WTB coordination response

0884-EX-ST-2015 Text Documents

ViaSat, Inc.

2015-08-25ELS_166349

                                                                                                               #03/iz/i5+00/o2f15
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$2935       SAT—LOI—20141029—00118       182014002150
O3b Limited                                                                       File#_SBT— LOL— 2oltio29— oons                 SAt— AMD—20150115 — coco4
03B

                                                                                  ufism Szgfi GantDate 01722 /is
                                                                                  (orotheridentifics);                           Approved by OMB
                                                                                                                                        3060—0678

      Date & Time Filed: Oct 29 2014 4:03:04:330PM         International Boreau
      File Number: SAT—LO1I—20141029—00118                                                                  . Duall
                                                        *with condifions
      Callsign/Satellite ID: $2935                                                                Chte" Scdelh‘fe %kd Banch
                           APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                                 FCC Use Only
                                              FCC 312 MAIN FORM
                                            FOR OFFICIAL USE ONLY

      APPLICANT INFORMATION
      Enter a description ofthis application to identify it on the main menu:
      PDR to access 03b satellite network (Oct 2014) — FINAL
        1—8. Legal Name ofApplicant
                 Name:         O3b Limited                         Phone Number:                         202—813—4026
                 DBA Name:                                         Fax Number:
                 Street:       900 17th Street, NW, #300           E—Mail:                               suzanne.malloy@o3bnetworks.
                                                                                                         com


                 City:         Washington                          State:
                               USA                                 Zipcode:
                 Attention:    Ms Suzanne Malloy


                                              O3b Limited
                              IBFS File Nos. SAT—LO1—20141029—00118 and
                                       SAT—AMD—20150115—00004
                                             Call Sign $2935

 The request of 03b Limited, IBFS File No. SAT—LOI—20141029—00118 (Call Sign $2935), as amended,
 to modify prior grants ofaccess to the U.S. market by adding four new medium earth orbit non—
 geostationary orbit (NGSO) satellites, for a total of 12 satellites in an equatorial orbit, is GRANTED.‘
 O3b Limited‘s satellites operate underthe authority of the United Kingdom in the 18.8—19.3 GHz (space—
 to—Earth) and 28.6—29.1 GHz (Earth—to—space) frequency bands on a primary basis, the 27.6—28.35 GHz
 (Earth—to—space) and 28.35—28.4 GHz (Earth—to—space) frequency bands on a secondary basis, and the
 17.8—18.6 GHz (space—to—Earth) frequency bands on a non—conforming basis." Communications between
 U.S.—licensed earth stations and O3b Limited‘s NGSO system must be in accordance with theterms,
 conditions, and technical specifications set forth in 03b Limited‘s application, the Federal
 Communication Commission‘s rules not waived herein, and are subject to the following conditions:

 1.       This grant does not include provision of any Direct—to—Home (DTH) service, Direct Broadcast
 Satellite Service (DBS) or Digital Audio Radio Service (DARS) to, from, or within the United States.

 2.       O3b Limited‘s operations must comply with all coordination agreements reached between the
 United Kingdom and other Administrations, including all coordination agreements reached between the
 United Kingdom and the United States(see, e.g., UK telefax SSU 2000 dated 29 May 2009).

 3.      O3b Limited must maintain an electronic web site bulletin board listing the ephemeris data for
 each satellite in the O3b Limited constellation, using the North American Aerospace Defense Command
 (NORAD) two—lineorbital element format. 03b Limited must update the orbital elements at least once
 every three days.

 4.       O3b Limited‘s request for a waiver of the Ka—band Plan® and the United States Table of
 Frequency Allocations, 47 C.F.R. § 2.106, is GRANTED. Transmissions from the 03b Limited NGSO


 ‘ 03b Limited‘s system is comprised of 12 satellites: four launched on June25, 2013, four launched on July 10,
 2014, and four launched on December 18, 2014. 03b Limited states that three of the 12 space stations will be
 operated as spares, with the remaining space stations evenly distributed in O3b‘s authorized orbital plane, a "9+3"
 configuration. 03b Limited, IBFS File No. SAT—LOI—20141029—00118, Attachment at 3 (O3b Application). On
 February 5, 2015, the Satellite Division determined that 03b Limited commenced operations of its four new space
 stations and therefore O3b Limited was not required to file a bond as set forth in Section 25.165 of the
 Commission‘s rules. See Public Notice, Policy Branch Information, Actions Taken, Report No. SAT—01065 (Feb. 6,
 2015).
. 2 03b Limited‘s application was placed on Public Notice. Public Notice, Policy Branch InformationSatellite Space
  Applications Accepted for Filing, Report No. SAT—01053 (Nov. 14, 2014). No comments were filed in response to
  the Notice. O3b Limited was previously granted authority to operate two fixed gateway earth stations and one
  blanket license for maritime operations with the O3b Limited‘s satellite system as a point of communication. See
 IBFS File Nos. SES—LIC—20100723—00952 (fixed gateway earth station in Haleiwa, Hawaii, granted Sept. 25, 2012);
 SES—LIC—20130124—00089 (fixed gateway earth station in Vernon, Texas, granted June 20, 2013), and IBFS File
 No. SES—LIC—20130528—00455 (a blanket licensefor maritime operations in limited frequencies, granted May 13,
 2014).
 * The Commission issued a series of related orders in CC Docket No. 92—297. The First Report and Orderin the
 proceeding established an allocationplan for use of the Ka—band by non—Federal users. Rulemaking to Amend Parts
 1, 2, 21, and 25 of the Commission‘s Rules to Redesignate the 27.5—29.5 GHz Frequency Band, to Reallocate the
 29.5—30.0 GHz Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution Service and for
 Fixed Satellite Services, First Report and Order and Fourth Notice of Proposed Rulemaking, 11 FCC Red 19005
 (1996) (Ka—band Report and Order), modified by Third Report and Order, 12 FCC Red 22310 (1997).


                                            O3b Limited
                            IBFS File Nos. SAT—LO1—20141029—00118 and
                                     SAT—AMD—20150115—00004
                                           Call Sign $2935

space stations to earth stations in the 17.8—18.6 GHz (space—to—Earth) frequency bands must be on a non—
conforming basis. 03b must immediately terminate non—conforming operations upon notification of
harmfulinterference. In addition, the 03b Limited network‘s operations must meet the following
requirements:

         (a)     The powerflux density (pfd) at the Earth‘s surface produced by emissions from 03b
Limited‘s system forall atmospheric conditions, and for all methods of modulation in the 17.8—18.6 GHz
(space—to—Earth) frequency bands must notexceeda level of —118 dBW/m‘/MHzat any angle ofarrival.*

         (b)     Operations in the 17.8—18.6 GHz (space—to—Earth) frequency band must comply with the
         applicable equivalent power flux density requirements in Articles 22.5C and 22.5F of the
         International Telecommunication Union (ITU) Radio Regulations.

         (©)     Operations in the 17.8—18.6 GHz (space—to—Earth) frequency band are on an unprotected
basis.   No earth station receiving these frequencies may claim interference protection from any other
authorized     userin the band that is operating in accordance with the United States Table of
Frequency Allocations, 47 C.F.R. § 2.106, and/or the Ka—band plan.

5:       The pdf at the Earth‘s surface produced by emissions from 03b Limited‘s system for all
atmospheric conditions, and for all methods of modulation in the 18.8—19.3 GHz (space—to—Earth)
frequency bands, must not exceed a level of —118 dBW/m?/MHz atany angle of arrival.©

6.       O3b Limited‘s system operations in the 27.6—28.6 GHz (Earth—to—space) frequency band must
comply with the applicable equivalent power flux density requirements in Article 22.5D of the ITU Radio
Regulations.

7.       3b Limited must coordinate its operations in the 17.8—19.3 GHz (space—to—Earth) frequency
band with the U.S. Federal Systems, including Federal operationsto earth stations in foreign countries. In
addition to meeting the termsofthe coordination agreement, the non—conforming 03b Limited operations
in the 17.8—19.3 GHz frequency band must notcause harmfulinterference to, nor claim protection from,
present and future Federal, non—Federal, international geostationary orbit (GSO) and NGSO systems, or
any non—conforming services previously authorized on a non—harmful interference basis, and must
immediately cease operations upon notification of such harmful interference resulting from its operations.

8.       Operations with the 03b Limited system in the 27.6—28.35 GHz (Earth—to—space) frequency band
are on a secondary basis for service and gateway links. This band is designated on a primary basis to the
Local Multipoint Distribution Service (LMDS). See Rulemaking to Amend Parts 1, 2, 21 and 25 ofthe
Commission‘s Rules to Redesignate the 27.5—29.5 GHz Frequency Band, to Reallocate the 29.5—30.0 GHz
Frequency Band, to Establish Rules and Policiesfor Local Multipoint Distribution Service and For Fixed
Satellite Services, Third Report and Order, FCC 97—378, 12 FCC Red 22310 (1997). Accordingly,
operations must be on an unprotected, non—harmful interference basis relative to LMDS in accordance


* O3b Application, Attachment A at 14.
5 See, e.g., Third Report and Order, 12 FCC Red 22310.
* 03b Application, Attachment A at 14.


                                              O3b Limited
                              IBFS File Nos. SAT—LOI—20141029—00118 and
                                       SAT—AMD—20150115—00004
                                             Call Sign $2935
with 47 C.F.R. §2.105(c)(2). The 03b Limited network‘s operations must not cause harmfulinterference
to, nor claim protection from, authorized LMDS stationsin the 28.10—28.35 GHz frequency band that are
presently assigned or that may be assigned these bands in thefuture. Further, operations must terminate
immediately upon notification of such interference.

9.      Operations with the 03b Limited system in the 28.35—28.4 GHz (Earth—to—space) frequency band
are on a secondary basis and as such must not cause harmfulinterference to primary users. Further, these
operations cannot claim protection from harmful interference caused by primary users.

10.     Operations with the 03b Limited system in the 18.8—19.3 GHz (space—to—Earth) and 28.6—29.1
GHz (Earth—to—space) frequency bandsare subject to the sharing method specified in Establishment of
Policies and Service Rulesfor the Non—Geostationary Satellite Orbit, Fixed Satellite Service in the Ka—
band, Report and Order,IB Docket 02—19, 18 FCC Red 14708 (2003) and 47 C.F.R. § 25.261.

11.     If O3b Limited makes changes to the orbital positions of its non—active NGSO space stations on
whichit is only performing TT&C, it may do so without prior Commission approval, provided:

        (a) The 03b system will continue to meet the conditions specified in this grant after the
             repositioning.

        (b) The repositioning will not increase risk of harmful interferenceto other systems not
            permitted by coordination agreements.

        (c) O3b will not request increased interference protection because of the repositioning.

        (d) O3b will monitor collision risk during the maneuver and take any necessary evasive
            measures.

        (¢) Any change oforbital altitude entailed by the repositioning will not exceed 150 kilometers in
             extent or 60 days in duration.

If 03b seeks to make any changes to its constellation as specified in this grant, such as changes to the
active satellites or activating a spare satellite at a location offset from the 9 equally—spaced locations, it
must receive a modification ofits market access grant before commencing communications with U.S.—
licensed earth stations pursuant to the changes or new activation.

12.     O3b Limited‘s request for a waiver of Sections 25.137(c) and 25.157 of the Commission‘s rules,
47 C.F.R. §§ 25.137(c) and 25.157, regarding modified processing round and band segmentation
procedures, is GRANTED. 03b Limited will employ satellite diversity at low to medium latitudes, which
will enable it to share spectrum with other NGSO FSS systems. At higher latitudes, O3b Limited will
employ a band segmentation approach to accommodate other systems if interference occurs. We grant
these waivers given the opportunities for additional entrants to operate in O3b Limited‘s requested
frequency bands.

13.     03b Limited‘s requestfor a waiverof Section 25.210(i)(1) of the Commission‘s rules, 47 C.F.R.
§ 25.210()(1), is GRANTED. Section 25.210(i)(1) requires spacestation antennas in the Fixed—Satellite


                                            O3b Limited
                            IBFS File Nos. SAT—LOI—20141029—00118 and
                                     SAT—AMD—20150115—00004
                                           Call Sign $2935

Service to be designed to meet a cross—polarization isolation of 30 dB within the primary coverage area of
the antenna. We grant this waiver with the condition that O3b Limited must accept interference to its
non—compliant operations caused by space stations that comply with Section 25.210(i)(1).

14.     O3b Limited‘s request for a waiver of Section 25.145(c) of the Commission‘s rules, 47 C.F.R. §
25.145(c), is GRANTED. Section 25.145(c) requires Ka—band NGSO systems to provide service
coverage to (i) all locations as far north as 70 degrees latitude and as far south as 55 degrees latitude for at
least 75% of every 24 hour period and (ii) on a continuous basis throughout the fifty states, Puerto Rico
and the U.S. Virgin Islands. We grant this waiver because O3b Limited states that its system operates in
an equatorial orbit as opposed to inclined orbit and as a result, due to look angle constraints, there is a
limitation on the northernmost and southernmost latitudes that can be served by its system, providing less
extensive coverage than the geographic coverage areas required in Section 25.145(c)."

15.     This grant is based upon the finding that O3b Limited is and will be subject to direct and effective
regulation by the United Kingdom concerning orbital debris mitigation. This grant will remain effective
only to the extent that launch and space operations continue to be authorized by the United Kingdom
Space Agency under the United Kingdom Outer Space Act.

16.     We grant 03b Limited‘s amendment, IBFS File No. SAT—AMD—20150115—00004, to allow
temporary U.S. market access using eight active satellites and four spare satellites (a "8+4"
configuration). O3b Limited states that this configuration is necessary to permit two of the spare satellites
to be drifted to their eventual orbital positions required for the "9+3" configuration.s Accordingly, O3b
Limited may access the U.S. market while operating its satellites in this temporary "8+4" configuration,
subject to the conditions in this grant.

17.     O3b Limited has 30 days from the date of this action to decline this grant as conditioned. Failure
to respond within this period will constitute formal acceptance ofthis grant as conditioned.

18.      This action is taken pursuant to Section 0.261 of the Commission‘s rules on delegated authority,
47 C.F.R. § 0.261, and is effective immediately. Petitions for reconsideration under Section 1.106 or
applications for review under Section 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may
be filed within 30 days of the public notice indicating that this action was taken.
                                                  L                      02 /1/i5
                                   x RE—IssuED/CorrecEep on 03/i2/5 ano 06/02 fis *
                                                                  qumm§hit—LOt—20!41029— 00118
                                                                  File    #_ShT— APMD—2015011 5 — 00004


                                                                  dfls‘sn "S2935 GrantDate_O1/22/i5
                                                                  (or other identifier)
                                                                                           Term Dates
                                                                  From_O1/22/l5                       To:
                                             GRANTED*®
                                           International Burean   Approved:
           rnogt Narrative
7 03b Application,     : at 15.        with
                                      *bid      condifiens                            Chi a       %         ;
                 ‘
                                                                                               ¢4    Bench
                                                                                          |’\|€(: Srttellite iblic
8 See 03b Limited, IBFS File No. SAT—AMD—20150115—00004, Attachmentat 2, and footnote 1, supra.
                                                                                                  Be



                                                          4


  9—16. Nameof Contact Representative
          Name:        Joseph A. Godles                           Phone Number:                       202—429—4900
            Company:         Goldberg Godles Wiener & Wright Fax Number:                              202—429—4912
                            LLP
            Street:          1229 19th Street, NW                 E—Mail:                            jgodles@g2w2.com


            City:           Washington                            State:                              DC
            Country:         USA                                  Zipcode:                           20036      —2413
            Attention:                                            Relationship:                      Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                 b.
classification that applies to thisfiling for   3 b1— Application for License ofNew Station
both questions a. and b. Choose only one        (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 176.                   (N/A) b3. Amendment to a Pending Application
                                                (N/A) bd. Modification of License or Registration
  a.
                                                (N/A) b5. Assignment of License or Registration
(N/A) al. Earth Station                         (N/A) b6. Transfer of Control of License or Registration
   @ a2. Space Station                          (N/A) b7. Notification ofMinor Modification
                                                (N/A) b8. Application for License ofNew Receive—Only Station Using Non—U.S. Licensed Satellite

                                                @ 59. Letter of Intent to Use Non—U.S. Licensed Satellite to ProvideService in the United States
                                                > b10. Replacement Satellite Application — no new frequency bands
                                                } b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                > b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


  17¢. Is a fee submitted with this application?
[ IfYes, complete and attach FCC Form 159.
  If No, indicate reason for fee exemption (see 47 C.RR.Section 1.1114).
  0 Governmental Entity 0 Noncommercial educational licensee
@ Other(please explain):       Petition for Declaratory Ruling — no fee required


17¢. Fee Classification      CLW — Space Station (Non—Geostationary)


18. If this filing is in reference to an existing station, enter:
(a) Call sign ofstation:
   Not Applicable



19.If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                    (b) File number ofpending application:

Not Applicable                                                            Not Applicable


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) ofservice(s): Select all that apply:


E a. Fixed Satellite
D b. Mobile Satellite
    c. Radiodetermination Satellite
D d. Earth Exploration Satellite
D e. Direct to Home Fixed Satellite
    £. Digital Audio Radio Service
D g. Other (please specify)


21. STATUS: Choose thebutton nextto the applicable status. Choose       22. If earth stationapplicant, check all that apply.
only one.                                                               Not Applicable
  &3 Common Carrier @y         Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
      3 Connected to a Public Switched Network y Not connected to a Public Switched Network @y N/A

24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s).
O+* C—Band (4/6 GHz)       0 b. Ku—Band (12/14 GHz)
  E c.Other (Please specify upper and lower frequencies in MHz.)
          Frequency Lower: 18800             Frequency Upper: 29100            (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.

 (N/A) a. Fixed Barth Station
 (N/A) b. Temporary—Fixed Earth Station
 (N/A) c. 12/14 GHz VSAT Network
 (N/A) d. Mobile Barth Station
 0+ Geostationary Space Station.
 @ £ Non—Geostationary Space Station
 > & Other (please specify)



26. TYPE OF EARTH STATION               FACILITY: Not Applicable
PURPOSE OF MODIFICATION

27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
apply)

 ENVIRONMENTAL POLICY

28. Would a Commission grant of any proposal in this application or amendment have a significant environmental    o Yes @ No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.F.R. §§ 1.1308 and 1.1311, as an exhibit to this application. A Radiation Hazard
Study must accompany all applications for new transmittingfacilities, major modifications, or major amendments.


 ALIEN OWNERSHIP
Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station
services are not required to respondto Items 30—34.


29. Is the applicanta foreign governmentor the representative of any foreign government?                                  0 Yes @ No




30. Is the applicant an alien or the representative of an alien?                                                          gYes gN @NA




31. Is the applicant a corporation organized under the laws of any foreign government?                                    0 Yes 0 No @© NA




32. Is the applicant a corporation of which morethan one~fifth ofthe capital stock is owned of record or voted by         ©Yes Ne @NA
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?




33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          ©Yes Ne @NA
one~fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?



34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.


BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                             @ Yos _ No
 IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.




36. Has the applicantor any party to this application or amendment had any FCC station authorization or license          © Yes @ No
revoked or had any application for an initial, modification or renewal ofFCC station authorization, license, or
construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances.




37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    © Yes @ No
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of ciroumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,        o Ye @ No
guilty ofunlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangementor any other
means or unfair methods of competition? If Yes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   Yes @ No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.


40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s
voting stock and the percentages so held. In the caseof fiduciary control, indicate the beneficiary(ies) or class of   Response to Q40
beneficiaries. Also list the names and addresses ofthe officers and directors of the Filer.



41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is       @ Yes 0 No
subject to a denial ofFederal benefits that includes FCC benefits pursuantto Section 5301 of the Anti~Drug Act of
1988, 21 U.S.C. Section 862, because of a conviction for possessionor distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of "party to the applicationquot; for these purposes.



422. Does the applicant intend to use a non—U.$. licensed satellite to provide service in the United States? IfYes,    @ Yo o N
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. IfNo,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be
issued, what administration has coordinated or is in the process ofcoordinating the space station? United Kingdom


43. Description. (Summarize the nature of the application and the services to be provided).     (If the complete description does not appear in this
box, please go to the endof the form to view it in its entirety.)
     See attached narrative.




  Narrative


432. Geographic Service Rule Certification                                                                                    0A
By selecting A, the undersigned certifies that the applicantis not subject to the geographic service or geographic
coverage requirements specifiedin 47 C.ER. Part 25.

                                                                                                                              0B
By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coveragerequirements specified in 47 C.ER. Part 25 and will comply with such requirements.
                                                                                                                              @ C
By selecting C, the undersigned certifies that the applicantis subject to the geographic service or geographic
coverage requirements specified in 47 C.FR. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.


CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or ofthe electromagnetic spectrum as against the regulatory power of the
United States because of the previous use ofthe same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicantto be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements madein exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in goodfaith.


44.   Applicantis a (an): (Choose the button next to applicable response.)


 0 Individual
 3 Unincorporated Association
 [ Partnership
 @) Corporation
 > Governmental Entity
 [ Other (please specify)


45. Name of Person Signing                                              46. Title of Person Signing
Suzanne Malloy                                                          Vice President, Regulatory Affairs

47. Please supply any need attachments.
 1:                                              3                                               3:



          WILLEUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                 (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


Completed Schedule S




10


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1


Leann Nguyen

From:                             Stephen Buenzow
Sent:                             Monday, August 17, 2015 8:33 AM
To:                               Thuan Pham; Leann Nguyen
Subject:                          RE: coordination for 0884-EX-ST-2015
Attachments:                      O3b - Grant Jan 22 re-issued june 2 -00118.pdf


The O3B authorization is attached. Condition #8 addresses their status wrt to LMDS operation.

From: Stephen Buenzow
Sent: Monday, August 17, 2015 8:27 AM
To: Thuan Pham <Thuan.Pham@fcc.gov>; Leann Nguyen <Leann.Nguyen@fcc.gov>
Subject: RE: coordination for 0884‐EX‐ST‐2015

I believe that this Viasat earth station is communicating with an 03B satellite that has some conditions on it that
constrain their use to a secondary non‐interference basis. The FSS service has a secondary allocation and this
operation seems consistent with that. Rather than outright dismissing the application I think it would make sense to
have them clarify whether they are in fact operating with that satellite and confirm that they’ve coordinated with any
LMDS licenses in the area. I’ll see if I can find the information on the O3B satellite grant and forward it shortly.

From: Thuan Pham
Sent: Friday, August 14, 2015 11:57 AM
To: Leann Nguyen <Leann.Nguyen@fcc.gov>
Cc: Stephen Buenzow <Stephen.Buenzow@fcc.gov>
Subject: Re: coordination for 0884‐EX‐ST‐2015


Hi Ms. Nguyen,

With respect to this STA request, coordination No. 0884-EX-ST-2015, Broadband Division would
recommend that the application be dismissed. The proposed frequency band includes 27.5-29.5 MHz
band which is allocated to Fixed Microwave Service under Part 101, and the applicant may not be aware of
it. The applicant has failed to provide an engineering analysis to protect the microwave users. The
requested geographic area is very wide and the proposed powers are too high compared to the microwave
service operations.

Thanks,
Thuan


From: Leann Nguyen
Sent: Thursday, August 13, 2015 2:00 PM
To: Thuan Pham; Jeanette Spriggs
Cc: Stephen Buenzow; Paul Blais; Hsing Liu
Subject: coordination for 0884‐EX‐ST‐2015

Ladies and Gentlemen,


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Please see the attachments for coordination. The requested start date is 08/17/2015 and will end 09/17/2015. Any
comments must be received by this office by COB 08/17/2015; thereafter, it will be considered that there are no
objections toward authorization.

Thanks,
Leann




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Document Created: 2015-08-25 09:54:49
Document Modified: 2015-08-25 09:54:49

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