Attachment STA Narrative

This document pretains to SES-STA-INTR2019-03095 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201903095_1869695

REQUEST FOR SPECIAL TEMPORARY AUTHORITY Comcast Cable Communications Management, LLC (“Comcast”) requests Special Temporary Authority (“STA”) to operate three previously licensed transmit-only C-band earth station facilities for a period of sixty (60) days beginning September 6, 2019. The purpose of this STA is to authorize interim operation of these facilities at their licensed parameters pending action on a forthcoming 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 stations are 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 licenses for E940005, E940006 and E940007 expired on December 17, 2018 without renewal applications 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 stations (which are not being operated) were 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 finding that operation of these stations will not exceed applicable RF exposure limits (see Attachment B). Favorable action on this request will also serve the public interest. As indicated, the stations are being used to distribute video programming to Comcast customers nationwide and will be operated in accordance with the technical parameters set forth on the most recent license authorizations for stations E940005, E940006 and E940007. Grant of the requested STA will thus simply reinstate the operational authority of three earth stations that have 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: 2019-08-26 13:08:20
Document Modified: 2019-08-26 13:08:20
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