Attachment Narrative

This document pretains to SES-STA-20190724-00973 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019072400973_1814456

                                      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”),1 Alaska Communications Internet LLC (“Alaska Communications

Internet”) respectfully seeks a 60-day special temporary authorization (“STA”), commencing on

Wednesday, July 24, 2019, to continue to operate four (4) remote earth station sites as part of its

existing C-band very small aperture terminal (“VSAT”) network2 during the Commission’s

review of its pending modification application.3 Consistent with its existing STA for the

identical operations proposed herein,4, Alaska Communications Internet seeks to continue to

operate these new sites in the C-band at fixed locations in Alaska while communicating with the

EUTELSAT 115WB satellite located at the 114.9° W.L. orbital position.

          Alaska Communications Internet seeks this STA to continue the provisioning of critical

broadband satellite communications services to these locations while that ACI Modification

Application is under the Commission’s consideration. Grant of this STA request will serve the



1
      See 47 C.F.R. § 25.120.
2
      See Alaska Communications Internet LLC, File No. SES-LIC-20171116-01257, Call Sign E170205,
      and subsequent modification and amendment applications (“ACI Network License”).
3
      See Alaska Communications Internet LLC, File No. SES-MOD-20180626-0142, Call Sign E170205
      (“ACI Modification Application”). Alaska Communications Internet anticipates filing an application
      for regular authority to operate these sites as soon as the Commission completes action on the
      pending ACI Modification Application.
4
     See Alaska Communications Internet LLC, File No. SES-STA-20190515-00602 (“Trident
     STA”).


public interest because it will enable Alaska Communications Internet to deliver uninterrupted

broadband services to support commercial operations in the Alaska Bush,5 both for Trident

Seafood Corporation (“Trident”), the largest seafood company in the United States, at three

coastal seafood processing plants (the “Trident Sites”), and for the operations of Pebble Limited

Partnership (“Pebble”) in Iliamna, Alaska (the “Pebble Site”), to exploit a large porphyry deposit

in southwest Alaska.

         With employees and facilities sprawled across the Alaskan coastline, Trident needs reliable

broadband services at the Trident Sites to support its operations, management and personnel, manage

logistics, coordinate shipments and keep its employees connected to their families and the larger

world. Pebble has a similarly urgent need for service at the Pebble Site, as it works to realize the

Pebble Deposit’s potential to provide critical minerals to bolster America’s resource independence.

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.6 Alaska Communications




5
     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.
6
     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-20050822-00382,
     ITC-T/C-20040414-00190 (International Section 214 authorization).


                                                    2


Internet provides essential broadband and voice-over-Internet Protocol (“VoIP”) services to

enterprise, business, educational, health care, and residential customers throughout the state.

        The ACI Network 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 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”),7 providing

broadband connectivity that supports the local fishing and seafood industries, as well as a test site

located in Anchorage, Alaska. In the ACI Modification Application, Alaska Communications

Internet has also sought authorization to extend its network to deliver broadband

telecommunications and Internet access services to the Kuspuk School District’s nine primary and

secondary schools, as well as the District Office, located in additional Alaska Bush communities.8

While that application remains pending, Alaska Communications Internet has obtained special

temporary authority to serve those sites,9 as well as a seafood processing plant operated by Silver

Bay Seafood, LLC at False Pass, Alaska.10 This STA is similar in scope to Alaska

Communications Internet existing Silver Bay STA and will enable Alaska Communications



7
     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/.
8
     See ACI Modification Application, supra, n.3.
9
     See, e.g., Alaska Communications Internet LLC, SES-STA-20190130-00038 and SES-STA-
     20190408-00472, Call Sign E170205 (“Kuspuk STA”).
10
     See Alaska Communications Internet LLC, File Nos. SES-STA-20190211-00110 and SES-STA-
     20190418-00526, Call Sign E170205 (“Silver Bay STA”).


                                                  3


Internet to continue providing broadband and internet connectivity to facilities across hundreds of

miles of rugged Alaskan coastline, as well as to a remote interior site at Iliamna, Alaska.

          Alaska Communications Internet incorporates by reference a pro forma FCC Form 312

Schedule B and Technical Appendix submitted with the Trident STA, no information is changing

as a result of this request. Those documents provide relevant information relating to the earth

station operating parameters, performance information and radiation hazard analyses. At all four

new remote sites, Alaska Communications Internet will continue to operate a 2.4m General

Dynamics (the “2.4m”) earth station with a Prodelin antenna, which is on the Commission’s

Approved Non-Routine Earth Station Antennas List (“Non-Routine Antenna List”).11 Moreover,

Alaska Communications Internet will operate the earth stations below the maximum EIRP

spectral density (“ESD”) levels previously approved by the Commission.12

II.       Discussion

          This STA requests seeks to extend Alaska Communications Internet’s authority to

operate four remote earth station sites at various locations in the Alaska Bush, which will

communicate with the C-band network hub operated by Alaska Communications Internet under

the ACI Network License via the EUTELSAT 115WB satellite in the C-band.

          A.      New Site Locations

          Alaska Communications Internet seeks to operate the following four sites as part of its C-

band VSAT network in Alaska:


11
      Alaska Communications Internet will operate the General Dynamics Prodelin Antenna Model 1251 at
      the Trident Sites, and its newer, technically identical variant, the Model 1241 at the Pebble Site.
      Alaska Communications Internet will operate these earth stations at maximum EIRP spectral density
      (“ESD”) levels lower than those previously authorized by the Commission. See Approved Non-
      Routine Earth Station Antennas, https://www.fcc.gov/approved-non-routine-earth-station-antennas.
12
      Each site will utilize an iDirect modem, which assigns individual time slots for each earth station’s
      transmissions, and thus there is no potential for aggregation of transmissions resulting in an
      exceedance of the off-axis ESD levels provided in this application.


                                                     4


        The Trident Sites

            •   North Naknek Facility
                (geographic coordinates: 58° 43' 41.4" N, 157° 0' 26.2" W)

            •   Akutan Facility
                (geographic coordinates: 54° 7' 59.3" N, 165° 47' 22.1" W)

            •   Sand Point Facility
                (geographic coordinates: 55° 20' 10.9" N, 160° 30' 8.3" W)

        The Pebble Site

            •   Pebble Mine Facility
                (geographic coordinates: 59° 45' 26.0" N, 154° 54' 22.8" W)

        Each site will use a technically identical 2.4m earth station that is on the Commission’s

Non-Routine Antenna List.13 Although the 2.4m earth station 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

in compliance with the ESD mask set forth in Section 25.218(d) of the Commission’s rules.14

        At the each of the Trident Sites, the earth station will be mounted on a previously-

installed pole in an area inaccessible to the general public. At the Pebble Site, which is located at

an airstrip to support freight and cargo management, the earth station will be placed on a non-

penetrating mount on an existing rooftop, also inaccessible to the general public. These planned

locations are not among any “districts, sites, buildings, structures or objects, significant in

American history, architecture, archeology, engineering or culture, that are listed, or are eligible




13
     Supra n.10.
14
     See 47 C.F.R. § 25.218(d).



                                                  5


for listing, in the National Register of Historic Places,”15 and thus they fall within the exemptions

of Section 1.1306(a)-(b) and Note 1 to that rule.16 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, 47 C.F.R. § 1.1306.

         B.      Frequency Coordination

         Alaska Communications Internet engaged Micronet Communications, Inc. (“Micronet”)

to perform frequency coordination in support of the subject operations, which was completed on

May 6, 2019.17 Pursuant to Sections 25.115(c)(2)(ii) and 25.203 of the Commission’s rules,18

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 Trident sites.

         As demonstrated in the provided frequency coordination reports, 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




15
     47 C.F.R. § 1.1307(a)(4).
16
     See 47 C.F.R. § 1.1306, Note 1 (“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.”).
17
     Alaska Communications Internet originally completed coordination the Trident and Pebble Sites on
     April 30, 2019 but re-coordinated the sites as of May 6, 2019 at higher maximum power levels. Now,
     the coordinated values at each site are “worst-case” scenario and, in reality, Alaska Communications
     Internet will operate below the coordinated levels at all times pursuant to the parameters provide in
     the Schedule B.
18
     See 47 C.F.R. §§ 25.115(c)(2)(ii) and 25.203.



                                                    6


will coordinate any additional hub or remote operations prior to bringing them into use as part of

the C-band VSAT network.

        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, 2018.19 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 conitnued 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 Trident

sites as part of the network licensed under its existing ACI Network License, Alaska

Communications Internet intends to seek a waiver, to the extent required, of the Temporary

Freeze Public Notice. As discussed in the Silver Bay STA Legal Narrative, grant of that waiver

request, when filed, would enable Alaska Communications Internet to expand its delivery of

reliable and effective broadband services to additional remote locations, namely Trident

processing plants for employee and operational communications.20


19
     See Public Notice, 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 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).
20
     See Silver Bay STA, Legal Narrative, Section II.C. To the extent that the Commission deems the
     Temporary Freeze Public Notice applicable here, Alaska Communications Internet hereby seeks a



                                                  7


III.      Request for Special Temporary Authority and Public Interest Considerations

          Alaska Communications Internet respectfully requests this 60-day STA pursuant to

Section 25.120 of the Commission’s rules, 47 C.F.R. § 25.120. 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, the ACI Modification Application has already been filed with the

Commission and the Public Notice period for the application ended on August 17, 2018.

Ongoing Commission coordination has necessitated this STA extension request to ensure Alaska

Communications Internet has appropriate authority during the Commission’s ongoing review of

the ACI Modification Application. Pursuant to Commission rules and precedent, Alaska

Communications Internet understands that this extension request will effectively extend its

current temporary authority until the Commission acts on the instant request, affording sufficient

time for coordination and action on the ACI Modification Application.21

          This extended authority is critical to ensure delivery of satellite services to these

locations, and grant of the requested 60-day STA will strongly serve the public interest by

allowing Alaska Communications Internet to continue to provide broadband services to

additional remote Alaskan businesses that must rely on this service for basic connectivity needs.

Grant of the STA will also allow Alaska Communications Internet to serve underserved

communities in the remote Alaska Bush and help improve the local economy, enhance economic

opportunity and well-being of its residents, and bridge the digital divide. Users will have


      waiver of that freeze for the reasons set forth in Section II.C of the Silver Bay STA, Legal Narrative
      which it incorporates here by reference.
21
     See 47 C.F.R. §§ 25.120 & 25.163(b); Administrative Procedure Act § 9(b). See also 47 C.F.R.
     §1.955(b); In the Matter of Marc D. Sobel Application for Consent to Assign the License for
     Conventional 800 MHz SMR Station KKT934, Montrose, California, Memorandum Opinion & Order,
     FCC 05-90, ¶¶ 2 & 6.


                                                      8


broadband Internet access, e-mail, voice and data services, greatly enhancing economic

opportunities in these remote locations. Finally, grant of this application will facilitate additional

competitive alternative for customers in the Alaska Bush, an undeserved area with little access to

telecommunications connectivity.

IV.    Conclusion

       Based on the foregoing, the public interest would be served by a grant of this STA to

Alaska Communications Internet to continue to operate four additional sites as part of its C-band

VSAT network in Alaska for a period of 60 days, commencing on July 24, 2019.




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Document Created: 1210-08-28 00:00:00
Document Modified: 1210-08-28 00:00:00

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