Federal Communications Commission DA 11-1650
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of 
VERIZON WASHINGTON D C, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KGC79
VERIZON NEW YORK, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KEB29
AT&T CALIFORNIA
Applications For Renewal of License For 
Common Carrier Fixed Point to Point Microwave 
Station KME49 and KMQ44
VERIZON VIRGINIA, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KIP50
VERIZON NEW JERSEY, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KEB35
ILLINOIS BELL TELEPHONE COMPANY
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KSA96
MICHIGAN BELL TELEPHONE
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KQH74
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File No. 0004233156
File No. 0004233190
File Nos. 0004244291, 0004248651
File No. 0004255375
File No. 0004258994
File No. 0004264280
File No. 0004276706
Federal Communications Commission DA 11-1650
2
VERIZON PENNSYLVANIA, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KGB74
VERIZON MARYLAND, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KGB72
BELL SOUTH TELECOMMUNICATIONS, 
INC.
Applications For Renewal of License For 
Common Carrier Fixed Point to Point Microwave 
Station KIL20 and KZS88
FRONTIER WEST VIRGINIA, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KQH73
OHIO BELL TELEPHONE COMPANY
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KQG58
WISCONSIN BELL, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KSE73
VERIZON DELAWARE, INC
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KGG34
ALASCOM, INC
Application for Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
WSL69
GTE SOUTHWEST INC dba VERIZON 
SOUTHWEST
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File No. 0004295256
File No. 0004295232
File Nos. 0004295944; 0004295948
File No. 0004319746
File No. 0004320246
File No. 0004320258
File No. 0004321335
File No. 0004523906
File No. 0004562030
Federal Communications Commission DA 11-1650
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Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KYJ33
VERIZON CALIFORNIA INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
WAX78
INFORMATION SUPER STATION, LLC
Application For Renewal of License For Local 
Television Transmission Service Station 
WMK817
ACS WIRLESS LICENSE SUB, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
WMP367
HAWAIIAN TELECOM, INC.
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
KVH83
M.U.T. LICENSING, LLC
Application For Renewal of License For Common 
Carrier Fixed Point to Point Microwave Station 
WLT380
Request to Exclude the 28.35-29.1 GHz and 
29.25-29.5 GHz Band Segments From Included 
Frequencies on the Renewal of Licenses
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File No. 0004575228
File No. 0004576055
File No. 0004587843
File No. 0004590012
File No. 0004596696
MEMORANDUM OPINION AND ORDER
Adopted:  September 27, 2011 Released:  September 30, 2011
By the Chief, Broadband Division, Wireless Telecommunications Bureau:
I. INTRODUCTION
1. In this Memorandum Opinion and Order, we grant in part requests filed by Hughes 
Network Systems, LLC (“Hughes”) and DIRECTV Enterprises, LLC (“DIRECTV”) to delete the 28.35-
29.1 GHz and 29.25-29.5 GHz band segments from the list of frequencies included on the above-
captioned licenses.  Specifically, we grant the requests with respect to the 28.35-29.1 GHz band, deny the 
Federal Communications Commission DA 11-1650
4
requests with respect to the 29.25-29.5 GHz band, and direct processing of the renewal applications filed 
for these licenses.  We also deny a motion filed by Hughes and DIRECTV to change the ex parte status of 
these application proceedings.
II. BACKGROUND
2. The licenses in question in this proceeding were originally authorized under the former 
Part 21 of the Commission’s Rules prior to 1996.1 Licensees “use these authorizations on an infrequent 
and irregular basis to operate back-up facilities when other forms of wireline services are unavailable or 
non-existent.”2 Except for the license for Station KMQ44, the licenses in question authorize operation, 
inter alia, in the 27.5-29.5 GHz band.3
3. In 1996, the Commission designated band segments for the 27.5-30 GHz band (28 GHz 
band) for several types of wireless systems, including Local Multipoint Distribution Service (LMDS) 
providers, Fixed Satellite Service (FSS) systems, and feeder links for certain Mobile Satellite Service 
(MSS) systems.4 The Commission designated 27.5-28.35 GHz and 29.1-29.25 GHz for LMDS,5 28.35-
28.6 GHz and 29.5-30 GHz for geostationary orbit (GSO) FSS systems,6 and 28.6-29.1 GHz for non-
geostationary orbit (NGSO) FSS systems.7 The Commission authorized sharing of the 29.25-29.5 GHz 
band between GSO FSS and MSS feeder link earth stations on the basis of spectrum sharing principles 
provided by relevant interests.8 The Commission declined to retain a designation for fixed point-to-point 
microwave services (FS) in the 28 GHz band.9  
4. In 2002, in response to a petition for reconsideration filed by Hughes, the Commission 
authorized blanket licensing of earth stations for geostationary orbiting (GSO) Fixed Service Satellite 
(FSS) in the 29.25-29.5 GHz band.10 The Commission noted the existence of the FS licenses at issue in 
this proceeding and required GSO FSS earth stations to “take these co-primary FS operations into account 
when deploying blanket earth stations in the 29.25-29.5 GHz band.”11 The Commission also stated:
  
1 In the Matter of Redesignation of the 17.7-19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations 
in the 17.7-20.2 GHz and 27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-
17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite-Service Use, IB Docket No. 98-172, 
Second Order on Reconsideration, 17 FCC Rcd 24248, 24260 ¶ 25 (2002) (“Second Order”).
2 Id.
3 The license for Station KMQ44 does not include the 28.35-29.1 GHz and 29.25-29.5 GHz bands that are in 
controversy.  We therefore deny the comments filed by Hughes and DIRECTV with respect to that call sign as moot.
4 See Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission’s Rules to Redesignate the 27.5-29.5 GHz 
Frequency Band, to Reallocate the 29.5 GHz Band, to Establish Rules and Policies for Local Multipoint Distribution 
Service and for Fixed Satellite Services, CC Docket No. 92-297, First Report and Order and Fourth Notice of 
Proposed Rulemaking, 11 FCC Rcd 19005, 19007 ¶ 2 (1996) (“28 GHz Band Order”).
5 Id. at 19025 ¶¶ 45-46.
6 Id. at 19029-19030 ¶¶ 57-58.
7 Id. at 19030 ¶¶ 59-60.
8 Id. at 19034-19035 ¶¶ 72-74.
9 Id. at 19042 ¶¶ 93-94.
10 Second Order, 17 FCC Rcd at 24258-24261 ¶¶ 23-25.
11 Id. at 24261 ¶ 25.
Federal Communications Commission DA 11-1650
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Due to the limited number of the legacy terrestrial licensees, the temporary nature of their 
operations, and the large amount of available authorized bandwidth, we anticipate that 
private arrangements among the GSO FSS operators and the terrestrial licensees in the 
29.25-29.5 GHz band can protect terrestrial operations without the need for formal 
frequency coordination.12
5. Between May 4, 2010 and January 31, 2011, the Wireless Telecommunications Bureau 
received the above-captioned applications for renewal of common carrier point-to-point microwave 
licenses.13 Each of the licenses, which were originally issued prior to 1996 under the provisions of former 
Part 21 of the Commission’s Rules, includes the 27.5-29.5 GHz band, in addition to other bands.  
6. Hughes and DIRECTV hold a number of authorizations from the Commission to operate 
Ka-band fixed-satellite service earth stations that transmit on frequencies in the 28.35-29.5 GHz band.14  
Between July 30, 2010 and February 24, 2011, Hughes and DIRECTV submitted joint comments on the 
applications.15 Hughes and DIRECTV seek to have the 28.35-29.1 GHz and 29.25-29.5 GHz band 
segments excluded from the licenses upon renewal.16 According to Hughes and DIRECTV, excluding 
these frequency band segments from the renewed licenses will remove uncertainty for satellite network 
operators with earth stations in the subject bands.17 Hughes and DIRECTV suggest that because the 
licenses at issue can operate in multiple frequency bands, it is reasonable to exclude the 28.35-29.1 GHz 
and 29.25-29.5 GHz band segments.18 In the alternative, Hughes and DIRECTV suggest that the 
Commission condition renewal of the licenses, allowing operations in the 28.35-29.1 and 29.25-29.5 GHz 
band only if the other licensed frequencies are unavailable for use, and then only subject to successful 
completion of coordination with FSS earth station licensees.19 One opposition was filed in response to 
the comments filed by Hughes and DIRECTV.20
  
12 Id. at 24261 n.72.
13 The Appendix to this Memorandum Opinion and Order provides a complete list of the applications and the 
comments filed by Hughes and DIRECTV, as well as pertinent dates.  One of the licenses in question, Station 
WMK817, is a Local Television Transmission Service license.
14 See, e.g., Comments of Hughes Network Systems, LLC and DIRECTV Enterprises, LLC, In re Application of 
Bellsouth Telecommunications, Inc. For Renewal of License Call Sign KZS88, File No. 0004295948 (filed Jul. 30, 
2010) (Hughes/DIRECTV Comments) at 2.  
15 See Appendix.  There are no material substantive differences among the various comments filed by Hughes and 
DIRECTV.  The comments filed on August 4 were filed more than 30 days after public notice was given that the 
applications were accepted for filing.  With respect to those comments, Hughes and DIRECTV filed petitions for 
leave to submit late-filed comments.  See, e.g., Petition for Leave to Submit Late-Filed Comments, In re the 
Application of Illinois Bell Telephone Company for Renewal of License Call Sign KSA96, File No. 0004264280 
(filed Aug. 4, 2010).
16 See Hughes/DIRECTV Comments at 2.
17 Id.
18 Id.
19 Id. at 2-3.
20 See Opposition of ACS Wireless License Sub, Inc., In re Comments of Hughes Network Systems, LLC and 
DIRECTV Enterprises, LLC, In re Application of ACS Wireless License Sub, Inc. for Renewal of License Call Sign 
WMP367, File No. 0004587843 (filed Mar. 9, 2011) (ACS Wireless Opposition).  Hughes and DIRECTV filed a 
reply.  Reply of Hughes Network Systems, LLC and DIRECTV Enterprises, LLC to Opposition of ACS Wireless 
License Sub, Inc. (filed Mar. 21, 2011).
Federal Communications Commission DA 11-1650
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III. DISCUSSION
7. Late Filed Comments.  Section 1.46(a) of the Commission rules states that motions for 
extension of time are not to be routinely granted.21 In this instance, comments on the renewal applications 
were due 30 days after the applications were placed on public notice.22 Hughes and DIRECTV submitted 
comments on a number of the applications, together with a motion for leave to file late-filed comments, 
on August 4, 2010, more than 30 days after the filing deadlines.23 Hughes and DIRECTV state they 
belatedly became aware of the license renewal applications and do not seek denial of the applications.24  
Further, they assert that the frequency exclusion they advocate in their late-filed comments would 
advance broadband satellite services and pose no meaningful detriment to the licensee or to terrestrial 
fixed service in general.25  
8. Hughes and DIRECTV have failed to persuade us that there is good cause to grant an 
extension for their comments.  We find that they had ample time to submit these comments.  Public notice 
of the relevant applications was given between May 12, 2010 and June 2, 2010.26 Hughes and DIRECTV 
did not submit their comments until August 4, 2010, over two months after these public notices.  
Furthermore, their failure to become aware of the renewal applications in a timely fashion does not justify 
permitting them to late-file their comments.  Consequently, we deny the petitions to submit formal late-
filed comments.  Hughes and DIRECTV alternatively request that the late-filed comments be treated as 
informal objections.27 Pursuant to Section 1.41 of the Commission’s Rules,28 we grant this alternative 
request and will consider the late-filed comments as informal requests for Commission action.
9. Requests to Exclude Band Segments.  We grant Hughes’ and DIRECTV’s request to 
exclude the 28.35-29.1 GHz band segment from the licenses in question.  The Commission declined to 
retain a designation for FS in that band and did not provide for any grandfathering of existing microwave 
licenses in that band.  While ACS Wireless, the only party to oppose Hughes and DIRECTV, argues that 
the grandfathering rights applied to the 29.25-29.5 GHz band (see infra) should also be applied to the 
28.35-29.1 GHz band,29 we decline to revisit at this time the Commission’s decision to treat the two bands 
differently.  Furthermore, ACS Wireless has not shown that excluding the 28.35-29.1 GHz band would 
limit its ability “to provide critical emergency services over its voice, data and Internet networks when its 
wireline backhaul facilities are unavailable.”30
10. We deny Hughes’ and DIRECTV’s request to exclude the 29.25-29.5 GHz band from the 
licenses in question.  The requests are inconsistent with the Commission’s determinations that (1) the 
  
21 47 C.F.R. § 1.46(a).
22 See 47 C.F.R. § 1.939(a)(2).
23 See Appendix. Specifically, Hughes and DIRECTV untimely filed comments on  applications for call signs 
KSA96, KQH74, KGC79, KEB29, KME49, KMQ44, KIP50, and KEB35. 
24 See, e.g., Petition for Leave to Submit Late-Filed Comments, In re the Application of Illinois Bell Telephone 
Company for Renewal of License Call Sign KSA96, File No. 0004264280 (Aug. 4, 2010) at 1.
25 Id.
26 See Appendix.
27 See, e.g., Petition for Leave to Submit Late-Filed Comments, In re the Application of Illinois Bell Telephone 
Company for Renewal of License Call Sign KSA96, File No. 0004264280 (Aug. 4, 2010) at 1-2.
28 47 C.F.R. § 1.41.
29 See ACS Wireless Opposition at 2-3 n.4.
30 Id. at 1.
Federal Communications Commission DA 11-1650
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licenses in question would retain co-primary status,31 and (2) that FSS licensees should work out private 
business arrangements with microwave licensees in order to protect to those co-primary microwave 
operations.32 While Hughes and DIRECTV offer policy reasons why they believe the microwave 
licensees should be excluded from the band segments in question, they fail to acknowledge the 
Commission’s determinations to the contrary in the Second Order.   Accordingly, we must deny the 
request as inconsistent with established Commission policy.  Furthermore, if Hughes and DIRECTV are 
correct that excluding the 29.25-29.5 GHz segments “in no meaningful way conflicts with the service 
objectives of the fixed wireless licensee,”33 they are free to work out private agreements with the licensees 
to modify the licenses to delete the band segments in question. Hughes and DIRECTV make no showing 
that they have attempted to work out such arrangements.
11. We also deny Hughes’ and DIRECTV’s alternative request that the Commission allow 
operations in the 29.25-29.5 GHz band only if the other licensed frequencies are unavailable for use, and 
then only subject to successful completion of coordination with FSS earth station licensees.  That 
restriction, too, would be inconsistent with the licenses’ co-primary status and the Commission’s 
determination that FSS licensees should work out business arrangements with microwave licensees.  We 
also note that because the 29.25-29.5 GHz band is allocated for Earth-to-space use by FSS systems,34 the 
potential for interference into GSO FSS from FS is limited.35
12. Request to Modify Ex Parte Status.  We deny Hughes’ and DIRECTV’s request to modify 
the ex parte status of this proceeding from restricted to permit-but-disclose.36 Pursuant to Section 1.1208 
of the Commission’s Rules,37 we may determine that a restricted proceeding be conducted according to 
the permit-but-disclose proceedings, if the proceeding “involves primarily issues of broadly applicable 
policy rather than the rights and responsibilities of specific parties….”38 As discussed above, our decision 
in this matter involves a determination of the rights and responsibilities of particular parties under existing 
policy, rather than revisiting an applicable policy ruling.   Under these circumstances, we find that 
modifying the ex parte status of the proceeding would not be appropriate, and we therefore deny Hughes’ 
and DIRECTV’s request that we do so.   
IV. CONCLUSION AND ORDERING CLAUSES
13. As explained above, we grant Hughes and DIRECTV’s request to exclude the 28.35-29.1 
GHz band from the licenses in question.  We deny the request to exclude the 29.25-29.5 GHz band as 
inconsistent with Commission policy and not in the public interest.  We therefore grant the comments in 
  
31 Second Order, 17 FCC Rcd at 24261 ¶ 25.
32 Id. at 24261 n.72.
33 See Hughes/DIRECTV Comments at 3.
34 See 47 C.F.R. § 2.106.
35 This is primarily an interference problem to the FS stations.  Since these stations are point-to-point stations with 
highly directive receive antennas, there are a very limited number of geometric angles that could give rise to 
interference from earth stations.  This factor, coupled with the extremely limited number of these stations, leads us 
to continue to believe that the potential for interference is very low.
36 See Request to Modify Ex Parte Status to Permit-But-Disclose of Hughes Network Systems, LLC and DIRECTV 
Enterprises, LLC, In re Application of ACS Wireless License Sub, Inc. For Renewal of License Call Sign WMP367, 
File No. 0004587843 et al (filed Apr. 11, 2011) (Ex Parte Status Request).  
37 47 C.F.R. § 1.1208.
38 47 C.F.R. § 1.1208 at n.2.
Federal Communications Commission DA 11-1650
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part and deny them in part, and direct the licensing staff of the Broadband Division to process the renewal 
applications consistent with this Memorandum Opinion and Order.
14. Accordingly, IT IS ORDERED that, pursuant to Sections 4(i) and 309 of the 
Communications Act of 1934, as amended, 47 U.S.C. §§ 154(i), 309, and Sections 1.3 and 1.41 of the 
Commission’s Rules, 47 C.F.R. §§ 1.3, 1.41, that the comments filed by Hughes Network Systems, LLC 
and DIRECTV Enterprises, LLC on July 30, 2010, August 4, 2010, August 19, 2010, January 14, 2011, 
and February 24, 2011 against the applications listed in the Appendix ARE GRANTED to the extent 
indicated above and are otherwise DENIED.
15. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and 309 of the Communications 
Act of 1934, as amended, 47 U.S.C. §§ 154(i), 309, and Sections 1.41, 1.46(a) and 1.939 of the 
Commission Rules, 47 C.F.R. §§ 1.41, 1.46(a), 1.939, that the Petitions for Leave to Submit Late-Filed 
Comments, filed by Hughes Network Systems, LLC and DIRECTV Enterprises, LLC on August 4, 2010 
ARE GRANTED to the extent that the comments will be treated as informal requests for Commission 
action and are otherwise DENIED. 
16. IT IS FURTHER ORDERED, pursuant to Sections 4(i) and 309 of the Communications 
Act of 1934, as amended, 47 U.S.C. §§ 154(i), 309, and Sections 1.949 of the Commission’s Rules, 47 
C.F.R. § 1.949, that the licensing staff of the Broadband Division SHALL PROCESS the applications 
listed in the Appendix in accordance with this Memorandum Opinion and Order by and the Commission’s 
rules and policies.  Any grant of these applications shall exclude the 28.35-29.1 GHz band from the 
licenses in question.
17. IT IS FURTHER ORDERED, pursuant to Section 4(i) of the Communications Act of 
1934, as amended, 47 U.S.C. § 154(i), and Sections 1.1200 and 1.1208 of the Commission Rules, 47 
C.F.R. §§ 1.1200 and 1.1208, that the Request to Modify Ex Parte Status to Permit-But-Disclose, filed by 
Hughes Network Systems, LLC and DIRECTV Enterprises, LLC on April 11, 2011 IS DENIED.  
18. These actions are taken under delegated authority pursuant to Sections 0.131 and 0.331 of 
the Commission’s Rules, 47 C.F.R. §§ 0.131, 0.331. 
FEDERAL COMMUNICATIONS COMMISSION
Blaise A. Scinto
Chief, Broadband Division
Wireless Telecommunications Bureau
Federal Communications Commission DA 11-1650
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APPENDIX
File Number Call Sign Licensee Date Filed Accepted 
for Filing
Date 
Comments 
Filed
Comm
ents 
Timely
?
0004233156 KGC79 Verizon Washington D C 
Inc.
5/4/2010 5/12/2010 8/4/2010 No
0004233190 KEB29 Verizon New York, Inc. 5/4/2010 5/12/2010 8/4/2010 No
0004244291 KME49 AT&T California 5/12/2010 5/19/2010 8/4/2010 No
0004248651 KMQ44 AT&T California 5/14/2010 5/26/2010 8/4/2010 No
0004255375 KIP50 Verizon Virginia Inc. 5/21/2010 5/26/2010 8/4/2010 No
0004258994 KEB35 Verizon New Jersey Inc. 5/25/2010 6/2/2010 8/4/2010 No
0004264280 KSA96 Illinois Bell Telephone 
Company
5/28/2010 6/2/2010 8/4/2010 No
0004276706 KQH74 Michigan Bell Telephone 6/9/2010 6/16/2010 8/4/2010 No
0004295256 KGB74 Verizon Pennsylvania, 
Inc.
6/22/2010 6/30/2010 7/30/2010 Yes
0004295232 KGB72 Verizon Maryland Inc. 6/22/2010 6/30/2010 7/30/2010 Yes
0004295944 KIL20 BellSouth 
Telecommunications, Inc.
6/23/2010 6/30/2010 7/30/2010 Yes
0004295948 KZS88 BellSouth 
Telecommunications, Inc.
6/23/2010 6/30/2010 7/30/2010 Yes
0004319746 KQH73 Frontier West Virginia, 
Inc.
7/12/2010 7/21/2010 8/19/2010 Yes
0004320246 KQG58 Ohio Bell Telephone 
Company
7/12/2010 7/21/2010 8/19/2010 Yes
0004320258 KSE73 Wisconsin Bell Inc. 7/12/2010 7/21/2010 8/19/2010 Yes
0004321335 KGG34 Verizon Delaware, Inc. 7/13/2010 7/21/2010 8/19/2010 Yes
0004523906 WSL69 Alascom, Inc. 12/6/2010 12/15/2010 1/14/2011 Yes
0004562030 KYJ33 GTE Southwest Inc. dba 
Verizon Southwest
1/6/2011 1/12/2011 1/14/2011 Yes
0004575228 WAX78 Verizon California Inc. 1/18/2011 1/26/2011 2/24/2011 Yes
0004576055 WMK817 Information Super Station, 
LLC
1/18/2011 1/26/2011 2/24/2011 Yes
0004587843 WMP367 ACS Wireless License 
Sub, Inc.
1/25/2011 2/02/2011 2/24/2011 Yes
0004590012 KVH83 Hawaiian Telecom, Inc. 1/26/2011 2/02/2011 2/24/2011 Yes
0004596696 WLT380 M.U.T. Licensing, LLC 1/31/2011 2/09/2011 2/24/2011 Yes