Attachment Explanatory Stmt

This document pretains to SES-STA-20151221-00956 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015122100956_1119431

Row 44, Inc. STA Extension Request December 2015 Page 1 of 1 EXPLANATORY STATEMENT Row 44, Inc. hereby requests Special Temporary Authority (“STA”) for an additional 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 authorized aeronautical mobile earth stations (“AMES”) transmitting via AMC-1 at 129.15 W.L. Row 44 has filed an application seeking the permanent modification of its ESAA license to operate with AMC-1 as a point of communication (“Modification Application”). See File No. SES-MFS-20150928-00635. Row 44 has been granted Special Temporary Authority (“STA”) permitting initiation of service using AMC-1 with up to three hundred (300) AMES while the Modification Application remains pending. See File No. SES- STA-20151023-00773 (granted Oct. 7, 2015). The current STA will expire on January 4, 2015. Row 44 requires the ability to continue operations using AMC-1 on an STA basis because it has fully transitioned its operations over western portions of North America from Satmex 5 (Eutelsat 115 West A) to AMC-1. The underlying Modification Application has not yet appeared on an Accepted for Filing Public Notice, so an additional period of STA operation on AMC-1 is required, extending authority through March 5, 2016. Row 44 has already been using AMC-1 for a period of several months under STA and its operations are otherwise consistent with all terms and conditions of its current license. Proposed operations on AMC-1 are limited to conventional Ku-band capacity frequencies at 11.7 to 12.2 GHz (downlink) and 14.0 to 14.5 GHz (uplink). All technical and other required information concerning Row 44’s use of AMC-1 is contained in the pending Modification Application. 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. See 47 C.F.R. § 25.120(b)(1). Such authority may be granted for a period not to exceed 60 days where the applicant has filed a request for permanent authority. See 47 C.F.R. § 25.120(b)(3). This is the case here. Grant of the authority requested in this instance will promote the public interest by permitting Row 44 to continue to serve existing customers using capacity on the AMC-1 satellite. Continued use of this space segment will maintain effective coverage of transcontinental routes, as well as Row 44’s primary U.S. service area (CONUS) and parts of Central America. Grant of the requested STA is consistent with Commission 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 its 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-1 is already in use. Accordingly, Row 44 respectfully requests that the FCC grant it authority effective January 5, 2016 for an additional period of sixty (60) days to transmit in the conventional Ku-band via the AMC-1 satellite using up to three hundred (300) deployed TECOM AMES that operate under its FCC ESAA network license.


Document Created: 2015-12-21 16:02:01
Document Modified: 2015-12-21 16:02:01
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