Attachment 2019_02_21_16_21_02.

2019_02_21_16_21_02.

DECISION submitted by FCC

Grant

0000-00-00

This document pretains to SES-STA-20190211-00110 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019021100110_1628080

E170205 SES-STA-2019021 1-00110 1B2019000303 Alaska Communications Internet, LLC Approved by 0MB 3060—0678 APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY APPLiCANT 1NFORMATIONEnter a description of this application to identify it on the main menu: 60—day STA (Silver Bay) 1. Applicant Name: Alaska Communications Internet, Phone Number: 907—297—3000 LLC DBA Name: Fax Number: 907—297—3153 Street: 600 Telephone Avenue E—Mail: Lisa.Phillips@acsalaska.com MS #60 City: Anchorage State: AK Zipcode: 90503 — Country: USA Attention: Ms. Lisa Phillips File # — -2// — Call Si/7&icGrant Date__/%t, (or other identifier) Term Dates lnernationa1 Bureau Approve&%,Jfr,%

Applicant: Alaska Communications Internet LLC Call Sign: E170205 File No.: SES-STA-2019021 1-001 10 Special Temporary Authority (STA) Alaska Communications Internet, LLC is granted special temporary authority, for 60-days beginning February 22, 2019 to operate a 3.8 meter earth station located at Silver Bay False Pass, AK (54°5154.00’N 163°2442.20”W) with the EUTELSAT1 15WB(S2938) at 114.9° W.L. in the 5925-6425 MHz (Earth-to-space) and 3700-4200 MHz (space-to-Earth) frequency bands under the following conditions: 1. All operations shall be on an unprotected and non-harmful interference basis, Alaska Communications Internet LLC, shall not cause harmful interference to, and shall not claim protection from, interference caused to it by any other lawfully operating station and it shall cease transmission(s) immediately upon notice of such interference and must inform the Commission, in writing, immediately of such an event. 2. The licensee shall, always, take all necessary measures to ensure that operation of this (these) authorized earth station(s) does not create potential exposure of humans to radiofrequency radiation in excess of the FCC exposure limits defined in 47 CFR § 1.1307(b) and 1.1310. Physical measures must be taken to ensure compliance with limits for both occupational/controlled exposure and for general population/uncontrolled exposure, as defined in these rule sections. Compliance can be accomplished in most cases by appropriate restrictions, such as fencing. Requirements for restrictions can be determined by predictions based on calculations, modeling, or by field measurements. The FCC’s OET Bulletin 65 (available on-line at www.fcc.gov/oet/rfsafety) provides information on predicting exposure levels and on methods for ensuring compliance, including the use of warning and alerting signs and protective equipment for workers. 3. Grant of this authorization is without prejudice to any determination that the Commission may make regarding pending FCC IBFS File No.: SES-MOD-20180626-01472 or future Alaska Communications Internet LLC ‘s applications. 4. Any action taken, or expense incurred as a result of operations pursuant to this STA is solely at Alaska Communications Internet LLC ‘s risk. This action is issued pursuant to Section 0.261 of the Commissions rules on delegated authority, 47 C.F.R. §0.261, and is effective immediately. File # ES- S719 —%c/7oz//- gJ,O Call Sign7tg4Graflt Date______ (or other identifier) Term Dates To: GRANTED Intcrnational Bureau

2. Contact Name: Richard Cameron Phone Number: 2022304962 Company: LMI Advisors Fax Number: Street: 2550 M Street. MW E—Mail: rcameton@lmiadvisors.com Suite 319 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 TB Submission ID of the related application. Please enter only one.) 3. Reference File Number SESLIC2OI7I 11601257 or Submission ID 4a. Is a fee submitted with this application? If Yes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114). Governmental Entity Noncommercial educational licensee Q o Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request Use Prior to Grant Change Station Location Other Q 0 6. Requested Use Prior Date 02/14/2019 7. CitySilver Bay False Pass 8. Latitude (dd mm ss.s Ii) 54 51 54.0 N 2

9. State AK 10. Longitude (dd mm ss.s h) 163 24 42.2 W 1 1. Please supply any need attachments. Attachment 1: Narrative Attachment 2: Technical Appendix 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 for operations at Silver Bay False Pass. 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is Yes No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 198$, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes. 14. Name of Person Signing 15. Title of Person Signing Rick Benken VP WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND I OR IMPRISONMENT (U.S. Code, Title 1$, 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). 3

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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Application of Alaska Communications ) Call Sign: E170205 Internet LLC for 60-Day Special Temporary ) Authorization (“STA”) ) File No. SES-STA______________ APPLICATION FOR SPECIAL TEMPORARY AUTHORIZATION Pursuant to Section 25.120 of the rules of the federal Communications Commission (the “FCC” or “Commission”),’ Alaska Communications Internet LLC (“Alaska Communications Internet”) respectfully seeks a 60-day special temporary authorization (“STA”), commencing on Thursday, February 14, 2019, to operate one remote earth station site, to be located at False Pass, Alaska, on Unimak Island in the Aleutian chain. The new site will communicate with the C-band network hub operated by Alaska Communications Internet as part of its existing C-band very small aperture terminal (“VSAI”) network, Call Sign El 70205.2 Alaska Communications Internet anticipates filing an application for regular authority to operate this site as part of the network licensed under its existingAClNetworkLicense in the very near term. Alaska Communications Internet seeks this STA to permit immediate provisioning of critical broadband satellite communications services to this location, while that application is under the Commission’s consideration. Consistent with the ACI Network License, Alaska Communications Internet seeks to operate this new site in portions on the C-band at fixed locations in Alaska while communicating with the EUTELSAT I I 5W3 satellite located at the 114.9° W.L. orbital position. See 47 C.F.R. § 25.120. 2 See 47 C.F.R. § 25.11 5(c)(2); Alaska Communications Internet LLC, File No. SES-LIC-20 171116- 01257, Call Sign E170205, and subsequent modification and amendment applications (“A CI Network License”).

Grant of this STA request will serve the public interest because it will enable Alaska Communications Internet to deliver critically needed broadband services to support Silver Bay Seafood, LLC (“Silver Bay Seafood”), an integrated processor of frozen salmon, herring and squid products for U.S. domestic and export markets, and the Alaska bush community surrounding its False Pass processing plant.3 As one of the largest seafood companies in Alaska, Silver Bay Seafood needs reliable broadband services to support its operations, management and personnel, manage logistics, coordinate shipments, establish a solid fish buying system, and keep its employees on Unimak Island connected to their families and the larger world. I. Background Alaska Communications Internet is an affiliate of Alaska Communications Systems Group, Inc. (“Alaska Communications”), a publicly-traded company that, through its subsidiaries, provides terrestrial wireline telecommunications and broadband-enabled services throughout Alaska as the largest incumbent local exchange carrier in the state.4 Alaska Communications Internet provides essential broadband and voice-over-Internet Protocol (“V0IP”) services to enterprise, business, educational, health care, and residential customers throughout the state. The ACI Net’4’ork License authorizes Alaska Communications Internet to operate a network of C-band satellite earth stations in order to provide satellite services to diverse users in remote locations in Alaska. Specifically, from the gateway hub in Anchorage, Alaska, the network Unlike Alaska’s three largest population centers, and the surrounding rural communities, Alaska Bush communities are isolated geographically from infrastructure resources commonly available elsewhere in the state, and the nation as a whole. Most Bush communities cannot be accessed by road, nor are they connected to the state’s power grid. To reach these communities, people, as well as goods and services, must arrive by plane, barge, snow machine, all-terrain vehicle, or other off-road transportation means. Communications services in these communities generally must rely on satellite or terrestrial point-to-point microwave transport links to Anchorage, Fairbanks, or Juneau. The incumbent local exchange carrier (“ILEC”) subsidiaries of Alaska Communications are: ACS of Anchorage, LLC; ACS of Fairbanks, LLC; ACS of Alaska, LLC; and ACS of the Northland, LLC; see also ACS Long Distance, Inc., File Nos. ITC-214-19960612-00248, ITC-T/C-20050$22-00382, ITC T/C-200404 14-00190 (International Section 214 authorization). 2

currently serves the Alaska Native population of St. Paul Island, and the Tanadgusix Corporation (“TDX”), an Alaska Native corporation created pursuant to the Alaska Native Claims Settlement Act (“ANCSA”). In addition, the C-band VSAT network serves local businesses co-owned by the Bristol Bay Economic Development Corporation (“BBEDC”),5 providing broadband connectivity that supports the local fishing and seafood industries, as well as a test site located in Anchorage, Alaska. Alaska Communications Internet has also sought authorization to extend its network to deliver broadband telecommunications and Internet services to ten primary and secondary school locations in additional Alaska bush communities.6 This STA will enable Alaska Communications Internet to extend this network to provide broadband and Internet connectivity on the Aleutian Island chain. Alaska Communications Internet incorporates by reference (and attaches as an Exhibit to this STA) aproforma FCC Form 312 Schedule B and Technical Appendix showing the details of its proposed earth station operations at the False Pass site. Those documents provide relevant information relating to the earth station operating parameters, performance information and radiation hazard analyses. II. Discussion This STA requests seeks authority to operate one remote earth station site at False Pass, Alaska, which will communicate with the C-band network hub operated by Alaska Communications Internet under the ACI Network License via the EUTELSAT 1 I5WB satellite in portions of the C-band. The BBEDC is a not-for-profit company whose mission is to promote economic growth and opportunities for residents of BBEDC’s member communities through sustainable use of the Bering Sea resources. See http://www.bbedc.com. 6 See Alaska Communications Internet, LLC, File No. SES-MOD-20180626-01472, Call Sign E170205 (“A CI Kuspuk Modification Application”). 3

A. New Site Location The False Pass site is located the Aleutians East Borough on Unimak Island (geographic coordinates: 54°5 I 54.OOtN 163 °24’42.20”W). There, Alaska Communications Internet proposes to operate a 3.8m Prodelin Model 2385 (the “3.8m”) earth station. The Prodelin 2385 is, in all material respects, electrically identical to the Prodelin 1383, a model that the Commission has licensed for two other sites in the AC’J Network License, and which appears on the Commission’s Approved Non-Routine Earth Station Antennas List (‘Non-Routine Antenna List”).7 The Prodelin 2385 includes a stronger, reinforced support structure than that supplied with the Prodelin 1383, which is necessary to withstand the high winds and inclement weather that Unimak Island frequently experiences. Although the Prodelin 2385 earth station (like the Prodelin 1383) does not comply with the gain mask in Section 25.209 of the Commission’s rules, Alaska Communications Internet demonstrates in the attached Schedule B that it will operate the terminals at maximum ESD levels below those currently authorized in the AC’I Network License and in compliance with the ESD mask set forth in Section 25.218(d) of the Commission’s rules.8 Alaska Communications Internet will operate the earth stations below the maximum EIRP spectral density (“ESD”) levels authorized in the AC’I Network License and consistent within levels previously approved by the Commission.9 The earth station will be mounted on a pole in an area inaccessible to the general public. Its planned location is not among any “districts, sites, buildings, structures or objects, significant See Approved Non-Routine Earth Station Antennas, https :/!www.fcc. gov/approved-non-routine-earth station-antennas. $ See 47 C.F.R. § 25.218(d). See AClNetworkLicense (Dimond D and St. Paul tsland sites); RCN License Subsidiary, Inc., SES LIC-200501 14-00077, Call Sign E050016 (Max EIRP density 45.4 dBW/4kHz); Intelsat LLC, File No. SES-LIC-201 10627-00745, Call Sign El 10100 (Max EIRP density 31.9 dBW/4kHz); Public Broadcasting of Colorado, Inc., SES-MOD-20060608-00951, Call Sign E030163 (Max EIRP density 43.2 dBW/4kHz); Harris Corporation, File No. SES-LIC-20060302-00342, Call Sign E060075. 4

in American history, architecture, archeology, engineering or culture, that are listed, or are eligible for listing, in the National Register of Historic Places,”° and thus falls within the exemptions of Section 1.1306(a)-(b) and Note Ito that rule.1’ Accordingly, no environmental assessment is required as part of this application because each proposed site is categorically exempt under Section 1.1306 of the Commission’s rules.’2 B. Frequency Coordination Alaska Communications Internet engaged Micronet Communications, Inc. (“Micronet”) to perform frequency coordination in support of theACI Modfication Application, which was completed on January 5, 2019. Pursuant to Sections 25.1 15(c)(2)(ii) and 25.203 of the Commission’s rules,’3 Micronet has conducted a coordination analysis on behalf of Alaska Communications Internet that considers all existing, proposed, and prior coordinated microwave facilities within the contours of the proposed earth stations at the Silver Bay False Pass site. As demonstrated in the attached freqtiency coordination report, as coordinated and limited, there is no potential for interference into other users of the C-band spectrum sought herein by Alaska Communications Internet. Moreover, Micronet received no objections in response to its Prior Coordination Notices, and Alaska Communications Internet currently operates its network with no reported cases of interference. Alaska Communications Internet will coordinate any additional hub or remote operations prior to bringing them into use as part of the C-band VSAT network. ‘° 47 C.E.R. § 1.1307(a)(4). ‘ See 47 C.F.R. § 1.1306, Note I (“The provisions of § 1.1307(a) requiring the preparation of EAs do not encompass the mounting of antenna(s) and associated equipment (such as wiring, cabling, cabinets, or backup-power), on or in an existing building, or on an antenna tower or other man-made structure, unless §1.1307(a)(4) is applicable.”). 12 See 47 C.F.R. § 1.1306. ‘ See 47 C.F.R. § 25.1 15(c)(2)(ii) and 25.203. 5

C. The C-Band Temporary freeze Public Notice Alaska Communications Internet acknowledges the Commission’s Public Notice placing a temporary freeze on the filing of all new or modification applications for earth stations in the 3.7-4.2 GHz band, effective as of April 19, 201 8.14 The Temporary freeze Public Notice does not include a freeze on requests for special temporary authority for short-term operations, and thus the instant request is outside the scope of the freeze. Furthermore, grant of this STA Application will strongly serve the public interest by enabling the delivery of critically needed broadband telecommunications and Internet access services in the Alaska bush, where terrestrial connectivity is mostly unavailable. In conjunction with its forthcoming request for regular authority to operate the False Pass site as part of the network licensed under its existing ACJNeti’orkLicense, Alaska Communications Internet intends to seek a waiver, to the extent required, of the Tenzporaiy freeze Public Notice. As discussed below, grant of that waiver request, when filed, would enable Alaska Communications Internet to expand its delivery of reliable and effective broadband services to an additional remote location, namely the Silver Bay Seafood processing plant and nearby residents of false Pass. The Commission may waive its rules for “good cause shown.”5 Specifically, the Commission may waive its rules where the particular facts make strict compliance inconsistent 14 See Public Notice, Temporaty 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 the 3.7-4.2 GHz Band, DA 18-398 (rel. on April 19, 2018) (“Temporary Freeze Public Notice”). See also, Public Notice, GN Docket Nos. 17- 183, 18-122, “International Bureau Announces 90-Day Extension of Filing Window, to October 17, 2018, to File Applications for Earth Stations Currently Operating in 3.7-4.2 GHz Band; Filing Options for Operators with Multiple Earth Station Antennas,” DA 18-639 (rel. Jun. 21, 2018). ‘ See 47 C.F.R. § 1.3. WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cit. 1969). 6

with the public interest.16 In addition, the Commission may take into account considerations of hardship, equity, or more effective implementation of overall policy on an individual basis.17 Waiver is appropriate if special circumstances warrant a deviation from the general rule, and such deviation would better serve the public interest than strict adherence to the general rule.18 The request below amply meets that standard. The Commission has released a Public Notice placing a temporary freeze on the filing of all new or modification applications for earth stations in the 3.7-4.2 GHz band, effective as of April 19, 201 8.19 The Temporary Freeze Public Notice contains an exception stating that “entities that own or operate existing fSS earth stations in the 3.7-4.2 GKz band [...] may file an application to modify a current registration or license” during the freeze period.20 Although Alaska Communications Internet operates existing FSS earth stations in the C- band under the AC’I Network License, because the earth station proposed proposed for the False Pass site is not currently “constructed and operational”2’ and because the forthcoming application for regular authority to operate it as part of its existing C-band network is being filed after the release of the Temporary Freeze Public Notice, Alaska Communications Internet 16 Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (“Northeast Cellular”). 17 WAITRadio v. FCC, 41$ F.2d 1153, 1157, (D.C. Cir. 1969), affirmed by WAIT Radio v. FCC, 459 f.2d 1203 (D.C. Cir. 1972), cert. denied, 409 U.S. 1027 (1972). 18 Northeast Celltdar, 897 F.2d at 1166. See Public Notice, Ternporaiy Freeze on Applications for New or Modfled Fixed Satellite Service Earth Stations and fixed Microwave Stations in the 3.7-4.2 GHz Band, 90-Day Windoi,’ to File Applications for Earth Stations Currently Operating in the 3. 7-4.2 GHz Band, DA 18-398 (rel. on April 19, 2018) (“Ternporaiy Freeze Ptthlic Notice”). See also, Public Notice, GN Docket Nos. 17- 183, 18-122, “International Bureau Announces 90-Day Extension of Filing Window, to October 17, 2018, to File Applications for Earth Stations Currently Operating in 3.7-4.2 GHz Band; Filing Options for Operators with Multiple Earth Station Antennas,” DA 18-639 (rel. Jun. 21, 2018). 20 Temporary Freeze Public Notice, at 1. 21 Id 7

intends to request a waiver of the Temporary Freeze Public Notice, to the extent required, consistent with precedent, to permit licensing of the operations to be proposed therein. first, Alaska Communications Internet proposes to add a site for service to an Alaska bush seafood business and its employees, who collectively make up a large portion of the residents of False Pass. Grant of this STA and the forthcoming associated application would thus greatly advance the public interest goals of Commission to expand the availability of affordable broadband services and thereby provide enhanced economic growth and development opportunities for residents of the area.22 Many remote bush villages in Alaska tack terrestrial communications infrastructure, making the opportunities offered by satellite broadband services particularly critical. Without a waiver, Alaska Communications Internet would be unable to serve this additional site and the economic benefits for the local business and residents would be lost to this community. Second, applying the Temporary freeze Pztblic Notice to the Silver Bay site in false Pass would not serve the purpose of the freeze. The Commission imposed the freeze “to preserve the current landscape of authorized operations in the 3.7-4.2 GHz band pending Commission action as part of its ongoing inquiry into the possibility of permitting mobile broadband use and more intensive fixed use of the band,”23 with particular focus on terrestrial “5G” mobile broadband service. The Silver Bay False Pass site is located in a remote area of the Alaska bush, and is not candidate for 5G deployment anytime in the foreseeable future. Today, mobile wireless service at this site is limited and the prohibitive cost of backhaul, coupled with the small size of the potential market in the area, makes additional terrestrial broadband deployment challenging. While terrestrial wireless use of this band and initial 5G deployments may occur in densely 22 See generally Connect America Fund, WC Docket No. 10-90, Report and Order and Further Notice of Proposed Rulemaking, FCC 11-161, 26 FCC Rcd 17663 (2011) (“Transformation Order”). 23 Temporaiy Freeze Public Notice at 1. $

populated urban areas far removed from the remote Alaskan bush communities served by Alaska Communications Internet, it is highly unlikely that grant of this application will hinder the Commission’s analysis of additional mobite and fixed use of this band.24 Third, Alaska Communications Internet currently operates satellite earth stations at multiple locations in the Alaska bush with no reported cases of implementation constraints. There is no reason to expect a different result here. Alaska Communications Internet is also limiting its usage in the C-band as necessary to avoid any potential interference with other authorized spectrum users in the band, although these constraints have primarily arisen, if at all, in the 5.925-6.425 GHz uplink portion of the band. These operations were deemed compatible with terrestrial operations and entered into frequency coordination databases as of the date of the filing of this application. Thus, there is no potential for any adverse impact or other prejudice to terrestrial systems or services from grant of the requested waiver. III. Request for Special Temporary Authority and Public Interest Considerations Section 25.120(a) provides that an STA request should be filed at least three business days prior to commence of proposed operations. Here, Alaska Communications Internet has timely filed this 60-day STA request so that the Commission may permit operations by February 14, 2019. Further, Alaska Communications Internet believes this application involves “extraordinary circumstances” (i.e., the delivery of critical broadband services to the seafood industry to improve connectivity and efficiency of local businesses), and requests that the Commission authorize operations under this STA by that date. Moreover, Section 25.120(b)(2) states that the Commission may grant a temporary authorization for up to 60 days if the STA request has not been placed on public notice and the applicant plans to file a request for regular authority for the service. As noted, Alaska 24 jj 9

Communications Internet anticipates filing its application to add the false Pass site to its C-band network license for the operations proposed herein. This interim authority during the pendency of Alaska Communications Internet’s commercial license application is critical to ensure delivery of satellite services to the population of St. Paul, Alaska, which is unable to rely on other forms of communication for basic connectivity needs. Grant of the requested 60-day STA will strongly serve the public interest by allowing Alaska Communications Internet to provide broadband services to an additional remote Alaskan community that must rely on this service for basic connectivity needs. Grant of the STA will allow Alaska Communications Internet to serve underserved communities in false Pass, and help improve the local economy, enhance economic opportunity and well-being of its residents, and bridge the digital divide. Users will have broadband Internet access, e-mail, voice and data services, greatly enhancing economic opportunities in these remote locations. Finally, grant of this application will also create an additional competitive alternative for customers in the Alaska Bush, an undeserved area with little competition to existing terrestrial microwave and satellite providers. IV. Conclusion Based on the foregoing, the public interest would be served by a grant of this STA application authority to Alaska Communications Internet to operate one additional site as part of its C-band VSAT network in Alaska for a period of 60 days commencing on February 14, 2019. 10

60-Day Special Temporary Authorization Application Alaska Communications Internet LLC Technical Appendix I. Frequency Coordination Report II. Radiation Hazard Analysis III. Draft FCC Form 312 Schedule B

I. Frequency Coordination Report Micronet Communications, Inc. 720 F Avenue, Suite 100 Piano, Texas 75074 972—422—7200 SUPPLEWENTAL SHOWING PART 101.103(0) File Number: M1833223 5.93 GHz Licensee: Alaska Communications Internet, LLC Page 1 Pursuant to Parts 25.203 and 101.103(d) of the FCC Rules and Regulations, a frequency coordination study was conducted by Nicronet Communications, Inc. for the following proposed earth station: Silver Bay False Pas, AK The results of the study indicate that no unacceptable interference will result with existing, proposed or prior coordinated radio facilities. Coordination was performed with existing, proposed and prior coordinated carriers within coordination range on the following dates: 12/06/2018 Original PCN There were no unresolved interference objections. The attached coordination data was forwarded on the latest date to the following parties within coordination range or their authorized coordination agents: Respectfully Submitted, Jeremy Lewis Systems Engineer Attached: 1 data sheet

Micronet Communications, Inc. 720 F Avenue, Suite 100 Piano, Texas 75074 972—422—7200 File: M1833223 TECHNICAL CHARACTERISTICS OF TRANSMIT RECEIVE EARTH STATION Company: Alaska Communications Internet, LLC Site Name, State: Silver Bay False Pas, AK Call Sign: Latitude (NADB3) 54 51 54.0 N Longitude (NAD83) 163 24 42.2 N Elevation AMSL (ft/m) 11.00 3.35 Receive Frequency Range (MHz) 3700—4200 Transmit Frequency Range (MHz) 5925—6425 Range of Satellite Orbital Long. (deg N) 114.00 116.00 Range of Azimuths from North (deg) 125.02 126.93 Antenna Centerline (ft/m) 9.84 3.00 Antenna Elevation Angles (de g) 13.55 14.52 Equipment Parameters Receive Transmit Antenna Gain, Main Beam (dbl) 42.00 46.20 15 DB Half Beamwidth (deg) 1.40 1.30 Antennas Receive: PRODELIN 3.8 METER Transmit: PRODELIN 3.8M Max Transmitter Power (dbw/4KHz) —17.08 Max EIRP Main Beam (dbW/4KHz) 29.12 ; Modulation / Emission Designator DIGITAL 2M80G7W 72M0G7W - -- • • Coordination Parameters Receive Transmit Max Greater Circle Distances (km) 448.34 158.44 Max Rain Scatter Distances (km) 374.45 100.00 Max Interference Power Long Term (dbW) —158 60 . —154.80 Max Interference Power Short Term (dbW) —149.90 —130. 80 Rain Zone / Radio Zone 3 A /

II. Radiation Hazard Analysis ANALYSIS OF NON-IONIZING RADIATION for Alaska Communications Internet LLC Site: Silver Bay False Pas State: AK Latitude: 54 51 54.0 Longitude: 163 24 42.2 (NAD83) 01—25—2019 The Office of Science and Technology Bulletin, No. 65, october 1985 and revised August 1997, specifies that the maximum level of non—ionizing radiation that a person may be exposed to over a six minute period is an average power density equal to 5 mW/cm**2 (five milliwatts per centimeter squared) for a controlled environment. For an uncontrolled environment, the maximum level of non-ionizing radiation that a person may be exposed to over a thirty minute period is an average power density equal to 1 mW/cm**2 (one milliwatt per centimeter squared) It is the purpose of this . report to determine the maximum power flux densities of the earth station in the far zone, near zone, transition zone, at the main reflector surface, and between the antenna edge and the ground. Parameters which were used in the calculations: Antenna Diameter, (D) = 3.8000 m Antenna Surface Area )Sa) = pi(D**2)/4 = 11.3411 m**2 Wavelength at 6.1750 GHz (lambda) = 0.0485 m Transmit Power at Flange (P) = 10.0000 Watts Antenna Gain at Earth Site (GES) = 46.2000 dBi = 41686.9383 Power Ratio: AntiLog (GES/lO) pi = 3.1415927 Antenna Aperture Efficiency )n) = 0.6000 -

1. FAR ZONE CALCULATIONS Distance to the Far Zone (Df) (n) (D**2) = 178.6392 m lambda Far Zone Power Density (Rf) = (GES) (P) = 1.0395 W/m**2 4*pi* (Df**2) = 0.1040 mW/cm**2 2. NEAR ZONE CALCULATIONS Power Flux Density is considered to be at a maximum value throughout the entire length of this Zone. The Zone is contained within a cylindrical volume which has the same diameter as the antenna. Beyond the Near Zone, the Power Flux Density will decrease with distance from the Antenna. Distance to the Near Zone (Dn) D**2 = 74.4330 m 4*lambda Near Zone Power Density (Rn) 16.0(n)? = 2.1162 W/m**2 p1 (D**2) = 0.2116 mW/cm**2 3. TRANSITION ZONE CALCULATIONS The Power Density begins to decrease with distance in the Transition Zone. While the Power Density decreases inversely with distance in the Transition Zone, the Power Density decreases inversely with the square of the distance in the Far Zone. Since the maximum Power Density in the Transition Zone will not exceed the Near Zone values, it is not calculated.

4. MAIN REFLECTOR ZONE Main Reflector Power Density 2(P) = 1.7635 W/m**2 Sa = 0.1763 mW/cm**2 5. ZONE BETWEEN THE MAIN REFLECTOR AND THE GROUND Applying uniform illumination of the Main Reflector Surface: Main to Ground Power Density = P = 0.8817 W/m**2 Sa = 0.0882 mW/cm**2

CALCULATED SAFETY MARGINS SUMMARY AND EVALUATION Controlled Safety Margin = 5.0 — Calculated Zone Value (mW/cm**2) Safety Zones Margins Conclusions (mW/cm* *2) 1. Far Zone 4.8960 Complies with ANSI 2. Near Zone 4.7884 Complies with ANSI 3. Transition Zone Rf < Rt < Rn Complies with ANSI 4. Main Reflector Surface 4.8237 Complies with ANSI 5. Main Reflector to Ground 4.9118 Complies with ANSI Uncontrolled Safety Margin = 1.0 — Calculated Zone Value (mW/cm**2) Safety Zones Margins Conclusions (mW/cm**2) 1. Far Zone 0.8960 Complies with ANSI 2. Near Zone 0.7884 Complies with ANSI 3. Transition Zone Rf < Rt < Rn Complies with ANSI 4. Main Reflector Surface 0.8237 Complies with ANSI 5. Main Reflector to Ground 0.9118 Complies with ANSI 6. EVALUATION A. Controlled Environment B. Uncontrolled Environment All Zones comply with ANSI Standards.

I Approved by 0MB III. Draft FCC Form 312 Schedule B 3060-0678 Date & Time Filed: File Number: FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD - MAIN FORM 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: vlodification to Add a VSAT Network Site 1-8. Legal Name of Applicant Name: Alaska Communications Internet, LLC Phone Number: 907-297-3000 DBA Fax Number: 907-297-3b3 Name: Street: 600 Telephone Avenue E-Mail: Lisa.Phillips@acsalaska.com MS #60 City: Anchorage State: AK Country: USA Zipcode: 90503 — Attention: Ms Lisa Phillips 9-1 6. Name of Contact Representative Name: Richard Cameron Phone Number: 2022304962 Company: LMI Advisors Fax Number: Street: 2550 M Street NW E-Mail: rcarneron@lmiadvisors.com Suite 343 City: Washington State: DC Country: USA Zipcode: 20037— Attention: Mr. Richard Cameron Relationship: Other CLASSIFICATION OF FILING 17. Choose the button next to the classification that applies to this filing for both questions a. (N/A) bl. Application for License of New Station and b. Choose only one for 17a and only one (N/A) b2. Application for Registration of New Domestic Receive-Only Station for 17b. b3. Amendment to a Pending Application . • b4. Modification of License or Registration • al. Earth Station b.- Assignment of Ltcense or Registration . a2. Space Station b6. Transfer of Control of License or Registration 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 (N/A) blO. Other (Please specify) (N/A) bI 1. 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. 17c. Is a fee submitted with this application? • If Yes, complete and attach FCC Form 159. if No, indicate reason for fee exemption (see 47 C.ER.Section 1.1114). Q Governmental Entity (‘; Noncommercial educational licensee ‘ Other(please explain): 1 7d. fee Classification CGX - Fixed Satellite Transmit/Receive Earth Station 18. If this filing is in reference to an existing 19. If this filing is an amendment to a pending application enter both fields, if this filing is a modification station, enter: please enter only the file number: (a) Call sign of station: . . . (b) File number: (a) Date pending application was filed: 1170205 SESM0D201806260 1472

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 b. Mobile Satellite c. Radiodetermination Satellite L d. Earth Exploration Satellite e. Direct to Home Fixed Satellite f. Digital Audio Radio Service g. Other (please specify) 21. STATUS: Choose the button next to the applicable status. Choose only 22. If earth station applicant, check all that apply. one. Using U.S. licensed satellites Common Carrier • Non-Common Carrier ‘ 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: (‘ Connected to a Public Switched Network 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). a. C-Band (4/6 GHz) fi b. Ku-Band (12/14 GHz) c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: Frequency Upper: (Please specify additional frequencies in an attachment) 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 ç. b. Temporary-Fixed Earth Station c. 12/14 GHz VSAT Network ( d. Mobile Earth Station C e. Geostationary Space Station C’ f. Non-Geostationary Space Station - g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: • Transmit/Receive Transmit-Only (‘ Receive-Only N/A “for Space Station applications, select 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.) a authorization to add new emission designator and related service -- ‘ b authorization to change emission designator and related service -- c authorization to increase EIRP and EIRP density -- U authorization to replace antenna -- .1 e authorization to add antenna -- f authorization to relocate fixed station -- g authorization to change frequency(ies) -- h authorization to add frequency -- authorization to add Points of Communication (satellites & countries) -- authorization to change Points of Communication (satellites & countries) -- k authorization for facilities for which environmental assessment and -- radiation hazard reporting is required I authorization to change orbit location -- m authorization to perform fleet management -- : n authorization to extend milestones -- o Other (Please specify) -- 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 1.1308 and 1.1311 of the Commissions Yes • No rules, 47 C.F.R. 1.1308 and 1.1311, as an exhibit to this apptication.A Radiation Hazard Study must accompany..all applications for new transmitting facilities, major modifications.jor 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 govemment? C’ Yes • No

30. Is the applicant an alien or the representative of an alien? QYes No • N/A 31 Is the applicant a corporation organized under the laws of any foreign government? () Yes 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 corporation organized under the laws of Yes No • N/A a foreign country? 33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than one-fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign govemment or representative Yes No • N/A 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? • Yes No If Yes, attach as an exhibit, copies of the requests for waivers or exceptions tvith supporting documents. 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license revoked or Yes ‘ No had any application for an initial, modification or renetval of FCC station authorization, 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’ controlling the Yes • No 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, directly or indirectly, through Yes • No control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of competition?lf 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 pending matter Yes “ No 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. • Yes No 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. 42a. Does the applicant intend to use a non-U.S. licensed satellite to provide service in the United States? If Yes, answer 42b • Yes No 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?Mexico 43. Description. (Summarize the nature of the application and the services to be provided). Modification to add a new site to the C-band VSAT Network 43a. Geographic Service Rule Certification By’ selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic coverage • A 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 coverage B 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.F.R. Part 25 and tvill not comply with such requirements because it is not feasible as a c technical matter to do so, or that, while technically’ feasible, such services would require so many’ compromises in satellite j” 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.) O Individual C’ Unincorporated Association ‘9 Partnership () Corporation (‘ Governmental Entity Other (please specify) 45. Name of Person Signing 46. Title of Person Signing Rick Benken VP 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 (US. 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 El: Site Identifier: SilverBay false Pass ES. Call Sign: E2: Contact Name Greg Tooke E6. Phone Number: (907) 550-8364 E3. Street: N/A E7. City: false Pass E8. County: Aleutians East Borough E4. State AK E9. Zip Code 99583 ElO. Area of Operation: AK ElI. Latitude: 54051 ‘54.0” N Et2. Longitude: 163 0 24’ 42.2 W “ El3. Lat/Lon Coordinates are: (‘ NAD-27 . NAD-83 N/A E14. Site Elevation (AMSL): 3.35 meters El5. 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 manufacturers Yes • No N/A qualification measurement? If NO, provide as a technical analysis showing 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 Yes No • N/A specified in Section 25.209(a2) and (b) as demonstrated by the manufacturer’s qualification measurements? E17. Is the facility operated by remote control? If YES. provide the location and telephone number of the control point. ] Yes • No E18. Is frequency coordination required? If YES, attach a frequency coordination report as falsePass • Yes t No Freq Coord E19. Is coordination tvith another country required? If YES, attach the name of the country(ies) and ‘P” Yes • No plot of coordination contours as 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? 9 Yes • No FAILURE TO COMPLY WITH 47 CFR PARTS 17 AND 25 WILL RESULT IN THE RETURN OF THIS APPLICATION. POINTS OF COMMUNICATION Satellite Name:EUTELSATII5WB(S2938) I EUTELSAT 115 WB I 114.9 W.L. If you selected OTHER, please enter the following: E21. Common Name: jE22. ITU Name: jE23. Orbit Location: E24._Country:

POINTS OF COMMUNICATION (Destination Points) jE25. Site Identifier: I E26. Common Name: 11E27. Country: ANTENNA E28. E32. E29. E30. E31. E41/42. Antenna Gain Transmint and/or Site ID Antenna . Antenna Quantity Manufacturer Model Recieve(__dBi at Id Size SilverBay 46.2 dBi at 5965 VSAT 1 Prodelin 2385 3.8 False Pass E37. Building 138. Total 139. Maximum E40. Total E28. E35. Above E36. Above . . Height Above Input Power Antenna Height EIRP for al . 133/34. Diameter Antenna .Ground Sea . Minor/Major(meters) Ground at antenna Above Id Levet(meters) Level(meters) carriers(dBW) Level(meters) flange(Watts) Rooftop(meters) VSAT 0.0/0.0 113.0 13.35 10.0 110.0 110.0 149.42 FREQUENCY 128. 143/44. 145. 147. 148. Maximum 149. Maximum ERIP E46. Antenna Densityper Antenna frequency T/R Emission EIRPper rOiariZa iOfliri,v,i,i . Carrier(dBW/4kHz) Id Bands(MHz) Mode Designator Carrier(dBW) VSAT 37004200 flR IHorizontal I72MOG7W l1o.0 110.0 E50. Modulation and Services Modulation and Services Digital VSAT 5925 6425 lIT Ivertical 112M$OG7W 1149.42 1129.12 E50. Modulation and Services Modulation and Services Digital FREQUENCY COORDINATION E56. 158. E57. E59. Earth Earth 154/55. Range Antenna . . Antenna 160. Maximum E28. E2/53. Station . Station . E51. Satellite . of Satellite Arc Elevation . . Elevation EIRP Density Antenna Frequency Azimuth Azimuth Orbit Type . Eastern/Western . . Angle Angle toward the Id Limits(MHz) Angle Angle . Limit . Eastern Western Horizon(dBW/4kHz) Eastern Western . . Limit . . . . Limit Limit Limit VSAT IlGeostationaryll3700 4200 I 14.0/1 16.0 11125.02 lii 3.55 L 26.93 1114.52 10.0 IIGeostationatyllS92S 6425 1L4.0/1 16.0 11125.02 1113.55 126.93 1114.52 11-62.91 REMOTE CONTROL POINT LOCATION 161. Call Sign 166. Phone Number NOTE: Please enter the callsign of the controlling station, not the callsign for which this application is being filed 162. Street Address 163. City 168. County 167/68. 164. Zip Code State/Country FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this 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, Papertvork 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@fcc.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 0MB control number or if we fail to provide you with this notice. This collection has been assigned an 0MB 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. —



Document Created: 2019-04-26 11:17:51
Document Modified: 2019-04-26 11:17:51
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