Attachment STA Narrative

This document pretains to SES-STA-20170428-00486 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017042800486_1211944

AC BidCo LLC Attachment A Page 1 REQUEST FOR SPECIAL TEMPORARY AUTHORITY AC BidCo LLC (“AC BidCo”), which holds a license to operate an earth station aboard aircraft (“ESAA”) network, 1 hereby requests special temporary authority (“STA”) for a period of 60 days commencing no later than May 12, 2017, to permit up to 200 AeroSat model HR6400 ESAA terminals and up to 400 ThinKom model 2Ku ESAA terminals to communicate in the conventional Ku-band with the Colombian-licensed SES-10 satellite at 66.9° W.L. At that location, SES-10 will replace Ku-band capacity AC BidCo is currently using on the AMC-6 satellite. Grant of the requested STA will serve the public interest by allowing AC BidCo to meet customer demand for service continuity and expansion over North America, including in U.S. airspace. AC BidCo is preparing a modification application to add SES-10 as an authorized point of communications, and seeks STA pending submission of and action on that application. Background AC BidCo is authorized to operate Ku-band terminals with specified satellites for ESAA service in U.S. airspace, foreign airspace, and the airspace over international waters. AC BidCo’s license was issued based on demonstration that the proposed network would enhance competition in the provision of in-flight broadband service to air travelers and airline crew members and that the planned operations were fully consistent with technical standards designed to ensure protection of other authorized communications networks. AC BidCo’s authority permits it to use the AMC-6 satellite at 67° W.L. 2 The SES-10 satellite, which will ultimately operate at 66.9° W.L., 3 was launched recently and will provide follow-on capacity for services being provided today on AMC-6. AC BidCo understands that SES-10 is expected to arrive at its operational orbital location in May once in-orbit testing is complete. AC BidCo traffic currently on AMC-6 would then be transferred to SES-10, and that traffic transfer is currently scheduled to occur on May 14, 2017. 1 See Call Sign E120106, File Nos. SES-MFS-20170109-00015 & SES-AFS-20170208- 00139, granted in part and deferred in part Apr. 12, 2017 (the “AC BidCo ESAA License”). 2 The AC BidCo ESAA License authorizes the ThinKom AES2 terminals to communicate with AMC-6, and the AeroSat AES1 terminals are authorized to communicate with AMC-6 pursuant to special temporary authority granted in File Nos. SES-STA-20170321-00321 and SES-STA-20170421-00455. 3 See New Skies Satellites B.V., Call Sign S2950, File No. SAT-MPL-20170108-00002, reissued Mar. 22, 2017 (“SES-10 Market Access Grant”).

AC BidCo LLC Attachment A Page 2 STA Request AC BidCo seeks STA to permit its ESAA terminals to commence communications with SES-10 pending submission of and action on its upcoming application to add SES-10 to the AC BidCo ESAA License. Because SES-10 has been placed on the Permitted Space Station List, full technical data regarding the satellite is already on file with the Commission, 4 and AC BidCo incorporates that information by reference herein. AC BidCo is also attaching a letter confirming that its proposed ESAA operations are consistent with SES’s coordination agreements with operators of the satellites within six degrees on either side of SES-10. The technical parameters of AC BidCo’s proposed operations with SES-10 are consistent with those specified in the AC BidCo ESAA License. 5 AC BidCo seeks authority to use SES-10 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum, consistent with the SES-10 Market Access Grant and the Commission’s orders in the ESAA proceeding. 6 Communications with the satellite will be supported by a teleport in Perris, CA, Call Sign E940448. SES-10 will provide coverage of North America. AC BidCo requires access to this capacity to ensure continuity for existing operations being carried by AMC-6 and to provide sufficient bandwidth to meet near-term additional customer demand for in-flight connectivity. AC BidCo emphasizes that the scope of this STA request is limited. AC BidCo is only seeking authority to add SES-10 as an authorized point of communication for a limited number of ESAA terminals. AC BidCo is otherwise prepared to operate consistently with the terms and conditions set forth in the existing AC BidCo ESAA License. In addition, AC BidCo is willing to operate pursuant to the STA on an unprotected, non-harmful interference basis. Grant of the requested STA is consistent with Commission policy and will not adversely affect other authorized operations. AC BidCo’s proposed operations with SES-10 are consistent 4 New Skies Satellites B.V., Call Sign S2950, File Nos. SAT-PPL-20160117-00005 & SAT- MPL-20170108-00002. 5 Operations of the AC BidCo ESAA terminals with SES-10 will not involve any increase in the maximum off-axis EIRP density levels previously described to the Commission for the terminals. 6 Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14-14.5 GHz Frequency Bands, Notice of Proposed Rulemaking and Report and Order, IB Docket Nos. 12-376 & 05-20, 27 FCC Rcd 16510 (2012); Second Report and Order and Order on Reconsideration, IB Docket No. 12-376, 29 FCC Rcd 4226 (2014).

AC BidCo LLC Attachment A Page 3 with SES’s coordination agreements with adjacent satellite operators and will also conform to the terms of AC BidCo’s agreements with the National Science Foundation and the National Aeronautics and Space Administration. In addition, AC BidCo will comply with power flux density limits to protect terrestrial services outside the U.S. Grant of the proposed STA will allow AC BidCo to provide service continuity and respond to customer demand for increased capacity on important air transport routes in U.S. airspace and in the remainder of North America, promoting competition in the provision of aeronautical services and expanding the availability of in-flight broadband to air travelers and crew members.

Kimberly M. Baum Vice President Spectrum Management & Development, Americas Federal Communications Commission International Bureau 445 12th Street, S.W. Washington, D.C. 20554 2 4 April2017 Subject: Engineering Certification of New Skies Satellites B.V. for the SES-10 Satellite To whom it may concern, This letter confirms that New Skies Satellites B.V. ("SES") is aware that AC BidCo LLC. ("AC BidCo"), licensed by the Federal Communications Commission ("FCC") as AC BidCo LLC, is planning to file an application seeking a modification to its blanket authorization (the "Modification Application") to operate technically identical Ku-band Earth Stations Aboard Aircraft ("ESAA") pursuant to ITU RR 5.504A and Section25.227 of the Commission's rules (Call Sign E1201 06). The Modification Application will seek authority for AC BidCo's ESAA terminals to communicate with the SES-10 satellite at 66.9° W.L. , under the current ESAA rules, including Section25.227. Based upon the representations made to SES by AC BidCo concerning how it will operate on SES-10 according to its letter dated April21, 2017: • SES certifies that it has completed coordination as required under the FCC's rules and that the power density levels specified by AC BidCo are consistent with any existing coordination agreements to which SES is a party with adjacent satellite operators within +/- 6 degrees of orbital separation from SES-10. • If the FCC authorizes the operations proposed by AC BidCo, SES will include the power density levels specified by AC BidCo in all future satellite network coordination with other operators of satellites adjacent to SES-1 0. Kimberly M. Baum SES Tel. +1 202 478 7100 1129 20th Street NW, Suite 1000 Fax +1 202 478 7101 Washington, DC 20036 kimberly.baum@ses.com 1/1 USA www.ses.com


Document Created: 2017-04-28 16:26:52
Document Modified: 2017-04-28 16:26:52
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