LMI Advisors LLC 2550 M Street, NW Suite 320 Washington, D.C. 20037 Carlos M. Nalda T +1 571 332 5626 cnalda@lmiadvisors.com

June 30, 2021 Marlene H. Dortch, Secretary Federal Communications Commission 45 L Street, N.E. Washington, D.C. 20554

Re: Eutelsat S.A., Quarterly Status Report, GN Docket Nos. 18-122 and 20-173 Dear Ms. Dortch:

On behalf of Eutelsat S.A. and its affiliates (collectively, “Eutelsat”), and pursuant to Section 27.1412(f) of the Commission’s rules, 47 C.F.R. § 27.1412(f), I am pleased to submit the attached “C-band Transition Quarterly Status Report,” dated June 30, 2021.

Eutelsat’s approach is described in its “Updated Revised Transition Plan,” previously filed in these dockets, as well as its previous quarterly reports.1 The current Report describes Eutelsat’s progress in clearing C-band downlink (3.7-4.0 GHz) spectrum over the past three months and also summarizes the most recent updates to Eutelsat’s list of claimed earth stations and projected relocation costs.2 Eutelsat expects to include more detail concerning these matters in a further revision to its Transition Plan, which is due to be filed with the Commission by July 7, 2021.3

Please do not hesitate to contact me with any questions regarding this matter.

Respectfully submitted,

Carlos M. Nalda for Eutelsat S.A.

1 Eutelsat S.A., “Updated Revised Transition Plan,” GN Docket Nos. 18-122 and 20-173 (filed Oct. 28,

2020); Letter from Wladimir Bocquet, Eutelsat S.A. and Carlos Nalda, LMI Advisors LLC, GN Docket Nos. 18-122 and 20-173 (filed Dec. 31, 2020); Letter from Wladimir Bocquet, Eutelsat S.A. and Carlos Nalda, LMI Advisors LLC, GN Docket Nos. 18-122 and 20-173 (filed March 31, 2021). This work is also proceeding in a manner consistent with the latest quarterly report filed in April 2021 by RSM US LLP, the C-band Relocation Coordinator, see Letter from Andrew C. Ely, RSM US LLP, GN Docket Nos. 18-122 (filed Apr. 15, 2021), and attachments.

2 See, e.g., Public Notice, “International Bureau Releases Updated List of Incumbent Earth Stations in the 3.7-4.2 GHz Band in the Contiguous United States,” IB Docket No. 20-205, GN Docket No. 20-305, DA 21-731 (Int. Bur., rel. June 22, 2021).

3 Public Notic, “Wireless Telecommunications Bureau Opens Window for Eligible C-Band Satellite Operators to Account for Updates in Their Transition Plans,” GN Docket Nos. 18-122 and 20-173, DA 21-736 (Wir. Tel. Bur., rel. June 23, 2021).

C-BAND TRANSITION

QUARTERLY STATUS REPORT

June 30, 2021

2

1.TRANSITION PLAN SNAPSHOT

33

C-BAND TRANSITIONPlan SnapshotEutelsat C-Band transition involves four space stations (E113WA, E115WB, E117WA & E172) to be transitioned to operations above 4.0 GHz. FAA Wide Area Augmentation System (“WAAS”) involving two earth station antennas utilizes a fifth satellite (E117WB)

Transition plan relies on more complete utilization of Eutelsat’s C-band transponders in the 4.0-4.2 GHz band enabling a reduction in the total number of transponders used in serving CONUS customers (current content migration is described in slide 5 and 6).

No new C-band satellite launches required.

No earth station technology upgrades (including compression, encoding, or modulation equipment) required for full time services.

Initial outreach to all earth station operators is complete. 48 incumbent earth station antennas served by Eutelsat for Phase I and Phase II and needs Eutelsat intervention to be transitioned above 4.0 GHz. 39 of 48 transitions are now fully complete.

Additional earth station antenna systems may be added in a very short term as a result of the Eutelsat effort to identify potential Eutelsat feeds through IBFS research of all registered antennas.

Transition is now complete for two earth stations located in Southbury, CT and Santa Paula, CA that are part of the FAA’s WAAS program.

Services migration above 4.0GHz is 90% completed

The estimated budget is updated to approximately $6.5M, caused by the increase of number of antenna and other execution implementation costs

Targeting completion of transition of all 48 identified incumbent earth station antennas by August 2021.

4

2.CURRENT STATUS

5

RESHUFFLING PLAN: INITIAL SITUATION

1/2 3/4 5/6 7/8 9/10 11/12 13/14 15/16 17/18 19/20 21/22 23/24

1/2 3/4 5/6 5/6 7/8 7/8 9/10 9/10 11/12 11/12 13/14 13/14

1/2 3/4 5/6 7/8 9/10 11/12 13/14 15/16 17/18 19/20 21/22 23/24

Transponder

Transponder

Transponder

Transponder

E117WA(116.8°W)

E115WB(114.9°W)

E113WA(113.0°W)

E172B(172.0°E)

1/2 3/4 5/6 5/6 7/8 9/10 11/12

Possibly used withinCONUS

Services to be relocatedabove 4.0 GHz

3.70 – 4.00 GHz3.70 – 3.82 GHz

6

RESHUFFLING PLAN: CURRENT SITUATION

1/2 3/4 5/6 7/8 9/10 11/12 13/14 15/16 17/18 19/20 21/22 23/24

1/2 3/4 5/6 5/6 7/8 7/8 9/10 9/10 11/12 11/12 13/14 13/14

1/2 3/4 5/6 7/8 9/10 11/12 13/14 15/16 17/18 19/20 21/22 23/24

Transponder

Transponder

Transponder

Transponder

E117WA(116.8°W)

E115WB(114.9°W)

E113WA(113.0°W)

E172B(172.0°E)

1/2 3/4 5/6 5/6 7/8 9/10 11/12

Possibly used withinCONUS

Services to be relocatedabove 4.0 GHz3.70 – 4.00 GHz

3.70 – 3.82 GHz

Cleared in CONUS

Services migration above 4.0GHz is 90% completed. Finalization is expected in July 2021.

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•CommScope is serving as Project Management Lead for the Eutelsat transition efforts with a team based in the United States.

•List of earth station antennas requiring transition has been updated on a regular basis, in close coordination with the Relocation Coordinator.

•Eutelsat has performed extensive due diligence, as further described on the following slide, to identify earth station feeds which may be receiving content from Eutelsat satellites. To date, 12 antennas have been added to Eutelsat claims through these processes.

•Total current antenna count is 48. The antenna counts at each site associated with particular ESIDs, whether each antenna is potentially shared with other SSOs, and the current transition status.

Dual illumination plan has been implemented to allow for transition of earth station operators currently receiving content between 3700-4000 MHz.

•Eutelsat has sufficient filters on hand to address all transitions. No transition delays are expected due to filter procurement lead times.

•Estimated transition costs have been updated to approximately $6.5M, caused by the increase of number of antenna and other execution implementation costs

C-BAND TRANSITIONCurrent Status

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à Asked Relocation Coordinator to assist with finding any remaining feeds which may have not been identified and pointing to Eutelsat satellites. Worked with the RC through multiple discussions to determine possible methodology to uncover existing Eutelsat feeds.

à Coordinated with the Relocation Coordinator and other satellite operators to determine possible Eutelsat feeds which may have been identified during other outreach efforts.

à On 5/27/21, received list from Intelsat of 10 previously unidentified antennas that potentially had Eutelsat feeds. 7 of these were in Phase 1 markets. The status for all of these Phase 1 antennas has been confirmed and 4 have been added to Eutelsat claims.

à On 6/10/21, received list from SES of 9 previously unidentified antennas that appear to have Eutelsat feeds. 6 of these are in Phase 1 markets. The status for all of these Phase 1 antennas has been confirmed and 3 have been added to Eutelsat claims.

à Downloaded antenna manufacturer and model fields as well as contact information from the IBFS for all registered antennas. These data fields as well as Site ID and Antenna ID fields have been reviewed to identify any possible multi-feed antennas even if claimed by another satellite operator. A total of 154 antennas have been identified. Outreach has been initiated with focus on Phase 1 antennas. To date, 5 new Eutelsat claims have been added through this process and are being transitioned.

à Such extensive outreach efforts and coordination with different stakeholders will enable Eutelsat to complete the overall outreach of the earth station and feed receiving Eutelsat content. This is expected to be performed by 7/15/2021

à Still working to confirm a possible BFI Licenses, LLC antenna claim in Atlanta. The Relocation Coordinator had attempted to contact this incumbent to determine their status but was unable to reach the operator. Eutelsat is still attempting to reach the site contact to determine status and complete the transition if required.

EUTELSAT OUTREACH EFFORTSTaking All Steps Possible to Identify Eutelsat Claims

9

CURRENT LIST OF EARTH STATION ANTENNAS BY APPLICANT

Applicant NameQuantity of Antennas

Phase 1 Transition

Phase 2 Transition Applicant Name

Quantity of Antennas

Phase 1 Transition

Phase 2 Transition

Altice USA, Inc. 1 Complete Complete Golden Rain Foundation 1 Complete CompleteAzteca Broadcasting Corporation 1 Complete Complete Harpole Telecom, Inc. 1 Not Complete Not CompleteBonneville International Corporation 1 Complete Complete International Communications Network, Inc. 1 Complete CompleteBroadwater County 1 Complete Complete Kaplan Telephone Co Inc 1 Complete CompleteCebridge Acquisition, L.P. 1 Complete Complete LifeTalk Radio, Inc. 1 Complete CompleteComcast Cable Communications Management, LLC 8 Complete Complete MADISON COMMUNICATIONS, INC. 1 Complete CompleteCOMSAT, INC. 2 Complete Complete Michael J Diehl 1 Not Complete Not CompleteCSC TKR LLC (Parsippany) 1 Complete Complete Morris Broadband LLC 1 Complete CompleteCSC TKR LLC (Piscataway) 1 Not Complete Not Complete MTC Cable 1 Complete CompleteDenali 20020, LLC 3 Complete Complete Overon America 1 Complete CompleteDIRECTV Enterprises, LLC 3 Complete Complete Radio Vision Cristiana Management 2 Complete CompleteDIRECTV Enterprises, LLC 1 Not Complete Not Complete Radio Vision Cristiana Management 2 Not Complete Not CompleteESPN, Inc. 1 Not Complete Not Complete Suncoast Broadcasting of Lafayette County 1 Not Complete Not CompleteFirstlight Media US Holdings Inc. 2 Complete Complete Thompson Falls Tv District 1 Not Complete Not CompleteFrontier Communications Corporation, Debtor-in-Possession

4 Complete Complete X2nSat 1 Complete Complete

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3.PLANNED ACTIVITIES

1111

u Finalize scheduling and complete remaining transitions.

u Finalize outreach for list of antennas identified through Eutelsat’s IBFS research and due diligence in coordination with the Relocation Coordinator.

u For any potential new claims, determine need for and procure additional equipment, as required, including possible equipment replacement or hardware upgrades (ie. larger antenna), etc.

u Preparing cost-related documentation for submittal of claims to Clearinghouse

u Preparing certificate of completion for Phase I and Phase II

C-BAND TRANSITIONPlanned Activities

12

ESO Outreach

On-site/Virtual Site Audits

Equipment Procurement

SOW/BOM Development

Phase 1 Implementation

Phase 2 Implementation

Clearinghouse Submissions

C-BAND TRANSITIONProject Timeline

Feb 2021

Apr 2021

Jun 2021

Dec 2020

Aug 2021

Oct 2021

Dec 2021

Feb 2021

Apr 2021

Jun 2021

Dec 2020

Aug 2021

Oct 2021

Dec 2021

13

4.RISKS & ISSUES

1414

C-BAND TRANSITIONRisks & Issues

On-going outreach is underway to identify additional Eutelsat feeds. Eutelsat has performed extensive due diligence in this area internally and in coordination with the Relocation Coordinator and Space Station Operators. Eutelsat is confident that it can meet its schedule, but any new assignment may impact overall transition timeline.

Currently no filter procurement delays exist, but delay in procurement of other required materials (i.e. upgraded antennas, etc.) could impact overall transition timeline.

Unforeseen COVID-19 related delays in equipment procurement, site permitting, etc. could pose timeline risks.