Attachment STA Narrative

This document pretains to SES-STA-20121009-00907 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012100900907_970591

                                                                                       Gogo LLC
                                                                                          Page 1
                 REQUEST FOR SPECIAL TEMPORARY AUTHORITY

       Gogo LLC (“Gogo”) hereby requests special temporary authority (“STA”) for a period of
180 days beginning December 10, 2012, to operate 30 technically identical Ku-band
transmit/receive earth stations for the provision of Aeronautical Mobile Satellite Service
(“AMSS”) on domestic and international flights. In addition, Gogo seeks authority for continued
ground-based testing of its AMSS terminals. Grant of the requested STA is consistent with
Commission precedent and will serve the public interest by enabling Gogo to evaluate the AMSS
network’s performance prior to full-scale deployment of AMSS terminals.

        Gogo has filed an application for a blanket license for AMSS operations1 and seeks
temporary authority to initiate its AMSS offering pending action on the application. The Gogo
AMSS Application includes complete technical information regarding the Gogo AMSS system,
and Gogo incorporates that information by reference herein. The materials on file with the
Commission demonstrate that Gogo’s proposed AMSS operations have been coordinated with
adjacent satellite operators and with the National Science Foundation.2 Gogo seeks STA to
permit it to offer AMSS using any spacecraft included in the Gogo AMSS Application.3

        In addition to commencing AMSS service on a limited scale, Gogo also proposes to
continue ground-based testing pending action on the Gogo AMSS Application. Gogo requested
and received Commission authority earlier this year to begin ground-based testing of the AMSS
terminal at and near the Gogo headquarters in Itasca, IL and the AeroSat facility in Amherst,
NH.4 Initial testing was limited to the SES-1 spacecraft, but Gogo is concurrently seeking
authority to add capacity on a second spacecraft, spot beam 2 of the NSS-703 satellite. Gogo
requests that the authority granted pursuant to the instant STA request permit further ground-
based testing with any spacecraft included in the Gogo AMSS Application that has U.S.
coverage.

       Grant of the requested STA will facilitate the introduction of a new competitive AMSS
network to the benefit of U.S. air travelers. Furthermore, Gogo seeks to operate on a non-
harmful interference basis, so grant of the requested authority will not harm adjacent satellite
operators or other regularly authorized Ku-band spectrum users.




1
        Gogo LLC, Call Sign E120106, File Nos. SES-LIC-20120619-00574; SES-AMD-
20120731-00709; & SES-AFS-20121008-00902 (the “Gogo AMSS Application”).
2
        Gogo LLC, Call Sign E120106, File No. SES-AMD-20120731-00709, Amendment
Exhibits A and B.
3
        Gogo LLC, Call Sign E120106, File No. SES-AFS-20121008-00902, Annex 2 (updated
table of spacecraft to be used in the Gogo AMSS network).
4
        Gogo LLC, Call Sign E120106, File No. SES-STA-20120727-00698, granted Aug. 29,
2012 (the “Gogo Testing STA”).


                                                                                Gogo LLC
                                                                                   Page 2
     For the foregoing reasons, Gogo requests STA to permit the commencement of limited
AMSS operations and to continue ground-based testing pending Commission action on the Gogo
AMSS Application.



Document Created: 2012-10-09 11:34:58
Document Modified: 2012-10-09 11:34:58

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