Attachment STA Narrative

This document pretains to SES-STA-20170619-00660 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017061900660_1239324

EXPEDITED ACTION REQUESTED 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 immediate special temporary authority (“STA”) for a period of 60 days to permit up to 100 AeroSat model HR6400 ESAA terminals and up to 100 ThinKom model 2Ku ESAA terminals to communicate in conventional and extended Ku-band frequencies with the U.S.-licensed AMC-6 satellite at 85° W.L. Grant of the requested STA will serve the public interest by allowing AC BidCo to restore capacity that it had been using on the AMC-9 satellite, which recently experienced an anomaly and is not currently capable of providing service. AC BidCo is preparing a modification application to add AMC-6 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 is seeking authority to add AMC-6 as a point of communication to replace capacity it had been using on the AMC-9 satellite. STA Request AC BidCo seeks STA to permit its ESAA terminals to commence communications with AMC-6 pending submission of and action on its upcoming application to add AMC-6 to the AC BidCo ESAA License. Because AMC-6 is a U.S.-licensed satellite, full technical data regarding the satellite is already on file with the Commission, 2 and AC BidCo incorporates that information by reference herein. AC BidCo received Commission authority to use AMC-6 conventional Ku-band capacity at the satellite’s prior 67° W.L. orbital location, 3 and now 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 SES Americom, Inc., Call Sign S2347, File No. SAT-MOD-20170316-00051, granted June 14, 2017 (the “AMC-6 License”). 3 The AC BidCo ESAA License authorizes the ThinKom AES2 antennas to communicate with AMC-6 at 67° W.L., and AC BidCo requested and received special temporary authority to permit AeroSat AES1 antennas to communicate with AMC-6 at that location. See Call

EXPEDITED ACTION REQUESTED AC BidCo LLC Attachment A Page 2 proposes to operate with the satellite at 85° W.L. in both the conventional and extended Ku-band frequencies. The technical parameters of AC BidCo’s proposed operations with AMC-6 are consistent with those specified in the AC BidCo ESAA License. 4 AC BidCo seeks authority to use AMC-6 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 11.45-11.7 GHz downlink spectrum, consistent with the AMC-6 License and the Commission’s orders in the ESAA proceeding. 5 Communications with the satellite will be supported by a teleport in Perris, CA, Call Sign E940448. AC BidCo is attaching two letters confirming that the proposed operations with AMC-6 at 85° W.L. are consistent with coordination agreements with operators of the satellites within six degrees on either side of AMC-6. SES, the AMC-6 licensee, has provided a coordination letter pertaining to AC BidCo’s proposed use of the extended Ku-band frequencies on AMC-6. In the conventional Ku-band frequencies, SES is operating pursuant to an agreement with EchoStar, which holds conventional Ku-band authority at the 85° W.L. orbital location and has entered into coordination agreements for those frequencies. As a result, EchoStar is providing a coordination letter to support AC BidCo’s proposed conventional Ku-band operations with AMC-6. AMC-6 will provide coverage of North America. AC BidCo requires immediate access to this satellite to restore service that was interrupted when AMC-9 unexpectedly ceased operations. AC BidCo emphasizes that the scope of this STA request is limited. AC BidCo is only seeking authority to add AMC-6 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 Sign E120106, File Nos. SES-STA-20170321-00321, granted Mar. 28, 2017, & SES-STA- 20170421-00455, granted Apr. 26, 2017. 4 Operations of the AC BidCo ESAA terminals with AMC-6 will not involve any increase in the maximum off-axis EIRP density levels previously described to the Commission. 5 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).

EXPEDITED ACTION REQUESTED AC BidCo LLC Attachment A Page 3 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 AMC-6 are consistent with 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 STA on less than three business days’ notice is justified under the facts here. Section 25.120(a) specifies that an STA request received less than three working days in advance can be accepted “upon due showing of extraordinary reasons” why the request could not have been filed earlier. In this case, the anomaly affecting AMC-9 occurred suddenly and without warning, preventing AC BidCo from anticipating the need for replacement capacity and submitting this request with more advance notice. Grant of the proposed STA will allow AC BidCo to restore capacity needed to satisfy customer demand on important North American air transport routes, including in U.S. airspace, 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 United States 19 June 2017 Subject: Engineering Certification of SES for the AMC-6 satellite To whom it may concern, This letter confirms that SES is aware that AC BidCo LLC (“AC BidCo”), an affiliate of Gogo LLC (“Gogo”), 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 Ku-band Earth Stations Aboard Aircraft (“ESAA”) transmit/receive terminals (Call Sign E140054) pursuant to ITU RR 5.504A and Section 25.227 of the Commission’s rules, on domestic and international flights. The Modification Application will seek authority for AC BidCo’s ESAA terminals to communicate with the AMC-6 satellite at 85°W.L., under the current ESAA rules including Section 25.227. Based upon the representations made to SES by AC BidCo concerning how it will operate on AMC-6 in the extended Ku-band according to its letter dated 24 May 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 existing coordination agreements to which SES is a party with all adjacent satellite operators within +/- 6 degrees of orbital separation from AMC-6. • 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 AMC-6. Yours Sincerely, _____________/s/____________ Kimberly M. Baum SES Americom, Inc. Tel. +1 609 987 4000 4 Research Way Fax +1 609 987 4517 Princeton, NJ 08540 Enter sender e-mail USA www.ses.com

16 June 2017 Subject: Engineering Certification of EchosStar Satellite Operating Corporation ("EchoStar") for the AMC—6 Satellite To whom it may concern, This letter confirms that EchoStar is aware that AC BidCo LLC ("AC BidCo"), and affiliate of Gogo LLC ("Gogo"), 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 5.504 and Section 25.227 of the Commission‘s rules (Call Sign E140054). The Modification Application will seek authority for AC BidCo‘s ESAA terminals to communicate with the AMC—6 satellite at 85° W.L., under the current ESAA rules, including Section 25.227. Based upon the contents of the applications and the representations made to SES by AC BidCo concerning how it will operate on AMC—6 according to its letter dated June 14, 2017: * EchoStar 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 EchoStar is a party with adjacent satellite operators within +/— 6 degrees of orbital separation from AMC—6. * If the FCC authorizes the operations proposed by AC BidCo, EchoStar will include the power density levels specified by AC BidCo in all future satellite network coordination with other operators of satellites adjacent to AMC—6. Yours Sincgrely, A /4/( P aime Londono Vice President, Advanced Programs and Spectrum Management Echostar Satellite Operating Corporation ECHOSTAR SATELLITE SERVICES L.L.C. 100 Inverness Terrace East + Englewood, CO 80112 + Tel: 303.706.4000


Document Created: 2017-06-19 21:07:46
Document Modified: 2017-06-19 21:07:46
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