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

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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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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