Attachment submitting memorandu

submitting memorandu

LETTER submitted by Final Analysis

Submission of Memorandum

1999-11-17

This document pretains to SAT-AMD-19971030-00175 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD1997103000175_975228

KELLEY DRYE & WARREN ccr A LIMITED LIABILITY PARTNERSHIP 1200 I9"" STREET, N.W. NEW YORK, NY SsUITE 500 FACSIMILE LOS ANGELES, CA (202) p55—07902 WASHINGTON, D.C. 20036 CHICAGO, IL STAMFORD, CT (202) 955—9600 PARSIPPANY, NJ DIRECT LINE (202) 955—9771 BRUSSELS, BELGIUM E—MAIL: apisciotta@kelleydrye.com HONG KONG AFFILIATE OFFICES BANGKOK, THAILAND HECE!VEQ JAKARTA, INDONESIA MA”'L:; ;:il"':;'f'“":s November 17, 1999 N rep OV 1 7 1999 OFmicE 0miesecmeiagy" Mr. Donald Abelson Chief, International Bureau Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Final Analysis Communication Services, Inc. — Application for Clarification and Review of Non—Voice Non—Geostationary Mobile Satellite Service ("NVNG MSS") License, 13 FCC Red 6618 (1998) (File No. 7—SAT—AMEND—98) Dear Mr. Abelson: On behalf of Final Analysis Communication Services, Inc., enclosed please find a copy of a memorandum dated March 11, 1998 from Nelson V. Pollack, Air Force Frequency Management Agency, to William Hatch, Deputy Associate Administrator of NTIA ("Air Force Memorandum"), which is Attachment C to my letter to you dated November 16, 1999 in the above—referenced matter. The wrong document was inadvertently provided as Attachment C in the version that was filed. Please substitute the Air Force Memorandum for that document. I apologize any inconvenience. Sincerely, & /d stks= a Aileen A. Pisciotta Counsel to Final Analysis Communication Services, Inc. ge: All parties

Attachment C DEPARTMENT OF THE AIR FORCE AF FREQUINCY MANAGEMENT AGENCY 4040 NORTH PAJZXFAX DRIVE BDTT% 262 ARLDNCTON YIRGEIA 3327961413 DATE 11 Mirch 1997¢ MEMORANDUM FOR Mr. Wilifam Hatch, Deputy Associate Administrator, NTIA FROM: APFPMA/SCA SUBTECT: FPCC Draft Order for Final Analysis (FAI) REFERENCES: (a) FCC Draft Order for Final Arialysis (FAI) (b) STARSYS Amendment to Application (4/94) (c) VITA Afiendment to Application {4/94) (d) FAI Amendment to Application (10/87), Tevised on 4 and 12 November 1997. Final Analysis (FAI) is proposing to operate within the 400.505—400.645 Miz portion of the 400.15—401 MHz band that is situated betwesn the two DMSP channels. The spectrum proposed includes that allocated for use by the first round applicants VITA and STARSYS. Specifically, FAL proposes to time share frequencies previdusly allocated to VITA and to ‘addiyionally operate within that portion recently vacated by STARSYS. Air Force agreed during the FCC Negotisted Rulemaking in 1992 to the principle of sharing the spectrum between the two DMSP channels with two U.S. mobile satellite systems besed on the proposed technical parameters of the first round applicants. In 199%4, AF agréeed to the licensing of VITA and STARSYS systems based on the technical parameters proposed for these systems (REF b and c). The VITA system was specified in Ref c to have an effective radiated power (EIRP} of 8 dBW at the Earth‘s horizon. The STAKRSYS system was specified in Ref a to have an EILRP of 8.2 dBW in the vicinity of the Earth‘s horizon. FAI‘sg recent application proposes an EIRP of 17.8 dBW at the Earth‘s hbhorizon. This value is 9.56 dB greater than that planned by STARSYS. This value of EIRP substantially increases the interference

power received by the DMSP over that which would have resulted from the STARSYS system. The FAI application states the power flux—density {PFD3} near the Earth‘s horizon ({at a 5 degree arrival angle) will be —127.8 dBW/m2?/4 kHMz. This value of PFD is adequate to avoid harmful interference to the DMSP. The FALI application indicates their system design will use a shaped beam antenna to produce uniform power flux—density (PFD) at the Earth‘s surface. The AF is concerned that the amount of antenna beam shaping needed to accomplish this uniform PEFD cannot be practically achieved, especially once the antenna has been mounted on the spacecraft. This situstion could cause the PFD at higher arrival angles to be greater than the —127.8 dswW/m2/4 kHz value calculated in the applic¢ation. PFD values greater than —126.0 dBW/m2/4 KHz are unacceptable to AF since such values will cause unacceptable interference to the DMSP. It is essential that ~— FAI‘s license be conditioned on fNot producing PFD levels at amny point on the earth‘s surface that exceed —126.0 aBwW/m2/4 kHz. It is also essential that the FCC require FAI to demonstrate through tests on the first conpleted spacecraft that thig PFD value will be met at all arrival _ angles. Theses tests should be performed within 120 days of the launch of the first satellite and monitored by the AF. Because greatoer PFD levels could prevent the DMSP from satisfying its mission, it is iwportant that the FCC emphasize their intent to revoke this license unless tests are performed to conclusively show this PFD limit is met. . Also, AF requests that FCC encourag« FAI to implement a variable power capability to be able to compensate for any unexpectedproblems which may be encountered in meseting £his PFD level. ' In summary, we request the PCC to condition the FAl license to meet a level of —126 dBW/m2/4 kHz to protect the DMSP system. This requested limit is consistent with the calculated PFD levels stated in the FAL application. We further request the FCC require tests to demonstrate compliance with this limit as a condition on the license. This precaution is warranted since failure to meet this limit will have an adverse effect on DMSP. We beliéve these actions promote a reasonable balance between U.S. economic¢ interests and national security. NELSON V. POLLACK

Technical Director, AFFMA Ce¢: Richard Barth (DoC) Jim Vorhiés (NTIA/O8BM)

CERTIFICATE OF SERVICE I, Beatriz Viera, hereby certify that a true and correct copy of the foregoing Letter to Donald Abelson, on behalf of Final Analysis Communication Services, Inc., was delivered by hand or regular mail this 17"" day of November 1999, to the individuals on the following list: Chairman William E. Kennard* Mr. Daniel Harrold* Federal Communications Commission Office of General Counsel Portals — Room A302 Federal Communications Commission 445 12"" Street, S.W. 445 12"" Street, S.W. Washington, D.C. 20554 Washington, D.C. 20554 Commissioner Gloria Tristani* Ms. Anna M. Gomez* Federal Communications Commission Deputy Chief, International Bureau Portals — Room C302 Federal Communications Commission 445 12"" Street, S.W. 445 12"" Street, S.W. Washington, D.C. 20554 Washington, DC 20554 Commissioner Harold W. Furchtgott—Roth* Mr. Thomas Tycz* Federal Communications Commission Chief Satellite and RadioCommunications Portals — Room B201 Division 445 12"" Street, S.W. Federal Communications Commission Washington, D.C. 20554 445 12"" Street, S.W. Washington, D.C. 20554 Commissioner Susan Ness* Federal Communications Commission Ms. Cassandra Thomas* Portals — Room B115 Deputy Chief, International Bureau 445 12" Street, S.W. Federal Communications Commuission Washington, D.C. 20554 445 12" Street, S.W. Washington, D.C. 20554 Commissioner Michael K. Powell* Federal Communications Commission Mr. Harold Ng* Portals — Room A204 Chief, Satellite Engineering Branch 445 12¢" Street, S.W. Satellite and RadioCommunication Div. Washington, D.C. 20554 International Bureau Federal Communications Commission Mr. Christopher J. Wright* 445 12"" Street, S.W. General Counsel Washington, D.C. 20554 Federal Communications Commission Portals 445 12"" Street, N.W. Mr. Alex Roytblat*® Washington, D.C. 20554 Satellite and RadioCommunication Div. International Bureau Federal Communications Commission 445 12"" Street, S.W. Washington, D.C. 20554

Mr. William T. Hatch Robert A. Mazer, Esq. Associate Administrator Vinson & Elkins Spectrum Management 1455 Pennsylvania Avenue, N.W. U.S. Department of Commerce Washington, D.C. 20004—1008 NTIA — Room 4099 Counsel for Leo One Worldwide, Inc. 14th & Constitution Avenue, N.W. Washington, D.C. 20230 Leslie Taylor, Esq. Leslie Taylor Associates, Inc. Kathy D. Smith 6800 Carlynn Court U.S. Department of Commerce Bethesda, MD 20817—4302 NTIA — Room 4713 Counsel for E—Sat 14th & Constitution Avenue, N.W. Washington, D.C. 20230 Mr. Nelson Pollack AFFMA James Vorhies 4040 North Fairfax Drive, Suite 204 U.S. Department of Commerce Arlington, VA 22203—1613 NTIA — Room 4076 14th & Constitution Avenue, N.W. Mr. Richard Barth Washington, D.C. 20230 U.S. Department of Commerce National Oceanic and Atmospheric Stephen Goodman, Esq. Administration Halprin, Temple & Goodman Office of Radio Frequency Management Suite 650 East Room 2246, SSMC—2 1100 New York Avenue, N.W. 1325 East West Highway Washington, D.C. 20005 Silver Spring, MD 20910 Counsel for ORBCOMM SMC/CIHIS Henry Goldberg, Esq. Attn: Lt. Dave Meyer Joseph Godles, Esq. 2420 Vela Way, Suite 1467—A8 Mary Dent, Esq. Los Angeles AFB Goldberg, Godles, Wiener & Wright El Segundo, CA 90245—4659 1229 19th Street, N.W. Washington, D.C. 20036 Counsel for Volunteers in Technical Assistance 7 + + Beatriz Viera * Via Hand Delivery


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Document Modified: 2012-11-15 13:37:12
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