Exhibit 1

0201-EX-ST-2013 Text Documents

LightSquared Subsidiary LLC, Debtor-in-Possession

2013-03-05ELS_134127

LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1

NARRATIVE STATEMENT

Pursuant to Section 5.3 and Section 5.61 of the Commission’s rules, 47 C.F.R. §§ 5.3, 5.61,
LightSquared Subsidiary LLC, Debtor-in-Possession (“LightSquared”) respectfully requests
special temporary authority (“STA”) for a four-month period, commencing as soon as possible,
for the purpose of ascertaining (i) the technical compatibility of fixed commercial wireless base
stations in the 1675-1680 MHz band with existing spectrum operations in and around that
frequency range, and (ii) the technical compatibility of radiosonde operations in the 400.15-406
MHz band with existing spectrum operations in and around that frequency range.

1. Applicant’s Name, Address, and FCC Registration Number (“FRN”).

LightSquared Subsidiary LLC, Debtor-in-Possession
10802 Parkridge Boulevard
Reston, VA 20191
FRN: 0021783881

2. Description of Operations and Purpose of Assessment.

LightSquared is a satellite service provider in the L Band, and also holds Commission authority
to conduct certain 4G LTE terrestrial wireless operations in that spectrum. LightSquared has
proposed to conduct a portion of those terrestrial operations in the 1670-1680 MHz band. 1

LightSquared currently has authority to use the 1670-1675 MHz band for terrestrial operations
nationwide. The 1675-1680 MHz band, however, currently is allocated on a primary basis for
both non-Federal and Federal use by Meteorological Aids (e.g. radiosondes) and the
Meteorological-Satellite Service (e.g., MetSats, like the GOES system). Continued use of this
band by radiosondes may not be compatible with the expected operation of the new GOES-R
satellite system that is expected to be deployed in the next few years. 2

1
       LightSquared’s September 28, 2012 license modification applications (the “License
       Modification Applications”) provide a comprehensive solution to the issues that have
       precluded the deployment of its terrestrial wireless network, and include a proposal to
       permanently relinquish its authority to conduct terrestrial downlinks in the L Band at
       1545-1555 MHz and, in lieu thereof, conduct them at 1670-1680 MHz. See IBFS File
       Nos. SAT-MOD-20120928-00160, SAT-MOD-20120928-00161, and SES-MOD-
       20121001-00872; see also Public Notice: FCC Invites Comment on LightSquared
       Request to Modify its ATC Authorization, DA 12-1863, IB Docket No. 12-340 (Nov. 16,
       2012).
2
       See International Telecommunication Union and World Meteorological Organization,
       Handbook Use of Radio Spectrum for Meteorology: Weather, Water and Climate
       Monitoring and Prediction, at 30 (2008 ed.) (“Co-channel MetAids and MetSat
       operations are not compatible and significant band segmentation has already occurred.
       MetAids cause significant levels of interference to the MetSat ground stations.”).

                                                1


LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1


The proposed assessment will examine the technical feasibility of operating fixed commercial
wireless base stations at 1675-1680 MHz, with or without also relocating radiosonde operations
in the U.S. from 1675-1680 MHz to 400.15-406 MHz (which is internationally harmonized for
radiosonde operations). This assessment will take into account existing spectrum operations in
and around those frequency ranges, and ascertain commercial operating parameters that are
needed to protect critical federal operations, including the continued, uninterrupted nature of
NOAA’s vital meteorological mission.

The proposed assessment will involve the procurement, deployment and operation of terrestrial
radio transmitters at fixed locations in the 1675-1680 MHz band (and also in the 1670-1675
MHz band to which LightSquared already has leased spectrum rights). LightSquared will
coordinate the deployment and operation of those radio transmitters at those locations in advance
with the FCC and NTIA, as may be required, including the frequencies and power levels used.

The proposed assessment also may involve the procurement, deployment and operation of
radiosonde transmitters in the atmosphere in the 400.15-406 MHz band. LightSquared similarly
will coordinate the deployment and operation of those radiosondes in advance with the FCC and
NTIA, as may be required, including the frequencies and power levels used.

LightSquared will bear the cost of procuring, deploying and operating this equipment, and of
contracting for conducting the proposed assessment through an entity that is acceptable to NTIA
and NOAA.

LightSquared will (i) work in cooperation with the FCC, NTIA, NOAA, and other interested
federal agencies to develop specific assessment plans, including identifying the specific locations
for the deployment of terrestrial radios and the salient operating parameters, (ii) allow
representatives of those federal agencies to observe and participate in the assessment, and (iii)
make any reports available to those federal agencies.

3. Public Interest Basis for STA.

Timely grant of STA would enable LightSquared to commence the assessment as soon as
possible, and thus gather data that can be used to advance a number of important policy goals.

The 1675-1680 MHz band is part of the spectrum that (i) NTIA (in consultation with the FCC)
already has identified as potentially available for wireless broadband use, and as warranting
further evaluation, 3 and (ii) LightSquared has proposed as part of the License Modification
Applications to use for its fixed wireless base stations (in lieu of the 1545-1555 MHz portion of
the L Band). See LightSquared Subsidiary LLC Request for Relief from Build-Out Conditions,

3
       U.S. Department of Commerce, Plan and Timetable to Make Available 500 Megahertz of
       Spectrum for Wireless Broadband, at 6-7 (Oct. 2010).



                                                 2


LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1

DA 12-2051, IB Docket No. 12-296, at ¶ ¶ 12, 13 (2012) (“[W]e find that it is in the public
interest to provide for an orderly deliberative process in which LightSquared will have the
opportunity to explore solutions to GPS interference concerns”).

Moreover, grant of this STA will enable the gathering of data that will facilitate the modification
of current radiosonde operations in and around the 1675-1680 MHz band that is required by the
“downshift” of a portion of the GOES-R satellite downlink channels. 4 Additionally, it will
facilitate an assessment of the cost of potentially relocating radiosondes to the 400 MHz band,
which would then inform an eventual determination of an appropriate vehicle for meeting these
costs.

For these reasons, expeditious grant of this STA would serve the public interest, convenience,
and necessity by enabling LightSquared to gather on timely basis data that will facilitate the
assessment of these types of issues by the FCC, NTIA, and other federal agencies. See 47 C.F.R.
§ 5.61(a).

4. Dates of Operation.

LightSquared requests STA for four months, commencing as soon as possible. 5 LightSquared
anticipates the proposed assessment will take from two to four months.

5. Classes of Stations.

LightSquared proposes to operate (i) wireless base stations at fixed terrestrial locations in the
1675-1680 MHz band (and also in the 1670-1675 MHz band to which LightSquared has leased
spectrum rights), and (ii) radiosondes in the atmosphere in the 400.15-406 MHz band.

6. Location of Proposed Operations.

LightSquared requests authority to conduct the proposed assessment throughout the continental
United States. As noted above, LightSquared will coordinate the deployment and operation of its
RF transmitters in advance with the FCC and NTIA, as may be required.

The terrestrial radios currently are expected to be located within a 6 to 25 km radius of Wallops
Island, VA and Suitland, MD, at sites with the following characteristics:

4
       U.S. Department of Commerce, An Assessment of the Near-Term Viability of
       Accommodating Wireless Broadband Systems in the 1675-1710 MHz, 1755-1780 MHz,
       3500-3650 MHz, and 4200-4220 MHz, 4380-4400 MHz Bands, at 1-6 (Oct. 2010).
5
       Because the STA Application Form requires an applicant to specify a “start date “and an
       “end date” for the requested authorization, LightSquared has done so. However,
       LightSquared recognizes that the Commission may not have processed the application
       fully by the specified “start date.” As discussed above, LightSquared simply seeks STA
       for four months, commencing as soon as possible.

                                                 3


LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1


 Site ID       Lat (°N)   Long (°E)    Ground   Antenna     No. of    Average   Azimuths    City
                                       Elev.    Height      Sectors   Radius    (degrees)
                                       AMSL     AGL                   (km)
                                       (feet)   (feet)
 LSSX061858    38.9314    -76.6736     245      153         1         2-3       135         Suitland
 LSSX062798    39.0448    -76.8512     365      125         1         2-3       185         Suitland
 LSSX056198    37.9872    -75.4584     221      189         1         2-3       190         Wallops
 LSSX055953    37.9397    -75.5418     311.77   275         1         2-3       105         Wallops

Two sites for each such geographic area have been selected for contingency purposes.
Additional assessments may be needed in other geographic areas as well, subject to coordination
with the FCC, NTIA, NOAA, and other interested federal agencies.

For each location of a terrestrial radio, LightSquared will provide a “Stop Buzzer” name and
phone number for that specific location as part of the federal coordination process.

LightSquared will cease operations of any particular activity if the FCC or NTIA (or another
designated agency) provides LightSquared with notice of suspected interference and will not
recommence that such activity until the FCC authorizes the recommencement of that activity.

7. Equipment To Be Used.

LightSquared will employ reliable methods to simulate 4G LTE wireless base station emissions
operating in the 1675-1680 MHz band, including assembling the required signal generators, high
powered amplifiers, RF transmit filters and the necessary antennas (e.g., Argus HPX308R,
TongYu TDJ151717DE-65, Agilent 4438C, ComTech ARD88259-50). In the 400.15-406 MHz
band, LightSquared will make use of Sippican Mark II Microsonde radiosondes and associated
telemetry equipment, and potentially also will make use of radiosonde equipment manufactured
by Vaisala. As part of the coordination process with the FCC, NTIA, and other agencies,
LightSquared will make available the technical specifications of all RF equipment used in its
assessment under this STA.

8. Frequencies Desired.

LightSquared requests operating authority at 1675-1680 MHz (for fixed base station operations),
and at 400.15-406 MHz for radiosondes.

9. Power Levels.

For the 1675-1680 MHz band: 1585 W is the maximum transmitter power output including
antenna gain.

For the 400.15-406 MHz band: 380 mW is the maximum transmitter power output including
antenna gain. Devices will be compliant with ITU RS.1165-2 for Type B digital transmitters and
thus transmit power will typically be less than the quoted maximum.
                                                4


LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1


10. Type of Emission, Modulation, and Bandwidth.

In the 1.6 GHz band, LightSquared will operate with the following emission types, modulations,
and associated bandwidths:

Type of Emission                     Modulation                     Bandwidth

5M00W7D                              QPSK                           5 MHz
5M00W7D                              16-QAM                         5 MHz
5M00W7D                              64-QAM                         5 MHz
10M0W7D                              QPSK                           10 MHz
10M0W7D                              16-QAM                         10 MHz
10M0W7D                              64-QAM                         10 MHz

In the 400.15-406 MHz band, LightSquared will operate with the following emission type,
modulation, and associated bandwidth:

Type of Emission                     Modulation                     Bandwidth

200KF1D                              FSK                            200 kHz

LightSquared has specified the emission designator and calculated the necessary bandwidth in
accordance with Sections 2.201 and 2.202 of the Commission’s rules.

11. Other Frequency Requirements/Equipment Specifications.

   Signal duty cycle: 100% loading
   Tone spacing of multiple tones are used with 15 kHz subcarrier spacing
   Antenna polarization: +/- 45 degrees cross pole
   Main beam antenna gain: 17 dBi
   Number of base station sectors: 1
   Typical radius: 2-3 km

   LightSquared’s operations in the 1675-1680 MHz band will utilize directional antennas with
   the following characteristics:

   Width of the beam in degrees at the half-power point: 65°H, 7.5°V
   Orientation in horizontal plane: Varies per transmitter site, see Section 7, above, for antenna
   azimuth information.
   Orientation in vertical plane: 3° mechanical down-tilt




                                                5


LightSquared Subsidiary LLC, Debtor-in-Possession
Experimental STA Request
Exhibit 1

12. Overall Height of Antenna(s) Above Ground.

Base station heights will be lower than 200 meters and may be placed at existing LightSquared
or industry partner base station locations to facilitate compliance with FAA requirements.

Radiosondes will be operated in the atmosphere, at heights of approximately 3-100,000 feet.

13. Contact Information.

General:

Jeffrey J. Carlisle
Executive Vice President, Regulatory Affairs and Public Policy
LightSquared Subsidiary LLC
10802 Parkridge Boulevard
Reston, VA 20191
703-390-2001

Operational and Technical:

Operational (Stop-Buzzer): Ismael Garcia (571-355-3896)

Technical: Maqbool Aliani (703-677-1267)




                                               6



Document Created: 2013-03-05 17:50:06
Document Modified: 2013-03-05 17:50:06

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC