Attachment Explanatory Stmt

This document pretains to SES-STA-20161223-00972 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016122300972_1162637

Row 44, Inc. STA Request December 2016 EXPLANATORY STATEMENT Row 44, Inc., pursuant to Section 25.120(b) of the FCC’s Rules, hereby requests Special Temporary Authority (“STA”) for an initial period of sixty (60) 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-3 satellite (“AMC-3”) at 72 W.L. Row 44 is currently authorized to transmit to AMC-3 at the 67 W.L. orbital location as part of its existing ESAA license. The AMC-3 satellite, however, is in the process of being permanently relocated to 72 W.L. Capacity on AMC-6 at 67 W.L. is currently being used on an interim basis pursuant to STA (see FCC File No. SES-STA-20161207-00932) as replacement capacity for space segment on AMC-3, but Row 44 expects to transition back to AMC-3 once it is on station and operating at its new location, as early as January 8, 2017. Row 44 also intends to file within the initial term of the requested STA an application to modify its license to specify long-term operation on AMC-3 at 72 W.L. Row 44’s operations on AMC-3 at 72 W.L. will not cause harmful interference to any adjacent satellites operating in accordance with FCC's two-degree spacing policy. Attached to this STA request is a coordination certification letter from SES, in accordance with Sections 25.227(b)(2) of the Commission’s Rules, covering the proposed operation, which will also be consistent with its existing, long-term coordination agreements with the National Science Foundation and the National Aeronautics and Space Administration. 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 where the applicant has filed, or plans to file, a request for permanent authority for the parameters and facilities requested. See 47 C.F.R. § 25.120(b)(3). This is the case here, where Row 44 anticipates submitting an application to modify its license permanently to permit access to AMC-3 at its new 72 W.L. orbital location within the initial STA term sought in this request. Grant of the authority requested here will promote the public interest by permitting Row 44 to continue providing service to its customers using capacity on the AMC-3 satellite at 72 W.L. in lieu of its prior use of AMC-3 at 67 W.L. and its current use of AMC-6 at that location under separate STA. Continued use of AMC-3 at its new orbital location will 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 as of January 8, 2017, for an initial period of sixty (60) days, to use the AMC-3 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 14:28:05
Document Modified: 2016-12-23 14:28:05
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