Attachment STA Narrative

This document pretains to SES-STA-20141125-00874 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014112500874_1069984

                                               EXHIBIT

                                     Purpose of STA Application

       The Boeing Company (“Boeing”) herein seeks extension of its existing special temporary
authorization (“STA”) for a renewal period of 180 days to continue to operate the Boeing
Broadband Satellite Network (“BBSN”) in support of U.S. Air Force missions.1

Background

      On September 22, 2014, Boeing filed an application for authority to operate its existing
BBSN pursuant to a license issued under the Commission’s recently adopted Earth Stations
Aboard Aircraft (“ESAA”) rules.2 On that same date, Boeing sought an STA for 60 days to
permit continued operations while its ESAA application remains pending before the
Commission.3

       On October 1, 2014, the International Bureau (“IB”) granted a portion of Boeing’s STA
application, allowing it to operate its BBSN for a period of 60 days using the E113WA satellite
(previously known as SatMex 6) as a new point of communication to support its operations on
behalf of the U.S. Government in South America.4 Boeing’s authority to operate the rest of its
BBSN with eight other geostationary (“GSO”) satellites in the fixed satellite service (“FSS”)
continues to be provided by experimental license call sign WC2XVE, which was issued by the
Commission’s Office of Engineering and Technology (“OET”).

Discussion

        As explained in the initial STA application, Boeing has operated in-flight broadband
services for more than a decade. Boeing’s Connexion by Boeing system was the first satellite-
based in-flight broadband service authorized by the IB in 2001. 5 Since 2008, Boeing has
operated under OET experimental authority pending the Commission’s adoption of ESAA rules.6
Based on discussions with IB and OET staff, Boeing filed its initial STA application with the IB
in order to transfer all or portions its operating authority from its OET experimental license to an
IB STA during the processing of its ESAA application.

1
    47 C.F.R. § 25.120.
2
  Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard
Aircraft Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations Operating in
the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14.0-14.5 GHz Frequency Bands, IB Docket
No. 12-267, Notice of Proposed Rulemaking and Report and Order, FCC 12-161 (rel. Dec. 28, 2012)
(“ESAA Order”).
3
 The Boeing Company Request for Special Temporary Authorization and Expedited Treatment, File No.
SES-STA-20140922-00747 (Sept. 22, 2014) (granted Oct. 1, 2014).
4
    See id.
5
    See The Boeing Company, Order and Authorization, 16 FCC Rcd. 22645 (Int’l Bur. 2001).
6
    See Experimental License Call Sign WC2XVE.


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        Although Boeing initially sought an STA period of 60 days, Boeing now seeks an STA
extension period of 180 days. This significantly longer period is warranted by the processing
time that may be required for the IB to consider and grant Boeing’s ESAA application. 7
Although Boeing’s ESAA application was filed on October 1, 2014, the application has not yet
been placed on public notice for comment, likely reflecting the administrative difficulties for the
IB of developing procedures for the review and licensing of this new type of satellite service.
Boeing will therefore likely require an additional 180 days of temporary operating authority
before its ESAA license is granted and its request for a longer STA period is therefore warranted.

Public Interest Statement

       Boeing’s BBSN exclusively serves the needs of the United States Air Force Air Materiel
Command to support the operation of critically-important VIP/SAM (Very Important
Personnel/Special Air Mission) aircraft used to transport senior leadership of the U.S.
Government and the Department of Defense. The BBSN achieves near global coverage through
the use of selected U.S. and foreign satellites. As with Boeing’s experimental authorization,
Boeing requests STA authority to operate the BBSN on a non-conforming, non-interference
basis.

       Grant of the requested STA would serve the public interest because the U.S. Air Force
uses Boeing’s service to support Homeland Security and National Defense efforts. These efforts
have increased significantly in focus in the South America region and these efforts require secure,
ubiquitous, and uninterrupted communications to VIP aircraft used by Federal Government
leadership.




7
 Application of The Boeing Company for Authority to Operate Up to 100 Earth Stations Aboard Aircraft,
File No. SES-LIC-20140922-00748 (Filed Sep. 22, 2014) (“Boeing ESAA Application”).


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Document Created: 2014-11-25 17:26:31
Document Modified: 2014-11-25 17:26:31

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