Attachment STA Narrative

This document pretains to SES-STA-20180817-02314 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2018081702314_1497543

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 September 14, 2018, to permit up to 100 AeroSat model HR6400 ESAA terminals and up to 100 ThinKom model 2Ku terminals to communicate in the 14-14.5 GHz uplink spectrum and in the 10.95-11.2 GHz, 11.45-11.7 GHz, and 11.7-12.2 GHz downlink spectrum with the Brazilian-licensed SES-14 satellite at 47.5° W.L. The Commission has authorized SES-14 to serve the U.S. in both the conventional and extended Ku-band frequencies, 2 and complete technical information regarding the satellite is therefore already on file with the Commission. Grant of the requested STA will serve the public interest by allowing AC BidCo to use additional bandwidth on a new, high throughput satellite to meet demand for in-flight connectivity on flights over the United States and Latin America. AC BidCo seeks STA pending Commission action on AC BidCo’s application to modify its ESAA license, which includes a request to add SES-14 as an authorized point of communication. 3 Background AC BidCo is currently authorized to operate two types of Ku-band terminals, AeroSat model HR6400 antennas designated as AES1 on the AC BidCo ESAA License and ThinKom model 2Ku antennas designated as AES2 on the license, 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. In order to enhance and expand its ESAA operations, AC BidCo is seeking to modify the AC BidCo ESAA License to update the satellites authorized as points of communication for the AC BidCo network. STA Request Pending action on the AC BidCo Modification Application, AC BidCo requests STA to commence communications in the conventional and extended Ku-band with SES-14. The AC BidCo Modification Application contains complete information regarding AC BidCo’s proposed 1 Call Sign E120106, File No. SES-MFS-20171220-01351, granted Mar. 9, 2018 (the “AC BidCo ESAA License”). 2 SES DTH do Brasil Ltda, Call Sign S2974, File No. SAT-MPL-20170606-00083, granted Sept. 7, 2017 (“SES-14 Authorization”). 3 See Call Sign E120106, File No. SES-MFS-20180813-02152 (the “AC BidCo Modification Application”).

AC BidCo LLC Attachment A Page 2 operations with SES-14, and AC BidCo incorporates that information by reference herein. As described in the application, AC BidCo seeks to communicate with SES-14 on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 10.95-11.2 GHz and 11.45-11.7 GHz downlink spectrum. 4 AC BidCo proposes to use SES-14 for service over North America, including in U.S. airspace. 5 AC BidCo requires access to this capacity to ensure that it has sufficient bandwidth to satisfy near-term 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-14 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. Public Interest Showing 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-14 are consistent 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 meet demand for additional capacity in the U.S. and Latin America, promoting competition in the provision of aeronautical services and expanding the availability of in-flight broadband to air travelers and crew members. AC BidCo understands that any Commission grant of this STA will be without prejudice to the ultimate determination the Commission will make regarding the AC BidCo Modification Application. In addition, AC BidCo acknowledges that any action taken pursuant to a grant of the requested STA will be at AC BidCo’s own risk. 4 See AC BidCo Modification Application, Narrative at 4. 5 Id., Annex 2.


Document Created: 2018-08-17 09:57:23
Document Modified: 2018-08-17 09:57:23
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