Narrative Statement

0158-EX-ST-2012 Text Documents

Intelsat License LLC

2012-02-27ELS_123485

                                   Request for Experimental Special Temporary Authority
                                                                     Intelsat Licensee LLC


        NARRATIVE DESCRIPTION AND PUBLIC INTEREST STATEMENT
                   Ground Testing of Ku-Stream Terminal


        Intelsat Licensee LLC (“Intelsat”) seeks experimental special temporary authority

(“STA”) for ground testing of a vehicle-mounted earth station (“VMES”) terminal to

demonstrate the functionality of the terminal with the Intelsat network to a U.S. Government

customer. Intelsat seeks to commence operations no later than March 15, 2012 for a period of 30

days.

I.      INTRODUCTION

        Intelsat, a leading satellite service provider, is demonstrating Ku-band mobile VSAT

connectivity using its Fixed-Satellite Service (“FSS”) network. The demonstration involves

temporary operation of a vehicle-mounted terminal in the 14.0-14.5 GHz band (transmit) and

11.7-12.2 GHz band (receive). The terminal – the TECOM KuStream 1500 – is designed for

aeronautical applications but is being demonstrated in the land mobile context.

        Adjacent FSS satellites will be protected from harmful interference by limiting the off-

axis EIRP spectral density along the GSO arc to no more than the levels permitted for routinely

licensed Ku-band VSAT terminals and VMES terminals. Intelsat’s temporary operations, which

are also limited in geographic scope, will not impact other users of the Ku-band (including U.S.

Government radio astronomy and space services).

        There is ample precedent for granting Intelsat an experimental STA to perform this

testing based on prior authority for experimental operations granted to Boeing (Call Sign

WC2XVE), ARINC (Call Sign WC2XPE), Hughes Network Systems (Call Sign WE2XEW),

Panasonic Avionics (Call Sign WD9XQT) and others. In fact, the KuStream terminals

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                                   Request for Experimental Special Temporary Authority
                                                                     Intelsat Licensee LLC

manufactured by TECOM/Qest have been previously licensed to operate on both an

experimental and commercial basis by the Commission. (For more information on the KuStream

terminal, see www.kustream.com.)

II.    DESCRIPTION OF PROPOSED EXPERIMENTAL OPERATIONS

       Intelsat seeks to demonstrate the TECOM KuStream 1500 terminal on a stationary and

in-motion vehicle. Intelsat seeks to conduct ground testing for a 30-day period commencing no

later than March 15, 2012. The demonstration will be confined to a 50 mile radius around

coordinates 35º 09’ 47” N, 79 º 00’ 15” W near Fayetteville, North Carolina. Intelsat recognizes

and accepts that any experimental STA authority will be conditioned upon non-interference and

protection of co-frequency operations, including Ku-band FSS operations and U.S. Government

radio astronomy and space services.

       The general objectives of the testing to be carried out under this experimental STA

include: (i) integrating and testing of the KuStream 1500 terminal in the Intelsat network; (ii)

demonstrating two-way data service using a mobile platform; (iii) validating the predicted

performance of the system; and (iv) demonstrating that the system meets the established

interference requirements for Ku-band mobile VSAT systems. This testing will be very limited

in duration (several days of testing over the 30-day STA period). In all cases, the terminal will

operate in selected test conditions in a dedicated manner under close control of Intelsat’s network

control personnel.

       A. The KuStream 1500 Terminal

       The KuStream 1500 terminal, manufactured by TECOM/Qest, is a government version of

the KuStream terminal that has been previously authorized by the Commission for both


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                                    Request for Experimental Special Temporary Authority
                                                                      Intelsat Licensee LLC

experimental and commercial operations.1 For example, the TECOM terminal was authorized

for aeronautical experimental operations by Row 44, Inc. in 2009 (File No. 0236-EX-PL-2009,

Call Sign WF2XBY), and for commercial operations in 2010 (File No. SES-MOD-20091021-

01342, Call Sign E080100).2

         The material operating parameters of the KuStream antenna are well-known to the

Commission, including:

         -   0.2º pointing accuracy; automatic muting within 100ms if pointing offset exceeds 0.5º

             and transmissions do not resume until pointing accuracy is within 0.2º;

         -   Compliance with Section 25.209 antenna gain pattern through 35º skew angle (the

             terminal automatically mutes transmissions at skew angles greater than 35º);

         -   Compliance with Section 25.222 and 25.226 off-axis EIRP levels (i.e., VSAT routine

             licensing levels applicable to Ku-band ESV and VMES operations).

Thus, the KuStream antenna complies fully with the Commission’s two-degree spacing policies

and VMES rules designed to protect co-frequency operations from harmful interference.

Charts are provided below showing the gain of the KuStream 1500. Section 25.209 gain

patterns and off-axis EIRP levels are provided below and confirm applicable limits are met for

co-polarization and cross-polarization for all operating scenarios.




1
    See Attachment A.
2
  The technical data associated with these authorizations are hereby incorporated by reference.
Minor differences in operating parameters, including higher transmit power, are addressed
through wider bandwidth to ensure equivalent off-axis EIRP performance. Intelsat reserves the
right to supplement the technical demonstration to set forth herein.
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                                              KuStream 1500 Gain
                                         Co—polarization, GEO Plane
             o                            Full Azimuth: +/— 180 Degrees

                                                                               —Stew=0 Dog.
             &                                                                 —stew=35 bog.                L
                                                                               ——FCC25.20% GEO Plane Gain
Gain (aBi)




             w           mt

                 saso   aso   420   90   so     30        0       30      so      so      120      150      180
                                                Asimuth Angle {degree}


                        KuStream 1500 Gain
                     Co—polarization, GEO Plane
                     Close in: +/— 15 Degrees Azimuth
                                                        —Stew=0 ber.

                              fN                        |Eerelomeeose
                                                        —Stew=25 beg.


             22) \                        \
Gain (aBi)




                              C




                                                   S SA Y

                          4         0          3         6        9     12   15
                          Asimuth Angle {degree)


                                    Request for Experimental Special Temporary Authority
                                                                      Intelsat Licensee LLC




The terminal will be configured to not transmit more than 44 dBW EIRP. (This translates into a

an ERP of 15,310 W and a transmit power of 17.35 W). This power limitation is implemented as

part of the commissioning procedure of the terminal.

       The terminal includes an iDirect modem which will be set with an appropriate maximum

Tx IF level to ensure that 44 dBW EIRP is not exceeded. In addition, the terminal and space

segment will operate in single carrier mode (i.e., there will be a single hub to terminal carrier and

a single terminal to hub carrier.) Below are charts showing the off-axis power spectral density of

the carrier transmitted from the KuStream 1500 terminal.




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                                                              KuStream 1500 Power Spectral Density
                                                                     Co—polarization, GEO Plane
                                                                    44 dBW Tx EIRP over 4.992 MHz
                                                                     Full Azimuth:+/— 180 Degrees
                                     ®                                                                         |___L          _
                                     10                                                                      —Stew=0 Deg.          a
                                                                                                             —Stew=35 Deg.
                                     0                                                                       —rcc25225 Geo Plane
Power Spectral Density {dBW/Aktt2)
                         &s




                                                                   wl  w
                                     &




                                                                    [— wfi

                                                                                                         _
                                                   (JW\{ HT
                                             z.1
                                             2 }




                                          saso   aso   420    90          30       0       30       so               120     150   180
                                                                         Asimuth Angle {degree}


                                                  KuStream1500 Power Spectral Density
                                                        Co—polarization, GEO Plane
                                                        44 dBW Tx EIRP over 4.992 MHz
                                                       Close in: +/— 15 DegreesAzimuth
                                     20

                                     10



                                                                              m   t
                                          ——i—{a/ lW
Power Spectral Density {dBW/Aktt2)




                                                                              Wik     L
                                          /\/A”( ~
                                              I




                                                                                  3      s   12   is
                                                             Asimuth Angle {degree)


                                   Request for Experimental Special Temporary Authority
                                                                     Intelsat Licensee LLC




       B.      Satellite Point of Communications

       Intelsat will utilize commercial FSS satellite capacity to conduct its experimental

operations. Specifically, the antenna will communicate with Intelsat’s Galaxy 25 satellite at

93.1ºW.L. and Intelsat’s Galaxy 19 satellite at 97.0º W.L. The operations proposed herein will

be in compliance with the off-axis EIRP limits set forth in the Commission’s VMES rules.

Example link budget analyses are below.




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                                                                                                                                            Request for Experimental Special Temporary Authority
                                                                                                                                                                              Intelsat Licensee LLC

Galaxy 25 – Forward and Return Carriers

Customer Support Engineering & Capacity Management
                                                                            Satellite and Role:          G-25 @ 93.10°W                               Total lease resource [MHz]:                       27.0
Link Budget Report for: TECOM Demo                                          Transponder:             KH07/KV07 (NAKH/NAKV)                            Total D/L EIRP Avail. at be/bp [dBW]:          36.1 / 47.1
                                                                            Platform bias:                -0.52°E; 0.00°N                             Total D/L EIRP Used at be/bp [dBW]:            34.4 / 45.4
Opportunity-ID / SSR-ID                                                     Sat. TWT Power [Watts]:            100.0                                  Total BW Used [MHz]:                              23.5
Done by: bauerf           Date: 21 Jan 2012                                 Sat. D/L EIRP at be/bp [dBW]:       39.9 / 50.9                           Xp Operational Mode: Multi-Carrier                              OBO= -3.8         dB
                                                                            SFD at be/bp [dBW/m2]:             -80.5 / -87.4
Application:                STRIP7 v3.9                 Operational         Band Up/Dw [MHz]:         (14154 - 14181) / (11854 - 11881)
                                                                            Polarization Up/Dw:                   H/V

               Diameter        Gtx              G/T          Latitude      Longitude        Xpol                                                                                                                                                           TOTAL HPA
 Antennas                                                                                                            Location (Nearest City and Country)                                                  Notes
                  [m]         [dBi]           [dB/K]           [°N]          [°E]           [dB]                                                                                                                                                            Power [W]
MTN-K11          11.0         62.0            38.7            39.70         282.27          30.0                        MTN-K11 - United States                                                                                                               1.8
TECOM            0.44         33.0            11.8            35.16         280.75          26.0                     Fayetteville - UNITED STATES                                                                                                            16.3

                                                                                                                                                                Per Carrier Link Parameters and Results
                                                                                               Noise     Space          Alloc.             b.e. D/L     C/N     Clear Sky     Eb/No      Clear Sky          Link         U/L    HPA          HPA                    Gx
   Tx E/S       Rx E/S                                 Carrier Type                                                                PEB                                                                                                              WGL UPC
                                                                                                BW       Factor          BW                 EIRP      thresh.      C/N       thresh.      Eb/No            Availab.     EIRP    size         OBO                  apprvl
                                        #, Type, [I.R, OH, FEC, RS, modulation]               [MHz]     (Roll-off)      [MHz]     [MHz]     [dBW]      [dB]       [dB]        [dB]         [dB]             [%/yr]     [dBW]   (Watt)        [dB]   [dB]   [dB]
 MTN-K11       TECOM             DIG (6.221 Mbps, OH=0.0%, 0.3059 FEC, QPSK)                   10.168     1.20          12.203    18.075       34.4      0.2        6.3        2.3          8.4             99.93       64.6    1.8          0.0    0.0 0.0         n/a
 TECOM         MTN-K11           Spread (1.040 Mbps, OH=0.0%, 1/2 FEC, BPSK)                    4.160     1.20           4.992     0.136       13.1     -3.2       -0.6        2.8          5.4             99.95       44.0   12.6          0.0    0.0 0.0         No
                                                   TOTAL:             2 Carriers                                        17.195    18.211       34.4

ISCO comments:

Antenna pattern comments:

                            Clear Sky C/N includes 1.5 dB additional margin for terrestrial interference, antenna mis-pointing
Notes:                      Eb/No includes 0.4 dB IF-RF degradation.
                            * Analysis results based on today's operational levels of interference. Results are not guaranteed due to possible fluctuations in operational interferences over time.




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         Request for Experimental Special Temporary Authority
                                           Intelsat Licensee LLC




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         Request for Experimental Special Temporary Authority
                                           Intelsat Licensee LLC




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                                   Request for Experimental Special Temporary Authority
                                                                     Intelsat Licensee LLC



III.   PROTECTION OF OTHER USERS IN THE 14.0–14.5 GHZ BAND

       Protection of Fixed-Satellite Service. Intelsat will comply with the Commission’s VMES

rules set forth in 47 C.F.R. § 25.226. Thus, the terminal will operate in such a manner that the

off-axis EIRP levels are no greater than the levels produced by a routinely licensed VSAT earth

station. To the extent that any adjacent satellite operator experiences unacceptable interference

from Intelsat’s experimental operations, Intelsat will cease terminal transmissions immediately.

       Protection of Potential NGSO FSS Systems.               Intelsat acknowledges that non-

geostationary orbit (“NGSO”) systems are also permitted to operate in the Ku-band. However,

no such systems are currently authorized or plan to operate within the period contemplated for

the proposed experimental operations.

       Protection of Terrestrial Radio Services. Intelsat has examined current spectrum use in

the 14.0-14.5 GHz band and has determined that there are no active FCC-licensed terrestrial

services in this band in North America with which its proposed operations could conflict.

       Protection of the Radio Astronomy Service. Given the time and geographic limitations on

the proposed operations, there is no potential for interference into US Government radio

astronomy sites. However, Intelsat nonetheless agrees to comply with exclusion zones designed

to protect such radio astronomy sites set forth in Section 25.226(d).

       Protection of Space Research Service. Intelsat recognizes the utilization of the frequency

band from 14.0-14.05 GHz and the possible use of the band from 14.05-14.2 GHz allocated to

the National Aeronautics and Space Administration (“NASA”) Tracking and Data Relay Satellite

System (“TDRSS”) for space research conducted at White Sands, New Mexico and Blossom


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                                    Request for Experimental Special Temporary Authority
                                                                      Intelsat Licensee LLC

Point, Maryland. For purposes of this experimental STA application and consistent with Section

25.226(c), Intelsat will avoid AES operation within line-of-sight vicinity of these earth stations.

IV.    SUPERVISION AND CONTROL

       For purposes of these experiments, the Intelsat terminals will be operated under Intelsat’s

full supervision and control. The point of contact for the planned experimental operations is:

       Christopher M. Hudson                            (cell) +1-202-352-1272
                                                        chris.hudson@intelsatgeneral.com

       ISOC – Intelsat Secure Operating Center          +1 (404) 381-2727
                                                        ISOC@intelsatgeneral.com

This contact will have access to all network functions, and will have the ability and authority to

cease all transmissions from the terminals wherever they are located.

VIII. CONCLUSION

       Grant of this experimental STA will allow Intelsat to further develop and demonstrate the

mobile VSAT technologies for US government customers. The subject terminal has been

designed to protect other uses in the Ku-band from interference and will comply with FCC rules

and policies to protect co-frequency users of the Ku-band. Because there is ample precedent for

granting this experimental STA and it is plainly in the public interest to do so, Intelsat

respectfully requests grant at the earliest practicable time.




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Document Created: 2012-02-27 14:37:03
Document Modified: 2012-02-27 14:37:03

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