Exhibit B Interference Analysis

0961-EX-CN-2018 Text Documents

Swarm Technologies, Inc.

2018-12-01ELS_220523

Swarm Technologies Inc. Exhibit B to FCC Form 442 FCC File No. 0961-EX-CN-2018 Exhibit B - Interference Study Interference and Electromagnetic Compatibility Study The experimental Swarm satellite network, which includes satellites and US ground stations and ground devices, employs the 137-138 MHz band for space-to-earth links1 and the 148-150.05 MHz band for earth-to-space links, consistent with the US and International Table of Frequency Allocations. To demonstrate compliance with an experimental system’s obligation to operate on a non-interference basis with other authorized operators in the bands, this report provides a study of compatibility with other systems operating in the 148-150.05 MHz band. Statement of Satellite Service System Compatibility For this experimental deployment, Swarm proposes to operate on the 148.300-148.420 MHz band in the Earth-to-space direction (accommodating four channels; see accompanying Exhibit A: Narrative for additional details). From the ITU Space Network Systems Online (SNS), a list of satellite systems using the 148-150.05 MHz band was collected and shown in Table 1. For each satellite system, the table indicates the administrative jurisdiction, service areas, frequency overlaps, and ultimately a disposition for a coordination requirement. Most satellites have either no frequency overlap with Swarm satellites, have no area coverage overlap, or have no apparent earth stations in the USA. In addition, a search of the FCC IBFS for the 148-150.05 MHz band show that only Orbcomm is licensed for a space system using these space services links within the United States. In summary, only Orbcomm requires some form of coordination for operations in the USA. Swarm will seek consent from Orbcomm regarding those systems. There are several ​other satellite systems shown in Table 1 deserving additional attention: EBSAT-LEO-1, EBSAT-LEO-1B, MNSAT, and NSL-1. In each of these cases there is potential frequency overlap and the USA is a designated coverage area in the ITU notices. However, none of these systems have launched yet, and no US licenses or applications were submitted to the FCC as of November 2018. The EBSAT-LEO-1 and -1B systems are planned Mobile Satellite Service constellations by Thales Alenia Space filed through the French administration. The MNSAT system is a planned Mobile Satellite Service constellation filed through the Australian administration. The NSL-1 system is a planned constellation by NSLComm, filed through Israel. For each of these systems, the status of the launch authorization licensing and construction progress of the systems is unknown by Swarm, and the systems have no space system licensing within the United States. As such, no coordination is required with these systems. Two additional satellite systems listed in Table deserving additional discussion are KELYPSIS and HOL-MG-A006. The KELYPSIS system is a planned constellation by Kepler Communications with an 1 The ground stations and ground devices for which authorization is requested will receive transmissions from previously authorized satellites (see 1140-EX-ST-2018 and 0976-EX-ST-2018) on the downlink frequencies granted in the respective STAs or experimental licenses. As such, this application and interference study reflects only the uplink frequencies.

Swarm Technologies Inc. Exhibit B to FCC Form 442 FCC File No. 0961-EX-CN-2018 ITU filing through Canada. Kepler filed for US market access (IBFS File No. SAT-PDR-20161115-00114), but only requested access to the 10.7-12.7 GHz and 14-14.5 GHz frequency bands in the United States. No request was made to the Commission for access to frequencies in the 148-150.05 MHz band, so coordination with Kepler will not be required. The HOL-MG-A006 system is a planned constellation by Hiber (formerly Magnitude Space), licensed by the Netherlands. Hiber filed for US market access (IBFS File No. SAT-PDR-20180910-00069), but only requested access to the 399.9-401 MHz bands. No request was made to the Commission for access to frequencies in the 148-150.05 MHz band, so coordination with Hiber will not be required. In these tables, red-colored boxes indicate frequency overlap between the respective system in the row and the Swarm satellite. Green rows indicate some level of coordination or additional consideration is required for the system. Table 1: ​List of Satellite Systems in the ITU SNS, transmitting 148-150.05 MHz. Satellite Country Service Area Freq. Overlap Coordination Notes (closest freq. requirement shown) AGILE Italy XVE 149.0 None Equatorial NGSO, no orbital space-to- (2 MHz) access to USA space link ATS-5 USA GEO 148.26 None No frequency overlap NC ES (30 kHz) CASSIOPE-1A Canada XAA 150.005 None No frequency overlap EBSAT-LEO-1 France XAA 148-150.05 None Not launched yet? No US license/stations EBSAT-LEO-1B France XAA 148.150.05 None Not launched yet? No US license/stations GOES West USA GEO 148.545 None No frequency overlap Wallops VA HOL-MG-A006 Nether XAA 148-149.9 None Not launched yet? lands Magnitude Space (Hiber). Filed for US market access (IBFS File No. SAT-PDR- 20180910-00069), but only requested access to 399.9-401 MHz bands. No area overlap for 148-149.9 MHz band. IMP-J USA AK, NC ES 148.98 None No frequency overlap Inactive, (30 kHz) 1970’s IPS Nether HOL 148.118 None No area or frequency overlap lands IRS-1B, 1E India India 149.522 None No area or frequency overlap (12 kHz) KELYPSIS Canada XAA 148-150.05 None Kepler Communications, filed for US market access (IBFS File No. SAT- PDR-20161115-00114), but

Swarm Technologies Inc. Exhibit B to FCC Form 442 FCC File No. 0961-EX-CN-2018 only requested access to 10.7-12.7 GHz and 14-14.5 GHz frequency bands. No area overlap for 148-150.05 MHz band. KITSAT-3 Korea Korea 148.025,148.9 None No area or frequency overlap (20 kHz) LEOTELCOM-1 USA XAX 148-150.05 Orbcomm To be coordinated with Consent Orbcomm LEOTELCOM-2 USA XAX 148-148.905 Orbcomm To be coordinated with Consent Orbcomm LEOTELCOM-3 USA XAX 149.81-149.9 None No frequency overlap LEOTELCOM-5 USA XAA 148-150.05 Orbcomm To be coordinated with Consent Orbcomm LUOJIA-1A China CHN 148.35-148.4 None No area overlap LUX-NGSO Luxemb XAA 149.0-151.0 None No frequency overlap -1/2/3 ourg MCSCS China XAA 149.025 None No frequency overlap No US (44 kHz) stations MNSAT Australia XAA 148-150.05 None Not launched yet? No US license/stations NSL-1 Israel XAA 148-149.9 None Not launched yet No US license/stations QS-1 China CHN ...148.025 None No area or frequency overlap RS-D2 India IND (India) ...148.265 None No area or frequency overlap Inactive, 1980’s SAMSON-2 Israel ISR 148.8... None No area or frequency overlap S4P Swiss HOL, SUI 148.2635 None No area overlap -148.5865 SAUDISAT-1C Saudi ARS 149.025 None No area or frequency overlap Arabia (Saudi (44 kHz) Arabia) SAUDISAT-4, -5, Saudi ARS 148.035, None No area or frequency overlap -6 Arabia 148.085, 149.035 (30 kHz) SEO India IND ...148.265, None No area or frequency overlap BHASKARA-1 148.595... Inactive, 1980’s SEO India IND ...148.265, None No area or frequency overlap BHASKARA-2 148.595... Inactive, 1980’s SIMBA Belgium HOL ...148.118 None No area or frequency overlap SI-SAT-BILIKIK Solomon XAA 149.025 None No frequency overlap I Island (100 kHz) No US license/stations SROSS-1,-3 India IND 149.272... None No area or frequency overlap TELEOS-1 SNG SNG 148.6875... None No area or frequency overlap TSYKADA Russia XAA 149.903... None No frequency overlap YOUTHSAT India XAX 149.995... None No frequency overlap

Swarm Technologies Inc. Exhibit B to FCC Form 442 FCC File No. 0961-EX-CN-2018 Conclusion Swarm’s experimental testing with ground stations and ground devices poses no risk of creating harmful interference with any known system with the exception of Orbcomm. Swarm will seek specific consent from Orbcomm to mitigate any potential for interference with their system.2 2 On November 29, 2018, Swarm contacted Orbcomm, the only mobile satellite service provider licensed to conduct commercial operations in the United States in the 148-150.05 MHz bands, to initiate coordination to prevent interference with Orbcomm’s system. Coordination between Swarm and Orbcomm remains ongoing. Swarm appreciates that operations in the proposed VHF frequencies must occur on a sufferance basis, and Swarm cannot create interference and must accept interference from other authorized users. Should the Commission act prior to the conclusion of discussions with Orbcomm, Swarm will accept a condition on its grant of experimental authority that requires successful coordination prior to the initiation of communications.


Document Created: 2019-02-14 14:19:29
Document Modified: 2019-02-14 14:19:29
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