Attachment comments

This document pretains to SAT-MOD-20080516-00106 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008051600106_650679

DUPLICATE BEFORE THE Federal Communications Commission WASHINGTON, DC 20554 In the Matter of ) ) GLOBALSTAR LICENSEE LLC ) ‘FileNo. SAT-MOD-20080516-00106 1 Call Sign: S2115 Application for Minor Modification 1 Of Space Station License ) RECEIVED - FCC To: International Bureau JUN 2 3 2008 l municat ions Cornmlsslon F e c f ~Corn Bureau / Off ice COMMENTS AND REQUEST FOR CLARIFICATION OF U.S. GPS INDUSTRY COUNCIL The U.S. GPS Industry Council (“USGPSIC”), by counsel and pursuant to Section 25.154 of the Commission’s rules, 47 C.F.R. 8 25.154, hereby comments on and requests clarification of the above-captioned application of Globalstar Licensee LLC (“Globalstar”), which requests modification of its authorization for operation of Ancillary Terrestrial Component (“ATC”) stations in the 1.6-2.4 GHz Mobile Satellite Service bands (“Modification Application”). Contradictory portions of Globalstar’s application require clarification to make clear that the modified ATC operations, if authorized, properly protect Radionavigation Satellite Service (“RNSS”) operations in the 1559-1610MHz band from out-of-band emissions. As an additional protection against interference, USGPSIC also requests that Globalstar be required to apply to its ATC base stations filters which reduce emissions in the 1559-16 10 MHz band. USGPSIC first requests clarification of the out-of-band emission limits proposed by Globalstar for its ATC mobile earth terminals (“METs”). The International Bureau (“Bureau”) conditioned Globalstar’s existing ATC operations on comportment with the MET emission limits specified in Paragraph 23 of the authorization order. See Globalstar LLC, Order and

-2- Authorization, 21 FCC Rcd 398,414 (7 44) (IB2006) (“Authorization Order”). As the Bureau observed, these limits, which were agreed to by Globalstar and the National Telecommunications and Information Administration (“NTIA”) following discussions between the parties, were stricter than those “originally proposed” by Globalstar. Id. at 406 (7 23). Globalstar, however, now proposes modifications that “will not result in any changes to the certifications and demonstration of compliance with the Commission’s rules governing ATC services set forth in Globalstar’s original ATC Application . . . .” See Attachment to Modification Application at 7 (emphasis added). Taken literally, Globalstar’s modification request can be interpreted as a proposal to operate in compliance with the less restrictive out-of-band emission limits Globalstar originally sought rather than the stricter limits agreed to with NTIA and incorporated into the license authorized by the Authorization Order. To be sure, Globalstar elsewhere in its application indicates that its proposed MET operations will comply with the stricter emission limits, as evidenced by the inclusion of these limits in the Technical Exhibit accompanying the application. See Technical Exhibit at 19-20 (reproducing the out-of-band emission limits specified in Paragraph 23 of the Authorization Order), which is attached hereto as Attachment 1. Nevertheless, because of the ambiguity introduced by Globalstar’s reference to its “original” ATC application, USGPSIC believes it is incumbent on Globalstar to make clear in the record of this proceeding that the instant application proposes to operate its METs in compliance with the out-of-band emission limits imposed on Globalstar’s MET operations by the Authorization Order. Likewise, USGPSIC respectfully requests that the Bureau condition the grant of the instant application on Globalstar’s operating its METs consistent with the Modification Application’s Technical Exhibit at 19-20. Requiring anything less than the existing protection of RNSS will risk harmful interference to

-3- vital Global Positioning System operations - a condition that USGPSIC will be compelled to oppose. To meet the emission limits agreed to with NTIA and imposed by the Authorization Order, Globalstar must fit its METs with filters that restrict out-of-band emissions in the 1559- 1610 MHz band. USGPSIC believes that filters serving this same critical purpose should also be required of Globalstar’s ATC base stations. Today’s commercial off-the-shelf filters should make this addition to the base stations technically and economically feasible. In the event Globalstar objects to adding base station filters that provide out-of-band emission protection in the 1559-1610 MHz band, USGPSIC believes it should have to demonstrate why such a minor requirement is not necessary. Respectfully submitted, U.S. GPS INDUSTRY COUNCIL By: Raul R. Rodriguez Stephen Dmaruch Of Counsel Philip A. Bonomo Leventhal Senter & Lerman PLLC 2000 K Street, NW Suite 600 Washington, DC 20006- 1809 (202) 429-8970 June 23,2008 Its Attorneys

ATTACHMENT 1

The following user equipment (UE) power classes pertain to the different ATC technology options. Note that the ATC terminal falls within the particular power classes identified, but will not exceed a maximum transmit power of 23 dBm. UE Power Classes for WCDMA Power Class 3 Power To1 I Power Class 3bis Power To1 Power Class 4 Power To1 (dBm) (dB) (dBm) (dB) (dBm) (dB) +24 +1/-3 23 +2/-2 +21 +2/-2 UE Power Class for TD-CDMA UE power classes for Nominal maximum Tolerance FDD TD-CDMA output power 2 +24 dBm +1 dB / -3 dB WirelessMAN-OFDMA Power Class profiles (802.16) A power class profile contains the class(es) of BS and Subscriber Station (SS) transmitters used in a system. A power class profile may contain transmitters from more than one class, with the profile indicating the highest power level class permitted. The power classes for BS and SS transmitters in a system are listed below: Class identifier Tx power (dBm) Class 2 20 PTx,max < 23 Class 3 23 PTx,max < 30 Class 4 30 PTx,max 5.3.1 ATC Antenna Facilities The internal ATC antenna for the handheld terminal will radiate with near spherical pattern coverage and a peak gain less than 2 dBi. The optional high gain ATC antenna will be separate and detachable. General characteristics are given below. As with the ATC base stations, Globalstar will require its ATC terminal supplier(s) to provide equipment in compliance with the applicable FCC rules governing ATC, including: 0 ATC mobile terminals will meet a peak EIRP density limit of 1.0 dBWA.25 MHz. ATC mobile terminals will meet an out-of channel EIRP limit of -57.1 dBW/3O kHz at the edge of Globalstar’s licensed MSS frequency assignment. 19

Frequency ATC Mobile Terminal EIRP Spectral Density (MHz) dBW/MHz dBW/kHz 1559 - 1590 -90 -100 1590 - 1600 -90 to -85, linearly interpolated - 100 to -95, linearly interpolated 1600 - 1605 -85 -95 1605 - 1610 -85 to -42, linearly interpolated -95 to -52, linearly interpolated Frequency ATC Mobile Terminal EIRP Spectral Density (MHz) dBW/MHz dBW/kHz 1559 - 1605 -95 -105 1605 - 1610 -95 to -47, linearly interpolated -105 to -57, linearly interpolated 5.3.1.1 ATC Handheld Antenna Parameter Value Freauencv Bands 1610-2500 MHz I PeakGain I <2.0 dBi I Elevation Plane Coverage -45 to 45 degrees Azimuth Plane Coverage 360 degrees Size <0.5” diameter, 4 ’ ’ length 5.3.1.2 ATC High Gain External Antenna Parameter Value ~ Freauencv Bands ~~~ ~ 2483.5-2495 MHz Polarization Vertical Peak Gain 4 2 . 0 dBi Elevation plane Coverage -45 to 45 degrees Azimuth Plane Coverage 360 degrees Size 4 . 5 ” diameter, < 11” length 5.3.2 ATC Antenna Heights The extremely small size of the mobile terminal makes FAA notification unnecessary. See Section 17.14(b) of the FCC rules. The MSS/ATC terminal is intended to be used as a handheld portable radio at roughly waist level of approximately three to four feet AGL, but will still operate if held higher or set 20

CERTIFICATE OF SERVICE I, Rebecca J. Cunningham, hereby certify that a true and correct copy of the foregoing “Comments and Request for Clarification of U.S. GPS Industry Council” was sent by first-class mail, postage prepaid, on this 23rd day of June, 2008 to the following: William F. Adler Vice President Legal and Regulatory Affairs Globalstar, Inc. 461 S. Milpitas Boulevard Milipitas, CA 95035 Mike Kozlowski Globalstar, Inc. 46 1 S. Milpitas Boulevard Milpitas, CA 95035 p-j.L4L Rebecc . Cunningh


Document Created: 2008-06-30 10:15:33
Document Modified: 2008-06-30 10:15:33
© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC