Narrative Statement

0196-EX-ST-2012 Text Documents

Intelsat License LLC

2012-03-06ELS_123741

Request for Experimental Special Temporary Authority
Intelsat License LLC

NARRATIVE DESCRIPTION AND PUBLIC INTEREST STATEMENT
In-flight Testing of KuStream Terminal

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

(“STA”) for in-flight testing of a Ku-band satellite earth station 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 April 2, 2012 for a period of 90 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 an aircraft-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 and has been previously licensed by the Commission.

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. Intelsat’s experimental operations 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, including for Intelsat experimental

operations in the land mobile context (File No. 0158-EX-ST-2012, currently pending). For more

information on the KuStream terminal, see www.kustream.com.

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Request for Experimental Special Temporary Authority
Intelsat License LLC

II. DESCRIPTION OF PROPOSED EXPERIMENTAL OPERATIONS

Intelsat seeks to demonstrate the TECOM KuStream 1500 terminal for in-flight

operations onboard a U.S. Government transport aircraft. Intelsat seeks to conduct flight testing

for a 90-day period commencing no later than April 2, 2012. Authority is sought for operations

in continental United States (“CONUS”) and adjacent international waters.

Intelsat’s experimental flight-test operations are being conducted in connection with U.S.

Government evaluation and procurement activities. Thus, Intelsat seeks authority to provide

services under contractual agreement with the U.S. Government pursuant to Section 5.3 of the

Commission’s rules (47 C.F.R. § 5.3).

Intelsat recognizes and accepts that any experimental STA 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. In the absence of coordination

agreements, Intelsat will conduct flight testing only in areas that are outside exclusion zones for

radio astronomy sites (during observations) and NASA TDRSS sites in accordance with

applicable FCC rules. In addition, Intelsat may conduct flight tests in international airspace (e.g.,

off the U.S. coastline).

Intelsat will examine the following performance objectives in connection with flight

testing:

o forward carrier (hub to terminal) throughput rate;
o return carrier (terminal to hub) throughput rate;
o re-acquisition time when switching between satellite beams;
o two-way videoconferencing between aircraft and ground;
o geographic mapping; and
o network management and operation.

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Request for Experimental Special Temporary Authority
Intelsat License LLC

The operations will be intermittent and limited in duration and, in all cases, the aircraft

will operate in selected conditions in a dedicated manner under 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

experimental and commercial operations. 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).

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

Commission, including:

o 0.2º pointing accuracy; automatic muting within 100ms if pointing offset exceeds
0.5º and delaying resumption of transmissions until pointing accuracy is within
0.2º;
o compliance with Section 25.209 antenna gain pattern through 35º skew angle (the
terminal automatically mutes transmissions at skew angles greater than 35º); and
o 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), which
have been applied in the aeronautical context.

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Request for Experimental Special Temporary Authority
Intelsat License 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 off-

axis EIRP limits set forth in analogous ESV and VMES rules. See 47 C.F.R. §§ 25.222 and

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. Intelsat 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

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

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Request for Experimental Special Temporary Authority
Intelsat License LLC

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 to support U.S. 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 governing Ku-band aeronautical operations and analogous services. Because

grant of this request would serve the public interest, Intelsat respectfully requests approval at the

earliest practicable time.

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Document Created: 2012-03-06 20:29:19
Document Modified: 2012-03-06 20:29:19

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