Attachment Exhibit 1

This document pretains to SES-STA-20180423-00391 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018042300391_1380272

                                                                    GCI Communication Corp.
                                                  Application for Special Temporary Authority


               APPLICATION FOR SPECIAL TEMPORARY AUTHORITY

       Pursuant to Section 25.120 of the Federal Communications Commission (the “FCC” or

“Commission”) rules, 47 C.F.R. §25.120, GCI Communication Corp. (“GCI”) is seeking a 60-

day special temporary authorization (“STA”) commencing immediately,1 to operate an

emergency temporary fixed satellite service (“FSS”) earth station in the 3.7-4.2 GHz band (the

“C-Band”).2 Specifically, GCI is seeking temporary authorization to install and operate one 3.6

meter Scientific Atlanta 8136 antenna earth station (the “Station”) located at Chevak Central

Office in Chevak, Alaska to communicate with SATMEX 7. Because GCI is requesting an STA

for a period not to exceed 60 days pursuant to 47 C.F.R. §25.120(3), and will be filing a request




1
  GCI submits that there are “extraordinary reasons . . . that could not have been earlier foreseen”
that warrant a waiver of the three working day review period pursuant to 47 C.F.R. § 25.120(a).
Here, GCI is seeking emergency, immediate, support for its microwave communications link that
has gone down due to harsh weather in remote areas of Western Alaska. GCI has attempted to
remedy this situation by relying on flyaway Ku-Band VSAT stations in these areas, but these
emergency deployments have recently proven unable to withstand the high wind and severe
weather in this area of Alaska. As a result, services have been severely impacted, and therefore
GCI seeks this emergency STA to utilize the above-reference antenna on C-Band spectrum as
soon as possible in order to restore reliable services to these areas.
2
  GCI recognizes that the International, Public Safety and Homeland Security, and Wireless
Telecommunications Bureaus (the “Bureaus”) recently announced a freeze effective April 19,
2018 “on the filing of new or modification applications for [FSS] earth station licenses, receive-
only earth station registrations, and fixed microwave licenses in the 3.7-4.2 GHz frequency
band.” Based on the text of the Public Notice, STA requests for FSS earth station licenses in the
C-Band are not covered by the freeze. However, out of an abundance of caution, if the Bureaus
were to determine that such an STA is considered a filing prohibited by this freeze, GCI
respectfully requests a waiver of the freeze, as a grant of this STA request would “serve the
public interest and not undermine the objectives of the freeze,” as detailed herein and further
discussed in GCI’s request for waiver of this filing freeze in connection with its application for a
new FSS earth station license. See also Temporary Freeze on Applications for New or Modified
Fixed Satellite Service Earth Stations and Fixed Microwave Stations in the 3.7-4.2 GHz Band,
90 Day Window to File Applications for Earth Stations Currently Operating in 3.7-4.2 GHz
Band, Public Notice, 1, 3, DA 18-398 (rel. Apr. 19, 2018).


                                                                    GCI Communication Corp.
                                                  Application for Special Temporary Authority

for regular authority for this service,3 this application need not be placed on public notice and

should be granted expeditiously pursuant to the rules. GCI’s operation of this Station would not

cause harmful interference into surrounding networks, and as demonstrated below, there are

extraordinary circumstances supporting the immediate grant of these temporary operations which

are in the public interest and any delay in the institution of these temporary operations would

seriously prejudice the public interest.

       Grant of this request for STA is necessary for GCI to continue providing reliable

communications services, including critical emergency 911 services, to GCI’s customers and

would serve the public interest. GCI seeks this STA due to extensive damage caused by weather

elements in remote areas of Alaska. Specifically, GCI’s Askinuk Mountain tower is

experiencing severe icing issues that has caused its microwave link, which services remote

villages in western Alaska (Chevak and Hooper Bay), to become unreliable. This link is the

primary link to communications in these villages, and provides not only mobile wireless voice

and broadband services, but also supports telehealth services, school access services, wireless

911 routing, and serves as a backup to wireline 911 services. In an effort to remedy this

situation, GCI initially intended to temporarily operate in this area using flyaway Ku-Band

VSAT stations, however these emergency deployments have proven unable to withstand the high

wind and severe weather in this area of Alaska. As a result, GCI recently discovered that its

services continue to be severely impacted, and therefore seeks this emergency STA to utilize the

above-referenced antenna on C-Band spectrum. Without a grant of this requested temporary



3
  As discussed above, GCI recognizes the current filing freeze on new applications for FSS earth
station licenses, and will be seeking a waiver of the freeze in connection with its filing of a new
application for a FSS earth station license, demonstrating that waiver will serve the public
interest and not undermine the objectives of the freeze.
                                                 2


                                                                    GCI Communication Corp.
                                                  Application for Special Temporary Authority

authority, remote residents in western Alaska may not have access to vital communications

services, including accessing 911 services.

         Here, “there are extraordinary circumstances requiring temporary operations in the public

interest” and “delay in the institution of these temporary operations would seriously prejudice the

public interest.”4 A grant of this STA would continue to allow GCI to provide critical services to

approximately 2300 western Alaskan residents over this license. Many, if not most, of these

affected residents rely solely on GCI’s services for a link to the world outside of their remote

villages. This is due in large part to the challenging nature of providing mobile service in

Alaska. Such challenges include “its remoteness, lack of roads, challenges and costs associated

with transporting fuel, lack of scalability per community, satellite and backhaul availability,

extreme weather conditions, challenging topography, and short construction season.”5 GCI relies

on the 3.7 GHz band in order to provide its FSS operations, and has a very long history of

providing C-band satellite communications solutions in Alaska in ways that advance the satellite

technology space in an effort to provide communications services in rural Alaska. In addition,

the substantial public service record of GCI indicates that the company is committed to providing

service to consumers in Alaska. Therefore, it has sought regular authority for such a license, in

order to avoid encountering a situation such as this next winter. Because GCI does not want

service to its customers, including potential access to emergency services, to be implicated

during the pendency of this request, it is also requesting this STA. Allowing a STA to permit


4
    47 C.F.R. §25.120(b)(1).
5
  Connect America Fund; Universal Service Reform – Mobility Fund; Connect America Fund -
Alaska Plan, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 10139,
10162,¶ 72 (2016) (“Alaska Plan R&O”) (citing Connect America Fund et al., Report and Order
and Further Notice of Proposed Rulemaking, 26 FCC Rcd 17663, 17829,¶ 507 (2011)
(“USF/ICC Transformation Order”), aff’d sub nom. FCC 11-161, 753 F.3d 1015 (10th Cir.
2014)).
                                                 3


                                                                     GCI Communication Corp.
                                                   Application for Special Temporary Authority

GCI to continue to provide service over the C-Band, for 60 days, would certainly be in the public

interest. This continued service illustrates a “compelling reason” to expeditiously grant the

requested STA.

         In addition, GCI’s proposed construction of the earth station antenna as detailed in this

application does not require FAA notification prior to construction pursuant to the FCC’s rules,

as the antenna height will be under 6.10 meters or 20 feet.6




6
    See 47 C.F.R. § 17.7.
                                                  4



Document Created: 2019-04-18 08:02:19
Document Modified: 2019-04-18 08:02:19

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