Description of Modification

0100-EX-ML-2008 Text Documents

HNS License Sub, LLC

2008-08-26ELS_92887

                                                                           HNS License Sub, LLC
                                                                          Form 442 - Modification
                                                                             Call Sign WE2XEW
                                                                                     August 2008


             DESCRIPTION OF MODIFICATION APPLICATION AND
           PROPOSED CHANGES TO PROGRAM OF EXPERIMENTATION

       By this application, HNS License Sub, LLC (“Hughes”) proposes a further modification

of its existing experimental license, Call Sign WE2XEW, File Nos. 0011-EX-PL-2006, 0023-

EX-ML-2008, 0047-EX-ML-2008, and 0097-EX-ML-2008. Specifically, Hughes seeks to

expand the mobile operations of the authorized Ku-band and Ka-band mobile terminals to

include aeronautical mobile use, which will allow testing of terminals mounted on helicopters,

airplanes and unmanned aerial vehicles (“UAVs”).

       Hughes anticipates that within the relatively near term, it is likely to receive requests

from Federal or other customers with which it has contracts to begin experimental testing of

mobile terminals on-board one or more types of aircraft. For more than a year, Hughes has been

engaged in testing the operational capabilities of several types of mobile antenna equipment

mounted on various types of military and other vehicles. Earlier this year, it received approval to

extend this testing to include maritime mobile operations in U.S. coastal waters (see File No.

0047-EX-ML-2008). With this further modification application, Hughes seeks authority to

extend its testing program to the third type of mobile operation, permitting it to mount mobile

antennas on military and other aircraft, including airplanes, helicopters and UAVs.

       Processing of this modification request will not require detailed technical review. With

the exception of the fact that terminals are proposed to be tested on aircraft operating within

CONUS and over adjacent coastal waters, all other parameters – including all technical and

operational parameters – of the proposed use are consistent the terms of the existing


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authorization and the licensing conditions applicable to Call Sign WE2XEW will remain in full

force and effect. Hughes notes in this respect that the conditions currently applicable to

Hughes’s vehicle-mounted and vessel-mounted operations include limitations on off-axis EIRP

spectral density from the Commission’s Rule governing operation of Earth Stations on Vessels

(“ESV Rule”). See Hughes Authorization, Call Sign WE2XEW, at Condition 10. Conditions

regarding coordination with NASA over operation near Tracking and Data Relay Satellite

System receive sites, and requiring the automatic cessation of transmissions from mispointed

antennas, are also taken from the Commission’s ESV Rule. See Hughes Authorization, Call Sign

WE2XEW, at Conditions 8 and 11; 47 C.F.R. § 25.222. These conditions, as well as Conditions

6 and 7 (governing protection of National Science Foundation sites), are equivalent to the

requirements of ITU Recommendation M.1643 (“Rec. ITU-R M.1643”), which sets forth the

ITU requirements for the operation of aircraft Earth stations operating in the aeronautical

mobile-satellite service in Ku-band.

         Grant of the non-technical modification proposed herein would provide an important new

platform for the domestic testing, demonstration and training operations of mobile aircraft

terminals within and just beyond CONUS. Hughes will be able to continue its program of

developing small, high-throughput terminals that are desired by the Department of Defense for

military use in command, control, communications, intelligence, surveillance and reconnaissance

(“C3ISR”) functions. Critically, there will be no change whatsoever in Hughes’s ability and

responsibility to satisfy its obligation not to cause harmful interference through the terminals it

will be using.




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Document Created: 2008-08-26 11:26:02
Document Modified: 2008-08-26 11:26:02

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