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April 15, 2021

Filled Via ECFS

Marlene H. Dortch Secretary Federal Communications Commission 45 L Street NE Washington, DC 20554

Subject: Relocation Coordinator – Quarterly Status Report (Q4 2020), GN Docket Nos. 18-122 and 20-173.

Dear Ms. Dortch:

In accordance with the Expanding Flexible Use of the 3.7 to 4.2 GHz Band proceeding1, RSM US LLP as

Relocation Coordinator hereby submits its quarterly report on the progress in clearing the lower 300 MHz

portion of the conventional C-band (3.7-4.0 GHz) for space station operations in the contiguous United States

(CONUS) and repacking services into the upper 200 MHz of the conventional C-band (4.0-4.2 GHz).

The Relocation coordinator quarterly report provides summarized updates of space station operator progress

made against all areas of their Transition Plans along with the findings and progress of assigning earth stations

not yet included in a Transition Plan. The space station operators have not reported any information to the RC

indicating that they are not on schedule to meet their Phase I milestones to clear 120 MHz of the C-band

spectrum in 46 PEAs and make 100 MHz available for new 5G users by December 5, 2021.

The Relocation Coordinator team welcomes continued engagement with all C-band stakeholders, along with

the FCC, for a timely transition of the 3.7-4.2 GHz band. Please contact the undersigned with any questions

regarding this matter.

Respectfully Submitted,

Relocation Coordinator Andrew C Ely Principal, RSM US LLP 213 330 4665

1 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Report and Order and Proposed Modification, 35 FCC Rcd

2343, 2450-52 (2020) (3.7 GHz Report and Order).

Page 1 of 14Page 1 of 14

3.7- 4.2 GHz Band Transition Quarterly Status Report

January 1, 2021 to March 31, 2021

Relocation Coordinator April 15, 2021

TABLE OF CONTENTS

1. Introduction ......................................................................................................................................... 1

2. Executive Summary ............................................................................................................................ 2

Executive Summary – Schedule Risk ............................................................................................... 2

3. Overall Transition Schedule Progress .............................................................................................. 3

Satellite Manufacture and Launch ..................................................................................................... 4

Satellite Service Migration ................................................................................................................. 4

Technology Upgrades ......................................................................................................................... 4

Equipment Delivery for Lump Sum Electors.................................................................................. 5

Earth Station Migration ....................................................................................................................... 5

PEA Progress ................................................................................................................................ 5

Unclaimed Earth Stations .............................................................................................................. 7

Unclaimed Temporary Fixed Earth Stations.................................................................................. 8

TT&C Gateway Consolidation ............................................................................................................ 9

Brewster Teleport (Intelsat) ........................................................................................................... 9

Paumalu Teleport (Intelsat) ........................................................................................................... 9

Andover Teleport (Intelsat) ............................................................................................................ 9

Latin America Teleport (Intelsat) ................................................................................................... 9

Hartebeesthoek, South Africa Teleport (Intelsat) .......................................................................... 9

TT&C Antennas (Intelsat) .............................................................................................................. 9

Hawley Teleport (SES) ................................................................................................................ 10

Brewster Teleport (SES).............................................................................................................. 10

4. Overall Transition Cost Summary ................................................................................................... 10

5. Overall Transition Schedule Risks and Issues .............................................................................. 10

6. Overall Disputes Resolution Status ................................................................................................ 11

Exhibit A - PEA Progress

Exhibit B - Unclaimed Earth Station Status

Exhibit C - Unclaimed Incumbent Earth Station List

Exhibit D - List of FCC Incumbent Earth Stations (with ESIDs)

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1. Introduction In accordance with the Expanding Flexible Use of the 3.7 to 4.2 GHz Band proceeding1 (3.7 GHz Report and Order), the Relocation Coordinator (RC) will ensure all incumbent space station operators are relocating in a timely manner based on the Accelerated Relocation Deadlines agreed upon by the electing eligible space station operators – Embratel2, Eutelsat, Intelsat, SES and Telesat. According to the 3.7 GHz Report and Order, in paragraph 171, “In order to satisfy the Phase I Accelerated Relocation Deadline, a space station operator must repack any existing services and relocate associated incumbent earth stations throughout the contiguous United States into the upper 380 megahertz of the C-band (3820-4200 MHz) and must also provide passband filters to block signals from the 3700-3820 MHz band to associated incumbent earth stations in 46 of the top 50 PEAs by December 5, 2021. To satisfy the Phase II Accelerated Relocation Deadline, a space station operator must repack any existing service and relocate associated incumbent earth stations throughout the contiguous United States into the upper 200 megahertz of the C-band (4.0- 4.2 GHz), and provide passband filters to block signals from the 3700-4000 MHz band to all associated incumbent earth stations in the contiguous United States by December 5, 2023.” On September 25, 2020, the Federal Communications Commission (FCC) announced the selection of RSM US LLP to serve as the RC for the 3.7 to 4.2 GHz band transition3. The RC has been contracted jointly by the space station operators to:

Coordinate the schedule for clearing the band

Perform engineering analysis, as necessary, to determine necessary earth station migration actions

Assign obligations, as necessary, for earth station migrations and filtering

Coordinate with overlay licensees throughout the transition process

Assess the completion of the transition in each Partial Economic Area (PEA) and determine overlay licensees’ ability to commence operations

Mediate scheduling disputes

To the extent that incumbent earth stations1 are unaccounted for in a space station operator Transition Plan, the RC must prepare an Earth Station Transition Plan for such incumbent earth stations. On a quarterly basis, the RC will report on the overall transition status for each PEA – inclusive of the space station operator Transition Plan progress, Earth Station Transition Plan progress (if any), excluding earth stations opting for a lump-sum payment in lieu of inclusion in any of the Transition Plans. This quarterly status report provides summarized updates of our understanding of the progress reported by space station operators against all areas of their Transition Plans. Our report also includes activities performed by the RC team, including progress made to reconcile unassigned incumbent earth stations. The RC welcomes continued engagement with all 3.7 GHz Transition stakeholders, along with the FCC, for a timely transition of the 3.7-4.2 GHz band. This report does not constitute legal or investment advice, a fairness or solvency opinion, an estimate of value, an audit, a review of internal controls, an accounting or tax opinion, or other attestation or review services in accordance with the standards of the AICPA, the Public Company Accounting Oversight Board or any other professional or regulatory body. Our work should not be relied upon to disclose errors, irregularities or illegal acts, including fraud or defalcations. Further, we have no responsibility to update this quarter’s report for events or circumstances occurring beyond the space station operators’ March 2021

1 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Report and Order and Proposed Modification, 35 FCC Rcd 2343, 2450-52 (2020) (3.7 GHz Report and Order). 2 Embratel, formerly known as both Claro S.A. and Star One S.A. (“Embratel”), continues to expect that the Star One C1 satellite used to provide 3.7 GHz Transition service to earth station customers located in Florida will be taken out of service in mid-2021. In anticipation of this retirement, Embratel agreed with SES to provide 3.7 GHz Transition services using available capacity on its SES-4 satellite, specifically a 6 MHz channel located above 4000 MHz, which will enable Embratel to transition its users out of the lower 300 MHz of 3.7 GHz Transition spectrum. 3 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Order, DA 20-1133, GN Docket No. 18-122 (rel. Sep. 25, 2020), available at https://ecfsapi.fcc.gov/file/0925061967809/DA-20-1133A1.pdf.

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reports and the RC’s report submitted on April 15, 2021. The RC will continue to submit updates from the previous quarter in the next quarter’s report.

2. Executive Summary The executive summary section summarizes the RC transition activities undertaken between January 1, 2021 and March 31, 2021. Our summary of such activities is provided below:

The space station operator March 2021 quarterly4 reports were reviewed, and no material issues or deficiencies were identified. Telemetry, Tracking and Command (TT&C) consolidation, satellite build and launch, re-grooming and customer service migration activities appear to be on schedule. No major delays to Phase I and Phase II schedules have been identified in the space station operator Transition Plans.

The RC completed outreach to over 400 incumbent earth stations not included in a space station

operator Transition Plan, to ensure applicable antennas are included in the transition efforts.

The RC worked closely with the FCC, the space station operators and industry trade associations to contact earth station operators. The efforts resulted in over 80% of the unclaimed earth stations being proposed to the space station operators and subsequently being claimed. The few remaining unassigned incumbent earth stations are planned to be added to space station operator Transition Plans by mid-May.

The RC filed an ex-parte on January 14, 2021 to provide the FCC with joint findings from the space

station operator and RC outreach efforts on the consolidated inactive and unresponsive earth stations. On January 19, 2021, the FCC published a Public Notice, asking earth stations listed in the RC ex parte

to submit a filing to the FCC no later than April 19, 2021, affirming the continued operation of the identified earth station antennas and the intent to participate in the C-band transition. The RC team is currently monitoring the ECFS site to capture responses and the findings are coordinated on weekly basis with space station operators and the FCC to determine next steps.

The RC worked closely with the temporary fixed earth station (TFE) operators and the space station

operators to incorporate TFEs into space station operator Transition Plans.

The RC received no disputes requiring mediation by the FCC or the RC this quarter. The transition disputes process was initiated to facilitate the resolution of scheduling disputes and to collect information on facilities, workmanship and preservation of service disputes for the FCC. The process and website have been refined in coordination with the FCC. The site has been published via ex-parte.

The RC held initial conversations with some of the auction winners on overall transition progress.

Executive Summary – Schedule Risk The schedule risk subsection summarizes transition schedule risks identified by the RC from transition activities undertaken between January 1, 2021 and March 31, 2021. Our summary of such risks is provided below:

During the quarter, the RC notified the FCC and the space station operator of a Phase I schedule risk related to fewer than 20 unclaimed TFE transitions. The risk has been escalated to the FCC for guidance and all space station operators are actively engaged. The RC is facilitating discussions between the operators in order for all parties to jointly agree upon a TFE transition plan and mitigate the schedule risk.

Beyond the above identified risk, the space station operators have not reported any information to the RC indicating that they are not on schedule to meet their Phase I milestones to clear 120 MHz of the C-band

4 Individual space station operators’ reporting period may have ended prior to March 31, 2021

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spectrum in 46 PEAs and make 100 MHz available for new 5G users by December 5, 2021. Any identified and reported schedule risks or issues appear to have mitigation plans in place.

3. Overall Transition Schedule Progress The overall transition schedule progress section includes summarized information provided by the space station operators via their March 2021 quarterly status reports and includes information from RC activities. The satellite manufacture and launch, service migration, technology upgrades and PEA progress, as well as the TT&C/Gateway consolidation summarized subsections, were generated with data and information provided by the space station operators reports5, that can be found here: Embratel, Eutelsat, Intelsat, SES, and Telesat. Phase I transition activities appear to be progressing according to the timelines indicated in the space station operator Transition Plans. Service migration and technology upgrade activities are expected to complete in calendar year (CY) 2021, quarter (Q) 2, while filter installations in and around 46 of the top 50 PEAs are expected to complete in CY2021 Q4. TT&C/Gateway consolidation and satellite manufacture design review activities are expected to be complete by CY2021 Q4. Figure 16 below provides a timeline view of Phase I transition activities.

Figure 1: Phase I Timeline Progress

Phase II transition activities appear to be progressing according to the schedule provided in the Transition Plans. Phase II transition activities include service migration, technology upgrades, filter installations, TT&C/Gateway consolidation and satellite build and launches. Space station operators reported that some Phase II activities are underway, and each have reported confidence in completing all Phase II activities ahead of the deadline.

5 Individual space station operators’ reporting period may have ended prior to March 31, 2021. 6 The Relocation Coordinator developed the timeline by aggregating the space station operator Transition Plan schedules and does not have control or management of these milestones.

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Satellite Manufacture and Launch The Intelsat and SES Transition Plans7 include programs for the replacement and launch of new satellites. Based on the March 2021 quarterly status reports submitted by the space station operators, satellite manufacturing and launch are progressing as set out in the Transition Plans. The majority of critical design reviews appear to be complete, while the remaining are scheduled to complete in the remainder of CY2021. The space station operators indicated that they continue to maintain focus on the potential impact of COVID-19 on supply chains and expect the satellites to be in service within the established deadlines.

Satellite Service Migration Based on the March 2021 quarterly status reports submitted by the space station operators, satellite service migrations appear to be progressing as set out in the Transition Plans. Minor changes were required to the customer migration plans to account for new services or the removal of terminated services, none of which affects the overall transition timeline. All space station operators expect to complete service migrations within the timelines outlined in the Transition Plans. The March 2021 quarterly status reports provided current satellite service migration milestone dates and status. The reported dates and status are summarized below in Table 1, with projected completion no later than the quarter (Q) presented by calendar year (CY).

Table 1: Overview of Service Migration Reported Milestones and Status

Overall Service Migration Reported Milestones and Status

Space Station

Operator

Phase I (No later than)

Phase I Status

Phase II (No later than)

Phase II Status

Embratel CY2021 Q3 On schedule CY2021 Q3 On schedule

Eutelsat CY2021 Q2 On schedule CY2021 Q4 On schedule

Intelsat CY2021 Q4 On schedule CY2023 Q4 On schedule

SES CY2021 Q3 On schedule CY2023 Q3 On schedule

Telesat CY2021 Q1 Complete CY2021 Q1 Complete

Technology Upgrades Based on the March 2021 quarterly status reports submitted by the space station operators, technology upgrades appear to be progressing as set out in the Transition Plans. Space station operators8 indicated that they are currently implementing plans for effectively consolidating services through compression technologies and the installation of encoding and modulation equipment. Phase I compression equipment shipments appear to be proceeding on schedule with the last outstanding items expected to be shipped at the end of April 2021. Equipment installation, configuration and testing appear to be proceeding. To date, space station operators indicated that some transitions to the new technology have occurred, and the remaining transitions will take place in the second quarter of CY2021. They also indicated that some of Phase II equipment has been ordered in time for necessary Phase II transitions. The space station operators indicated that technology upgrades for both Phase I and Phase II will be completed within the established timelines.

Table 2: Overview of Technology Upgrades Reported Milestones and Status

Overall Technology Upgrades Reported Milestones and Status

Space Station

Operator Phase I

(No later than) Phase I Status Phase II

(No later than) Phase II Status

Intelsat CY2021 Q2 On schedule CY2023 Q2 On schedule

SES CY2021 Q2 On schedule CY2023 Q2 On schedule

7 For Eutelsat, Telesat and Embratel, there are no satellite manufacture and launch programs. 8 For Eutelsat, Telesat and Embratel, there are no fixed earth stations necessitating technology upgrades.

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Equipment Delivery for Lump Sum Electors

The space station operators indicated in their quarterly status reports that they continue to provide technology upgrade equipment to those earth stations that elected to take a lump sum payment for transition activities. SES indicated that, IRD equipment was shipped directly to and has been received by those earth station operators that elected to receive a lump sum relocation payment and chose to receive compressed content. Intelsat indicated that all Phase I equipment will be installed by May 31, 2021 and affirmed that it was shipping equipment to earth stations based on availability of site needs and without discrimination for lump sum election status. The space station operators indicated that they continue to provide transition updates to the lump sum electing earth stations through various communication means, including transition update presentations provided to numerous industry trade associations. The space station operators also have websites, phone lines and emails dedicated to the transition activities, where they are able to communicate with stakeholders in the transition.

Earth Station Migration Based on the March 2021 quarterly status reports, some space station operators indicated that they have started installing passband filters at those incumbent earth stations where all the received services have been migrated (or already reside) above 3820 MHz or 4000 MHz as the case may be. Based on the progress made to date, the earth station transition and remediation work appears to be progressing as set out in the Transition Plans.

PEA Progress The majority of the Phase I passband filter installations on antennas is planned for the second and third calendar quarters of 2021. Exhibit A reports the transition progress for the individual PEAs through March 2021 based on completion status information provided by the space station operators via the quarterly status reports. The following tables provide a summary of the transition progress:

Table 3: Overview of the PEA Schedule Progress

Overall Transition Schedule Progress

Phase I Deadline Phase II Deadline

On schedule with no issues reported. On schedule with no issues reported.

Table 4: Overview of Migrated Earth Stations by Phase

Overall Earth Station Migration Progress

Transition Phase

Number of PEAs

Total Number of Incumbent Earth Stations9

(Excluding Lump Sum Electors)

Reported Number of Migrated Incumbent

Earth Stations (Excluding Lump Sum

Electors)

Phase I 46 2,266 64

Phase II 358 3,609 48

9 An incumbent earth station correlates to one record (i.e. row) within the FCC’s Updated List of Incumbent Earth Stations.

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The following figure illustrates the PEA progress as of March 2021. The PEA progress is based on the space station operators completion status reporting, which excludes lump sum electors:

Figure 2: Phase I Top 46 of 50 PEAs by PEA Number

Table 5: Phase I Top 46 of 50 PEAs by PEA Number and Name

Phase I Top 46 of 50 PEAs by PEA Number and Name

PEA # PEA Name

PEA # PEA Name

PEA # PEA Name

PEA # PEA Name

1 New York, NY 15 Phoenix, AZ 28 San Antonio, TX 40 Birmingham, AL

2 Los Angeles, CA 16 Seattle, WA 29 Jacksonville, FL 41 Syracuse, NY

3 Chicago, IL 17 Minneapolis – St. Paul, MN

30 Kansas City, MO 43 Charlotte, NC

4 San Francisco, CA 18 San Diego, CA 31 Indianapolis, IN 44 Rochester, NY

6 Philadelphia, PA 19 Portland, OR 32 Nashville, TN 45 Raleigh, NC

7 Boston, MA 21 Tampa, FL 33 Virginia Beach, VA 46 Little Rock, AR

8 Dallas, TX 22 Sacramento, CA 34 Fresno, CA 47 Brownsville, TX

9 Miami, FL 23 Pittsburg, PA 35 Austin, TX 48 Harrisburg, PA

10 Houston, TX 24 St. Louis, MO 36 New Orleans, LA 49 Albany, NY

12 Detroit, MI 25 Cincinnati, OH 37 Columbus, OH 50 Greenville, SC

13 Orlando, FL 26 Las Vegas, NV 38 Milwaukee, WI

14 Cleveland, OH 27 Salt Lake City, UT 39 Oklahoma City, OK

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Unclaimed Earth Stations The unclaimed earth stations are earth stations found in the FCC Incumbent Earth Station List10 that have not taken a lump sum payment, and that are not included in a space station operator Transition Plan. The space station operators continued conducting extensive outreach to inform their Transition Plans regarding incumbent earth stations receiving their services. Once determined that an earth station is receiving services from one of their satellites, the space station operator claims the earth station in their Transition Plan and becomes responsible for ensuring the earth station is transitioned out of the 3.7 to 4.0 GHz band in the appropriate phase. During this quarter, the RC reviewed updated lists of earth stations claimed by the space station operators. These lists of claimed earth stations were compared to the FCC Incumbent Earth Station List to generate an Unclaimed Earth Stations List. This unclaimed reconciliation process occurred on a weekly basis and will continue into next quarter. The RC has continued engagement with unclaimed earth station operators to determine which services and programming they receive and through which satellite(s). The information gathered assists the RC to recommend an incumbent earth station to be associated with a particular space station operator Transition Plan. This quarter’s outreach activities focused mostly on phone calls and emails; previously, outreach efforts also included delivery of certified letters. Additionally, the RC collaborated with the FCC International Bureau (IB) to conduct outreach for hard to reach sites. In an effort to reach as many earth stations as possible, the RC posted an ex parte with incumbent earth station records the team was unable to reach via outreach activities. This ex-parte filing also indicated potentially inactive incumbent earth stations. The ex-parte was followed by a Public Notice from the FCC IB requesting any corrections or responses no later than April 19, 2021. The RC outreach findings appear in Exhibit B of this report. Additionally, a summary of the outreach metrics based on claimed and unclaimed earth stations are shown in Figures 3 and 4. The overall number of active unclaimed earth stations decreases each month, while there is an increase in the total number of claimed and/or inactive earth stations (included in the assigned earth stations category). The RC works closely with the FCC IB to resolve data issues or questions requiring escalation prior to recommending an earth station for inclusion in a Transition Plan. The Statuses in the graphs are defined below for reference.

Table 6: Status and Description References for Figure 3 & 4

Status and Description References for Figure 3 & 4

Statuses in figure 3 & 4 Description

Assigned for Transition:

These earth stations include applicants who have already been incorporated into a space station operator’s Transition Plan. Also included in this figure are earth stations who have been confirmed as inactive by the space station operators and RC and will not be participating in the transition.

To Be Assigned – Pending Coordination with FCC:

These earth stations include applicants where the RC is working closely with the FCC International Bureau to reconcile the incumbent earth station data. For example, these earth stations may include applicants which should have been classified as a lump sum election on the December 3rd 2020 (DA-20-1448A2) Updated Incumbent C-Band Earth Station List.

To Be Assigned – Pending RC Outreach

These earth stations include sites that the RC has confirmed as active but require further investigation to identify the affiliated space station operator. Also included in this figure are earth stations where the RC has received information to connect the earth stations with a space station operator, but have not yet been incorporated into a Transition Plan.

10 International Bureau Releases Updated List of Incumbent Earth Stations in the 3.7-4.2 GHz Band in the Contiguous United States, Public Notice, DA 20-1424, IB Docket No. 20-205 (rel. Nov. 30, 2020), available at https://www.fcc.gov/document/erratum-november-30-2020-incumbent-earth-station-list-37-ghz.

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Figure 3: Incumbent Earth Station Outreach Metrics (excluding Lump Sum)

Figure 4: Active Unclaimed Earth Station

The RC will continue outreach efforts to ensure all unclaimed incumbent earth stations are claimed by the appropriate space station operator no later than CY2021 Q2. The RC is also keeping track of steerable and multi-feed antennas so they may be effectively allocated to the appropriate space station operator(s). A list of all unclaimed earth stations, with corresponding information from the FCC’s latest Incumbent Earth Station List, are presented in Exhibit C. A unique earth station identifier (ESID) was applied to each record, in consultation with the space station operators, to provide ease of corroboration amongst the space station operators and the RC. Exhibit D provides the complete FCC Incumbent Earth Station List to reference the ESID for each row.

Unclaimed Temporary Fixed Earth Stations This quarter, the RC worked closely with TFE operators to understand the unique transition requirements. This information was presented to the space station operators to inform the overall unclaimed reconciliation process. During the quarter, the RC notified the FCC and the space station operator of a Phase I schedule risk related to fewer than 20 unclaimed TFE transitions. The risk has been escalated to the FCC for guidance

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and all space station operators are actively engaged. The RC is facilitating discussions between the operators in order for all parties to jointly agree upon a TFE transition plan and mitigate the schedule risk.

TT&C Gateway Consolidation The Intelsat and SES Transition Plans11 include the consolidation of TT&C Gateway facilities. While space station operators continue to work on their entire TT&C Gateway consolidation plans, Intelsat’s Phase I focus is on consolidation of west coast facilities, while SES’s Phase I focus is on consolidating east coast facilities at their Hawley, PA gateway location. Applicable civil works and foundations necessary to support new Phase I antennas appear to be underway and appear to be progressing as scheduled. Based on the March 2021 quarterly status reports submitted by the space station operators, construction and upgrades of the TT&C Gateway facilities appears to be on schedule to meet the Phase I and II deadlines. TT&C Gateway activities necessary to support Phase I appear to be progressing on or ahead of schedule. Service transitions required of Phase I will likely be completed within the timelines required by the 3.7 GHz Report and Order. Phase II activities appear to be proceeding as set out in the Transition Plans. According to the March 2021 space station operator status reports, new antennas required for Phase II were ordered, and the antenna vendors have committed to a construction schedule. Analysis and planning for much of the Phase II activities appear to have completed in 2020. Site design of the locations to host the new antennas appear to be either in the final stages or are expected to commence in the first half of 2021.

Brewster Teleport (Intelsat) Considered a Phase I activity, installation of the seven antennas is expected to be complete in June 2021. The installation and integration of the required radiofrequency (RF) equipment associated with each antenna is progressing as planned.

Paumalu Teleport (Intelsat) Considered a Phase I activity, the schedules for the two new antenna builds and the two antenna upgrades are progressing as planned for a July 2021 readiness.

Andover Teleport (Intelsat) Considered a Phase II activity, six antennas set out in the Transition Plans for the Andover teleport have been ordered, and the final site design work is completed, with construction beginning in the spring of 2021. The antenna vendors have committed to the installation schedule to commence in the third quarter of CY2021.

Latin America Teleport (Intelsat) Intelsat expects to begin outreach to potential teleport operators in the region during the first half of CY2021.

Hartebeesthoek Teleport South Africa (Intelsat) Site evaluation started in Q4 2020 and continues, while design and procurement activities are expected to commence in the first half of CY2021.

TT&C Antennas (Intelsat) According to Intelsat’s March 2021 quarterly status report, additional TT&C activities to support the Galaxy satellites required for transition activities include the upgrade or new build of a total of seven antennas at three sites supporting seven satellites. Design and procurement activities, prioritized to support launch schedule, will begin in the second quarter of CY2021.

11 Eutelsat, Telesat and Embratel have no requirements nor plans to construct new TT&C facilities in CONUS in order to complete the transition.

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Hawley Teleport (SES) The gateway antennas and associated infrastructure to support the Phase I C-Band migration are on schedule. Phase II migration planning is underway. Delivery of the full motion TT&C antenna is expected by end-of March 2021, with enough time to support the operational date.

Brewster Teleport (SES) A full motion TT&C antenna has been installed. SES awaits state approval on shelter plans before finalizing and delivering equipment shelter to the site. All communications equipment is on site and ready to integrate once the shelter is complete. Full operation of the antenna and shelter will be available in time for the needed purpose.

4. Overall Transition Cost Summary The overall transition cost summary section provides cost estimate summary information based on the March 2021 quarterly status reports submitted by the space station operators. The cost estimates appear to remain in line with the Transition Plans with the exception of the changes reflected in red below.

Table 7: Summary of Space Station Operator Reported Cost Estimates

Space Station Operator Reported Cost Estimates

Space Station Operator

Previous Quarter Reported Cost Estimate

Current Quarter Reported Cost Estimate

Change from Previous Quarter

Embratel12 None filed None filed Not applicable

Eutelsat $12,162,069.50 $4,529,600.00 ($7,632,469.50)13

Intelsat $1,640,000,000 $1,640,000,000 None

SES $1,616,710,000 $1,616,710,000 None

Telesat $166,900 - $232,200 $166,900 - $232,200 None

5. Overall Transition Schedule Risks and Issues The overall transition schedule risks and issues section highlights transition risks and issues reported by the space station operators. In their March 2021 quarterly status reports, the space station operators indicated that they continue to monitor any potential impact COVID-19 may have on supply chains for equipment procurement, personnel availability and on-site installation schedules. The space station operators have also reported mitigation strategies utilized to address COVID-19 impacts. During the quarter, the RC notified the FCC and the space station operator of a Phase I schedule risk related to fewer than 20 unclaimed TFE transitions. The risk has been escalated to the FCC for guidance and all space station operators are actively engaged. The RC is facilitating discussions between the operators in order for all parties to jointly agree upon a TFE transition plan and mitigate the schedule risk. The RC will continue to monitor any potential delays that could affect the transition schedule integrity for Phase I and II deadlines.

12 Based on the August 14, 2020 Transition Plan, Embratel, formerly known as both Claro S.A. and Star One S.A. (“Embratel”), will incur costs for the 3.7 - 4.2 GHz Transition, and Embratel does not anticipate requesting reimbursement of those costs. 13 Eutelsat reported a change in transition cost estimates as a result of the reduced number of earth stations to be transitioned.

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6. Overall Disputes Resolution Status The overall disputes resolution section provides a brief overview, as well as summary information related to the disputes process. The 3.7 GHz Report and Order states that the RC is “responsible for receiving notice from earth station operators or other satellite customers of any disputes related to comparability of facilities, workmanship or preservation of service during the transition and shall subsequently notify the Wireless Telecommunications Bureau of the dispute and provide recommendation for resolution” and “mediating scheduling disputes.14” The RC can now receive notice of any disputes that may exist for the transition at the following web address: https://response.rsmus.com/RCmediationresolutionnotification. The RC received no disputes requiring mediation by the FCC or the RC this quarter. A summary of disputes reported and resolved as of March 31, 2021 is listed in the table below:

Table 8: Summary of Dispute Status

Overall Disputes Resolution Progress

Dispute ID

Dispute Type

Dispute Referral Date Disputing Parties Dispute Status

None None None None None

This concludes the RC’s quarterly status report for the period of January 1st, 2021 to March 31, 2021. The RC looks forward to continued coordination with the incumbent earth station operators, space station operators and the FCC to ensure all earth stations are properly transitioned.

14 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Report and Order and Proposed Modification, 35 FCC Rcd 2343, 2450-52 (2020) (3.7 GHz Report and Order), ¶ 309, ¶ 314.

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