Narrative Statement

0048-EX-CM-2016 Text Documents

Astronics AeroSat Corporation

2016-10-03ELS_182770

                             Astronics AeroSat Corporation

                      Application to Modify Experimental License
                                   Call Sign: WH2XJQ
                               File No.: 0392-EX-RR-2016

         Astronics AeroSat Corporation (“Astronics AeroSat”) hereby seeks modifica tio n

of its existing experimental license, Call Sign WH2XJQ. Astronics AeroSat currently has

authority to test and demonstrate up to five (5) earth stations aboard aircraft (“ESAAs”) –

three (3) Astronics AeroSat HR6400 (otherwise known as the “F-Series” F-210) and two

(2) HR129 (otherwise known as the “T-Series” T-210) terminals - in the 14.0-14.5 GHz

band. 1 In the present application, Astronics AeroSat respectfully requests authority to

increase the total number of authorized ESAA terminals to twenty (20), ten (10) of each

terminal type, and add new satellite points of communication that reflect the range of

available satellite in the network that may be accessed by the terminals.    Experime nta l

testing and demonstration operations will continue to be conducted within the contiguo us

United States (“CONUS”) and adjacent international waters until October 1, 2017,

pursuant to the terms and conditions included in the subject experimental license, and will

support Astronics AeroSat’s continuing development of its ESAA terminals.

    I.      Background

    As the Commission is aware, the HR129 and HR6400 terminals comply fully with

Section 25.227 of the Commission’s Rules governing ESAAs, although the terminals will



1 See Astronics AeroSat Corporation, Call Sign WH2XJQ (various file numbers).
Astronics AeroSat notes that in a submission adding the HR129, the terminal was
inadvertently identified as the “HR123” terminal. See Letter to Nnake Nweke, Chief,
Experimental Licensing Branch, Astronics AeroSat Corporation, Call Sign WH2XJQ,
File No. 0579-EX-PL-2014; Addition of New Antenna Type for Experimental Testing and
Demonstration (filed on January 20, 2015).


be operated pursuant to limited testing and demonstration experimental authority.

Moreover, Astronics AeroSat acknowledges and accepts that the conditions in its existing

experimental license will continue to apply, including operating on an unprotected, non-

interference basis and adhering to requirement to immediately cease operations in the event

of harmful interference.    The HR129 and HR6400 operate within the same emissio ns

envelope and operation of the terminals is consistent with Part 5 of the Commissio n’s

Rules.

      Astronics AeroSat fully incorporates by reference the information included as part of

the previous experimental application and filings, 2 and confirms that the termina l

parameters of the authorized experimental operations will not change. These parameters

are fully consistent with the Commission’s two-degree spacing policies and thus use of the

HR6400 and HR129 terminals to access to new CONUS-coverage satellites will not

increase the potential for interference from Astronics AeroSat’s experimental operations.

      II.     Protection of Users in the 14.0-14.5 GHz Band

      Astronics AeroSat understands that operations under this experimental license are

conducted on an unprotected, non-interference basis only and are conditioned upon

protection of co-frequency operations. Astronics AeroSat notes that there have been no

reported cases of interference relating to its operations under its existing experimental or

commercial licenses and, given the limited         testing operations under the subject

experimental license, it is unlikely that interference will occur. Astronics AeroSat,




2   See id.



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however, will immediately cease operations to the extent harmful interference is caused to

another user of the 14.0-14.5 GHz band.

    III.      New Satellite Points of Communication

           Astronics AeroSat notes that its current experimental license does not specify

authorized satellite points of communications, although satellites have been specified in its

underlying applications. 3    In addition to those satellites, Astronics AeroSat seeks FCC

authority to communicate with the following new satellite points of communication in the

context of this application: Eutelsat 115WB (Satmex 7) at 114.9°W and IS-29E at 50° W.

           Astronics AeroSat confirms that the proposed satellite points of communication can

be used for testing and demonstration of ESAA terminals consistent with Commission rules

and policies.     Each of the proposed satellites has been previously authorized by the

Commission to provide service in the U.S. market and thus their operating parameters have

been previously reviewed and approved. In addition, Astronics AeroSat is submitting

certifications from the satellite operators confirming that the proposed operations are

consistent with the coordination agreements of the serving satellites. Of course, Astronics

AeroSat will provide any additional information that may be appropriate for the

Commission to consider the instant request.

    IV.       Conclusion

           Astronics AeroSat respectfully requests that the Commission grant its applicatio n

to modify its experimental license to increase the number of authorized ESAA terminals to



3 See Astronics AeroSat Corporation, Call Sign WH2XJQ, File No. 0579-EX-PL-2014
(adding the Eutelsat 117WA satellite); File No. 002-EX-ML-2015 (adding the Galaxy
3C, Telstar-14R, and Telstar-11N satellites); File No. 0146-EX-ML-2015 (adding the
SES-6, Galaxy 16, Galaxy 17 and AMC-16 satellites); 0184-EX-ML-2015 (adding the
SES-1 satellite).


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twenty (20) total and add new satellite points of communication for the HR129 and

HR6400 terminals.     Granting the modification will serve the public interest by allowing

Astronics AeroSat to continue to test and demonstrate ESAA terminal performance with

new satellites and potential service applications.




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Document Created: 2016-10-03 13:25:03
Document Modified: 2016-10-03 13:25:03

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