Exhibit A

0309-EX-ST-2007 Text Documents

Mobile Satellite Ventures Subsidiary LLC

2007-06-08ELS_81643

                                        Exhibit A
I.     Overview

        Mobile Satellite Ventures Subsidiary LLC (“MSV”) requests an experimental
Special Temporary Authority (“STA”) to conduct a limited test and demonstration of the
Ancillary Terrestrial Component (“ATC”) portion of its next-generation Mobile Satellite
System (“MSS”) using L band spectrum coordinated for MSV and Mobile Satellite
Ventures (Canada) Inc.1 Among other things, MSV will use the STA to test and
demonstrate the provision of a variety of key broadband communications applications for
public safety users. These will include transmissions of video and accessing of CAD
drawings by firefighters on the scene of a fire, transmissions of video and monitoring
data by an ambulance at the scene of an auto accident, use of a surveillance camera by
police, transmissions of Amber Alerts, and coordination of the response to a chemical
spill. See Exhibit D. Based on the public interest benefit of the rapid development of
such public safety services, MSV seeks expedited processing of this application.

        The WiMAX system to be tested and demonstrated consists of six (6) base station
sites and up to 100 portable and fixed customer premise equipments (CPE). MSV will
locate the base station sites within the vicinity of the Reston and McLean, Virginia areas.
CPEs will operate within a 5 mile radius of the Reston Town Center site, defined below.

       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.3 With TDD, both the base transceiver stations (BTS) and CPE


1
  These frequencies do not include any of the “disputed” (also known as “loaned”)
frequencies between MSV and Inmarsat, as discussed in MSV’s June 20, 2006 letter. See
Letter from Jennifer A. Manner, MSV, to Ms. Marlene H. Dortch, FCC (June 20, 2006).
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
 MSV currently holds a license to operate an Ancillary Terrestrial Component (ATC) in
the L band, but this license does not yet include authority to operate using the WiMAX
air interface. MSV understands that a grant of this experimental STA is without
prejudice to the Commission’s consideration of MSV’s pending request to add the
WiMAX air interference to its ATC license. See MSV, Application, File Nos. SAT-
MOD-20051104-00212, SAT-MOD-20051104-00211, SES-MOD-20051110-01561


                                           -1-


transmit and receive in the same frequency band. The system will use carriers occupying
the following frequency ranges:
                            CPE and BTS Frequencies (MHz)
                            From           To          Center
                          1552.500      1556.000      1554.250
                          1652.620      1656.120      1654.370
                          1656.120      1659.620      1657.870

        MSV has completed all necessary coordination within its MSS system to avoid
interference to its existing MSS customers. MSV has contacted AFTRCC to coordinate
with any nearby Mobile Aeronautical Telemetry facilities and will update the application
when that process is complete.

        The test and demonstrations will entail terrestrial transmissions only; there will be
no satellite operations pursuant to this experiment. The equipment to be operated
pursuant to this STA is strictly for testing and demonstration purposes only and will
not be deployed commercially.

        MSV is in the process of evaluating and developing the technologies for its hybrid
MSS-ATC network. The key objectives of this trial are (i) validation of link budget
validation; (ii) assessment of system performance (e.g.. throughput); and (iii) verification
of applications.

        The CPE will be of two types: (i) a WiNetworks wireless router with WiMax
capability added, called the “Gateway” CPE; and (ii) a Kyocera PCMCIA card that can
be inserted into conventional personal computers.

        Five of the six BTS installations will be on buildings, and the sixth will be on a
tower, the Wireless Communications Tower (Columbia Gas). While the tip of the antenna
on the tower will be 53.6 meters above ground level, the top of the tower is 58 meters
above ground level. Therefore, the addition of the antenna for the MSV trial does not
increase the height of the existing tower and poses no additional threat to aviation. BTS
will be installed at the following locations:




(November 4, 2005); MSV, Application, File No. SAT-MOD-20070117-00012 (January
17, 2007).


                                            -2-


                                                                  Antenna
                                                                  Base Elev
          Site name                     Site address               (AGL)                     Lat                  Long.
                                   1760 Reston Parkway,
    Reston Town Center                                               19.2               38-57-51.78N           77-21-16.50W
                                     Reston, VA 20190

                                   13101 Worldgate Drive,
  Worldgate Marriott Hotel                                           43.1               38-57-34.26N           77-24-00.60W
                                     Herndon, VA 20170

                                 11800 Sunrise Valley Drive,
 Reston International Center                                         49.9               38-56-58.20N           77-21-20.70W
                                     Reston, VA 20191

                                   10802 Parkridge Blvd,
       Parkridge Five                                                20.9               38-56-42.59N           77-18-53.95W
                                     Reston, VA 20181

   U.S. Geological Survey        12201 Sunrise Valley Drive,
                                                                     34.6               38-56-54.50N           77-22-05.94W
          (USGS)                     Reston, VA 20192

  Wireless Communications              11000 Route 7;               51.8m               38-59-21.00N           77-19-35.00W
   Tower (Columbia Gas)               Dranesville, VA
                                    Site Elevation: 107m




Each site will use separate antennas for transmit and receive functions. Each site will
transmit in each of three azimuths: 0° (North), 120°, and 240°. Therefore, each of the six
(6) sites will be equipped with six antennas and three base transceivers, for a total of 36
antennas and 18 base transceivers.


                                                                                       Fixed CPE

                             North 0°
                                                                    Portable
                                                                     CPE                      Fixed CPE
                                    120°
                      240°
                                                                            Portable
                                                                             CPE
                                                                                                   Fixed CPE
 Nortel
                                                                          Portable
  BTS                                                                      CPE

                 1 of 6 Sites
                                                               Portable                      Fixed CPE
                                                                CPE



                                                                                Fixed CPE


                                 Figure 1: Network Overview


                                                -3-


II.       Interference Analysis

        Each base transceiver or CPE will transmit a 3.5 MHz wide carrier centered at
1554.25, 1654.37, or 1657.87 MHz. The interference considerations are different for the
1.5 GHz frequency and the 1.6 GHz frequencies and are considered separately. As
discussed below, 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.

          A.     Transmissions in the 1.6 GHz Band

                 1.     Base Station Transmissions in the 1.6 GHz Band

         Each of the three base transceivers at each of the six locations will transmit in
one 60º sector. The peak EIRP of each base transceiver will be 23.9 dBW, which is
outside the range (12-16 dBW) that MSV’s authorized and existing satellite-only mobile
earth terminals (“METs”) operate. However, as shown below, the radiated power
spectral density from the BTS will be much lower than that of MSV’s existing METs
because of the difference in bandwidth of the signals (3500 kHz for the base transceivers
and 6 kHz for the existing METs). Further, the antennas will be mounted with a main
beam down-tilt of 5° so that the EIRP toward the horizon will be lower, 17.4 dBW, and
the EIRP above the horizon will be lower still.

                                              MSV        BTS
                                             MSS MET (per Sector)
                       EIRP (dBW)              16        23.9
                       Bandwidth (kHz)          6       3500
                       EIRP Density (dBW/Hz)  -21.8     -41.5

       Therefore, the BTS transmissions in the 1.6 GHz band have less potential for
causing interference to satellite receivers than do MSV’s currently authorized satellite
METs.

       In addition, base transceivers transmitting in the 1.6 GHz band will meet the
following out-of-channel emission (OOCE) limits.

      •   The EIRP density will not exceed -100 dBW/MHz in the 1559-1610 MHz band
          which is consistent with the out-of-band emission limit that MSV previously
          committed to meet and which is more stringent than the limits specified in the
          Commission’s rules.4
4
 See MSV and U.S. GPS Industry Council ex parte presentation, IB Docket No. 01-185 (July 17,
2002); MSV ex parte presentation, IB Docket No. 01-185 (July 29, 2002); Application of Mobile
Satellite Ventures Subsidiary LLC, File No. SAT-MOD-20031118-00333 et al. (Nov. 18, 2003);
Mobile Satellite Ventures Subsidiary LLC, Order and Authorization, DA 04-3553 (Chief,
International Bureau, November 8, 2004).


                                            -4-


    •   There is 2.5 MHz separating the low edge of the base transceiver carrier and the
        high edge of the nearest Inmarsat spectrum. The base transceiver will meet an
        EIRP density of -90.3 dBW/4 kHz into that adjacent spectrum.


               2.     CPE Transmissions in the 1.6 GHz Band

         The BTS is expected to have a range of less than 1.0 kilometer. Thus, the CPEs
will be within approximately that distance when operating with the BTS. The CPEs will
operate in time-division duplex (TDD) mode. The CPE will transmit a 3.5 MHz wide
OFDM signal centered at 1654.37 or 1657.870 MHz and receive the same type of signal
at the same frequency from the terrestrial BTS. The peak EIRPs of the mobile CPEs in
terrestrial mode will be -9.0 dBW for the PCMCIA card and -1.0 dBW for the Gateway,
both of which are well below the power of MSV’s authorized and existing satellite-only
METs (12-16 dBW). Further, the radiated power spectral density from the mobile CPE
will be much lower than that of MSV’s existing satellite METs because of the difference
in bandwidth of the signals (3500 kHz for the mobile CPE and 6 kHz for the existing
METs).

       Therefore, the CPE transmissions in the 1.6 GHz band have less potential for
causing interference to satellite receivers than do MSV’s currently authorized METs.

        With respect to OOCE limits, CPE transmitting in the 1.6 GHz band will comply
with the OOCE limits specified in the FCC’s rules for ATC mobile terminals transmitting
in the 1.6 GHz band of -67.0 dBW/4 kHz. 47 C.F.R. § 27.253(g)(1). Further, the EIRP
density will not exceed -90 dBW/MHz in the 1559-1605 MHz, increasing linearly to no
more than -66 dBW/MHz at 1610 MHz thus satisfying the out-of-band emission limit
that MSV previously committed to meet, which is more stringent than the limits specified
in the Commission’s rules.

        B.     Transmissions in the 1.5 GHz Band

               1.     Base Station Transmissions in the band 1.5 GHz Band

        Pursuant to the FCC’s rules, MSV is permitted to operate an unlimited number of
L band ATC base transceivers stations in the 1.5 GHz band at a maximum EIRP of 31.9-
10*log (number of carriers) dBW/200 kHz, per sector, for each carrier.5 Under the
proposed experimental operation, MSV will operate a total of 18 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. Each of the three base
transceivers at each of the six locations will transmit in one 60º sector only. The peak

5
 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.


                                           -5-


EIRP of each BTS will be 17.4 dBW. Thus, the EIRP density will be 5 dBW/200 kHz,
well below the 31.9 dBW/200 kHz limit.

       With respect to OOCE limits, BTS transmitting in the 1.5 GHz band will comply
with the OOCE limits specified in the FCC’s rules for ATC BTS transmitting in the 1.5
GHz band.

    •   The power density into the base transceiver antenna will not exceed -57.9
        dBW/MHz in the adjacent channel. 47 C.F.R. § 27.253(b).

    •   The EIRP density will not exceed -100 dBW/MHz in the 1559-1610 MHz, thus
        satisfying the out-of-band emission limit that MSV previously committed to meet,
        which is more stringent than the limits specified in the Commission’s rules.

               2.     CPE Transmissions in the band 1.5 GHz6

        The BTS is expected to have a range of less than 1.0 kilometer and thus the CPEs
will be within approximately that distance when operating with the BTS. The CPEs will
operate in time-division duplex (TDD) mode. The CPE will transmit a 3.5 MHz wide
OFDM signal centered at 1554.250 MHz and receive the same type of signal on the same
frequency from the terrestrial BTS. The peak EIRPs of the mobile CPE in terrestrial
mode will be -9 dBW for the PCMCIA card and -1.0 dBW for the Gateway. Thus, the
total aggregate EIRP from the 100 CPEs in the trial if all were to transmit at the same
time (which is not likely to occur) would be 11 dBW, much less than that of a single BTS.
Moreover, the testing will occur in only a limited area, within five miles of the Reston
Town Center site.

       In addition to the foregoing, CPE transmitting in the 1.5 GHz band will comply
with the following limits:
   • CPE transmitting in the 1.6 GHz band will comply with the OOCE limits
       specified in the FCC’s rules for ATC mobile terminals transmitting in the 1.6
       GHz band of -67.0 dBW/4 kHz. 47 C.F.R. § 27.253(g)(1).

    •   The EIRP density will not exceed -90 dBW/MHz in the 1559-1610 MHz, which is
        consistent with the out-of-band emission limit that MSV previously committed to
        meet and which is more stringent than the limits specified in the Commission’s
        rules.

    •   MSV’s CPE and BTS will not transmit in the 1541.5-1547.5 MHz band.

    • MSV CPE OOCEs from terminals into the 1452-1525 MHz band will not exceed
    the limit of -90.3 dBW/4 kHz.

6
 MSV notes that the Office of Engineering and Technology previously authorized MSV
to conduct CPE transmissions in the 1.5 GHz band. See WC9XRS.


                                           -6-


•      There will be no direct terminal-to-terminal communications without the use of a base
       station.

•      MSV will coordinate any BTS whose service radius extends to 1 km or less from a
       SARSAT receive station operating in the 1544-1555 MHz band. The nearest
       SARSAT receive station is about 33 km away.

•      MSV will coordinate any BTS whose service radius extends to 1 km or less from a
       Mobile Aeronautical Telemetry receive site. However, the nearest Mobile
       Aeronautical Telemetry site is more than 100 km away.

III.      Other

       Contemplated Hours of Operation. The BTS and CPE will be capable of
operating 24 hours per day and 7 days per week.

        Given the limited nature of this testing, MSV is confident that this experimental
operation will not result in interference to other spectrum users. MSV will also ensure
that this testing does not result in interference to its existing customers. MSV will keep
records of the dates and times when operations are conducted pursuant to this
experimental authority.

       MSV acknowledges that operations pursuant to an experimental STA are strictly
on a non-harmful interference basis. MSV’s Network Operations Center (“NOC”) can be
contacted 24 hours/7 days per week in the event of interference concerns at the following
address and number:

              Mobile Satellite Ventures LP
              10802 Parkridge Boulevard
              Reston, VA 20191
              1-800-216-6728
********************************************************************




                                             -7-



Document Created: 2007-06-08 13:03:45
Document Modified: 2007-06-08 13:03:45

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC