Attachment Exhibit A

This document pretains to SES-STA-INTR2019-01417 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201901417_1679165

Exhibit 1 REQUEST 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”) commencing immediately,1 to operate an emergency temporary fixed satellite service (“FSS”) earth station in the 3.7 – 4.2 GHz and 5.925-6.425 GHz bands (the “C-Band”).2 Specifically, by this application (the “Application”), GCI is seeking temporary authorization to provide service over the license identified by call sign E020088 (referred to herein as the “License”), covering locations in the extremely rural geographic area of Kotlik (the “Market”). Because GCI is requesting an STA for a period not to exceed 60 days pursuant to 47 C.F.R. §25.120(3), this Application need not be placed on public notice and should be granted expeditiously pursuant to the rules. GCI’s operation of this station 1 GCI submits that there are “extraordinary reasons . . . that could not have been earlier foreseen” that warrant a waiver of the three working day review period pursuant to 47 C.F.R. § 25.120(a). Here, GCI recognized that due to an administrative error, the License was not renewed at the time of its expiration in June 2017. However, GCI needs to provide critical services pursuant to the License. GCI seeks this emergency STA to utilize the above-referenced station on C-Band spectrum as soon as possible in order to provide reliable services to these areas. 2 GCI recognizes that the International, Public Safety and Homeland Security, and Wireless Telecommunications Bureaus (the “Bureaus”) has imposed a freeze effective April 19, 2018 “on the filing of new or modification applications for [FSS] earth station licenses, receive-only earth station registrations, and fixed microwave licenses in the 3.7-4.2 GHz frequency band.” Based on the text of the Public Notice, STA requests for FSS earth station licenses in the C-Band are not covered by the freeze. However, out of an abundance of caution, if the Bureaus were to determine that such an STA is considered a filing prohibited by this freeze, GCI respectfully requests a waiver of the freeze, as a grant of this STA request would “serve the public interest and not undermine the objectives of the freeze,” as detailed herein and further discussed in GCI’s request for waiver of this filing freeze in connection with its accompanying license application. See also 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 3.7-4.2 GHz Band, Public Notice, 1, 3, DA 18-398 (rel. Apr. 19, 2018). {00137409;v2} 1

Exhibit 1 would not cause harmful interference into surrounding networks, and as demonstrated below, there are extraordinary circumstances supporting the immediate 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. By this filing, GCI seeks an STA to immediately provide service operations over the License for 60 days or less, pending FCC action on the waiver and license application filed by GCI with respect to the License.3 GCI seeks a STA in this instance in order to “provide the same service as previously authorized” under the License.4 Under the Commission’s rules, a STA may be valid for “60 days or less, pending the filing of any application for regular authorization of the subject operation.” In addition, a STA may be granted “upon a finding that there are extraordinary circumstances requiring operation in the public interest and that delay in the institution of such service would seriously prejudice the public interest.” GCI seeks such STA due to the untimely filing of its renewal application for the License. The GCI employee responsible for making the filing failed to file a renewal application due to an internal administrative error. Once this error became known, the employee took immediate steps to initiate a license application, a waiver and this STA request. Furthermore, GCI is currently adopting additional procedures to help avoid such administrative errors in the future. 3 GCI is concurrently seeking waiver of the renewal application filing deadline for the License due to an administrative error that resulted in GCI not timely filing the renewal application. 4 As explained in the related License application, if granted, the License will be slightly modified from its previously-authorized parameters to expand the western limit of the satellite arc to allow the earth station authority to access a new satellite (due to a current satellite reaching end-of- life), as well as to correct certain data. {00137409;v2} 2

Exhibit 1 Grant of this request for STA is necessary for GCI to provide reliable communications services to GCI’s customers and would serve the public interest. In this instance, the License will help provide important services, including critical and emergency communications, to an extremely rural and remote area of Alaska – the Kotlik village, which has a population of less than 650 residents.5 Specifically, this License will help support telehealth services to the local Yukon-Kuskokwim Health Corporation clinic; support the Lower Yukon School District; provide community Internet access and rural wireless service, as well as provide support for federal services. 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.”6 The substantial public service record of GCI indicates that the company is committed to providing service to consumers in Alaska. Thus, allowing a STA to permit GCI to provide service over the License, for 60 days (or less, pending the grant of GCI’s accompanying license application), would certainly be in the public interest. This service illustrates a “compelling reason” to expeditiously grant the requested STA. This Application demonstrates that the public interest would be served by a limited STA, of 60 days or less pending the grant of GCI’s license application. 5 State of Alaska, Kotlik, Alaska Information https://dcced.maps.arcgis.com/apps/MapJournal/index.html?appid=256b6a95c0b544d3bf5d742c fd76dfc7 (last visited May 2, 2019). 6 47 C.F.R. §25.120(b)(1). {00137409;v2} 3


Document Created: 2019-05-03 11:46:55
Document Modified: 2019-05-03 11:46:55
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC