Federal Communications Commission
Washington, D.C. 20554
July 27, 2015
DA 15-864
Mr. Adam Krinsky
2300 N Street, NW
Suite 700
Washington, DC 20037-1128
akrinsky@wbklaw.com
Call Sign:  E150095
File No.:  SES-LIC-20150616-00357
Dear Mr. Krinsky:
On June 16, 2015, Higher Ground LLC filed the above-captioned application for a 
license to operate 50,000 mobile earth terminals for consumer-based text messaging/light email 
and Internet of Things communications in the United States.  The application requested earth 
station communications with Permitted List satellites in the 5925-6425 (Earth-to-space) and 
3700-4200 MHz (space-to-Earth) frequency bands using a 0.07 meter antenna.  Pursuant to 
Section 25.112(a)(2), we dismiss the application in part as defective.
Section 25.112 of the Commission’s rules, 47 C.F.R. § 25.112, requires the Commission 
to return, as unacceptable for filing, any earth station application that does not substantially 
comply with the Commission’s rules.  The deficiency is as follows:
· Authorizations to communicate with Permitted List satellites may be granted only in 
cases where the earth station is eligible for “routine processing.”1 The requested earth 
stations do not meet the routine processing criteria specified in Section 25.212(d) of the 
Commission’s rules, 47 C.F.R. § 25.212(d).2
The narrative portion of the application specifically identifies three satellites that also are 
on the Permitted List:  Galaxy 3C at 95.05° W.L., Galaxy 12 at 129º W.L., and Galaxy 19 at 97° 
W.L.  Accordingly, we are dismissing the application insofar as it requests points of 
communication other than those three satellites. 
Though not a reason for partial dismissal please respond to the following:
  
1 See Amendment of the Commission's Regulatory Policies to Allow Non-U.S. Licensed Space Stations to 
Provide Domestic and International Services in the United States, IB Docket No. 96-111, First Order on 
Reconsideration, 15 FCC Rcd 7207 (1999), at 7213 ¶13).
2 The conventional C-band encompass the 5925-6425 MHz (Earth-to-space) and 3700-4200 MHz (space-
to-Earth) frequency bands.
 Federal Communications Commission                  DA 15-864 
2
1. Please provide a representative depiction of the SatPaq terminal in order to assist in 
analyzing the radiation hazard assessment.  
2. Please provide any test results supporting the effectiveness of using the ULS based fixed 
station location data and Higher Ground LLC SatPaq terminal operations logged by the 
remote control facilities.
3. Higher Ground LLC identified the SatPaq terminal class of station as a Mobile Earth 
Terminal (MET) in Item 25 of Form 312.  Although the application requests waiver of 
Note 6 to 47 C.F.R. § 101.147(a), which prohibits assignment of the 5925-6425 MHz 
band to mobile earth stations, we also note that the requested frequency bands are not 
allocated for mobile satellite service in the Table of Frequency Allocations of the 
Commission rules, Section 2.106, 47 C.F.R. §2.106.  See 47 C.F.R. §25.112 (a)(2).  
Please indicate whether Higher Ground also seeks waiver of this rule.
4. Please provide a 24/7 point of contact for resolution of any possible interference issues.
In light of the above, pursuant to Section 25.112(a) of the Commission’s rules, 47 C.F.R. 
§ 25.112(a) and Section 0.261 of the Commission’s rules on delegations of authority, 47 C.F.R. § 
0.261, we dismiss the application in part.  Please provide responses to the requests for 
information in this letter by August 28, 2015.
Sincerely,
Paul E. Blais
Chief, Systems Analysis Branch
Satellite Division
International Bureau