Attachment Explanatory Stmt

This document pretains to SES-STA-20150624-00365 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015062400365_1093594

                                                                                        Row 44, Inc.
                                                                                        STA Request
                                                                                          June 2015
                                                                                         Page 1 of 1



                                EXPLANATORY STATEMENT

        Row 44, Inc. hereby requests extension of Special Temporary Authority (“STA”) for an
additional period of sixty (60) days to permit it to operate its licensed Ku-band network of Earth
Stations Aboard Aircraft (“ESAA”) (Call Sign E080100) using the AMC-3 satellite at 67 W.L.
as a point of communication. On May 1, 2015, Row 44 was granted authority pursuant to
Section 25.120(b) of the FCC’s Rules for an initial 60-day period to operate using AMC-3 while
its underlying modification application (File No. SES-MFS-20150424-00270) for this authority
remains pending. See File No. SES-STA-20150424-00275. The current STA limits service on
AMC-3 to a maximum of fifty (50) earth stations during the period ending June 30, 2015. Row
44’s STA operations otherwise remain consistent with all terms and conditions of its current
license, and are 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.

        Row 44 has been operating successfully using the AMC-3 capacity for nearly two months
with no reported adverse effect on other authorized operations. This additional capacity has been
particularly important for the company’s operations because of increasing passenger demand for
in-flight entertainment and Internet access at a time when other capacity options are limited.
Grant of an additional 60-day STA period is therefore critical to maintain service availability,
and will affirmatively serve the public interest by helping to meet airline passenger demand for
connectivity.

        In light of current service demands, Row 44 also requests that the 50 unit limit on
antennas communicating via AMC-3 be increased to 100 units, allowing it greater operational
flexibility in the provision of its service. Although it is unlikely that this higher number of units
would need to access AMC-3 during normal operations, Row 44 seeks the added flexibility in
order to avoid capacity constraints during peak system use. The requested increase in the
number of terminals permitted to use AMC-3 will not increase the potential for interference
because antennas in use are individually assigned frequencies, and only one terminal will
transmit at any given time and frequency regardless of the total number of terminals authorized.
Such a modest expansion of an STA is consistent with Commission precedent for the ESAA
application of FSS. See, e.g., Row 44, Inc., File No. SES-STA-20150520-00300 (grant stamp,
May 28, 2015) (extending STA for a 60-day period and increasing the number of authorized
ESAA antennas from 50 to 100); Panasonic Avionics Corporation, File No. SES-STA-
20130516-00395 (grant stamp, July 24, 2013) (extending STA for a 60-day period and
increasing the number of authorized ESAA antennas from 20 to 100).

       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 pending modification
application. In addition, Row 44 acknowledges that any action taken pursuant to a grant of the
requested STA will continue to be at its own risk.



Document Created: 2015-06-24 18:47:36
Document Modified: 2015-06-24 18:47:36

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