Attachment STA Narrative

This document pretains to SES-STA-20101018-01301 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010101801301_845851

Attachment 1
Blue Marble Network LLC
Application for Earth Station Special Temporary Authority

             JUSTIFICATION FOR SPECIAL TEMPORARY AUTHORITY

        Blue Marble Network LLC (“Blue Marble”), pursuant to Section 25.120(b)(3) of the
Commission’s rules hereby requests that the Commission grant it special temporary authority
(“STA”) for a period of sixty (60) days beginning on October 20, 2010. Through the STA, Blue
Marble seeks to test its proposed earth stations onboard vessels network (“ESV Network”),
which is described in its pending license application.1 The STA operations will be for beta
testing purposes only.

        Blue Marble proposes to undertake its initial testing dockside in Seattle, Washington after
the ESV Network’s equipment is properly loaded and installed on the vessel during the week of
October 20, 2010. Blue Marble’s proposed testing would shift to beta testing once the vessel
leaves port, which it is scheduled for the following week. The vessel is expected to be at sea for
a period of 30-45 days. Beta testing during this period will allow Blue Marble to gain experience
in passing traffic through its ESV Network under operational conditions.

         While operating under STA, Blue Marble will operate within the parameters described in
its pending application, as amended, and will not claim protection from any other operator. The
only distinctions from the proposed operations under the permanent application are (1) Blue
Marble will not transmit in the 14.0-14.2 GHz band within 125 km of the NASA TDRSS
facilities on Guam or in the 14.47-14.5 GHz band within 125 km of the radio observatory on
Mauna Kea, Hawaii unless and until coordination through the National Telecommunications and
Information Administration’s Interdepartment Radio Advisory Committee is complete; and (2)
Blue Marble will not operate in the 12.2-12.75 GHz band, which it has requested a waiver to
operate in through the permanent application.

        Grant of the STA will serve the public interest. The STA will enable a testing program
that will allow Blue Marble to roll out its ESV Network in the most efficient manner. Through
the development of its ESV network, Blue Marble will be able to serve a customer base that will
include transoceanic merchants shipping cargo using both U.S. and foreign-flagged vessels. The
voice and data services that Blue Marble will provide will serve the public interest by enabling
its customers to supplement their existing communications systems to improve their internal
operations and give their crew members an effective means for communicating offshore.




       1
        Blue Marble Network, LLC, Application for Authority, Call Sign E100102, File No.
SES-LIC-20100917-01170 (accepted for filing Sept. 29, 2010), as amended Blue Marble
Network, LLC, Amended Application for Authority, Call Sign E100102, Temporary File No.
SES-AMD-INTR-2010-03230 (filed Oct. 18, 2010). The application, as amended, is
incorporated herein by reference.


        Accordingly, Blue Marble requests that the FCC issue STA to Blue Marble, effective
October 20, 2010, for a period of sixty (60) days, so that it may test the proposed ESV Network
before it is commercially deployed.




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Document Created: 2010-10-18 15:11:10
Document Modified: 2010-10-18 15:11:10

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