and other countries free of charge. In addition to Internet connectivity, the STM Networks’ system enables users to subscribe to third party IP phone services, bringing telephone service to users in remote locations or disaster areas where access to traditional telephone service is not available. STM Group is a leading provider of VSAT satellite communication networks for voice and data applications. STM Group designs, manufactures, markets, installs and services its own products and networks. During a recent license review to add additional antennas to its system, STM Networks determined that due to an oversight and immediate customer needs, additional changes to the Station’s license were needed to correct errors in its initial license application and to seek FCC approval for additional antennas. After discussions with FCC staff, this STA request and a contemporaneously filed modification of license application are being filed with the FCC. Pursuant to Section 1.3 of the FCC’s rules, STM Networks requests a waiver of Sections 25.117 and 25.120(a) and such other FCC rules1 as may be necessary to permit expeditious grant of the requested STA and operation of its VSAT system while its modification application is pending.2 Grant of this STA is in the public interest because it will permit STM Networks to immediately operate the proposed changes to its VSAT system, continue providing service to support military operations and humanitarian relief, and, without it, the public interest would be seriously prejudiced. See 47 C.F.R. § 25.120(b)(1). Users of STM Networks’ system, including many governmental users and relief agencies, protect public safety and respond to emergencies and natural disasters. Current users of the network include private and commercial ships and yachts, international charitable relief agencies, governments and the U.S. military. In many instances, these users do not have access to affordable alternative methods of broadband connectivity and, for some users, the STM Networks’ system may be an essential mode of broadband access in the event of terrestrial 1 47 C.F.R. §§ 25.117 & 25.120(a). 2 The FCC granted an STA to operate the Station while the initial license application was being processed. See File No. SES-STA-20070316-00358, STM Wireless, Inc., granted Mar. 20, 2007. 5094620.01

outages or the primary means of contacting emergency assistance. For example, STM Networks’ system is used by relief organizations and public safety agencies during natural disasters and may be the only available broadband satellite service when terrestrial broadband services fail. Its VSAT system also supports the U.S. military’s war effort in the Middle East and provides maritime vessels with access to emergency services. The FCC has recognized that satellite communication is a crucial element in public safety and emergency response situations.3 STM Networks’ system provides broadband connectivity that is essential to its users, particularly those engaged in public safety, homeland security and emergency situations. Without its services, maritime users may be unable to contact emergency services, public safety users will need to seek out an alternative satellite broadband provider, if one is available, and relief organizations will need to find another satellite broadband service provider to donate its services. Accordingly, expeditious grant of this STA request is in the public interest. 3 Federal Communications Commission, Connection America: The National Broadband Plan, available at http://download.broadband.gov/plan/national-broadband-plan.pdf at p. 313 (stating as one of its recommendations: “Ensure that broadband satellite service is a part of any emergency preparedness program.”) and Recommendations of the Independent panel Reviewing the Impact of Hurricane Katrina on Communications Networks, Order, 22 FCC Rcd 10541, ¶11 (2007) (“In particular, the Panel mentioned satellite systems and two-way paging systems as especially resilient to disaster.”). 5094620.01 2


Document Created: 2010-05-13 11:01:34
Document Modified: 2010-05-13 11:01:34
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