Attachment STA Narrative

This document pretains to SES-STA-20190828-01118 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019082801118_1871741

REQUEST FOR SPECIAL TEMPORARY AUTHORITY Comcast Cable Communications Management, LLC (“Comcast”) requests Special Temporary Authority (“STA”) to operate a previously licensed transmit C-band earth station facility (E940006) for a period of sixty (60) days beginning September 6, 2019. The purpose of this STA is to authorize interim operation of this facility pending action on a forthcoming license application for permanent operating authority. As set forth below, FCC approval of this request will serve the public interest, convenience and necessity. Section 25.120(b)(1) of the Commission’s rules provides that STA may be granted upon a finding of “extraordinary circumstances requiring temporary operations in the public interest and that a delay in the institution of service would seriously prejudice the public interest.”1 Section 25.120(b)(3) further provides that the Commission may grant STAs for a period of sixty (60) days without placing the request on public notice where the applicant plans to file a request for regulatory authority. Comcast submits that the instant request satisfies both rule sections. The subject earth station is located at Comcast’s national transmission center in Littleton, Colorado. Comcast uses the Littleton complex to distribute video programming to its cable television headends throughout the country, and to otherwise provide support to its various media operations. Comcast holds many FCC authorizations for earth stations located at the Littleton complex. In the past year, it has filed timely renewal applications for dozens of earth station authorizations and also surrendered the authorizations for numerous earth stations. Due to an accidental administrative error, however, the license for this station expired on December 17, 2018 without a renewal application being filed. This STA application is being filed promptly after discovery of the inadvertent error. No party will be prejudiced by FCC grant of this STA request. The subject station (which is not being operated) was previously licensed and the transmit frequencies remain protected in the frequency coordinator’s database, and prior coordination notifications for the forthcoming license application were mailed to all interested parties via first class U.S. Mail on August 21, 2019 (see Attachment A). In addition, a new radiation hazard study has been completed for this facility (see Attachment B). Favorable action on this request will also serve the public interest. As indicated, the station is being used to distribute video programming to Comcast customers nationwide and will be operated in accordance with the technical parameters set forth on the station’s most recent license authorization. Grant of the requested STA will thus simply reinstate the operational authority of an earth station that has been used by Comcast for many years without prejudice to any party. Accordingly, Comcast submits that FCC approval of this request for STA is warranted. 1 47 C.F.R. § 25.120(b)(1).


Document Created: 1900-08-30 00:00:00
Document Modified: 1900-08-30 00:00:00
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