File number S-2889-EX-97

0173-EX-RR-1999 Post Grant Documents

CRSI, Inc.

2001-09-07ELS_48403

5—2887— EX—97 ' %COMSATE\QSU INcC 1501 Moran Road Dulles, VA 20166 WA2XHS mt Telephone 703 450 5680 PDewreg LX RAY wobhnd" J salr April 4, 1997 W q/, ¢ é7 Mr. Paul Marrangoni Chief via R&S Courier Experimental Licensing Branch through Pittsburgh, PA Office of Engineering and Technology Federal Communications Commission 2000 M Street, N.W. Room 230 Washington, DC 20554 care of: Mellon Bank Three Mellon Bank Center via R&S Courier 525 William Penn Way P. 0. Box 358320 27th Floor Pittsburgh, PA 15251—5320 Attn: Federal Communications Commission Wholesale Lockbox Shift Supervisor Re: COMSAT RSI, Inc. Request for Special Temporary Authorization Office of Engineering and Technology Dear Mr. Marrangoni: Pursuant to Section 5.56 of the Commission‘s Rules, 47 C.F.R. § 5.56 (1995), COMSAT RSI, Inc., ("COMSAT RSI") requests special temporary authorization to operate ## DCOL/GOODP/39067.41

Mr. Paul Marrangoni April 2, 1997 Page 2 as described below. In accordance with the FCC‘s Fee Schedule (Fee Code EAE), a check for $45.00 is enclosed. Certification pursuant to 47 C.F.R. § 1.2002 is herein incorporated. COMSAT RSI requests authorization to cover operations —— specifically, the activities related to the testing of a customer‘s Gateway Earth Stations —— pending the grant of an application which was filed on December 20, 1996, for an experimental license in Ashburn, Virginia (copy attached). In support of this request, the following is shown: 1) Applicant‘s Name and Address: COMSAT RSI, Inc. 1501 Moran Road Sterling, VA 20166 Contact: Bill Klimcezak 703—450—5680 2) Need for Special Action: The rapid approval of a Special Temporary Authorization for 148— 150.05 Mhz is needed in order to commence and maintain scheduled production deliveries of the Gateway Earth Station System to ORBCOMM. The functionality of the system is described in Exhibit 1. In order for us to test reliably and deliver these systems to ORBCOMM in a timely manner, we will need to test each system on site at the COMSAT RSI facility. This testing will complement testing pursuant to existing lower power authority in this frequency band. The authority requested will permit testing consisting of transmitting to and receiving from a Low Earth Orbit Satellite. Exercising the system in an "as installed" configuration at COMSAT RSI will demonstrate to the customer the complete functionality of each system. COMSAT RSI sought approval for these operations in a "permanent" application which was filed on December 20, 1996, and which has not yet been acted upon. A rapid approval of special temporary authority ## DCO1/GOODP/39067.41

Mr. Paul Marrangoni April 2, 1997 Page 3 will enable COMSAT RSI to meet customer requirements and avoid costly delays related to fabrication, assembly, and testing of the systems. The prohibitively large size of each system makes it imperative that COMSAT RSI deliver each system as it comes off the production line. A long approval process will require COMSAT RSI to slow or stop production. A significant amount of capital equipment and personnel at COMSAT RSI have been dedicated to delivering the ORBCOMM systems on schedule in an effort to provide the highest quality system to ORBCOMM. 3) Type of Operation: See Exhibit 1. 4) Purpose of Operation: iSee Exhibit 1. 5) Date of Operation: April 16, 1997, through October 16, 1997 6) Class of Station: Experimental 7) Location of Operation: Arcola (38° 59‘ 40" N; 77° 31‘ 00" W), Virginia 8) Equipment to be Used: 2 radome—enclosed VHF antennas. Manufacturer is Powers Systems Technology. Model No. BHED147157—1000/307A. ## DCOL/GOODP/39067.41

Mr. Paul Marrangoni April 2, 1997 Page 4 9) Frequencies Desired: 148—150.05 MHz. 149.61 +/— 0.050 MHz is particularly vital. If 149.61 +/— 0.050 is not available, we request a 100 kHz band anywhere within 148—150.05 MHz. AW 148.85 Milz 10) Power: 500 W (cw) maximum ERP at transmitter terminals. 40 dBW (PEAK) maximum ERP from the antenna. 11) Type of Emission: SOKOGQN (QPSK) 12) Overall Height of Antenna Above Ground: 7.95 m 13) 47 C.F.R. § 1.2002 Certification: COMSAT RSI hereby certifies that it, its officers and directors, and any party with a five percent or greater interest in this request for special temporary authorization is not subject to a denial of the Federal benefits requested herein pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. § 853(a). If there are any questions about the foregoing, please contact the undersigned at 703—450— 5680 or Chip Yorkgitis at 202—955—9668. Respectfully submitted, dh1. h. J Harold Aryai Siegel Vice President —— Legal ## DCOL/GOODP/39067.41

COMSAT RSI, Inc. Request for Special Temporary Authority Items 2, 3, 4 EXHIBIT 1 COMSAT RSI ("CRSI") has recently been awarded a contract to produce a 16 element crossed—dipole array which will operate in a 28 foot radome. This antenna will be used in the ground segment in a communications system developed by ORBCOMM to provide wireless packet data services optimized for short message transfer via satellite links. The space segment will consist of 28 to 36 satellites referred to as ORBCOMM Space Vehicles in polar orbits of about 730 km. These orbits are considered ‘low Earth Orbits‘ making the system a LEO based system (in this case a little LEO based system). The role of the ground segment is to process messages within a specific geographic territory (such as a country or region), and to provide interconnection between the system and the various public and/or private data networks within the territory. The ground segment will consist of a number of ORBCOMM Gateways, to be located strategically throughout the world. The Gateway Earth stations (GES) consists of medium gain tracking antennas, RF and modem equipment, and communications hardware to send and receive packets. The GES are fully redundant and designed for unattended operation. The GES use two (separate) radome—enclosed, VHF antennas which will be supplied by CRSI (see Exhibit 1). The system is designed to operate in the 137—138 MHz and 148—150.05 MHz frequency bands. The downlink from the satellites to the GES is in the 137—138 MHz band. The transmissions to the satellites occur within the 148—150.05 MHz band with a 50 kHz bandwidth using QPSK modulation. Authority is sought throughout this entire 2.05 MHz band, although authority to operate is particularly important at 149.61 + 0.050 MHz to meet ORBCOMM‘s requirements. The pedestal mounted antennas are capable of full hemispheric coverage and will be designed to operate with the LEO satellites. Two separate radome enclosed antennas will be installed at the Ashburn, Virginia test site and will be used to verify the system components before shipment of each system to ORBCOMM. The installation will be operated similar to an actual GES in order to check out all of the major subsystem components. For this reason we require operation on at least a single frequency within the 148—150.05 MHz band. Typical communication times to the satellite will be approximately 10 minutes and this time will be a function of the geometry of the position of the satellite relative to the Ashburn, Virginia location. The position of the radomes at the Ashburn site is shown in the attached drawing. ## DCOL/YORKC/32773.42

Exhibit 2 012 oOs 9602

COMSAT RSI, Inc. FCC Form 442 Item 12 EXHIBIT 3 Radiation Hazard Analysis: The proposed antenna was analyzed using the Mininec Computer Software program which is a Method of Moments analysis, with 500 watts at the input to the antenna. The power density in miliwatts per square centimeter versus distance from the antenna is shown in the Figure 1. The field strength in volts per meter versus distance from the antenna is shown in Figure 2. The field strength in volts squared per meter squared versus distance from the antenna is shown in Figure 3. The assumption here is that the curves are calculated for the peak gain of the antenna. The levels from the sidelobes will be much less. Since the antenna is capable of full hemispherical coverage, there is a possibility that the mainbeam of the antenna could be pointed at a zero degree elevation angle as referenced to the horizon. However, in practice the antenna will generally be operated at elevation angles of about 10 degrees or more. As a precaution the worst case levels caused by the peak of the beam will be used in the analysis. In addition the ‘Controlled Environment‘ is assumed to be the test range and the ‘Uncontrolled Environment‘ is assumed to be any region outside of the test range. It is well over 200 feet from the proposed ORBCOMM Antenna location to any point outside of the test range property. During operation no CRSI or other authorized personnel will be closer than 60 feet to the antenna which will meet the requirement for Maximum Permissible Exposure for Controlled Environments. This occurs at approximately 50 feet as can be seen in Figures 1 and 2. For both the Uncontrolled Environment and General Public Exposure the acceptable limits are achieved at approximately 120 feet in Figures 1 and 2 and also Figure 3. The requirements from FCC 96—326 are as follows: Power Density Levels ( P, mW/cmz) or Requirement/Reference Field Strength (V/m or V /m‘) 61.4 (V/m) or 1.0 (mW/cm") Table 2 Appendix B: FCC 96—326, MAXIMUM PERMISSIBLE EXPOSURE (MPE) : CONTROLLED ENVIRONMENTS 27.5 (V/im) or 0.2 (mW/cmz) Table 2 Appendix B: FCC 96—326, MAXIMUM PERMISSIBLE EXPOSURE (MPE) FOR UNCONTROLLED ENVIRONMENTS 800 (V% /m*) or 0.2 (mW/cm") Table 3 Appendix B: FCC 96—326, GENERAL PUBLIC EXPOSURE CERTIFICATION I hereby certify that I am the technically qualified person responsible for the preparation of the radiation hazard assessment, that I have reviewed this radiation hazard assessment, and thatit is complete and accurate to the best of my information, knowledge, and belief. «< William N. Kli%czak Manager of Electrical Engineering COMSAT RSI, Inc. Dated: December 18, 1996

Figure 1 Power Density versus Distance in feet from ORBCOMM Antenna 6.00 5.00 4.00 mWisq—cm 3.00 2.00 1.00 0.00 20 40 60 & ~—— 80 100 Distance (feet) 120 140 160 180 200

Figure 2 Field Strength versus Distance in feet from ORBCOMM Antenna 160 140 120 4 i2zzon nlnlld 100 Vim 80 60 40 20 20 40 60 80 100 120 140 160 180 200 Distance (feet)

Figure 3 Field Strength versus Distance in feet from ORBCOMM Antenna 22000 21000 20000 18000 18000 17000 186000 15000 14000 13000 12000 V—sqisq—m 11000 10000 9000 8000 7000 6000 5000 4000 3000 2000 1000 20 40 60 80 100 120 140 160 180 200 Distance (feet)

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CERTIFICATION I hereby certify that I am the technically qualified person responsible for the preparation of the radiation hazard assessment dated December 18, 1996, attached hereto. I have reviewed this radiation hazard assessment, and certify that it continues to be complete and accurate to the best of my information, knowledge, and belief. /u’/ fl\ 7 fl%L William N. Klimezak COMSAT RSI, Inc. Dated: April 4, 1997 ## DCOU/KINNR/39182.41

KELLEY DRYE & WARREN LLP a PARTNERSHIP INCLUDING PROFESSIONAL asSOCIATIONS 1200 19Th STREET, N.wW. NEW YORK, N.Y. SsuITE 500 FACSIMILE LOS ANGELES, CA. (202) ©5S—9792 WASHINGTON, D. C. 20036 MIAMI, FL. CHICAGO, IL. (202) S55—9600 STAMFORD, CT. PARSIPPANY, N.J. WRITER‘S DIRECT LINE BRUSSELS, BELGIU M {(202) 955—9776 HONG KONG AFFILIATED OFFICES NEW DELHI, INDiA TOKYO, JAPAN April 4, 1997 Federal Communications Commission Experimental Radio Service P.O. Box 358320 via R&S Courier Pittsburgh, PA 15251—5320 Re: Application of COMSAT RSI, Inc. for Part 5 Experimental License Dear Sir or Madam: Enclosed herewith for filing on behalf of COMSAT RSI, Inc., is a request (the "Request") for special temporary authority covering operations related to the testing of Gateway Earth Stations in Ashburn, VA, beginning on April 16, 1997. Attached to the Request please find Exhibits and Form 159. The filing fee of $45.00 is enclosed herewith. Please date stamp the attached duplicate of the Request and return it to the courier. ## DCOL/KINNR/39216.41

KELLEY DRYE & WARREN LLP Federal Communications Commission Page 2 April 4, 1997 If there are any questions regarding this Request, please do not hesitate to contact the undersigned. Respectfully submitted, Rebekah J. Kinnett Counsel for COMSAT, RSI Inc. Enclosures ce: Douglas Young Experimental Licensing Branch Office of Engineering and Technology Federal Communications Commission 2000 M Street, Suite 230 Washington, DC ## DCO1/KINNR/39216.41

KELLEY DRYE & WARREN LLP A PARTNERSHIP INCLUDING PROFESSIONAL ASSOC:ATIONS 1200 19T" STREET, N.W. NEw york, w.y. SsuiTE 500 FacsimiLe LOs anGgELES, Ca. wasHiNngton, D. c. 20036 (202) ass—a792 MIAM1, FL. CcHIicaco, iL. (202) ass—2600 STAMFORD, CT. PARSIPPANY, N.J. BRUSSELS, BELGIUV M HONG kOnG AFFILIATED OFFICES NEW OELHI, INCiA May 16, 1997 EDWARD A. YORKGITIS, JR. TOKYO, JAPAN DIRECT LINE (202) ss—9668 Mr. H. Franklin Wright Office of Engineering and Technology Federal Communications Commission 2000 M Street, N.W., Room 276 Washington, DC 20036 Re: April 4, 1997, COMSTAT RSI Request for STA to Utilize 149.61 MHz for Antenna Testing Purposes Dear Mr. Wright: Pursuant to our earlier discussions, I am attaching herewith a more detailed explanation of COMSAT RSI‘s proposed operations on 149.61 MHz which the company has provided me. As explained in the attachment, COMSAT RSI needs to have access to enough of the sky as the non—geostationary ORBCOMM satellites pass overhead so that COMSAT RSI has the opportunity to communicate with the satellites for sufficient periods (approximately 10 minutes) to support the testing. It is our hope that this information will assist NTIA and the DOD in resolving any coordination difficulties. COMSAT RSI is willing to compromise and agree to reasonable conditions to allow the testing to proceed. As explained in COMSAT RSI‘s application, its testing for ORBCOMM is rapidly entering into a phase where authority to complete this portion of the testing is vital. An expeditious response from NTIA and DOD would be appreciated. To that end, COMSAT RSI would welcome a meeting with NTIA and DOD representatives to discuss the proposed ## DCOL/YORKC/42159.41

KELLEY DRYE & WARREN LLPp H. Franklin Wright May 16, 1997 Page 2 _ operations. I will be calling you Monday to discuss the prospects of such a meeting. At that time, I would be glad to address any further questions regarding the attached or additional information you would find useful. Respectfully submitted, / 0" ernéy for COMSAT RSI, Inc. @ Attachment ce: Douglas Young Stephen L. Goodman (via facsimile) ## DCO1/YORKC/42159.41

Attachment Discussion of Proposed COMSAT RSI Testing at 149.61 MHz (May 16, 1997) COMSAT RSI (CRSI) has been awarded a contract to produce a total of 20 (for the present contract) of sixteen—element crossed—dipole arrays. Under CRSI‘s contract, CRSI must also test the entire complement of deliverable hardware with an existing satellite to demonstrate compliance to specifications. The antennas, once delivered, will be used in the ground segment in a Low Earth Orbit satellite communications (i.e., Little LEO) system developed by ORBCOMM to provide wireless packet data services optimized for short message transfer. The space segment ultimately will consist of 28 to 36 satellites referred to as ORBCOMM Space Vehicles in polar orbits of about 730 km. The role of the ground segment is to process message traffic within a specific geographic territory (such as a country or region), and to provide interconnection between the system and the various public and/or private data networks within the territory. The ground segment will consist of a number of ORBCOMM Gateways, to be located strategically throughout the world. The Gateway Earth stations (GES) consists of medium gain tracking antennas, RF and modem equipment, and communications hardware to send and receive packets. The GES are fully redundant and designed for unattended operation. The GES use two (separate) radome—enclosed VHF antennas which are those to be supplied by CRSI. The system is designed to operate in the 137—138 MHz and 148—149.90 MHz frequency bands. The downlink from the satellites to the GES is in the 137—138 MHz band. The transmissions to the

satellites occur within the 148—149.90 MHz band with a 50 kHz bandwidth using QPSK modulation at an EIRP of 40 dBW. The pedestal—mounted antennas are capable of full hemispheric coverage and will be designed to operate with the Little LEO satellites. The authority to conduct its tests at 149.61 MHz‘ is necessary to enable CRSI to check out the complete complement of deliverable hardware, and to ensure satisfactory operation after installation at the respective host country. Some of the parameters that can be checked in this fashion are: o The received signal level from the satellite. o The tracking performance of the antenna and the associated control electronics. * The received Bit—Error—Rate (BER). * The compatibility of CRSI equipment/software with ORBCOMM equipment/software. & Certification that the system as delivered will function properly. Two separate radome—enclosed antennas are in the process of installation at the Ashburn, Virginia test site and will be used to verify the system components before shipment of each system to ORBCOMM. The installations will be operated similar to an actual GES in order to check out all of the major subsystem components. For this reason CRSI requires operation at 149.61 MHz, for which CRSI has sought both special temporary and a "permanent" license under Part 5 of the Rules. The radome 1 At the present time, there are two operational satellites in ORBCOMM‘s system and both satellites are tuned to 149.61 MHz. In order to change this frequency, ORBCOMM would be required to take its system off line and re—tune the satellite receivers to another frequency in the 148—149.90 MHz band. Service for existing customers would be seriously interrupted.

installation will be complete in the next few weeks. This will establish the antenna heights and positions at the present locations. The antenna heights when installed in the radomes will be approximately 16.5 feet above ground level. The emissions designator of the signals is 50KOGQN (QPSK). Typical communication times to a satellite during testing will be approximately 10 minutes. However, this time will be a function of the orientation of the current satellite orbital path relative to the Ashburn, Virginia location. With each orbit, the satellite‘s path through the sky will change from the vantage point of the GES. The GES antenna is capable of a software—controlled beam pointing to essentially any angle from about + 5.0° elevation to zenith and any azimuth angle. (The GES antenna will have approximately a 24—degree half power beamwidth.) If small areas of the sky were restricted, due to potential interference, the system could still be operated such that the antenna would not radiate in those specified areas. However, in order for the tests to be conducted appropriately, the GES must be capable of communicating with the satellite for at least 10 consecutive minutes. In the past, CRSI has performed high power testing of radar antennas under a special license obtained by the Air Force (for CRSI) where advance notice to the local airport control tower (Dulles) was given before each test, due to the perceived potential for interference. Arrangements such as a requirement for CRSI to provide reasonable advance notice of planned testing not less than 48 hours to an authorized representative of the DOD, can easily be made if necessary. In addition, specific areas in space can be excluded from transmit testing to avoid any potential interference.

FEDERAL CUMMUNICA NoN3 COMMISS{eXN Ap d hy MB Appruney mr 23 FCC REMITMANCE ADVICEK .}t"=,. pagek xo. _1 or (RESERVED» SPECIAL USE FCC USE ONLY \ O tRead instructions carefully BEFORE proceeding.) ) PAYOR INFORMATIO {1) FCC ACCOUNT NUMBER Did you have a number prior to thia Et.er it. 12) TOTAL AMOUNT PAID tdollars and cents: (0 11 ]3 [5 [ 313 | 5 |1 [ 9 [7 L 1 _4 | [ [ | | | | S 45 __% (3) PAYOR NAME (If paying by credit card, enter name exactly as it appears on your card} c0 Kelley Drye & Warren LLP (4) STREET ADDRESS LINE NO. i 1200 19th Street, N.W., Suite 500 &) STREET ADDRESS LINE NO. 2 @ iY¥ (" STtATE (8) ZIP CODE Washington DC 20036 (9) DAYTIME TELEPHONE NUMBER (Include area code) (10) COUNTRY CODE (if not U.S.A. 202—955—9600 T ‘ ommmEA Neormarion {11A) NAME OF APPLICANT, LICENSEE, REGULATEE, OR DEBTOR FCC USE ONLY COMSAT RSI, Inc. {12A) FCC CALL SIGN/OTHER ID (13A) ZIP CODE (14A) PAYMENT TYPE CODE (15A) QUANTITY (16A) FEE DUE FOR « PAYMENT TYPE CODE IN BLOCK t4 20166 r a ® 1 $45.00 (I7A) FCC CODE i (184) FCC CODE 3 (E9A) ADDRESS LINE NO. 1 (20A) ADDRESS LINE NO. 2) (21A) CITYSTATE OR COUNTRY CODE Sterling, VA 15 moran Road ITEM #2 INFORMATION (118B) NAME OF APPLICANT, LICENSEE, REGULATEE, OR DEBTOR PCC USE ONLY (128B) FCC CALL SIGN/OTHER ID (138) ZIP CODE (14B) PAYMENT TYPE CoDE (15B) QUANTITY |(16B) ree pu® ror PAYMENT TYPE CODE IN BLOCK 14 $ (178B) FCC CODE 1 (18B) FCC CODE 2 (19B) ADDRESS LINE NO. 1 (208B) ADDRESS LINE NO. 2 (218) CITY/STATE OR COUNTRY CODE CREDIT CARD PAYMENT inrormanos im (22) MASTERCARD/VISA ACCOUNT NUMBER: ' [ Mastercard EXPIRATION DATE: . Month Year l:] Visa AUTHORIZED SIGNATURE DATE (23) Ihereby authorize the FCC to charge my VISA or Mastercard for the service(s}/authorization(s) herein describe. See public burden estimate on reverse


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