Narrative

0359-EX-ST-2012 Text Documents

Intelsat License LLC

2012-05-02ELS_125268

Request for Experimental Special Temporary Authority Intelsat License LLC NARRATIVE DESCRIPTION AND PUBLIC INTEREST STATEMENT Intelsat License LLC (“Intelsat”) seeks experimental special temporary authority (“STA”) for in-flight demonstration and operation of two Ku-band satellite earth station terminal types in connection with development and implementation of service to a U.S. Government customer. Intelsat seeks to commence operations in U.S. and international airspace no later than June 1, 2012 for a period of 180 days. Authority is sought to test and operate up to 50 of each terminal type. This STA request is similar to one recently granted to Intelsat (File No. 0196-EX-ST- 2012) but adds a second antenna type. Thus, it is intended to replace the prior STA upon grant. For the reasons set forth herein, grant of the requested STA would serve the public interest. I. INTRODUCTION Intelsat, a leading satellite service provider, is developing a Ku-band aeronautical mobile VSAT connectivity offering for a U.S. government customer using its Fixed-Satellite Service (“FSS”) network. The operations involve aircraft-mounted satellite earth station terminals transmitting in the 14.0-14.5 GHz band. The terminals – the TECOM KuStream 1500 and Rantec Airborne SATCOM terminal – are both designed for aeronautical applications and have been previously authorized 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 also will not impact other users of the Ku-band (including U.S. Government radio astronomy and space services).

Request for Experimental Special Temporary Authority Intelsat License LLC There is ample precedent for granting Intelsat an experimental STA to conduct these operations 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 Intelsat itself (File Nos. 0158- EX-ST-2012 and 0196-EX-ST-2012). A. KuStream Aeronautical 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). Intelsat is presently operating this antenna pursuant to a separate experimental STA (File No. 0196-EX-ST-2012). 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), which have been applied in the aeronautical context. Thus, the KuStream antenna complies fully with the Commission’s two-degree spacing policies and 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-

Request for Experimental Special Temporary Authority Intelsat License LLC axis EIRP levels are provided below and confirm applicable limits are met for co-polarization and cross-polarization for all operating scenarios.

KuStream 1500 Gain Co—polarization, GEO Plane Close in: +/— 15 Degrees Azimuth * I —Stew=0 Deg. 30 ——Stew=35 Deg. /\ —CC25200 Gt0 Pline Gain . 1\ 20 $.h 8§ ® ANNMN LAML 4 Y . naAry z0 v "_| TN OV «30 40 50 45 42 3 6 4 0 3 6 9 12 15 Asimuth Angle {degree) KuStream 1500 Gain Cross—Polarization, GEO Plane % 1 T Siew—0 0ce. so —stew=25 beg. —FCC25 209 Cros—PolGain 20 10 § 8 ® 7 — & § 10 _ ‘n ..&8 nay I ~| A NJ _ ( AN L 50 NA 45 42 4 —6 =8 0 3 6 _ neny9 12 15 Asimuth Angle {degree)

Request for Experimental Special Temporary Authority Intelsat License LLC The terminal will be configured to not transmit more than 44 dBW EIRP. (This translates into an ERP of 15,310 W and a transmit power of 13.05 W). This power limitation is implemented as part of the commissioning procedure of the terminal.1 The terminal includes an iDirect modem which will be set with an appropriate maximum transmit power level to insure that 44 dBW EIRP is not exceeded. In addition, because iDirect- based networks employ TDMA, only one terminal will transmit at a given time slot (i.e., there is no aggregation of transmissions from multiple terminals). Below are charts showing the off-axis power spectral density of the carrier transmitted from the KuStream 1500 terminal. 1 In File No. 0196-EX-ST-2012, transmit ERP was inadvertently calculated at 17.35 W rather than 13.05 W. However, Intelsat has operated the terminal at the correct, lower value since grant of the STA.

KuStream1500 Power Spectral Density Co—polarization, GEO Plane 44 dBW Tx EIRP over 4.992 MHz Close in: +/— 15 Degrees Azimuth 20 1 1 —Stew =0 beg. 10 —stew=35 beg. 5 —rcc25 225 Geo Plane 3. ———1 KANL|_\ha —+— £ i t hx i &» t I~LA ]‘ mavealaya [ Q{ \ § £~ I § so $ «so 4o «s0 as 42 a s 4 0 3 s o 12 is Arimuth Angle (degree) KuStream 1500 Power Spectral Density Cross—polarization, GEO Plane 44 dBW Tx EIRP over 4.992 MHz 20 ; ; —Stew=0 ber. 10 —stew=35 bag. g —rce2s.225 crossPol § &10 5 i7 m_—_. §= & iL alpI II)\ a Eoo & 4. WRA yyy imM v TY \ v 4o x as 42 a s 4 0 3 s o 12 I is Asimuth Angle {degree)

Request for Experimental Special Temporary Authority Intelsat License LLC B. Rantec Aeronautical Terminal The Rantec 18in Ku-band Airborne SATCOM terminal, manufactured by Rantec Microwave Antennas, has been previously authorized by the Commission for on-ground and inflight operations. For example, the Rantec antenna was authorized for temporary operations by Tachyon in 2011.2 The material operating parameters of the Rantec antenna are consistent with the requirements imposed by the Commission on other Ku-band aeronautical systems, including: - Better that 0.2º pointing accuracy; automatic muting of transmission within 100ms if pointing offset exceeds 0.2º; - An 18in circular reflector antenna that has no skew angle limitations (i.e., circular aperture has equivalent off-axis performance at all skew angles); - 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. The pointing methodology of the Rantec terminal was thoroughly detailed in the application submitted in File No. 0504-EX-PL-2011, Call Sign WF2XZO, where is summarized below. Accurate pointing of the Rantec terminals antenna is achieved under direction of the antenna control unit (“ACU”), which is also used in over 150 units operating with 11.5” antennas. The ACU receives aircraft position, heading, orientation and rate of change information from a dedicated inertial reference unit (“IRU”), which is also widely deployed. The ACU determines the desired antenna azimuth and elevation by executing an open loop pointing algorithm using: (i) ephemeris data stored in the modem to determine the satellite location and polarization; (ii) stored constants to determine the antenna orientation relative to the airframe; 2 See Call Sign E070139, File Nos. SES-STA-20110901-01019 and SES-STA-20110926-01142; see also Call Sign WF2XZO, File No. 0504-EX-PL-2011.

Request for Experimental Special Temporary Authority Intelsat License LLC (iii) latitude, longitude and altitude data; (iv) heading, yaw, pitch, and roll data; and (v) speed, yaw rate, pitch rate, and roll rate data. Once the satellite is acquired, the ACU corrects for aircraft attitude changes based upon the IRU data, without waiting for degradation of the received signal strength. The IRU data is provided every 0.02 seconds, with a data resolution (least significant bit) of 0.05°. The ACU computes the desired antenna azimuth, elevation and polarization 1024 times every second (approximately once every millisecond). The antenna can move in azimuth and elevation at more than 15° per second, which is sufficient to track aircraft motion within a normal flight envelope. The total RMS pointing error for the antenna is calculated to be less than 0.1°. The Rantec antenna has configurable azimuth, elevation, and polarization error limits. If any of these limits are exceeded, or if there is a hardware fault reported in the pointing hardware, the antenna will automatically inhibit transmit. This is done independent of, and takes precedence over, any modem transmit inhibit/enable. The transmission will remain inhibited until the pointing error limit or hardware fault is removed. As such, transmit will be inhibited in less than 100 ms anytime pointing error exceeds 0.2 degrees Although the Rantec antenna does not comply with Section 25.209 gain patterns, appropriate selection of operating parameters (modulation, spreading, maximum transmit EIRP levels) allows the antenna to comply with the Commission’s two-degree spacing policies and rules designed to protect co-frequency operations from harmful interference.

Rantec 18inch Gain Co—polarization, GEO Plane Envelope +/90 DegreesAzimuth — tHlare Co—Pol —H—Plane Co—Pol — —£CC25.209 GE0 Plane 20 Power Spectral Density {dBW/Aktt2) 10 x" apbei(I hyMléin AAg o AA _ TyNV n * OV T NY t<—~—f+ 41 20 «30 «0 «so —so «so EJ 0 so so so Azimuth Angle (degree) Rantec 18inch Gain Co—polarization, GEO Plane Envelope Close in: +/— 15 DegreesAzimuth a0 1 1 1 —EHlare Co—Pol so —tiStane Co—Pal m {/ N oNEBERREEm w L CC 20 Power Spectral Density {dBW/Aktt2) [3 Y | 1 "G——= 0o l7 8 & 8 8 —s 3 0 3 Asimuth Angle (degree)

Request for Experimental Special Temporary Authority Intelsat License LLC The terminal will be configured to not transmit more than 43 dBW EIRP. (This translates into an ERP of 12,162 W and a transmit power of 7.13 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 transmit power level to insure that 43 dBW EIRP is not exceeded. In addition, because iDirect-based networks employ TDMA, only one terminal will transmit at a given time slot (i.e., there is no aggregation of transmissions from multiple terminals). Below are charts showing the off-axis power spectral density of the carrier transmitted from the Rantec terminal.

Rantec 18inch Power Spectral Density Co—polarization, GEO Plane Envelope 43 dBW Tx EIRP over 4.992 MHz +/— 90 Degrees Azimuth 20 10 —tBlare Co—Pot — \\ — H—Plane Co—Pol —rcc25225 Geo Plane > Power Spectral Density (dBW/Aktt2) allln § & & & ol _\M\A e I _ SWw \| Py VY "_ | [ 1 _1 & 8 30.00 000 30.00 so.00 20.00 Asimuth Angle (degree) Rantec 18inch Power Spectral Density Co—polarization, GEO Plane Envelope 43 dBW Tx EIRP over 4.992 MHz Close in: +/— 15 DegreesAzimuth 20 —tHlare Co—Pol 10 —tSlane Co—pol ——rec25 226 GE0 Plane as—*+—~—# _3 ——~—_ Power Spectral Density (dBW/Altts] F ” \ .00 —6.00 —3.00 2.00 3.00 6.00 2.00 1200 15.00 Asimuth Angle {degree)

Request for Experimental Special Temporary Authority Intelsat License LLC A Radiation Hazard study for the Rantec antenna is included as Attachment B. B. Satellite Points of Communications Intelsat will utilize commercial FSS satellite capacity to conduct its experimental operations. Specifically, the antennas will communicate with G-25 at 93.1ºW.L., G-19 at 97.0º W.L., IS 801 at 29.5ºW.L., IS-14 at 45ºW.L., IS-23 at 53ºW.L. (planned satellite), IS-19 at 166ºE.L. (planned satellite), T-11N at 37.6ºW.L., SES-4 at 22ºW.L. and NSS-7 at 20ºW.L. The operations proposed herein will be in compliance with the off-axis EIRP limits applicable to these satellites as set forth in the Commission’s analogous VMES and ESV rules. See 47 C.F.R. §§ 25.222 and 25.226. Commercial Ku-band satellites have been used by Intelsat for mobile VSAT operations without reported interference incidents. Given that the KuStream 1500 and Rantec antennas are specifically designed for Ku-band aeronautical operations, similar non-interfering operations can

Request for Experimental Special Temporary Authority Intelsat License LLC be expected. The terminals also have similar performance characteristics, including antenna gain, such that there transmit power levels and link performance are essentially identical. Representative link budget analyses for the KuStream 1500 operations are included below (the Rantec terminal and operations with other proposed satellites would have essentially identical link budgets).

Request for Experimental Special Temporary Authority Intelsat License 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.

on qn on nce Galaxy 19 — Forward and Return carriers Customer Support Engineering & Capacity Management Satelite and Role: c—10@er 00w Totallease resource [MHz]: 270 Link Budget Reportfor Transponder: ra0iek (Nakanam) Total DIL EIRP Availat befbp [dBWJ: 3677455 INTELSAT Plattorm bias: —100%€; 000°N Total DIL EIRP Used at bebp [dBW]: 364/452 Opportunity—1D /SERID Sat. TWT Power [Watte]: 1300 Total BW Used [MHz]: 272 Done by: bavert Date: 20 Sep 2011 Sat. DIL EIRP at befbp [dBW]: 405/403 Xp Operational Mode: MultCarrier oBo— 48 8 SFD at berbp [dBWim]: 4431027 Application: stripr se Operational Band UpDw [WMz (14207— 14274)7(MGAT— t1970) Polarization UpDw: HIV Anternas Bame "‘lfl] w x hy ar yasiq tatd [n,;'] * Tongiva °'E§é]“ * Tea [;g’] T and Country) Location (Nearest City Notes Toratrea en hus T33E «8 se2 315 3060 2eo m 357 MTN—K33 — Unied States sms [Remotes Gnd for Remotes =050° Rem—1 o4 xs to 260 Accordingto attached plot GFT @20.0°EL angle: Tina = 65.0°K; VSWRina = 22; Feed losses = 0.3 dB 100 Per GarrerLink Parameters and Resulls . Noise Space Alloc he. DL CN CCMafter| EbNo |CS EoNoafter| Link un hea nea 6 Te# Rees cemertives BW actor BW P58 RiRP thresh. as throsh. ast avatebs SBB se 880 1""T4sc 2.Type. [R OH, FEC, RS, moulation] qi|(Rokom| gukg uks em o) ts1 teel wel par gew way ce e toen MT—33E2_|_Remotes DIG (622! Maps. OH—0.0%. 0 3050 FEC. QPSK) to1ee] 120 ta20s] aaiee| se2] o2 or47 2s 2368 ontcoss ie sris 30 80| 50 na Rem1__|_MT33E2 3 x Spread (1.040 Mops. OFH0.0%, 122 FEC. BPSK) «160| 120 asge) osns| ire] 32 rerai 2s qs771 oo0seer aso too 00 08| na| No TOTAL 4 Garriers 2ra7e| 26002| 364) 18CO comments: Antenna pattern comments: Clear Siy C/N includes 15 dB additional margin fortrrestial interference, antenna mis—pointing EbNo includes 0.4 dB IF—RF degradation Notes: The total Dw—ink Avaiabiify is calculated for Up—ink Availablty better than or equal to 98.00%yr. Using Parc—3 rain model (Rice:—Holmberg),the UPC attenuator value is caleulated to provide tis Up—ink Avaiabiliy: * Analysis resuls based on today‘s operational evels ofinterference. Resulls are not quaranteed due to possible fuctuations in operational interferences over time.

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

Request for Experimental Special Temporary Authority Intelsat License LLC 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.


Document Created: 2012-05-02 14:02:26
Document Modified: 2012-05-02 14:02:26
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