Attachment SESSTA2017110301233.

SESSTA2017110301233.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20171103-01233 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017110301233_1305678

                                           E080100     SES—STA—20171103—01233       182017003142
                                           Row 44 Inc.



                                                                                                                        Approved by OMB
                                                                                                                               3060—0678

                            APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
STA Extension for Telstar 12 @ 109.2WL (Nov. 2017)
 1. Applicant

           Name:        Row 44 Inc.                       Phone Number:                        310—437—6000
           DBA Name:                                      Fax Number:

           Street:      c/o Global Eagle Entertainment    E—Mail:                              smclellan@geemedia.com
                        Inc.

                        4553 Glencoe Avenue, Suite 300

           City:        Marina Del Rey                    State:                                CA
           Country:     USA                               Zipcode:                             90292            =
           Attention:   MrSimon McLellan




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                                                            (or other identifier)
Applicant: Row 44, Inc.
Call Sign: E080100
File No.: SES—STA—20171103— OI2BPC5A§T§JBM
Special Temporary Authority (STA).           seies


Row 44, Inc., is granted extension of STA for 60 days to operate the TECOM 0.62m model Ku—
Stream and QEST 0.63 m model Q50000 earth station aboard aircraft (ESAA) terminals to
communicate with the Telstar 12 satellite (Call Sign $2462) at the 109.2° W. L. orbital location
in the 14.05—14.47 GHz (Earth—to—space) and 10.95—11.2 GHz, 11.45—12.2 GHz (space—to—Earth)
frequency bands under the following conditions:

1. Operations under this authority are on a non—interference basis only and non—protected basis
only and while operating under this temporary authority, Row 44 must not cause harmful
interference to, and must not claim protection from interference caused to it by, any other
lawfully operating radio—communications systems. Row 44 must cease operations immediately
upon notification of such interference and must immediately inform the Commission, in writing,
of such an event.

2. Operation pursuant to this authorization must be in compliance with the terms of the licensee‘s
coordination agreements with the National Science Foundation and the National Aeronautics and
Space Administration pertaining to operation of aircraft earth stations in the Ku—Band.

3. Operations of terminals shall not be within line—of—sight of TDRSS stations.

4. Operations will be over North America region, the Gulf of Mexico, and parts of the Caribbean
Sea.

5. Operations will exclude frequencies 11.2—11.45 GHz and 12.25—12.75 GHz (space—to—Earth)
with respect to Telstar 12.

6. Except as otherwise provided for herein, use of the bands 10.7—11.7 GHz (space—to—Earth) and
12.75—13.25 GHz (Earth—to—space) by geostationary satellites in the fixed—satellite service (FSS)
shall be limited to international systems, i.e., other than domestic systems. In the sub—bands
10.95—11.2 GHz and 11.45—11.7 GHz, Earth Stations on Vessels (ESV), Vehicle—Mounted Earth
Stations (VMES), and Earth Stations Aboard Aircraft (ESAA) as regulated under 47 CFR part 25
may be authorized for the reception of FSS emissions from geostationary satellites, subject to the
condition that these earth stations shall not claim protection from transmissions of non—Federal
stations in the fixed service. (NGS52)


7. Operations shall not exceed the proposed parameters in the underlying application FCC IBFS
File number SES—MOD—20171002—01094 for blanket authorization and shall not exceed the
power as coordinated with Telstar 12 satellite.

8. Any action taken or expense incurred as a result of operations pursuant to this special
temporary authority is solely at Row 44 Inc.‘s risk.


9. Grant of this STA is without prejudice to any determination that the Commission may make
regarding pending application FCC IBFS file number SES—MOD—20171002—01094.

10. Continued operations during this extension was authorized pursuant to Section 1.62 of the
Commission‘s rules, 47 C.F.R. § 1.62.

11. This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated
authority, 47 C.P.R. § 0.261, and is effective immediately.


2. Contact


             Name:         David S. Keir                       Phone Number:                        202—429—8970
             Company:      Lerman Senter PLLC                  Fax Number:                          202—293—7783
             Street:       2001 L Street, NW                   E—Mail:                              dkeir@lermansenter.com
                           Suite 400
             City:         Washington                          State:                                DC
             Country:      USA                                 Zipcode:                             20036      —4946
             Attention:                                        Relationship:                         Legal Counsel


(If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
3. Reference File Number or Submission ID 1B2017002776

 4a. Is a fee submitted with this application?
@ IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C Governmental Entity         ¢4 Noncommercial educational licensee
C Other(please explain):

4b. Fee Classification    CGX — Fixed Satellite Transmit/Receive Earth Station

5. Type Request

 @ Use Prior to Grant                             g4 Change Station Location                        & Other



6. Requested Use Prior Date
       11/06/2017
7. City                                                                   8. Latitude
                                                                          (dd mm ss.s h)    0   0   0.0


9. State                                                                   10. Longitude
                                                                           (dd mm ss.s h)    0   0    0.0
11. Please supply any need attachments.
Attachment 1: Explanatory Stmt                    Attachment 2:                                      Attachment 3:


12. Description.   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Request for special temporary authority for an additional period of sixty                                           (60)    days
     commencing November 6,             2017    to operate up to 110 SAA antennas using space                            seqgment capacity
     on Telstar 12 at 109.2 W.L. prior to action on Row 44‘s pending application to modify its
     license to specify use of T12 under its ESAAA license                              (File No.      SES—MOD—20171002—01094) .




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is                 Yes      gy No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name of Person Signing                                                 15. Title of Person Signing
   Simon McLellan                                                             Chief Engineer
           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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12. Description

Request for special temporary authority for an additional period of sixty            (60)   days commencing
November 6,       2017 to operate up to 110 SAA antennas using space seqgment capacity on Telstar 12 at
109.2 W.L. prior to action on Row 44‘s pending application to modify its license to specify use of
T12 under its ESAA license       (File No.   SES—MOD—20171002—01094) .   See Attached Explanatory Statement.


                                                                                              Row 44, Inc.
                                                                                             STA Request
                                                                                          November 2017



                                  EXPLANATORY STATEMENT

        Row 44, Inc., pursuant to Section 25.120(b) of the FCC‘s Rules, hereby requests Special
Temporary Authority ("STA") for an additional period of sixty (60) days to operate its licensed
Ku—band Earth Stations Aboard Aircraft ("ESAA") network (Call Sign EO80100) using the
Telstar 12 satellite at 109.2° W.L. ("T12") as an additional point of communication for up to one
hundred ten (110) of its 1,000 authorized TECOM/QEST SAA antennas (Remote #2). Row 44‘s
current authority for these operations will expire at 11:59pm on November 5, 2017.‘

        Row 44‘s operations on T12 will not cause harmful interference to any adjacent satellites
operating consistent with FCC‘s two—degree spacing policy. Row 44‘s September 21, 2017
coordination certification letter from Telesat Canada covering the proposed operations, in
accordance with Sections 25.227(b)(2) of the Commission‘s Rules, was included in its initial
STA request (FCC File No. SES—STA—20171002—01093), and is incorporated here by reference.
The operations are also consistent with Row 44‘s coordination agreements with the National
Science Foundation and the National Aeronautics and Space Administration pursuant to which
the existing ESAA license and STA were granted.

        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 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 has pending an application to modify its
license permanently to permit access to T12.

        Grant of the authority requested here will promote the public interest by permitting Row
44 to continue providing service to its customers using available capacity on T1l2. Grant of the
requested STA is consistent with Commission policy and will not adversely affect other
authorized operations. Indeed, Row 44 has already been operating as requested under the initial
STA for almost 30 days.

         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 grantit additional authority as of
midnight on November 6, 2017, for an additional period of sixty (60) days to and including
January 5, 2018, to use the T12 satellite as a point of communication in the conventional Ku—
band using its TECOM antenna (Remote #2) authorized under its FCC ESAA network license.


‘ Although Row 44 requested the full sixty (60) day operating period permitted by the Commission‘s
Rules in its initial STA request, it was granted only a 30—day STA. See 47 C.F.R. § 25.120(b)(3); FCC
File No. SES—STA—20171002—01093. The Bureau did not provide any reason for the shorter—term grant,
and Row 44 is aware of no reason why an operating period shorter than 60 days would be indicated.
Accordingly, Row 44 requests an additional 60—day STA in order to provide greater certainty of final
action on the underlying modification application in advance of expiration of the authority requested here.



Document Created: 2017-11-20 17:01:54
Document Modified: 2017-11-20 17:01:54

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