Attachment STA Narrative

This document pretains to SES-STA-20161027-00864 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016102700864_1157046

AC BidCo LLC Attachment A Page 1 REQUEST FOR SPECIAL TEMPORARY AUTHORITY AC BidCo LLC (“AC BidCo”), which holds a license to operate an earth station aboard aircraft (“ESAA”) network, 1 hereby requests special temporary authority (“STA”) for a period of 60 days commencing as soon as possible but no later than November 14, 2016, to permit up to 200 ESAA terminals to communicate in the conventional Ku-band with the U.S.-licensed SES-3 satellite located at 103° W.L. 2 Grant of the requested STA will serve the public interest by allowing AC BidCo to meet customer demand for additional capacity over North America, including in U.S. airspace. AC BidCo is preparing an application to add SES-3 as an authorized point of communications, and seeks STA pending submission of and action on that application. Background AC BidCo is currently authorized to operate Ku-band terminals with specified satellites for ESAA service in U.S. airspace, foreign airspace, and the airspace over international waters. AC BidCo’s license was issued based on demonstration that the proposed network would enhance competition in the provision of in-flight broadband service to air travelers and airline crew members and that the planned operations were fully consistent with technical standards designed to ensure protection of other authorized communications networks. In order to enhance and expand its ESAA operations, AC BidCo is preparing to seek authority to add SES-3 as a point of communication for its ESAA network. STA Request AC BidCo seeks STA to commence communications with SES-3 in the near term to meet customer demand. Because SES-3 is U.S. licensed, full technical data regarding the satellite is already on file with the Commission,3 and AC BidCo incorporates that information by reference herein. AC BidCo is also attaching a letter confirming that its proposed ESAA operations are consistent with SES’s coordination agreements with operators of the satellites within six degrees 1 See Call Sign E120106, File No. SES-MFS-20151022-00735, granted June 30, 2016 (the “AC BidCo ESAA License”). The ESAA license was granted to Gogo (“Gogo”), a commonly- owned affiliate of AC BidCo. A pro forma assignment of the ESAA license from Gogo to AC BidCo was approved by the Commission and consummated earlier this year. See File No. SES- ASG-20160714-00659, granted July 19, 2016. 2 AC BidCo is licensed for two ESAA terminals, the 0.24 meter AeroSat model HR6400 and the 0.74 meter ThinKom model 2Ku. AC BidCo seeks authority to use only the ThinKom antenna for communications with SES-3. 3 SES Americom, Inc., Call Sign S2892, File Nos. SAT-RPL-20121228-00227 & SAT- AMD-20131113-00132, grant-stamped Apr. 2, 2015 (“SES-3 License”).

AC BidCo LLC Attachment A Page 2 on either side of SES-3. The technical parameters of the proposed operations with SES-3 are provided in the following table. 4 Antenna Maximum EIRP Density Per EIRP (dBW) Emission Carrier (dBW/4 kHz) Designator AES2 15.8 42.6 3M00G7W AC BidCo seeks authority to use SES-3 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum, consistent with the SES-3 License and the Commission’s orders in the ESAA proceeding. 5 Communications with the satellite will be supported by a teleport in Woodbine, MD, Call Sign E140059. SES-3 will provide coverage of the Contiguous U.S., Hawaii, and parts of Alaska, Canada and Mexico. AC BidCo requires access to this capacity to ensure that it has sufficient bandwidth to meet near-term customer demand for in-flight connectivity. AC BidCo emphasizes that the scope of this STA request is limited. AC BidCo is only seeking authority to add SES-3 as an authorized point of communication for a limited number of ESAA terminals. AC BidCo is otherwise prepared to operate consistently with the terms and conditions set forth in the existing AC BidCo ESAA License. In addition, AC BidCo is willing to operate pursuant to the STA on an unprotected, non-harmful interference basis. Grant of the requested STA is consistent with Commission policy and will not adversely affect other authorized operations. AC BidCo’s proposed operations with SES-3 are consistent with SES’s coordination agreements with adjacent satellite operators and will also conform to the terms of AC BidCo’s agreements with the National Science Foundation and the National Aeronautics and Space Administration, as required by the AC BidCo ESAA License. 6 In addition, AC BidCo will comply with power flux density limits to protect terrestrial services outside the U.S. 4 Operations with SES-3 will not involve any increase in the maximum off-axis EIRP density levels previously described to the Commission for the ThinKom terminal. 5 Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14-14.5 GHz Frequency Bands, Notice of Proposed Rulemaking and Report and Order, IB Docket Nos. 12-376 & 05-20, 27 FCC Rcd 16510 (2012); Second Report and Order and Order on Reconsideration, IB Docket No. 12-376, 29 FCC Rcd 4226 (2014). 6 AC BidCo ESAA License at 7, condition 90057.

AC BidCo LLC Attachment A Page 3 Grant of the proposed STA will allow AC BidCo to respond to urgent customer demand for increased capacity on important air transport routes over the U.S. and the remainder of North America, promoting competition in the provision of aeronautical services and expanding the availability of in-flight broadband to air travelers and crew members. AC BidCo understands that any Commission grant of this STA will be without prejudice to the ultimate determination the Commission will make regarding AC BidCo’s future application to add SES-3 to the AC BidCo ESAA License. In addition, AC BidCo acknowledges that any action taken pursuant to a grant of the requested STA will be at AC BidCo’s own risk.

SES* Federal Communications Commission International Bureau 445 12Street, S.W. Washington, D.C. 20554 United States 21 October 2016 Subject: Engineering Certification of SES for the SES—3 satellite To whom it may concern, This letter confirms that SES is aware that AC BidCo LLC ("AC BidCo"), licensed by the Federal Communications Commission (°FCC") as AC BidCo LLC, is planning to file an application seeking a modification to its blanket authorization (the "Modification Application") to operate Ku—band Earth Stations Aboard Aircraft (°ESAA") transmit/receive terminals (Call Sign E120106) pursuant to ITU RR 5.504A and Section 25.227 of the Commission‘s rules, on domestic and international flights. Among other changes, the Modification Application will seek authority for AC BidCo‘s ESAA terminals to communicate with the SES—3 satellite at 103°W.L., under the current ESAA rules, including Section 25.227. Based upon the representations made to SES by AC BidCo concerning how it will operate on SES—3 according to its letter dated 19 October 2016: e SES certifies that it has completed coordination as required under the FCC‘s rules and that the power density levels specified by AC BidCo are consistent with existing coordination agreements to which SES is a party with all adjacent satellite operators within +/— 6 degrees of orbital separation from SES—3. e If the FCC authorizes the operations proposed by AC BidCo, SES will include the power density levels specified by AC BidCo in all future satellite network coordination with other operators of satellites adjacent to SES—3. Yours Sincerely, . \ || / 3 fJ ~=—L___2 4A VM / Kimberty N~Baum SES Americom, Inc. Tel. +1 609 987 4000 4 Research Way Fax +1 609 987 4517 Princeton, NJ 08540 kimberly.baum@ses.com USA www.ses.com


Document Created: 2016-10-27 10:39:25
Document Modified: 2016-10-27 10:39:25
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