Attachment Attachment A

This document pretains to SES-STA-20190826-01121 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019082601121_1870273

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”) to operate a temporary fixed satellite service (“FSS”) VSAT network system in the 12/14 GHz band (the “Ku-Band”). Specifically, GCI is seeking temporary authorization to operate currently-licensed antennas associated with Call Sign E120191, IBFS File No. SES-LIC-2012092500484 (the “License”), under modified parameters consistent with those requested in IBFS File No. SES-MOD-20190725-00956 that will allow it to communicate with a new satellite, Call Sign S2947, in order to obtain additional Ku-band satellite capacity.1 Because GCI is requesting an STA for a period not to exceed 60 days pursuant to 47 C.F.R. §25.120(3), and currently has a related modification application for regular authority pending before the FCC,2 this application need not be placed on public notice and should be granted expeditiously pursuant to the rules, and in any event, no later than September 16, 2019. GCI’s operation of this License would not cause harmful interference into surrounding networks, and as demonstrated below, there are extraordinary circumstances supporting the 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 telehealth services, to rural and remote hospitals and 1 These modified parameters include, but are not limited to: (1) Addition of the GD Satcom/Prodelin 1385/1386/2385 3.8m antennas; (2) modifications to the power levels of the 2.4m antennas and the 3.8m antenna; (3) extension of the western azimuth limit of the 2.4m antennas to 230W, and (4) modifications to the Emission Designators, Carrier EIRP and EIRP Density. See IBFS File No. SES-MOD-20190725-00956 for further details. 2 IBFS File No. SES-MOD-20190725-00956.

GCI Communication Corp. Application for Special Temporary Authority clinics in western Alaska on a new satellite that will accommodate the GCI’s growing network capacity needs, as spectrum for this growth is unavailable on GCI’s existing Ku-band satellite. 3 Although GCI filed a modification application to the E120191 underlying license to reflect the modifications necessary to utilize the new satellite, that application is still pending FCC review, and has yet to be placed on Public Notice. GCI needs access to this new satellite (and hence, needs to be able to modify its operations) in the near term – by September 16, 2019 – to meet commitments made to customers supported by the Rural Health Care Program.4 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.”5 A grant of this STA would continue to allow GCI to provide critical health communications services to remote and rural hospitals and clinics in western Alaska. GCI’s services support the delivery of telemedicine services such as teleradiology, remote patient monitoring, medical network solutions, and live video-conferencing to customers in Alaska. GCI has witnessed firsthand the transformational benefits of telemedicine for health care delivery in Alaska. These services improve healthcare in areas that traditionally have few physicians and even fewer medical specialists in a variety of medical fields, including audiology, cardiology, dental, family medicine, neurosurgery, ophthalmology, pediatrics, psychiatry, and women’s health. In most instances, GCI’s network is the only way that rural Alaskans may gain access to such specialists. For example, without telepsychiatry services, residents seeking 3 This service will provide high-availability supplements to terrestrial circuits. 4 GCI has committed to provide the additional capacity for telehealth communications services by October 8, 2019. The modified parameters requested herein are necessary for GCI to meet this commitment. GCI is requesting a grant data of this STA no later than September 16, 2019 to allow it to take the necessary actions to modify its services by this deadline. 5 47 C.F.R. §25.120(b)(1). 2

GCI Communication Corp. Application for Special Temporary Authority psychiatric care in many remote villages would either have to wait for a sporadic visit from a traveling psychiatrist, or would have to travel vast distances – usually at a prohibitively high cost – to seek the medical help that they needed. Neither of these options would likely be possible during the harsh long Alaskan winter. GCI’s network enables a patient to visit with a specialist remotely, via a remote village clinic, on their own schedule. The substantial public service record of GCI indicates that the company is committed to providing service to consumers in Alaska. It has sought regular authority for the requested modifications to E120191. However, because GCI does not want these services to be implicated during the pendency of this request, it is also requesting this STA. Continued service illustrates a “compelling reason” to expeditiously grant the requested STA, but no later than September 16, 2019, and would certainly be in the public interest. In addition, pursuant to the FCC’s rules, FAA notification is not required for earth station antennas associated with this application as the proposed antenna structure will be less than 6.10 meters above ground level.6 6 See 47 C.F.R. § 17.7. 3


Document Created: 2019-08-26 15:43:26
Document Modified: 2019-08-26 15:43:26
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