Response to FCC Questions

0165-EX-ST-2006 Text Documents

Mobile Satellite Ventures Subsidiary LLC

2006-05-31ELS_76298

                   Answers to FCC’s Questions Dated May 5, 2006

                             FCC File # 0165-EX-ST-2006
                                    May 31, 2006

Question 1. Measured out-of-channel and out-of-band emissions data on its base
station and customer premises equipment transmitters, including the frequencies of the
second and third harmonics of the carrier frequency

The following figure and tables provide measurement data for out-of-channel emissions
(OOCE) and out-of-band emissions (OOBE) and subsequent analyses of OOCE and
OOBE for the BTS and CPE.

Figure 1 provides measurement data for the carrier spectrum mask, centered at 1553.00
MHz, at the output of the L-band Radio which is used for both BTS and CPE. The
carrier bandwidth is 4.375 MHz. Therefore, the lower and upper edge of the carrier is at
1550.81 MHz and 1555.19 MHz, respectively. 1 For the BTS, in order to achieve higher
data throughput while maintaining an adequate link margin for the downlink (BTS to
CPE), the Radio output will be further amplified by a power amplifier (see Appendix 1
for PA specifications). Please note that the PA will be operating with an 8-10 dB back-
off from the P1dB power level. Finally, to ensure that OOCE and OOBE requirements
are met, a cavity filter is installed between the output of the PA and the input of the
antenna (see Appendix 2 for cavity filter specifications). Please note that the
measurements show the center marker at 1552.87MHz, instead of 1553.00MHz, as the
latter is the DC tone and its amplitude is not indicative of traffic tones.




1
  On this day, MSV has filed an amendment to its pending application to modify slightly
its center frequency. The center frequency and frequency range listed in the original
application were incorrectly specified due to miscommunication with the equipment
manufacturer.


                                       Page 1 of 15


Figure 1: Carrier Spectrum Mask Measurements




                 Page 2 of 15


BTS OOCE Analysis
The following table provides analysis of OOCE from trial BTS into adjacent MSS L-
band.

                        Analysis of OOCE from BTS into Adjacent Band
                Parameter                    Trial     Units             Remarks
            Transmit Frequency              1553.0      MHz
              Number of BTS                     1
           BTS PA Output Power                 10       dBW
            BTS Tx Bandwidth                 4.375      MHz
             Transmission loss                -2.0       dB
      BTS Tx PSD (at antenna input)            1.6   dBW/MHz
              Activation Loss                -1.25       dB      TDD 3:1
              OOCE Rejection                 -45.3      dBc       @ 1550.00MHz
              Additional Filter              -25.0       dB       @ 1550.00MHz
    Effective BTS OOCE power density         -70.0   dBW/MHz
       OOCE Limit for L-band BTS             -57.9   dBW/MHz
          (47 C.F.R. § 25.253(b))
                 Margin                     12.1        dB

CPE OOCE Analysis
The following table provides analysis of OOCE from trial CPE into adjacent MSS L-
band.

                          Analysis of OOCE from CPE into Adjacent Band
                 Parameter                     Trial     Units              Remarks
             Transmit Frequency               1553.0     MHz
              Number of CPEs                     10
               CPE PA Output                    -12      dBW
            CPE Tx Antenna Gain                  12       dBi
             CPE Transmit EIRP                    0      dBW
             CPE Tx Bandwidth                  4.375     MHz
                CPE Tx PSD                      -6.4   dBW/MHz
               Activation loss                -16.02      dB       TDD 3:1; 10 CPEs in TDMA
              OOCE Rejection                   -45.3      dBc      @ 1550.00MHz
     Effective CPE OOCE EIRP density           -67.8   dBW/MHz
      OOBE Limit for Broadband PCS              -43    dBW/MHz
           (47 C.F.R. § 24.238(a))
                 Margin                      24.8       dB




                                     Page 3 of 15


BTS OOBE Analysis into GPS

The following table provides analysis of OOBE from trial BTS into GPS band.

                              Analysis of OOBE from BTS into GPS
                Parameter                     Trial     Units            Remarks
            Transmit Frequency               1553.0      MHz
              Number of BTS                      1
          BTS PA Output Power                   10      dBW
             Transmission loss                  -2        dB
           BTS Tx Antenna Gain                  16       dBi
            BTS Transmit EIRP                   24      dBW
            BTS Tx Bandwidth                  4.375      MHz
               BTS Tx PSD                      17.6   dBW/MHz
              Activation Loss                  0.00       dB
 OOBE Rejection in GPS band@1558.5MHz         -60.5      dBc
             Additional Filter                -60.0       dB
    Effective BTS OOBE EIRP density          -102.9   dBW/MHz
   OOBE Limit for L-band BTS and User         -70.0   dBW/MHz
                Terminals
     (47 C.F.R. § 25.253(c)(9), (g)(3))
                 Margin                     32.9        dB




                                     Page 4 of 15


CPE OOBE into GPS

The following table provides OOBE from trial CPE into GPS band.

                              Analysis of OOBE from CPE into GPS
                Parameter                     Trial     Units             Remarks
            Transmit Frequency               1553.0     MHz
             Number of CPEs                     10
          CPE PA Output Power                  -12      dBW
           CPE Tx Antenna Gain                  12       dBi
            CPE Transmit EIRP                    0      dBW
            CPE Tx Bandwidth                  4.375     MHz
               CPE Tx PSD                      -6.4   dBW/MHz
              Activation loss                -12.04      dB      TDD 3:1; 10 CPEs in TDMA
 OOBE Rejection in GPS band@1558.5MHz         -60.5      dBc
    Effective CPE OOBE EIRP density           -79.0   dBW/MHz
   OOBE Limit for L-band BTS and User          -70    dBW/MHz
                Terminals
     (47 C.F.R. § 25.253(c)(9), (g)(3))
                  Margin                        9.0         dB




Regarding the second and third harmonics power density, measurement data in Figure 1
show that the power density of the second and third harmonics of the carrier are at a noise
level of approximately -106.00 dBW/MHz.




                                       Page 5 of 15


Question 2. Indicate the latitude/longitude/elevation coordinates of its base station
transmitting antenna and the azimuth of the peak of the main lobe of the base station
antenna

The specifics of the BTS are:

   •   Coordinates:
          o Latitude:       38 deg 56 min 44 sec N
          o Longitude: 77 deg 18 min 58 sec W
   •   Elevation: 367 ft AMSL
   •   Antenna radiation center: ~90 ft AGL
   •   Azimuth of peak antenna gain: 200 deg. TN
   •   Address:
       10780-10790 Parkridge Blvd
       Reston, VA 10191




                                      Page 6 of 15


Question 3. Clarify its base station transmitting antenna pattern with regard to
beamwidth in the vertical and horizontal planes.

The BTS antenna specifications are:

   •   Peak gain: 16 dBi
   •   Vertical beamwidth: 7 degrees
   •   Horizontal beamwidth: 63 degrees
   •   Tx Polarization: Left hand circular




                                      Page 7 of 15


Question 4. Provide the maximum EIRP of its customer premise equipment
transmitters.

The maximum EIRP of the CPE is set at 0 dBW (1Watt).




                                   Page 8 of 15


Question 5. Provide the geographic boundaries inside which it will operate its customer
premises equipment transmitters in terms of latitude/longitude coordinates.

The table below provides the link budget for both the downlink (BTS to CPE) and uplink
(CPE to BTS). As for most wireless systems, the coverage radius of this trial network is
also limited by the uplink path, due to the lower CPE EIRP relative to that of the BTS.
The radius also depends on the height of the CPE. Based on the link budget shown, the
service radius for this experiment ranges from 1.1 km (assuming a CPE antenna height of
1.5 meters) to 2.1 km (assuming a CPE antenna height of 5 meters). The effective
service area of the BTS is also determined by the BTS transmit/receive antenna’s
physical and electrical characteristics. As indicated in sections above, the BTS transmit
and receive antennas have 60 degree beamwidth and will be pointed at 200 degree TN.
The predicted coverage area is depicted in Figure 2.




                                       Page 9 of 15


Frequency band (MHz)                                 1553

Forward Link Budget                              Units
BTS RF PA output                                     dBm       50         50
Tx Backoff (peak-to-average)                          dB       10         10
Average BTS RF PA output                             dBm       40         40
BTS antenna gain (dBi)                               dBi       16         16
Incoherent power gain (4 antennas)                    dB        0         0
BTS Cable loss                                        dB       1.5       1.5
BTS EIRP                                             dBm      54.5       54.5
MS antenna gain (dBi)                                dBi      12.0       12.0
Coherent gain                                        dB          0         0
Channel bandwidth                                    MHz      4.375      4.375
FFT size                                                      256.0     256.0
Active Subcarriers                                            200.0      200.0
Oversampling                                                   5.00       5.00
Subcarrier spacing                                Hz        19531.25   19531.25
MS noise figure                                   dB             4         4
Thermal noise                                   dBm/Hz        -174       -174
Modulation scheme                                           QPSK-1/2   QPSK-1/2
MS SNR requirement for QPSK 1/2                   dB           5.5        5.5
Noise floor                                     dBm/Hz        -170       -170
Required instantaneous signal level              dBm          -98.1      -98.1
Log-Normal Fade Margin                            dB            7.0       7.0
Rayleigh fade margin                              dB           0.0        0.0
Penetration loss( in-building/in-car)             dB             0         0
Interference Margin                               dB            0.0       0.0
Max path loss based on traffic EIRP               dB          157.6     157.6
Reverse Link Budget                              Units
MS average PA output                             dBm          18.0       18.0
MS antenna gain (dBi)                             dBi         12.0       12.0
MS EIRP                                          dBm          30.0       30.0
Coherent gain                                     dB          0.0        0.0
BTS cable loss                                    dB           1.5       1.5
BTS Receive antenna gain (dBi)                    dBi          16         16
Number of subcarriers/subchannel                              200        200
Subchannelization gain                                dB      0.00       0.00
MRC (diversity) gain                                  dB        0          0
BTS SNR requirement for QPSK 1/2                      dB      5.5        5.5
BTS noise figure                                      dB        4          4
Required signal strength                             dBm     -98.1      -98.1
Log-Normal Fade Margin                                dB       7.0        7.0
Rayleigh fade margin                                  dB       0.0       0.0
In-Building penetration loss                          dB       0.0       0.0
Interference Margin                                   dB       0.0       0.0
Max path loss based on traffic EIRP                   dB     135.6      135.6
CPE Antenna Height                                           1.5 m       5m
Estimated Coverage Radius                            km       1.11       2.11


                                     Page 10 of 15


              Figure 2: Predicted Coverage Area




                                                       Predicted
                                                       Coverage
                                                       Area

                                                       1 in = 0.7km

38o 56’ 27”
77o 19’ 29”                                       38o 56’ 24”
                                                  77o 18’ 57”



38o 56’ 07”
                                                  38o 55’ 50”
77o 19’ 48”
                                                  77o 19’ 06”




                                                  38o 55’ 45”
                                                  77o 19’ 34”




                        Page 11 of 15


Question 6. Provide an analysis showing that the reverse-band operation is no more
interfering than forward-band operation

         The proposed experimental operations are neither “reverse-band” nor “forward-
band,” as those terms have been defined by the FCC. 2 Rather, the proposed experimental
network is based on the WiMAX 802.16d standard and uses the Time Division Duplex
(TDD) access scheme. With TDD, both the BTS and CPE transmit and receive in the
same frequency band. For this proposed experiment, both the BTS and CPE will transmit
and receive using the following frequencies in the 1.5 GHz MSS L band downlink:
1550.81-1555.19 MHz. The carrier frequency is 4.375MHz wide and centered at
1553.00 MHz. There will be no transmissions in the L band MSS uplink (1.6 GHz).
Moreover, the BTS and CPE will operate in terrestrial mode only; there will be no
satellite operations pursuant to this experiment.

        The proposed experimental TDD network will cause no more interference than
that permitted by the forward-band ATC network permitted by the FCC’s rules. Pursuant
to the FCC’s rules, MSV is permitted to operate an unlimited number of L band ATC
base stations in the 1.5 GHz band at a maximum EIRP of 31.9-10*log (number of
carriers) dBW/200kHz, per sector, for each carrier. 3 Under the proposed experimental
operation, MSV will operate a total of 11 transmitters in the 1.5 GHz band using its
licensed frequencies at temporary fixed locations at an EIRP well below that permitted by
the FCC’s rules for ATC base stations. Moreover, the one BTS used for this experiment
will transmit in one 60º sector only, thereby further limiting the potential for interference.




2
       The FCC has explained that with “reverse band” operations, mobile terminals
transmit in the downlink band and base stations transmit in the uplink band. With
“forward band” operations, mobile terminals transmit in the uplink band and base stations
transmit in the downlink band. See Flexibility for Delivery of Communications by MSS
Providers, Report and Order, IB Docket No. 01-185, 18 FCC Rcd 1962 (February 10,
2003) (“ATC Order”), at Appendix C1 at § 1.0.
3
       See 47 C.F.R. § 25.253(d)(1); see also Mobile Satellite Ventures Subsidiary LLC,
Order and Authorization, DA 04-3553 (Chief, International Bureau, November 8, 2004)
(“MSV ATC Decision”), at ¶ 83.


                                        Page 12 of 15


Appendix 1: BTS PA Specifications




          Page 13 of 15


Appendix 2: BTS Filter Specifications




            Page 14 of 15


Page 15 of 15



Document Created: 2006-05-31 17:25:43
Document Modified: 2006-05-31 17:25:43

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