Attachment SESSTA2015031900172.

SESSTA2015031900172.

DECISION submitted by FCC

STA GRANT WITH CONDITIONS

0000-00-00

This document pretains to SES-STA-20150319-00172 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015031900172_1083023

         E080100       SES—STA—20150319—00172        182015000527
         Row 44 Inc.




                                                                                                                            Approved by OMB
                                                                                                                                   3060—0678

                                APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
STA Request for AMC—2 (80.85 WL) — March 2015
 1. Applicant

           Name:           Row 44 Inc.                          Phone Number:            818—706—3111
           DBA Name:                                            Fax Number:

           Street:         4353 Park Terrace Drive              E—Mail:                  smclellan@globaleagleent.com


           City:           Westlake Village                     State:                    CA
           Country:         USA                                 Zipcode:                 91361                  —~
           Attention:      Mr. Simon McLellan




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2. Contact


             Name:         David S. Keir                       Phone Number:                       202—429—8970
             Company:      Lerman Senter PLLC                  Fax Number:                         202—293—7783
             Street:       2000 K Street, NW                  E—Mail:                              dkeir@lermansenter.com
                           Suite 600
             City:         Washington                          State:                               DC
             Country:      USA                                Zipcode:                             20006      —1809
             Attention:                                        Relationship:                        Legal Counsel


(If your application is related to an application filed with the Commission, entereitherthe file number or the IB Submission ID of the related
application. Please enter only one.)
 3. Reference File Number SESMFS201503 1800164 or Submission ID
 4a. Is a fee submitted with this application?
) IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
«3 Governmental Entity       g3 Noncommercial educational licensee
q4 Other(please explain):

4b. Fee Classification    CGB — Mobile Satellite Earth Stations

5. Type Request

(@) Use Prior to Grant                            g4 Change Station Location                      {» Other



6. Requested Use Prior Date
      03/25/2015
7. City                                                                  8. Latitude
                                                                         (dd mm ss.s h)   0   0   0.0    N


9. State                                                                    10. Longitude
                                                                            (dd mm ss.s h)     0   0O   0.0   W
11. Please supply any need attachments.
Attachment 1: ExplanatoryStatement                 Attachment 2: Mod. Application                       Attachment 3:


12. Description.    (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Row 44,       Inc.   requests authority commencing March 25,                       2015 to use conventional Ku—band
     capacity on the AMC—2 satellite at 80.85                          degrees W.L.         in advance of final action on Row
     44‘s pending license modification application.                              See Attached Narrative.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is                Yes        «4 No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name of Person Signing                                                   15. Title of Person Signing
   Simon McLellan                                                               Senior Engineer
           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you
have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the
Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fce.gov. PLEASE
DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
conduct or sponsor this collection, unless it displays a currently valid OMB control numberorif we fail to provide you with this notice. This
collection has been assigned an OMB control numberof 3060—0678.

THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


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Applicant: Row 44, Inc.                                                                                          a
Call Sign: E080100                                                                        Term Dates
File No.: SES—STA—20150319—00172          /     ;
Special Temporary Authority (STA)         Eo5
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Row 44, Inc. is granted special temporary authority for a perlod of 60 days to Operate up to 5 J
aeronautical terminals (0.62 meter TECOM Ku—Stream antenna) to communicate with AMC—2 (Call Sign
$2134) at the 80.85° W.L. orbital location using the 14.2—14.47 GHz (Earth—to—space) and 11.7—12.2 GHz
(space—to—Earth) frequency bands. Operations must be in accordance with the technical specifications
contained in Row 44, Inc.‘s application and are subject to the following conditions:

 1.   Operations under this grant of special temporary authority must be on an un—protected, non—harmful
      interference basis, i.e., while operating under this temporary authority Row 44, Inc. must not cause
      harmful interference to, and must not claim protection from interference caused to it by, any other
      lawfully operating radiocommunication system. Row 44, Inc. must cease operations immediately
      upon notification of such interference and must immediately inform the Commission, in writing, of
      such an event.

 2.   ESAA operations in the 14.2—14.47 GHz band shall not exceed the EIRP density limits specified in
      the current earth station authorization, Call Sign E080100, IBFS File No. SES—MOD—20121023—
      00963. We note that this grant does not authorize any higher power density levels as requested in
      SES—MFS—2015031800164.

 3.   Operation pursuant to this authorization outside the United States in the 14.2—14.47GHz band must
      be in compliance with the provisions of Annex 1, Part C of Recommendation ITU—R M.1643, with
      respect to any radio astronomy station performing observations in the 14.47—14.5 GHz band.

 4.   When operating in international airspace within line—of—sight of the territory of a foreign
      administration where Fixed Service networks have a primary allocation in the 14.0—14.5 GHz band,
      an aircraft earth station must not produce ground—level power flux density (pfd) in such territory in
      excess of the following values unless the foreign administration has imposed other conditions for
      protecting its FS stations: —132 + 0.5 x THETA dB(W/(m*~2 MHz)) for THETA <= 40° ; —112
      dB(W/(m*~2 MHz)) for 40° < THETA <=90°. Where: THETA is the angle of arrival of the radio—
      frequency wave in degrees above the horizontal, and the aforementioned limits relate to the pfd and
      angles of arrival that would be obtained under free space propagation conditions.

 5.   Operations pursuant to this authorization must conform with the terms of coordination agreements
      between the operator of AMC—2 and operators of other Ku—band geostationary satellites within six
      angular degrees of AMC—2. In the event that another GSO Fixed—Satellite Service (FSS) space
      station commences operations in the 14.0—14.5 GHz band at a location within six degrees of any of
      these space stations, aircraft earth stations operating pursuant to this temporary authority shall cease
      transmitting to that space station unless and until such operation has been coordinated with the new
      space station‘s operator or Row 44, Inc. demonstrates that such operation will not cause
      interference to the new co—frequency space station.


    Row 44, Inc. must take all necessary measures to ensure that the antenna does not create potential
    exposure of humans to radiofrequency radiation in excess of the FCC exposure limits defined in 47
    CFR §§ 1.1307(b) and 1.1310 wherever such exposures might occur. Measures must be taken to
    ensure compliance with limits for both occupational controlled exposure and for general
    population/uncontrolled exposure, as defined in these rule sections. Requirements for restrictions
    can be determined by predictions based on calculations, modeling or by field measurements. The
    FCC‘s OET Bulletin 65 (available on—line at www.fec.gov/oetlrfsafety) provides information on
    predicting exposure levels and on methods for ensuring compliance, including the use of warning
    and alerting signs and protective equipment for workers. The licensee shall ensure installation of
    terminals on aircraft by qualified installers who have an understanding of the antenna‘s radiation
    environment and the measures best suited to maximize protection of the general public and persons
    operating the aircraft and equipment. A terminal exhibiting radiation exposure levels exceeding 1.0
    mW/emin accessible areas, such as at the exterior surface of the radome, shall have a label
    attached to the surface of the terminal warning about the radiation hazard and shall include thereon
    a diagram showing the regions around the terminal where the radiation levels could exceed 1.0
    mW/cm*.

    Row 44, Inc. must maintain a U.S. point of contact available 24 hours per day, seven days per
    week, with the authority and ability to terminate operations authorized herein. The licensee shall
    have available, at all times, the technical personnel necessary to perform supervision of remote
    station operations.

    Aircraft earth stations authorized herein must employ a tracking algorithm that is resistant to
    capturing and tracking adjacent satellite signals, and each station must be capable of inhibiting its
    own transmission in the event it detects unintended satellite tracking.

     Aircraft earth stations authorized herein must be monitored and controlled by a ground—based
     network control and monitoring center. Such stations must be able to receive "enable transmission"
     and "disable transmission" commands from the network control center and must cease transmission
     immediately after receiving a "parameter change" command until receiving an "enable
     transmission" command from the network control center. The network control center must monitor
   . operation of each aircraft earth station to determine if it is malfunctioning, and each aircraft earth
     station must self—monitor and automatically cease transmission on detecting an operational fault
     that could cause harmful interference to a fixed—satellite service network.

10. Stations authorized herein must not be used to provide air traffic control communications.

11. Operation in the territory or airspace of any country other than the United States must be in
    compliance with the applicable laws, regulations, and licensing procedures of that country, as well
    as with the conditions of this authorization.


12. For each ESAA transmitter, Row 44, Inc. must maintain records of the following data for each
    operating aircraft earth station (AES), a record of the aircraft location (i.e.,


     latitude/longitude/altitude), transmit frequency, channel bandwidth and satellite used shall be time
     annotated and maintained for a period of not less than one year. Records shall be recorded at time
     intervals no greater than one (1) minute while the AES is transmitting. The ESAA operator shall
     make this data available, in the form of a comma delimited electronic spreadsheet, within 24 hours
     of a request from the Commission, NTIA, or a frequency coordinator for purposes of resolving
     harmful interference events. A description of the units (i.e., degrees, minutes, MHz ...) in which the
     records values are recorded will be supplied along with the records.

 13. Antenna elevation for all operations must be at least 5 degrees above the geographic horizon while
     the aircraft is on the ground.

 14. Row 44, Inc. must comply with any pertinent limits established by the International
     Telecommunication Union to protect other services allocated internationally.

 15. Grant of this authorization is without prejudice to any determination that the Commission may
     make regarding pending applications or future requests for special temporary authority. E.g. IBFS
     File No. SES—MFS—20150318—00164.

 16. Any action taken or expense incurred as a result of operations pursuant to this special temporary
     authority is solely at Row 44, Inc.‘s risk.

This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47
C.FR. § 0.261, and is effective immediately. Petitions for reconsideration under Section 1.106 or
applications for review under Sections 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may
be filed within thirty days of the date of the public notice indicating that this action was taken.


                                                                                       Row 44, Inc.
                                                                                       STA Request
                                                                                        March 2015
                                                                                         Page 1 of 2




                                EXPLANATORY STATEMENT

       Row 44, Inc. hereby requests Special Temporary Authority ("STA") for a period of sixty
(60) days, pursuant to Section 25.120(b) of the FCC‘s Rules, to operate its licensed Ku—band
network of Earth Stations Aboard Aircraft ("ESAA"), under Call Sign E080100, with an
additional satellite point of communication, AMC—2 at 80.85° W.L. Row 44 has recently filed an
application seeking permanent authority to operate with this satellite (as well as another satellite,
SES—6 at 40.5° W.L.) as a new point of communication, and to modify operating parameters for
use of two other satellites already authorized for Row 44‘s use (AMC—9 at 83° W.L. and SES—1
at 101° W.L.). See File No SES—MFS—20150318—00064 ("Modification Application"), copy
attached hereto. In this STA application, Row 44 seeks authority to permit initiation of service
on AMC—2 using up to fifty (50) operating earth stations while this underlying application
remains pending. Row 44‘s STA operation would change its current authority only through the
addition of AMC—2 as a point of communication for this limited number of units under the
operating approach outlined in the Modification Application, and its operations would otherwise
remain consistent with all terms and conditions of its current license. Proposed operations on
AMC—2 would be limited to conventional Ku—band capacity frequencies at 11.7 to 12.2 GHz
(downlink) and 14.0 to 14.5 GHz (uplink), as proposed in the pending Modification Application.

        All technical and other required information concerning Row 44‘s planned use of AMC—2
is contained in the underlying application. See Modification Application, File No. SES—MFS—
20150318—00064. Row 44‘s Modification Application includes a coordination certification letter
from SES confirming that its proposed ESAA operations are consistent with coordination
arrangements with operators of the satellites within six degrees on either side of AMC—2. Id. at
Exhibit B. Row 44‘s planned operations will also be fully consistent with its existing agreements
with the National Science Foundation and the National Aeronautics and Space Administration,
and will adhere to the terms and conditions of Row 44‘s current license.

       Under Section 25.120(b)(1) of the FCC‘s Rules, the International Bureau may grant an
STA when the public interest supports the relief requested, and/or delay in the institution of
temporary operations would be contrary to the public interest. See 47 C.F.R. § 25.120(b)(1).
Such authority may be granted for a period not to exceed 60 days if the STA Request itself has
not appeared on public notice but the applicant has filed a request for permanent authority for the
parameters and facilities requested. See 47 C.F.R. § 25.120(b)(3).

        Grant of the authority requested in this instance will affirmatively serve the public
interest by permitting Row 44 to continue to serve existing customers and to expand its ESAA
network for the broader benefit of air travelers and airline crew members. Access to this new
capacity is urgently needed at this time because higher than expected demand from airline
passengers has caused severe congestion on the network, and there are not currently additional
capacity options on satellites for which Row 44 has already obtained authorization. If Row 44
finds that it has insufficient bandwidth to operate normally, service availability would be


                                                                                   Row 44, Inc.
                                                                                   STA Request
                                                                                    March 2015
                                                                                     Page 2 of 2


impaired and the in—flight user experience significantly degraded. Due to these circumstances,
Row 44 has been forced to seek authority to add new satellite capacity in a much shorter
timeframe than would normally be expected. Addition of AMC—2 to Row 44‘s existing authority
will provide more effective coverage of its primary U.S. service area (CONUS), as well as parts
of Central America, the Caribbean and the Atlantic Ocean. This will provide enhanced
performance and also make new areas of operation available to U.S. airline passengers that use
the Row 44 service. Grant of the requested STA is consistent with Commuission policy and will
not adversely affect other authorized operations.

       Row 44 acknowledges that favorable FCC action on this STA request would be without
prejudice to the ultimate determination the FCC will make regarding the Modification
Application. In addition, Row 44 acknowledges that any action taken pursuant to a grant of the
requested STA will be at its own risk.

       The conventional Ku—band capacity that Row 44 seeks to use on AMC—2 will be available
in the very near term. Accordingly, Row 44 respectfully requests that the FCC grant it authority
for a period of sixty (60) days commencing on or before March 25, 2015 to use the AMC—2
satellite as a point of communication in the conventional Ku—band for up to 50 antennas
operating under its FCC ESAA network license. Row 44 desires to begin testing on that date
with the objective of commencing service to users during the first week of April.


1872015                                                                   Application Filing Results

                                                       FCC IBFS — Electronic Filing

                                             Submission_id :1B2015000519
                                   Successfully filed on :Mar 18 2015 2:40:29:336PM


  The current authorization of Call Sign E080100 expires on Aug 5 2024 1:10:00:000PM. The filing of a
  modification application does not automatically extend the expiration date of an authorization. In
  addition, grant of a modification will not extend the expiration date unless that is the modification
  sought. In general, an application for renewal of the authorization must be filed separately in order to
  extend the expiration date.

                                                                    _Return to Main Menu |




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                                         Approved by OMB
                                                       3060—0678

  Date & Time Filed: Mar 18 2015 2:40:29:336PM
  File Number: SES—MFS—20150318—00164
       FCC APPLICATION FOR SPACE AND EARTH STATION: MOD OR AMD —
                                                       MAIN FORM                                                         FCC Use Only

                               FCC 312 MAIN FORM FOR OFFICIAL USE ONLY

 APPLICANT INFORMATION
 Enter a description of this application to identify it on the main menu:
 2015 MOD to Increase EIRP, Change Max Skew & Add Satellites
  1—8. Legal Name of Applicant
   Name:        Row 44 Inc.                        —                    Phone Number:                818—706—3111
   OA                                                                   Fax Number:
   Name:
   Street:      4353 Park Terrace Drive                                 E—Mail:                      smclellan@globaleagleent.com
   City:        Westlake Village                                        State:                       CA
   Country:      USA                                                    Zipcode:                     91361 =—
   Attention: Mr. Simon McLellan
  9—16. Name of Contact Representative
   Name:        David S. Keir                                           Phone Number:                     202—429—8970
   Company: Lerman Senter PLLC                                          Fax Number:                       202—293—7783
   Street:  2000 K Street, NW                                           E—Mail:                           dkeir@lermansenter.com
                Suite 600
   City:        Washington                                              State:                            DC
   Country:      USA                                                    Zipcode:                          20006—

   Attention: David Keir                                                Relationship:                     Legal Counsel
  CLASSIFICATION OF FILING
  17. Choose the button next to the
  classification that applies to this filing for        (N/A) b1. Application for License of New Station
  both questions a. and b. Choose only one for ||(N/A) b2. Application for Registration of New Domestic Receive—OnlyStation
   17a and only one for 17b.                            O b3. Amendment to a Pending Application
   ©                 .                                  ® 14. Modification of License or Registration
     al. Earth Station                                  b5. Assignment of License or Registration
   O ar. Space Station                                  b6. Transfer of Control of License or Registration
                                                        C b7. Notification of Minor Modification
                                                        (N/A) b8. Application for License ofNew Receive—Only Station Using Non—U.S. Licensed Satellite
                                                        (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                        (N/A) b10. Other (Please specify)
                                                        (N/A) b11. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized to
                                                        Provide the Proposed Service in the Proposed Frequencies in the United States.
   17¢. Is a fee submitted with this application?
   @ If Yes, complete and attach FCC Form 159.

  If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
   O Governmental Entity © Noncommercial educational licensee
   O Other(please explain):
   17d.
   Fee Classification CGB — Mobile Satellite Earth Stations
   18. If this filing is in reference to an existing    19. If this filing is an amendment to a pending application enter both fields, if this filing is a
   station, enter:                                      modification please enter only the file number:
   (a) Call sign of station:                                                                                    (b) File number:
   E080100                                              (a) Date pending application was filed:
                                                                                                                SESMOD2012102300963

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 P                                                   11
                                                                       TYPE OF SERVICE
     20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:


     e a. Fixed Satellite
     C b. Mobile Satellite
     C c. Radiodetermination Satellite
     C a. Earth Exploration Satellite
     L e. Direct to Home Fixed Satellite
     [ ¢ Digital Audio Radio Service
     Eal g. Other (please specify)
     ESAA application of FSS

     21. STATUS: Choose the button next to the applicable status. Choose only ||22. If earth station applicant, check all that apply.
     one.                                                                     K Using U.S. licensed satellites
     O Common Carrier ® Non—Common Carrier                                    E3] Using Non—U.S. licensed satellites
     23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
     facilities:
     O Connected to a Public Switched Network O Not connected to a Public Switched Network ® N/A
     24. FREQUENCY BAND(S): Place an ‘X" in the box(es) next to all applicable frequency band(s).
     0 a. C—Band (4/6 GHz) F b. Ku—Band (12/14 GHz)
     { c.Other (Please specify upper and lower frequencies in MHz.)
     Frequency Lower: Frequency Upper: (Please specify additional frequencies in an attachment)
                                                                       TYPE OF STATION
     25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
      O a. Fixed Earth Station
      O b. Temporary—Fixed Earth Station
      O c. 12/14 GHz VSAT Network
      ® d. Mobile Earth Station
      O c Geostationary Space Station
      O ; Non—Geostationary Space Station
      O g. Other (please specify)
     26. TYPE OF EARTH STATION FACILITY:
     ® Transmit/Receive O Transmit—Only O Receive—Only 9 N/A
     "For Space Station applications, select N/A."
                                                               PURPOSE OF MODIFICATION
     27. The purpose of this proposed modification is to: (Place an ‘X‘ in the box(es) next to all that apply.)

     ) a —— authorization to add new emission designator and related service
     [ b —— authorization to change emission designator and related service
     EK c —— authorization to increase EIRP and EIRP density
     [ d —— authorization to replace antenna
     1 e —— authorization to add antenna
     [ £—— authorization to relocate fixed station
     OA g —— authorization to change frequency(ies)
     l n —— authorization to add frequency
          i —— authorization to add Points of Communication (satellites & countries)
     Dj —— authorization to change Points of Communication (satellites & countries)
     OA k —— authorization for facilities for which environmental assessment and
     radiation hazard reporting is required
     { 1 —— authorization to change orbit location
     C m — authorization to perform fleet management
     O n —— authorization to extend milestones
     ® o —— Other (Please specify)

                                                                 ENVIRONMENTAL POLICY
     28. Would a Commission grant of any proposal in this application or amendment have a significant environmental
     —                                                .                       .          .                                       O Yes ® No
     impact as defined by 47 CFR 1.1307? If YES, submit the statement as required by Sections 1.1308 and 1.1311 of the


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   Commission‘s rules, 47 C.F.R. 1.1308 and 1.1311, as an exhibit to this application.A Radiation Hazard Study must                    Exhibit C
   accompany all applications for new transmitting facilities. major modifications. or major amendments.

     ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
                                aeronautical fixed radio station services are not required to respond to Items 30—34.
   29. Is the applicant a foreign government or the representative of any foreign government?                                          O Yes ® No

   30. Is the applicant an alien or the representative of an alien?                                                                    O ves C No & N/A

   31. Is the applicant a corporation organized under the laws of any foreign government?                                              O ves 2 No & N/A

   32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by aliens
   or their representatives or by a foreign government or representative thereof or by any corporation organized under the             O ves 2 No & N/A
   laws of a foreign country?

   33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than one—
   fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign government or             O Yes 2 No ® N/A
   representative thereof or by any corporation organized under the laws of a foreign country?

   34 If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
   foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.

                                                                 BASIC QUALIFICATIONS
   35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                                        O Ves ® No
   If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.

   36. Has the applicant or any party to this application or amendment had any FCC station authorization or license                    C Ves         ®@ n
   revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or                             °s          0
   construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.

   37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling the           gy Yes        @ n
   applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an explination of                     hi          9
   circumstances.

   38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, guilty of
   unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or indirectly, through                O ves ® No
   control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of
   competition?If Yes, attach as an exhibit, an explanation of circumstances

   39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending matter O vYes ® No
   referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.

   40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names, address,
   and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s voting stock and
   the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of beneficiaries. Also list the
   names and addresses of the officers and directors of the Filer.

   41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is subject to
   a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988, 21 U.S.C. ©                        o
   Section 862. because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for                 ¥es           No
   the meaning of "partyto the application"for these purposes.

   42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes, answer ® ves O No
   42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. IfNo, proceed to
   question 43.                                                                                                                Exhibit B

   42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
   coordinated or is in the process of coordinating the space station?

  43. Description. (Summarize the nature of the application and the services to be provided). Row 44 seeks to expand its aeronautical mobile—
  satellite service network capacity and availability by increasing EIRP, modifying the maximum skew angle for and adding both
  new emission designators and additional satellite points of communication to its licensed ESAA network. See Attached
  Narrative.Description
   43a. Geographic Service Rule Certification
   By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic                 @ a
   coverage requirements specified in 47 C.F.R. Part 25.


   By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage            O B
   requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.


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   By selecting C. the undersigned certifies that the applicant is subject to the geographic service or geographic coverage
   requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not feasible as a            C
   technical matter to do so, or that, while technically feasible, such services would require so many compromises in
   satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis
   demonstrating this claim are attached.
                                                                                                                                   Exhibit A


                                                                      CERTIFICATION
  The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United
  States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this application. The
  applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All
  statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned, individually
  and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of
  his or her knowledge and belief, and are made in good faith.
  44. Applicant is a (an): (Choose the button next to applicable response.)


    C Individual
    O Unincorporated Association
    O Partnership
    © Corporation
    O Governmental Entity
    O Other (please specify)

   45. Name of Person Signing                                                     46. Title of Person Signing            .
   Simon McLellan                                                                 Senior Engineer

                 WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                        (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                          (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).

                                      SATELLITE EARTH STATION AUTHORIZATIONS
                             FCC Form 312 — Schedule B:;(Technical and Operational Description)



                                                                FOR OFFICIAL USE ONLY



  Location of Earth Station Site
   E1: Site Identifier: Remote Terminal #1         E5. Call Sign:                                E080100
   E2: Contact Name Simon McLellan                 E6. Phone Number:                             (949) 636—0732
   B3. Street:                                     E7. City:
                                                   E8. County:
   E4. State                                       E9. Zip Code
   E10. Area of Operation:                         CONUS + Territorial & International Waters (within Desigated Satellite Footprints)
   E11. Latitude:      0 ° 0‘ 0.0 " N
   E12. Longitude:     0 °0‘ 0.0 " W
   E13. Lat/Lon Coordinates are:                   ONAD—27                                       @NAD—83                                     ON/A
   E14. Site Elevation (AMSL):                     0.0 meters

  E15. If the proposed antenna(s) operate in the Fixed Satellite Service (FSS) with geostationary satellites. do(es) the
  proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a) and (b) as demonstrated by the
  manufacturer‘s qualification measurement? If NO, provide as a technical analysis showing compliance with two—degree
                                                                                                                                    OYes ®No           ON/A
  spacing policy.
  E16. If the proposed antenna(s) do not operate in the Fixed Satellite Service (FSS), or if they operate in the Fixed Satellite
  Service (FSS) with non—geostationary satellites, do(es) the proposed antenna(s) comply with the antenna gain patterns             OYes     CONo      ®@N/A
  specified in Section 25.209(a2) and (b) as demonstrated by the manufacturer‘s qualification measurements?

  E17. Is the facility operated by remote control? If YES, provide the location and telephone number of the control point.          ® Yes         © No



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  E18. Is frequency coordination required? If YES, attach a frequency coordination report as

  E19. Is coordination with another country required? If YES, attach the name of the country(ies) and
                ie o                                                                                                             O
  plot of coordination contours as                                                                                                   Yes     ® No
  E20. FAA Notification — (See 47 CFR Part 17 and 47 CFR part 25.113(c)) Where FAA
  notification is required, have you attached a copy of a completed FCC Form 854 and/or the
  FAA‘s study regarding the potential hazard of the structure to aviation?                                                       O Yes       ® No
  FAILURE TO COMPLY WITH 47 CFR PARTS 17 AND 25 WILL RESULT IN THE
  RETURN OF THIS APPLICATION.
  POINTS OF COMMUNICATION
  Satellite Name:OTHER OTHER If you selected OTHER, lease enter the foll
      1. Common Name:                                                               . ITU Name:
      3. Orbit Location:                                                           4.             : USA
  Satellite Name:OTHER OTHER If                   selected OTHER, lease enter the foll
      1..Common Name:                                                            E22. ITU Name:
      3. Orbit Location:                                                           4.             : USA
  POINTS OF COMMUNICATION (Destination Points)
  E25. Site Identifier: Remote Terminal #1
  E26. Common Name:                                                                                      [E27. Country: USA                          |
  ANTENNA

      Site ID        Anteuma       2              E30.           B3L        wanern,               E41/42. Antenna Gain Transmint and/or
                        1d      QuantityManufacturer|           Model            Size                    Recieve(           dBi at         GHz)

  Remote                                      Aerosat          70—100—                               :
  Terminal #1       5           wl            Avionics         0000—01     6.6               31.8 dBi at 1 1.7
  Remote                                      Aerosat          70—100—                             F
  Terminal #1       A           i             Avionics         0000—01     06               286 dBi at 1447
             ‘                                            E37. Building| E38. Total E39. Maximum
    F28     E33/34. Diameter   £3§. Above    E36. Above Height Above] Input Power Antenna Height         M LOfal
  Antenna                        Ground          Sea                                                    EIRP for al
     1d   Minor/Major(meters) Level(meters)|Level(meters)    Ground      at antenna         Above      carriees(dBw)
                                                          Level(meters) flange(Watts)| Rooftop(meters)
  A          0.0/0.0                   Jo.0              0.0               0.0                    10.0              0.0                    41.8
  FREQUENCY
    E28.             E43/44.        E45.    £46. Autenna         EA47.                       E48. Maximum                       E49. Maximum ERIP
  Antenna           Frequency       T/R Polariza.tion(H V,LR) Emission                          EIRP per                             Density per
     Id            Bands(MHz)      |Mode               h0     Designator                     Carrier(dBW)                        Carrier(dBW/4kHz)
  A             11700 12200        R       Horizontal and Vertical |36M0G7D               |0.0                            0.0
  E50. Modulation and Services QPSK or octal PSK
  A          [14050 14470         ___[T____|Horizontal and Vertical|1M60G7D               |38.6                       |14.6
  E50. Modulation and Services QPSK or octal PSK
  FREQUENCY COORDINATION
                                                                         E56.                              +
                                   £54/55. Range of
                                                                       l.
                                                                                      lE
                                                                                    Antenna R
                                                                                                                      s
                                                                                                                   Antenna   E60. Maximum
    E28.             .    E52/53.          .         Station                               .         Station               .            &
          E51. Satellite             Satellite Arce    .                           Elevation           s           Elevation  EIRP Density
  Antenna      &         Frequency                  Azimuth                                         Azimuth
     1d    Orbit Type Limits(MHz) Eastern/Western     Ansle                          Angle            Antle          Angle     toward the
                                         Limit             &                        Eastern                8       Western |Horizon(dBW/4kHz)
                                                    Eastern                            Pags         Western            Tmaf
                                                         faast                       Limit               foust       Limit
                                                      Limit                                           Limit
                    f      11700.0000
  A          Geostationary 12200.0000           83.0/127.0         206.6           35.0            138.7           11.2              0.0

                    .      14050.0000
             Geostationary 14470.0000           83.0/127.0         206.6           35.0            138.7           11.2              5.4

  REMOTE CONTROL POINT LOCATION
  E61. Call Sign                                                                                                 E66. Phone Number


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  NOTE: Please enter the callsign of the controlling station, not the callsign for which this application is being
  filed.                                                   —
  E62. Street Address


  E63. City                                                             E68. County                                         E67/68.                E64. Zip
                                                                         .                                                  State/Country          Code
                                                                                                                            P
  [mrrrrmmmmmmmrmmmmoolooonoommomumummummmmmmuunmuumumccmmommummconiicommmummmummummummmucmmmmmmmmmmemmel
                                  SATELLITE EARTH STATION AUTHORIZATIONS
                             FCC Form 312 — Schedule B;:(Technical and Operational Description)



                                                                 FOR OFFICIAL USE ONLY



   Location of Earth Station Site
   E1: Site Identifier: Remote Terminal #2 ES. Call Sign:                                        E080100
   E2: Contact Name Simon McLellan                  E6. Phone Number:                            (949) 636—0732
   E3. Street:                                      E7. City:
                                                    E8. County:
   E4. State                                        E9. Zip Code
   E10. Area of Operation:                          CONUS + Territorial & International Waters (within Desigated Satellite Footprints)
   E11. Latitude:       0 °0 ‘0.0 " N
   E12. Longitude:      0 °0 ‘0.0 " W
   E13. Lat/Lon Coordinates are:                    ONAD—27                                       ®@NAD—83                                    ON/A
   E14. Site Elevation (AMSL):                      0.0 meters
                                                                                                                                    ‘__—..__=

   E15. If the proposed antenna(s) operate in the Fixed Satellite Service (FSS) with geostationary satellites, do(es) the
   proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a) and (b) as demonstrated by the          0y        @n       ON/A
   manufacturer‘s qualification measurement? If NO, provide as a technical analysis showing compliance with two—degree                   t         O
   spacing policy.
   E16. If the proposed antenna(s) do not operate in the Fixed Satellite Service (FSS), or if they operate in the Fixed Satellite
   Service (FSS) with non—geostationary satellites, do(es) the proposed antenna(s) comply with the antenna gain patterns            OYes      CNo      ®@N/A
   specified in Section 25.209(a2) and (b) as demonstrated by the manufacturer‘s qualification measurements?

   E17. Is the facility operated by remote control? If YES, provide the location and telephone number of the control point.         ® Yes          O No
  mmooooorororommmmnnnmnmmmmnmmmmmmmunmmmmmmmnmmunmnmmmunmmnmmmtnmtmmmmmmnmmunmmmmumcsonmmuntnmmnminnmmmniminnnnmmnnnnman


   E18. Is frequency coordination required? If YES, attach a frequency coordination report as                                       O Yes          ® No
   E19. Is coordination with another country required? If YES, attach the name of the country(ies) and                              o y            @ n
   plot of coordination contours as                                                                                                       6              o
   E20. FAA Notification — (See 47 CFR Part 17 and 47 CFR part 25.113(c)) Where FAA
   notification is required, have you attached a copy of a completed FCC Form 854 and/or the
   FAA‘s study regarding the potential hazard of the structure to aviation?                                                         O Yes          ® No
   FAILURE TO COMPLY WITH 47 CFR PARTS 17 AND 25 WILL RESULT IN THE
   RETURN OF THIS APPLICATION.
  POINTS OF COMMUNICATION
   Satellite Name:SES—6 ($2870)            New Skies 40.5 W.L. If you selected OTHER, please enter the foll
       1. Common Name:                                                                            . ITU Name:
       3. Orbit Location:                                                                       4. Co
     atellite Name:SES—1 | SES—1          101.0 W.L. If you selected OTHER, please enter the follo
       1. Common Name:                                                                            . ITU Name:
       3. Orbit Location:                                                                       4. Co
   Satellite Name:AMC 9 ($2434) AMC 9 83 W.L. If you selected OTHER, please enter the foll
       1. Common Name:                                                                            . ITU Name:
       3. Orbit Location:                                                                       4.
     atellite Name:AMC 2 AMC 2 80.85 W.L. If you selected OTHER, please enter the foll
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       1. Common Name:                                                                       . ITU Name:
       . Orbit Location:                                                                   4. Coun
  POINT S OF COMMUNICATION (Destination Points)
  E25. Site Identifier: Remote Terminal #2
  E26. Common Name:                                                                                         [E27. Country: USA                        |
  ANTENNA

       Site ID       Amanna        !2             E30.           E31.       wler,,                   E41/42. Antenna Gain Transmint and/or
                        1d      QuantityManufacturer| Model                      Size                       Recieve(           dBi at         GHz)

  Remote            B           1000         |TECOM             C         (oss               28.8 dBi at 14.25
  Terminal #2                                                   Stream

  s                 B           1000         [TECOM             _         los                31.1 dBi at 11.75
  Terminal #2                                                   Stream
                                                             E37. Building| E38. Total E39. Maximum
    126.      E33/34. Diameter   35 Above       Fan: Above Height Above| Input Power Antenna Height         Te 1644
  Antenna),   ,.      3            Ground           Sea                                                    EIRP for al
     Id     Minor/Major{meters) Level(meters)] Level(meters)    tGround      at anteina       Above       carriers(dBW)
                                                             Level(meters)| flange(Watts)|Rooftop(meters)
  B          0.0/0.0                   0.0                0.0               0.0                      31.6               0.0                   43.8
  FREQUENCY
    E28.            E43/44.        E45.     E46. Antenna         E47.                           E48. Maximum                     E49. Maximum ERIP
  Antenna          Frequency       T/R Polariza.tion(H.V,L,R) Emission                             EIRP per                           Density per
     Id           Bands(MHz)      |Mode               C       Designator                        Carrier(dBW)                      Carrier(dBW/4kHz)
  B          11450 11700          R       Horizontal and Vertical ||36M0G7D                |0.0                           0.0
  E50. Modulation and Services QPSK or octal PSK
  B          [11700 12200        [R      ____[Horizontal and Vertical |36M0G7D             |0.0                           Jo.0
  E50. Modulation and Services QPSK or octal PSK
  B          [12250 12750        ___|R____[Horizontal and Vertical |36M0G7D                |0.0                           [o.0
  E50. Modulation and Services QPSK or octal PSK
   B         [14050 14470         ____[T____[Horizontal and Vertical|3M20G7D               __|41.8                        [14.8
  E50. Modulation and Services QPSK or octal PSK
                 10950.0000                   .               .
  B              11200.0000       R       Horizontal and Vertical |36M0G7D                  [0.0                          0.0

   E50. Modulation and Services QPSK or octal PSK
                 14050.0000                   .               .
   B             14470 0000       T       Horizontal and Vertical |1M60G7D                  |36.0                             11.9

   E50. Modulation and Services QPSK or octal PSK
                 14050.0000                   .              .
   B             14470 0000       T       Horizontal and Vertical|3M20G7D                   (43.3                             16.2

   E50. Modulation and Services QPSK or octal PSK
                 14050.0000                   .               .
   B             14470.0000       T       Horizontal and Vertical |6M40GT7D                 (43.8                             13.7

   E50. Modulation and Services QPSK or octal PSK



                                                                         5. || & o
  FREQUENCY COORDINATION



                                    E£54/55. Range of        %                      Antenna                  s         Antenna    E60. Maximum
     E28.              f   E52/53.           §         Station                              s           Station                 s            s
           E51. Satellite             Satellite Arc      >                          Elevation             s            Elevation   EIRP Density
   Antenna      7         Frequency                   Azimuth                                          Azimuth
      1d    Orbit Type LimitsMHz) Eastern/Western Antle                               Angle              Ansle           Angle      toward the
                                          Limit             8                        Eastern                 $         Western |Horizon(dBW/4kHz)
                                                      Eastern                           o and          Western             faas:
                                                           62.                        Limit                 2.           Limit
                                                                         Limit                              Limit
                    .      10950.0000
   B         Geostationary 112000000          40.5/40.5             323.4           28.7              299.2            17.3             0.0

                    .      11450.0000
             Geostationary 11700.0000         37.5/127.0            194.4           20.9               119.5        2:6                 0.0

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                     .      11700.0000
              Geostationary 12200.0000            37.5/194.0             194.4         20.9          259.8           6.3             0.0

                     .      12250.0000
              Geostationary 12750.0000            55.5/194.0             127.5         39.6          259.8           6.3             0.0

                        .       14050.0000
              Geostationary 14470.0000            37.5/194.0             194.4         20.9          259.8           6.3             13.3

  REMOTE CONTROL POINT LOCATION
  E61. Call Sign                                                                                                    E66. Phone Number
  E940460                                                                                               3           (301) 601—7205
  NOTE: Please enter the callsign ofthe controlling station, not the callsign for which this application is being
  filed.
  E62. Street Address
  One Aerojet Way
  E63. City                                                                            E68. County                         E67/68.          E64. Zip
  North Las Vegas                                                                      Clark                               State/Country    Code
                                                                                                                           NV/ USA          89030
  FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

  The public reporting for this collection of information is estimated to average 2 hours per response, including the time for
  reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and
  reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the
  collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM,
  Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the
  Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fee.gov. PLEASE DO NOT
  SEND COMPLETED FORMS TO THIS ADDRESS.

  Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the
  government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to
  provide you with this notice. This collection has been assigned an OMB control number of 3060—0678.

  THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13,
  OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.




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                                                                                       Row 44 Inc.
                                                                                     FCC Form 312
                                                                                       March 2015
                                                                                        Page 1 of 5




                                           Attachment

                    Description of Application for Modification of License



1.0    OVERVIEW

This application seeks to modify the current Row 44, Inc. ("Row 44")‘ Ku—band Earth Stations
Aboard Aircraft ("ESAA") license to increase EIRP for transmit conditions with 25° skew or
less to the receiving satellite, add new emission designators, and to transmit at lower EIRP than
is presently authorized at skew angles ranging up to 55°, angles of arrival at which Row 44 does
not currently operate. In addition, Row 44 seeks authority to add two additional satellites as
points of communication — AMC—2 at 80.85° W.L. and SES—6 at 40.5° W.L. These additional
points of communication are both space stations licensed to and operated by SES, S.A. SES—6 is
a non—U.S. satellite, but is already included on the FCC‘s Ku—band Permitted List.

All of the requested changes relate solely to the 0.62 meter TECOM Ku—Stream antenna, which
is identified as Remote Terminal #2 in the existing Row 44 license (Call Sign E0O80100). No
other changes in the technical parameters contained in the current ESAA license are proposed
except as set forth herein, in Form 312 and Schedule B thereto, and in the Technical Appendix,
Exhibit A to this application. To the extent practicable, the Form 312 includes only information
that is changing due to the requested modification (e.g., it includes both the new satellite points
of communication and those previously—authorized satellites for which changes in operating
parameters are requested, but not the other satellites included as points of communication under
Row 44‘s current license for which no operational modification is sought herein).

The proposed modifications to Row 44‘s existing authority apply only to certain satellite points
of communication that are currently part of the Row 44 license — specifically AMC—9 and SES—1,
operated by SES — as well as to the newly—requested satellites identified above. The requested
changes in operating parameters will provide enhanced service to airline passengers on flights
operating over North American airspace and in the Atlantic and Pacific Ocean regions by
allowing increased system capacity and service availability. Except as specifically set forth
herein, Row 44 seeks these modifications subject to all terms and conditions set forth in its
current license."


‘_The in—flight connectivity business established by Row 44 now operates under the name
Global Eagle Entertainment, which is the parent company of Row 44 (see IBFS File No. SES—
T/C—20121203—01063). As Row 44 remains the name of the FCC licensee, that designation is
used in this application.
* See Row 44 Inc., Radio Station Authorization, Call Sign E080100, File No. SES—MOD—
20121023—00963, as amended by SES—AFS—20130920—00833 & SES—AFS—20140203—00029
(Sat. Div., granted Aug. 29, 2014).


                                                                                       Row 44 Inc.
                                                                                     FCC Form 312
                                                                                       March 2015
                                                                                         Page 2 of 5




Row 44 seeks to implement service on one or more of the satellites subject to its amended
modification application as soon as practicable, and respectfully requests that this modification
application be placed on public notice as quickly as possible in order to facilitate this projected
implementation schedule. To the extent necessary, Row 44 will seek Special Temporary
Authority to permit modified service using certain satellites in advance of final action on the
entirety of the current request for modification.


2.0    TECHNICAL DESCRIPTION, LINK BUDGETS AND PREDICTED
       COVERAGE AREA

Exhibit A includes a technical description of the proposed changes, a depiction of the coverage
contours in relation to combinations of EIRP and skew angle (skew angle ranging from 25° to
55°), as well as representative link budgets. See 47 C.F.R. § 25.227(b)(4).


3.0    COORDINATION LETTER

Row 44‘s intended operations are within the scope that SES has coordinated with the adjacent
satellite operators, and should not cause harmful interference into adjacent satellites operating in
accordance with FCC‘s two—degree spacing policy. A copy of a supplemental coordination letter
covering Row 44‘s proposed new operations with the identified SES satellites is attached hereto
as Exhibit B. See 47 C.F.R. §25.227(b)(2).

Row 44‘s operations, as modified, will continue to conform to the terms of its existing
coordination agreements with the National Aeronautics and Space Administration ("NASA") and
the National Science Foundation ("NSF"), as required under Condition 90057 its current ESAA
license."




3 Row 44‘s coordination agreements with NASA and NSF pre—date the adoption of current rule
Sections 25.227(c)(1) & (d)(1), which provide for Public Notice to allow comment on
coordination agreements governing operations of ESAA networks in frequency bands shared
with NASA and NSF facilities. Accordingly, to the extent necessary, Row 44 requests that the
Public Notice issued announcing acceptance of this modification application include the
referenced notifications concerning Row 44‘s existing coordination agreements with NASA and
NSF.


                                                                                     Row 44 Inc.
                                                                                   FCC Form 312
                                                                                     March 2015
                                                                                      Page 3 of 5



4.0    RADIATION HAZARD STUDY

Exhibit C to this application is a revised radiation hazard assessment, submitted pursuant to
Section 25.227(b)(8) of the Commission‘s Rules, reflecting the changed operating parameters
requested for the TECOM antenna.


5.0    SPACECRAFT, FREQUENCY & BEAM COVERAGE

See chart on next page


                                                                                  Row 44 Inc.
                                                                                FCC Form 312
                                                                                  March 2015
                                                                                   Page 4 of 5




                 Spacecraft, Frequency & Beam Coverage Table
                 (All Provide Some Coverage to U.S. Locations)




                            North America,

   AMC—2          sosy      4e     tss
                            Caribbean and
                                                o faa,         11.712.3
                            North Atlantic
                            North America,
   AMC—9          83.0W     Caribbean and       141031447      1Lg7_l2.2
                            North Atlantic                                          SES
                            North America,
   SES—1          101.0W    Central America,    14.05—14.47    11.7—12.2
                             and Caribbean
                                  3                            10.95—11.2;
   SES—6
       —    *
                  40.5W     Atlantic Ocean      14.053—14.47
                                                     —
                                                               11.45—411.7  °




    1S—19         166.0E    Pacific Ocean       14.05414.47    1225—412.75         Intelsat
   Eutelsat                              .
   115WA
 (Satmex 5)*
                  114gw     Noh    Americasnd pamsragy
                            Pacific Ocean
                                                               |117.—12.2
                                                                                   Eutelsat
  Eutelsat                  North A      .
   117WA         116.8 w      q1     AmMeNe®    14.05—14.47    |11.7—12.2
 (Satmex 8y*                 and Caribbean

   THINt          37.5W     North Atlantic      14.05—14.47    11.45—11.7;
                             Ocean                             11.7—12.2
                                                                                   Telesat
                             North Atlantic
E“{;‘;:g;’*s“l    63.0W      Ocean, Canada and 14.05—14.47      11.7—12.2
                             Caribbean


 Horizons 1*      127.0y     North Americaand 14es j447         14171227            JSAT
                             Pacific Ocean


  * = Non—U.S.—licensed satellites included on Ku—band Permitted List

  t = TIIN is a U.S.—licensed satellite (Call Sign $2357) operated by Telesat Canada

 I_—_] = New Points of Communication requested in this modification application

 l:l = Existing Points of Communication, changed operating parameters requested


                                                                                  Row 44 Inc.
                                                                                FCC Form 312
                                                                                  March 2015
                                                                                    Page 5 of 5



6.0    LICENSEE CERTIFICATION

I, Simon McLellan, VP Engineering of Row 44, Inc., hereby certify as follows:

       1. The target space station operator for the satellites subject to this modification
          application has confirmed that proposed Earth Stations Aboard Aircraft operations are
          within coordinated parameters for adjacent satellites up to 6 degrees away on the
          geostationary arc; and

       2. The licensee will continue to comply with the requirements of paragraphs (a)(6),
          (a)(9), (a)(10), and (a)(11) of Section 25.227 of the Commission‘s Rules and the
          conditions of its existing license.




                                                          Simon McLellan
                                                          VP Engineering
                                                          Row 44, Inc.
March 17, 2015


                                              EXHIBIT A

                                                 Approach


Row 44‘s present implementation involves a single EIRP and skew—limit. Row 44 proposes to augment
its operation by establishing four EIRP—skew limit combinations and 3 emission bandwidth
combinations.



Table 1 depicts the present Row 44 authorization:

                                      Table 1 — Present Authorization


                EIRP Limit (in a 1.024 MHz emission bandwidth)                          Skew Limit
                  38.8 dBW (14.7 dBW/ 4 kHz, 40.0 dBm TX power)                          35 degrees



Table 2 depicts the proposed authorizations involving skew angle, EIRP density / TX power, and
emission bandwidth:


                                     Table 2 — Proposed Authorization


  EIRP Density and TX               EIRP Density and TX                 EIRP Density and TX           Skew
Power (1.024 MHz emission         Power (2.048 MHz emission              Power (4.096 MHz             Limit
       bandwidth)                        bandwidth)                     emission bandwidth)
16.2 dBW/ 4 kHz (41.5     dBm      16.2 dBW/ 4 kHz (44.5     dBm        13.7 dBW/ 4 kHz (45.0        25
        TX power)                          TX power)                        dBm TX power)          degrees
14.7 dBW/ 4 kHz (40.0     dBm      14.7 dBW/ 4 kHz (43.0     dBm        13.7 dBW/ 4 kHz (45.0        35
        TX power)                          TX power)                        dBm TX power)          degrees
13.7 dBW/ 4 kHz (39.0     dBm      13.7 dBW/ 4 kHz (42.0     dBm        13.7 dBW/ 4 kHz (45.0        45
        TX power)                          TX power)                        dBm TX power)     _    degrees
11.9 dBW/ 4 kHz (37.2     dBm      11.9 dBW/ 4 kHz (40.2     dBm        11.9 dBW/ 4 kHz (43.2         55
        TX power)                          TX power)                        dBm TX power)          degrees

Introducing the revised limits and emission bandwidths in Table 2 will allow:


(1) Row 44 to transmit at higher EIRP densities within geographic areas limiting skew to 25 degrees,
facilitating higher inroute data rates for users / aircraft within those areas

(2) Row 44 to continue to transmit at existing EIRP densities (and facilitating existing data rates), within
geographic areas where skew is limited to 35 degrees


(3) Row 44 to transmit at lower EIRP densities within geographic areas limiting skew to 45 and 55
degrees, thereby facilitating services for users / aircraft where data communications were previously
unavailable

(4) Row 44 to transmit at a variety of combinations of EIRP and emission bandwidths, thereby
optimizing bandwidth usage, and providing users higher data rates than those of the present.

In all cases of skew limits of 25, 35, 45, or 55 degrees, Row 44 shall comply with the EIRP density
limits established in Section 25.227.



Table 3 depicts the proposed applicability of the Table 2 categories between satellites and skew angles:

                          Table 3 — Applicability of Table 2 Skew—EIRP Limits


              Satellite               25 d             35 d             45 d
               SES—1
              AMC—9
              AMC—2
               SES—6




This Exhibit also includes sample link budgets pertaining to each of the combinations of EIRP, emission
bandwidth, skew limit, and satellite. These are located at the end of this Exhibit. Note that in all cases,
the link budgets for 1.024 MHz emission bandwidths apply to those for 2.048 MHz as well, as the EIRP
densities are the identical, and link performance subsequently the same.



Document Created: 2015-04-10 16:28:53
Document Modified: 2015-04-10 16:28:53

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