Attachment Explanatory Stmt

This document pretains to SES-STA-20161223-00971 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016122300971_1162636

Row 44, Inc. STA Request December 2016 EXPLANATORY STATEMENT Row 44, Inc., pursuant to Section 25.120(b) of the FCC’s Rules, hereby seeks Special Temporary Authority (“STA”) for an additional thirty (30) days to operate its licensed Ku-band network of Earth Stations Aboard Aircraft (“ESAA”) (Call Sign E080100) using space segment capacity on the SES, S.A. (“SES”) AMC-6 satellite (“AMC-6”) at 67 W.L. The capacity on AMC-6 is already being used pursuant to STA (see FCC File No. SES-STA-20161207-00932) as interim replacement capacity for AMC-3, which is currently included in the Row 44 license. AMC-3 is being relocated from 67 W.L. to 72 W.L. Row 44 expects to transition capacity back to AMC-3 at its new location in early 2017, and will soon submit a modification application that includes a request for long-term authorization to use AMC-3 at 72 W.L. Row 44’s operations on AMC-6 at 67 W.L. are subject to the existing coordination certification letter from SES with respect to AMC-3 under Section 25.227(b)(2) of the Commission’s Rules and to all other conditions of its existing license. In providing its fleet management notification under Section 25.118(e) of the Commission’s Rules, SES expressly stated that “it will operate within the technical parameters currently licensed and coordinated for AMC-3 … at that location.” FCC Public Notice, “Policy Branch Information: Satellite Space Station Applications Accepted for Filing,” Report No. SAT-01194 (released October 21, 2016). Accordingly, there has been no change in Row 44’s operations at this orbital location and the coordination certification provided for this slot remains valid. 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 30 days “if the STA request has not been placed on public notice, and an application for regular authority is not contemplated.” See 47 C.F.R. § 25.120(b)(4). Because Row 44 will not be filing an application for permanent access to AMC-6 at 67 W.L., its request is limited to thirty (30) days duration. Row 44 currently anticipates that operations using AMC-6 will continue only until mid-January, such that additional extensions of the requested STA may not be required beyond the authority requested here. Grant of the additional authority requested here will promote the public interest by permitting Row 44 to continue providing service to its customers using capacity on the AMC-6 satellite temporarily in lieu of capacity on AMC-3. Use of AMC-6 will help maintain effective coverage of all U.S. domestic routes currently served by Row 44. Grant of the requested STA is consistent with Commission policy and will not adversely affect other authorized operations. Row 44 acknowledges that any action taken pursuant to a grant of the requested STA will be at its own risk, and respectfully requests that the FCC grant it authority not later than January 8, 2017, the expiration date of its current STA, for an additional period of thirty (30) days to use the AMC-6 satellite as a point of communication in the conventional Ku-band in the United States using TECOM antennas now operating under its FCC ESAA network license.


Document Created: 2016-12-23 14:26:02
Document Modified: 2016-12-23 14:26:02
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