Attachment SESSTA2018011800042.

SESSTA2018011800042.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20180118-00042 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018011800042_1330818

SES—STA—20180118—00042 182018000176 RBC Signals, LLC 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: 60—Day STA for TT&C 1. Applicant Name: RBC Signals, LLC Phone Number: 404—803—7734 DBA Name: Fax Number: United States Street: 2205 152nd Ave NE E—Mail: crichins@rbcsignals.com City: Redmond State: WA Country: USA Zipcode: 98052 — Attention: Mr. Christopher Richins | rie #&§SBRR@npmsSCOUEL—O QQ\)\ Call Sign_________Grant Date3\\ \ "\\& | (or other 1dent1fier) | CGRANTED |h’ ecrnational Bureau ate:’I‘?o: %Q\j “\%

Applicant: RBC Signals, LLC File No SES—STA—20180118—00042 Call Sign: None Special Temporary Authority (STA) RBC Signals, LLC, is authorized from January 26, 2018, for 60 days, to operate a 3.57 meter Yagi antenna fixed earth station in Deadhorse, AK, to provide telemetry, tracking and command services to the U.S.—licensed Astranis Demosat—2 satellite in the 401.6— 401.75 MHz frequency band (Earth—to—space) and (space—to—Earth) frequency band — under the following conditions: 1. Operations must comply with pertinent conditions established in the FCC Experimental Licensing System (ELS) file number 1624—EX—ST—2017. 2. The Remote Control Point Location located at 2205 152nd Street NE, Redmond (King), Washington 98052, Tel.650—746—8744 must be available at all times to respond to interference issues and shut down operations if needed. 3. Operations shall be on an unprotected, non—interference basis with respect to other authorized stations, including federal stations. 4. This is not a grant of market access to the United States. 5. Any future requests or extensions will need to submit applications to the FCC, which will be re—coordinated with NTIA. 6. RBC Signals, LLC shall have no expectations that future operations will be approved. 8. Any action taken or expense incurred as a result of operations pursuant to this STA is solely at RBC Signals, LLC‘s risk. 9. Grant of this STA is without prejudice to any determination that the Commission may make regarding any future applications. This grant is issued pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 C.F.R. § 0.261, and is effective upon release. | rie ESSIB3ES&OI\Lt—0 oL. Call Sign » Grant Date SQSQ—\K \\ ' ( (or other identifier) GRANTED ates From: S To: FSAK International Bure au Approved/ Z & Page 1 of 1

2. Contact Name: Carlos Nalda Phone Number: 5713325626 Company: LMI Advisors —Fax Number: Street: 2550 M Street NW E—Mail: cnalda@Imiadvisors.com Suite 345 City: Washington State: DC Country: USA _ Zipcode: 20037 — Attention: Relationship: Other (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 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). g3, Governmental Entity {3 Noncommercial educational licensee J Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request & Use,Prior to Grant «34 Change Station Location { Other 6. Requested Use Prior Date 01/18/2018 7. CityDeadhorse 8. Latitude (dd mm ss.s h) 70 12 45.0 N

9. State AK 10. Longitude (dd mm ss.s h) 148 24 29.0 W 11. Please supply any need attachments. Attachment 1: Narrative Attachment 2: Form 312 Schedule B 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.) 60—day STA to perform TT&C for the U.S.—licensed Astranis Demosat—2 from Deadhorse, AK. 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is Yes (a] 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 Christopher Richins CEO WILLEFUL 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).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting forthis collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fcee.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control numberor if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.

1/18/2018 licensing.fec.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display Approved by OMB 3060—0678 Date & Time Filed: File Number: ——— Callsign/Satellite ID: APPLICATION FOR EARTH STATION AUTHORIZATIONS FCC Use Only FCC 312 MAIN FORM & FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: DRAFT FORM TO SUPPORT 60—DAY STA REQUEST 1—8. Legal Name of Applicant Name: RBC Signals, LLC Phone Number: 404—803—7734 DBA Fax Number: Name: Street: 2205 152nd Ave NE E—Mail: crichins@rbcesignals.com City: Redmond State: WA Country: USA Zipcode: 98052 =— Attention: Mr. Christopher Richins 9—16. Name of Contact Representative Name: Carlos Nalda Phone Number: 5713325626 Company: LMI Advisors Fax Number: Street: 2550 M Street NW E—Mail: s cnalda@Imiadvisors.com Suite 345 — City: Washington State: DC Country: USA Zipcode: 20037= Attention: Mr. Carlos Nalda Relationship: Other CLASSIFICATION OF FILING 17. Choose the button next to the b classification that applies to this filing || p1, Application for License of New Station f)(t)llebf?)trhl%l;e;ggl:)sn?)., ir;i ?OrClh’;);w only |g> b2. Application for Registration of New Domestic Receive—Only Station (N/A) b3. Amendment to a Pending Application (N/A) b4. Modification of License or Registration a. @ . (N/A) b5. Assignment of License or Registration al . Earth Station . (N/A) b6. Transfer of Control of License or Registration (N/A) a2. Space Station (N/A) b7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States ® 10. Other (Please specify) O oi1. Application for Earth Station to Access a Non—U.S .satellite Not Currently Authorized to Provide the Proposed Service in the Proposed Frequencies in the United States. 17¢. Is a fee submitted with this application? O if Yes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.ER.Section 1.1114). C Governmental Entity C Noncommercial educational licensee @ Other(please explain): DRAFT FORM 174. Fee Classification 18. If this filing is in reference to an 19. If this filing is an amendment to a pending application enter: http://licensing fce. gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101 .htm&mode=display 1/6

1/18/2018 licensing.fee.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display existing station, enter: (a) Date pending application was filed: (b) File numberof pending application: (a) Call sign of station: . . Not Applicable Not Applicable Not Applicable TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply: [ a. Fixed Satellite C] b. Mobile Satetlite C] c. Radiodetermination Satellite 0 a. Earth Exploration Satellite C1 e. Direct to Home Fixed Satellite O ¢. Digital Audio Radio Service K] g. Other (please specify) NGSO 21. STATUS: Choose the button next to the applicable status. 22. If earth station applicant, check all that apply. Choose only one. [X] Using U.S. licensed satellites C Common Carriert & Non—Common Carrier 0 Using Non—U.S. licensed satellites 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these facilities: O Connected to a Public Switched Network O Not connected to a Public Switched Network @© N/A 24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s). |nt| a. C—Band (4/6 GHz) L b. Ku—Band (12/14 GHz) K c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: 401.6 Frequency Upper: 401.75 TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. ® a. Fixed Earth Station O p. Temporary—Fixed Earth Station O c.12/14 GHz VSAT Network O d. Mobile Earth Station (N/A) e. Geostationary Space Station (N/A) f. Non—Geostationary Space Station & g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: Choose only one. ® Transmit/Receive O Transmit—Only t Receive—Only © N/A PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an ‘X" in the box(es) next to all that apply.) Not Applicable ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental impact as defined by 47 CFR 1.1307? If YES, submit the statement as required by Sections gy Yes ® No 1.1308 and 1.1311 ofthe Commission‘s rules, 47 C.E.R. §§ 1.1308 and 1.1311, as an exhibit to this application .A Radiation Hazard Study must accompany all applications for new transmitting facilities, major modifications. or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station services are not required to respond to Items 30—34. 29. Is the applicant a foreign government or the representative of any foreign government? C Yes & No 30. Is the applicant an alien or the representative of an alien? O Yes O No & N/A 31. Is the applicant a corporation organized under the laws of any foreign government? U Ves 2 No & N/A 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by aliens or their representatives or by a foreign government or representative thereof or by any U Ves 2 No & N/A corporation organized under the laws of a foreign country? 33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more O ¥es 2 No & N/A than one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a http://licensing fce.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101 htm&mode=display 216

1/18/2018 licensing fce.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATIONS 35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules? O Yes ® No If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents. — 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license revoked or had any application for an initial, modification or renewal of FCC station authorization, O Yes ® No license, or construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances. 37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly O Ves & No controlling the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an explination of circumstances. ' 38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, ¢y Yes ® No directly or indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of competition?If Yes, attach as an exhibit, an explanation of circumstances 39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any O Yes ® No pending matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances. 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names, address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of beneficiaries. Also list the names and addresses of the officers and directors of the Filer. 41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is 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 ® Yes O No substance. See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes. 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If @4 Yes ® No Yes, answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No, proceed to question 43. 42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has coordinated or is in the process of coordinating the space station? 43. Description. (Summarize the nature of the application and the services to be provided). Draft form to support 60—day STA request for TT&C for Astranis Demosat—2. 43a. Geographic Service Rule Certification By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or @ a geographic coverage requirements specified in 47 C.F.R. Part 25. By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic O B coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements. By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.FR. Part 25 and will not comply with such requirements because it is not feasible as a technical matter to do so, or that, while technically feasible, such services would require Oc so many compromises in satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis demonstrating this claim are attached. CERTIFICATION The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith. 44. Applicant is a (an): (Choose the button next to applicable response.) http://licensingfce. gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display 316

1/18/2018 licensing fce. gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display & Individual O Unincorporated Association & Partnership & Corporation & Governmental Entity ® Other (please specify) LLC 45. Name of Person Signing 46. Title of Person Signing Christopher Richins CEO 47. Please supply any need attachments. lAttachment 1: ”Xttachment 2: “Attachment 3: 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). SATELLITE EARTH STATION AUTHORIZATIONS FCC Form 312 — Schedule B;(Technical and Operational Description) FOR OFFICIAL USE ONLY Location of Earth Station Site E1: Site Identifier: RBC—Deadhorse E5. Call Sign: E2: Contact Name Christopher Richins E6. Phone Number: 650—746—8744 E3. Street: DS12 Access Road E7. City: Deadhorse E8. County: North Slope Borough E4. State AK E9. Zip Code 99734 E10. Area of Operation: Deadhorse, Alaska E11. Latitude: 70 ° 127 45.0 " N E12. Longitude: 148 ° 24‘ 29.0 " W E13. Lat/Lon Coordinates are: CNAD—27 ®NAD—33 CON/A E14. Site Elevation (AMSL): 15.0 meters E15. If the proposed antenna(s) operate in the Fixed Satellite Service (FSS) with geostationary satellites, do(es) the proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a) and (b) as demonstrated by the manufacturer‘s qualification measurement? If NO, provide asa technical analysis showing O Yes No I?/A compliance with two—degree spacing policy. E16. If the proposed antenna(s) do not operate in the Fixed Satellite Service (FSS), or if they operate in the Fixed Satellite Service (FSS) with non—geostationary satellites. do(es) the proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a2) and (b) as demonstrated by the manufacturer‘s ®@Yes ONo IiI}/A qualification measurements? E17. Is the facility operated by remote control? If YES, provide the location and telephone number of the @ y © N n control point. CS o E18. Is frequency coordination required? If YES, attach a frequency coordination report /y Yes ® No as E19. Is coordination with another country required? If YES, attach the name of the country(ies) and plot of coordination contours as O Yes ® No E20. FAA Notification — (See 47 CFR Part 17 and 47 CFR part 25.113(c)) Where FAA notification is required, have you attached a copy of a completed FCC Form 854 and or the FAA‘s study regarding the potential hazard of the structure to aviation? O Yes ® No FAILURE TO COMPLY WITH 47 CFR PARTS 17 AND 25 WILL RESULT IN THE RETURN OF THIS APPLICATION. http://licensing fce.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_10 1 htm&mode=display 416

1/18/2018 licensing.fce.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display POINTS OF COMMUNICATION ]Satellite Name:OTHER | OTHER | If you selected OTHER, please enter the following: [E21 . Common Name: DEMOSAT—2 |[E22. ITU Name: [E23. Orbit Location: NSGO HE24. Country: USA l POINTS OF COMMUNICATION (Destination Points) E25. Site Identifier: RBC—Deadhorse E26. Common Name: |E27. Country: USA ] ANTENNA . E28. E29. E30. E31. E32. E41/42. Antenpa Galn’h'aqsmmt Site ID Antenna Quantity|Manufacturer| Model Antenna and/or Recieve( dBi at Id Y Size ___GHz) RBC |Deadhorse Ivacr1 |1 M2 Antenna Systems lappop3qA|3.57 16.2 dBi at 0.400 eieeet E35. E36. |E37. Building| E38. Total |E39. Maximum Total E28. E33/34. Diameter Above Above ||Height Above| Input Power }.&ntenna EIRP for Antenna Minor/Major(meters) Ground| Sea Ground at antenna Height Above al 1d J Level Level Level flange Rooftop carriers (meters)|(meters)| (meters) (Watts) (meters) (dBw) YAGI—1 |0.025/3.57 15.0 0.0 0.0 8.93 0.0 25.7 FREQUENCY . E28. E43/44. E45. F46. Antenna E47. |FE48. Maximum||E49. Maximum ERIP Antenna| Frequency T/R Polariza.tion(H.VL.R) Emission EIRP per Density per Id Bands(MHz) Mode ‘ *~* ~"|Designator| Carrier(dBW) Carrier(dBW/4kHz) YAGI—1 1401.6 40175 |R Right Hand Circular [33K0OGID (0.0 0.0 E50. Modulation and Services TT&C Downlink YAGI—1 [401.6401.75 [R ____|Right Hand Circular __[4K13G1D (0.0 Jo.0 E50. Modulation and Services TT&C Downlink YAGI—1 (401.6 401.75 ‘[R [Right Hand Circular [99K1G1ID |0.0 Jo.0 E50. Modulation and Services TT&C Downlink YAGL—1 (401.6401.75 _[T [Right Hand Circular [33K0G1D |25.7 [16.5 E50. Modulation and Services TT&C Uplink YAGI—1 (401.6401.75 |[T____|Right Hand Circular [4K13G1D |25.7 |25.6 E50. Modulation and Services TT&C Uplink YAGI—1 |[401.6401.75 _[T_ _ |Right Hand Circular __|99K1G1D |25.7 |11.8 E50. Modulation and Services TT&C Uplink FREQUENCY COORDINATION E54/55.) ESG. E58. Range Earth E37. Earth E59. f . Antenna . Antenna} E60. Maximum E28. . E52/53. of Station . Station . . E51. Satellite . . Elevation| . Elevation EIRP Density Antenna — Frequency [Satellite/Azimuth Azimuth Orbit Type . ; . Angle |_ Angle toward the Id Limits(MHz)] Are Angle Angle . Eastern Western |Horizon(dBW/4kHz) E/W Eastern Limit Western Limit Limit Limit | Limit YAGI—1 g"“' _ _ f401.6 40175 lo.0/ 0.0 J0.0 eostationary 5.0 360.0 |5.0 25.6 REMOTE CONTROL POINT LOCATION REMOTE CONTROL POINT LOCATION E61. Call Sign E65. Phone Number 650—746—8744 NOTE: Please enter the callsign ofthe controlling station, not the callsign for which this application is being filed. E62. Street Address http://licensing fee.gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display 516

1/18/2018 licensing.fee. gov/ibfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101 .htm&mode=display 2205 152nd Street NE E63. City E67. County E64/68. E66. Zip Redmond King State/Country Code WA/ USA 98052 FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA @fcee.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control numberof 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507. http://licensing.fee.gov/bfsweb/ib.page.FetchForm?id_app_num=113813&form=PO13_101.htm&mode=display 616

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Application of RBC Signals LLC for a ) 60—Day Special Temporary Authorization ) Call Sign: To Operate an Earth Station To Provide > ) Tracking, Telemetry & Command to a ) File No.: U.S.—Licensed Satellite ) REQUEST FOR SPECIAL TEMPORARY AUTHORITY RBC Signals LLC ("RBC Signals"), pursuant to Section 25.120 of the Commission‘s rules, | 47 C.F.R. § 25.120, respectfully requests an expedited 60—day special temporary authorization ("STA") to operate the previously—licensed Yagi ground station (the "400 MHz Yagi") at an existing facility in Deadhorse, Alaska, to communicate with the U.S.—licensed Astranis Demosat— 2 satellite, a low—Earth orbit ("LEO") non—geostationary satellite orbit ("NGSO") cubesat operated by Astranis Space Technologies Corp. ("Astranis"). RBC Signals seeks to perform tracking, telemetry and command ("TT&C") for the Astranis Demosat—2 in the 401.6—401.75 MHz band (Earth—to—space/space—to—Earth) and requests expedited grant of this 60—day STA due to unforeseen and unidentified interference at Astranis‘ currently authorized TT&C site. The proposed TT&C operations are virtually identical to those already authorized at the RBC Signals facility in Deadhorse, Alaska,‘ and thus there is no material change in the potential for interference from RBC Signals® authorized operations at that location. Accordingly, grant of the requested STA — which is necessitated by extraordinary and unforeseen circumstances that prevent proper functioning of Astranis‘ original TT&C site — will serve the public interest, ! See RBC Signals, LLC, File Nos. SES—STA—20170613—00643 ("RBC Signals 60—day STA") and SES—STA—20170731—00848 ("RBC Signals 180—day STA"). These authorizations enabled RBC Signals to provide TT&C support for the 3 Diamonds NGSO satellites in the 401—402 MHz band.

convenience and necessity. 1. DISCUSSION TT&C for the Astranis Demosat—2 satellite was to be supported from a site in Fairbanks, Alaska, pursuant to Astranis‘ experimental authorization. Unknown interference has forced Astranis to seek TT&C support from a different facility and it has partnered with RBC Signals, which is able to provide immediate support for the Astranis Demosat—2 mission using its currently authorized TT&C earth station in Deadhorse, Alaska.. Grant of this STA request is critical for the ongoing reliability of the Astranis mission and will allow for the short—term continuation of — services while RBC Signals and Astranis attempt to address the interference issue at the Fairbanks facility and secure regular authority for TT&C operations from Deadhorse (should they be unsuccessful in resolving the issues in Fairbanks). RBC Signals has conferred with Commission staff regarding the emergency nature of this situation and received verbal and email confirmation from Commission staff to immediately begin TT&C operations on a non—interference basis." RBC Signals files this request to secure formal 60— day STA authority and will file an application for regular authority for these operations shortly.* RBC Signals‘ short—term TT&C operations, which are conducted on an unprotected and non—interference basis and only as—needed to communicate with the satellite as it passes over the Deadhorse earth station (between one and six times per day), are identical to the operations 2 See Astranis Space Technologies Corp., File Nos. 1624—EX—ST—2017 and 0113—EX—ST—2017, Call Sign WLOXAF ("Astranis Experimental Authorization"). 3 See Email Correspondence with Paul Blais, Chief, Systems Analysis Branch, Satellite Division, International Bureau, RE: URGENT — Astranis Satellite TT&C Issue (Jan. 17, 2018). 4 RBC Signals will soon file an application for regular authority for its Deadhorse, Alaska, facility that will include TT&C support for the Astranis Demosat—2 satellite. 2

previously described in the Astranis Experimental License application." RBC Signals incorporates by reference the satellite and earth station information previously provided by Astranis, and provides the draft FCC Form 312 Schedule B for information relating to the operating parameters of the 400 MHz Yagi with Astranis Demosat—2. The proposed TT&C operations are also consistent with fhe TT&C operations already authorized by the Commission and conducted by RBC Signals at the Deadhorse facility.© RBC Signals‘ existing operations in the 401—402 MHz band at Deadhorse have not caused interference to other users of the band and RBC Signals will work with Commission, NTIA, and NOAA staff to ensure that the additional Astranis Demosat—2 operations will not create any increase in potential interference to current or future government users. If RBC Signals learns that its operations are ‘causing harmful interference to others, it will suspend or modify its operations to immediately resolve such interference. The United States Table of Frequency Allocations ("Table of Allocations"), Section 2.106 of the Commission‘s rules, 47 C.F.R. § 2.106, provides that the 401—402 MHz band is shared on a co—primary basis between meteorological aids and space operations services. RBC Signals seeks to perform TT&C uplink and downlink operations in the 401.6—401.75 MHz band pursuant to the co— primary space operations allocation in this band." The public ifiterest would be served by a grant at the earliest praéticable time of a 60—day STA to allow RBC Signals to perform TT&C functions for the Astranis Demosat—2 satellite using * See Astranis Space Technologies Corp., File Nos. 1624—EX—ST—2017 and 0113—EX—ST—2017, Call Sign WLOXAF, Updated Narrative and Attachments (filed on Aug. 8, 2017). 6 See RBC Signals 60—day STA and RBC Signals 180—day STA. ? See 47 C.F.R. § 2.1 (defining "space operations" as "a radiocommunication service concerned exclusively with the operation of spacecraft, in particular space tracking, space telemetry, and space telecommand.").

the 400 MHz Yagi in Deadhorse, Alaska. Grant of this STA request will further the public interest by ensuring that RBC Signals‘ can provide immediate and critical TT&C support for the Astranis Demosat—2 satellite, thus enabling the continued control ofthis U.S.-licensed satellite and facilitating the development of next—generation satellite technologies. The proposed operations will cause no increase in interference to existing user of the band and RBC Signals acknowledges that any action on the requested STA will not affect the Commission‘s ultimate determination with respect to any forthcoming application for lohger—term earth station authority for these operations. IL. CONCLUSION As discussed herein, grant of the requested STA is warranted by unique and unforeseen circumstances and would strongly serve the public interest. In view of these circumstances, and because the proposed operations are essentially identically to those already authorized at the Deadhorse facility, RBC Signals respectfully requests grant of this 60—day STA pursuant to Section 25.120 of the Commission‘s rules, 47 C.F.R. § 25.120, at the earliest practicable time.8 8 47 C.F.R. § 25.120(a). The Commission may authorize RBC Signals to commence operations under this STA sooner than 3 working days "upon due showing of extraordinary reasons... which could not have been earlier foreseen by the applicant." 4


Document Created: 2018-01-26 16:38:19
Document Modified: 2018-01-26 16:38:19
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