Narrative

1129-EX-ST-2019 Text Documents

Kepler Communications Inc.

2019-06-19ELS_232561

                                                                    Kepler Communications Inc.
                                                                          196 Spadina Avenue, Suite 400
                                                                                    Toronto, ON Canada
                                                                                               M5T 2C2

                                           EXHIBIT A
                                            DESCR IPTION


        Kepler Communications (“Kepler”) hereby requests special temporary authority beginning

on June 26, 2019 and continuing for 90 days thereafter to operate a Sea Tel 9711 earth station in

Ku-band for a testing and proof-of-concept demonstration in Concord, California. The requested

operations are necessary to continue engineering efforts in relation to the delivery of Fixed Satellite

Services to customers in the scientific, oil and maritime sectors. This authorization will enable the

development of core user terminal functionality and compatibility ahead of commercial

deployment, allowing Kepler to deliver the service described in its market access grant in a timely

fashion.1 Delay or rejection of this request would jeopardize this ability and strongly prejudice the

public interest.

        Terminals will operate within the 11.7 – 12.2 GHz and 14.0 – 14.5 GHz bands for downlink

and uplink respectively. All transmissions in these bands will conform to the applicable power flux

density and equivalent power flux density levels specified by Article 21, Article 22, and Resolution

76 of the ITU Radio Regulations.

        In accordance with 47 C.F.R. § 17.7(e)(3), a notification to the FAA is not required for any

antenna structure of 6.10 meters (20 feet) or less in height, except one that would increase the




1
 See Kepler Communications Inc., Petition for Declaratory Ruling to Grant Access to the U.S. Market for
Kepler’s NGSO FSS System, Order and Declaratory Ruling, FCC 18-162 (Nov. 19, 2018).


June 19 2019                           Kepler Communications Inc.                                 1 of 2


                                                                  Kepler Communications Inc.
                                                                        196 Spadina Avenue, Suite 400
                                                                                  Toronto, ON Canada
                                                                                             M5T 2C2
height of another antenna structure. Kepler hereby certifies that the construction of the antennas

associated with this application will not exceed the minimum height requirement specified in the

above-mentioned limit.




Respectfully Submitted


/S/ Nickolas G. Spina
Nick G. Spina
Director, Launch & Regulatory Affairs




June 19 2019                         Kepler Communications Inc.                                 2 of 2



Document Created: 2019-06-19 17:50:45
Document Modified: 2019-06-19 17:50:45

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