Attachment Explanatory Stmt

This document pretains to SES-STA-INTR2016-01360 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201601360_1139299

                                                                                    Row 44, Inc.
                                                                                    STA Request
                                                                                      June 2016
                                                                                     Page 1 of 1


                               EXPLANATORY STATEMENT

        Row 44, Inc., pursuant to Section 25.120(b) of the FCC’s Rules, hereby requests Special
Temporary Authority (“STA”) for an additional thirty (30) days to operate its licensed Ku-band
network of Earth Stations Aboard Aircraft (“ESAA”) (Call Sign E080100), using space segment
capacity on the SES, S.A. (“SES”) AMC-6 satellite (“AMC-6”) at 72 W.L. The capacity on
AMC-6 is being used on an interim basis as replacement capacity for space segment on the
AMC-2 satellite, which is in the process of being relocated from 80.85 W.L. to 84.85 W.L.
Row 44 expects to transition back to AMC-2 once it is on station and operating at its new
location. It has now filed an amendment (FCC File No. SES-AFS-20160614-00506) to its
pending modification application (FCC File No. SES-MFS-20150928-00635) to shift its
authority to operate on AMC-2 to the new orbital location, and expects to file for STA to operate
using AMC-2 at 84.85 W.L. in the near future.

        Row 44 has been transmitting to AMC-6 since May 23, 2016 without causing any
interference into adjacent satellites operating in accordance with FCC's two-degree spacing
policy. It has previously provided a coordination certification letter from SES, in accordance
with Sections 25.227(b)(2) of the Commission’s Rules, covering the interim operation, which is
also fully consistent with its coordination agreements with the National Science Foundation and
the National Aeronautics and Space Administration.

        Under Section 25.120(b)(1) of the FCC’s Rules, the International Bureau may grant an
STA when the public interest supports the relief requested, and/or delay in the institution of
temporary operations would be contrary to the public interest. See 47 C.F.R. § 25.120(b)(1).
Such authority may be granted for a period not to exceed 30 days “if the STA request has not
been placed on public notice, and an application for regular authority is not contemplated.” See
47 C.F.R. § 25.120(b)(4). Because Row 44 will not be filing an application for permanent access
to AMC-6 at 72 W.L., its request is thus limited to thirty (30) days duration. Row 44
anticipates that operations using AMC-6 will continue for just a few more weeks, which may
mean that no further STA extensions will be required.

         Grant of the additional authority requested here will promote the public interest by
permitting Row 44 to continue providing service to its customers using capacity on the AMC-6
satellite in lieu of capacity on AMC-2. Use of AMC-6 will help maintain effective coverage of
all U.S. domestic routes currently served by Row 44. Grant of the requested STA is consistent
with Commission policy and will not adversely affect other authorized operations. Row 44
acknowledges that any action taken pursuant to a grant of the requested STA will be at its own
risk, and respectfully requests that the FCC grant it authority as of June 22, 2016, for an
additional period of thirty (30) days, to use the AMC-6 satellite as a point of communication in
the conventional Ku-band in the United States using TECOM antennas now operating under its
FCC ESAA network license.



Document Created: 2016-06-15 19:49:01
Document Modified: 2016-06-15 19:49:01

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