Attachment Exhibit C

This document pretains to SAT-MOD-20100412-00075 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010041200075_810384

                                         Before the
                              Federal Communications Commission
                                    Washington, D.C. 20554


    Application of                               )
                                                 )
    SkyTerra Subsidiary LLC                      )    File No. SAT-MOD-_____________
                                                 )
    For Modification of License to Operate       )
    MSAT-2 at 103.3ºW                            )


                                   Application for Modification

            SkyTerra Subsidiary LLC (“SkyTerra”) is licensed to operate a Mobile Satellite

Service (“MSS”) satellite, MSAT-2 (a.k.a. AMSC-1), at the 101.3ºW orbital location.1

SkyTerra’s next-generation satellite, SkyTerra 1, which will replace MSAT-2, is also authorized

to operate at that location, and its launch and operate milestone is May 26, 2010.2 To make room

for the replacement satellite and maintain continuity of service to customers pending the

transition of service from MSAT-2 to SkyTerra 1, SkyTerra hereby requests that the Commission

modify the license for MSAT-2 to permit continued operations at and during the drift from the

satellite’s current position to the 103.3ºW orbital location +/- 0.05 degrees.3 MSAT-2 will

operate at the new location for an estimated eight months until SkyTerra 1 has been fully tested




1
     Memorandum Opinion, Order and Authorization, 4 FCC Rcd 6041 (1989); remanded by
     Aeronautical Radio, Inc. v. FCC, 928 F.2d 428 (D.C. Cir. 1991); Final Decision on Remand, 7
     FCC Rcd 266 (1992); aff’d, Aeronautical Radio, Inc. v. FCC, 983 F.2d 275 (D.C. Cir. 1993);
     see also AMSC Subsidiary Corporation, Memorandum Opinion and Order, 8 FCC Rcd 4040
     (1993); see also Stamp Grant, File No. SAT-MOD-20080303-0005 (granted May 19, 2008).
2
     SkyTerra has requested an extension of this milestone requirement until October 31, 2010.
     See SAT-MOD-20100405-00064 (April 5, 2010).
3
     Subject to Commission approval, SkyTerra intends to begin drift of MSAT-2 15-30 days prior
     to the launch of SkyTerra 1.


and customers are transitioned to the new satellite.4 As discussed in the attached Technical

Exhibit, SkyTerra has coordinated the relocation of MSAT-2 with affected satellite operators, the

relocation of the satellite will not cause harmful interference to other satellite operators, and the

proposed license modification complies with the Commission’s technical rules.5 An updated,

comprehensive Schedule S attachment, reflecting the relocation of the satellite and associated

technical changes, is provided with this application.

         With respect to physical coordination of MSAT-2 at 103.3ºW +/- 0.05 degrees, SkyTerra

has reviewed the lists of FCC-licensed satellite networks, as well as those that are currently

under consideration by the FCC, and networks for which a request for coordination has been

published by the ITU within +/- 0.15 degrees of the relevant orbital location. SkyTerra

concludes that the station-keeping volume of MSAT-2 at the proposed new location will not

overlap the station-keeping volume of any other satellite, and accordingly, no physical

coordination will be required. For all of these reasons, SkyTerra submits that the Commission

should grant this application for the relocation of MSAT-2.6

         By this application, SkyTerra also modifies, in part, its orbital debris mitigation statement

for MSAT-2 and requests, to the extent necessary, waiver of that portion of Section 25.283(c) of

the Commission’s rules, 47 C.F.R. § 25.283(c), requiring the relief of pressure vessels at satellite




4
    After this period, SkyTerra intends to transfer MSAT-2 to a graveyard orbit or alternatively
    relocate the satellite to another orbital location to provide international services.
5
    The Technical Exhibit provides a Power Flux Density compliance demonstration (Tables A-1
    and A-2) and a two-degree spacing analyses for the applicable frequency bands (Tables B
    through I).
6
    As required by the Commission’s rules, SkyTerra hereby certifies that all other information
    related to MSAT-2’s licensed operations and not addressed in this application has not changed
    materially. See 47 C.F.R. § 25.117(d)(1).

                                                   2
401324871v1


end-of-life.7 MSAT-2 is a Boeing Model 601 satellite, which is not designed to allow for the

discharge of all pressurant upon satellite end-of-life. Rather, consistent with Boeing’s practice

with respect to a number of its spacecraft buses, the helium tanks are isolated at the end of

transfer orbit and the amount of the remaining gas and the low pressurization in the tanks result

in minimal potential for accidental explosions during and after completion of mission.

Accordingly, SkyTerra modifies its orbital debris mitigation statement and, to the extent

necessary, requests waiver of the Commission’s rule.

        The statement regarding minimizing accidental explosions is revised as follows:8

        MSVSkyTerra has assessed and will limit the probability of accidental explosions
        during and after completion of mission operations. The MSAT-1 and MSAT-2
        satellites are designed to minimize the potential for accidental explosions
        resulting from propellant leakage and fuel and oxidizer mixing or other means.
        Propellant tanks and thrusters are isolated using redundant values, and electrical
        power systems are shielded in accordance with standard industry practices.
        During the mission, batteries and various critical areas of the propulsion
        subsystem will be monitored to avoid conditions that could result in explosion.
        After MSAT-1 and MSAT-2 reach their final disposal orbits, all on-board sources
        of stored energy will be removed, with the exception of the pressurized vessels
        discussed below, by depleting all propellant tanks, venting all pressurized
        systems, discharging batteries, and turning off all active units. MSAT-1 and
        MSAT-2 each use a Boeing 601 spacecraft bus that has a liquid propulsion system
        design that includes two helium (pressurant) tanks plus two pairs of fuel and
        oxidizer tanks. Venting of the excess propellant in the fuel and oxidizer tanks is
        performed as part of the end-of-life shutdown operations. The helium tanks
        provide proper propellant tank pressurization for apogee engine firings during
        transfer orbit. Both helium tanks are isolated at the end of transfer orbit by firing
        pyrotechnic valves, and there is no venting provision for these helium tanks at the
        satellite end-of-life. SkyTerra has estimated that approximately 129 grams of
        helium will be sealed in each tank when they are isolated resulting in a final
        pressure of 262 psi, which is extremely low relative to the design burst pressure of
        5,250 psi. Due to the low pressure in the helium tanks at the satellite end-of-life,
        an explosive event is unlikely, even in the event of a tank rupture (e.g. a meteorite


7
    SkyTerra intends shortly to file a similar waiver request of the orbital debris mitigation
    requirement with respect to MSAT-1.
8
    See Application, File No. SES-MFS-20070530-00731, at Technical Appendix p. 33 (filed May
    30, 2007).

                                                  3
401324871v1


        strike). Accordingly, the satellite design results in minimal potential for the
        release of orbital debris.

        Under Section 1.3 of the Commission’s rules, 47 C.F.R. § 1.3, the Commission has

authority to waive its rules for good cause. Good cause exists if “special circumstances warrant

a deviation from the general rule and such deviation will serve the public interest.”9 In

determining whether a waiver is appropriate, the Commission should “take into account

considerations of hardship, equity, or more effective implementation of overall policy.”10

        MSAT-2 is an in-orbit spacecraft and was launched nearly a decade before the FCC’s

orbital debris mitigation rules became effective.11 Accordingly, any satellite design change now

is not possible. Moreover, any such requirement would be retroactive rulemaking that would

impermissibly “increase a party’s liability for past conduct.”12 Under similar circumstances, the

Bureau has granted such a waiver request and it should do so here, as well.13




9
   Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
10
   WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027
   (1972).
11
   MSAT-2 was launched in 1995 and the relevant rules became effective October 12, 2004.
   Mitigation of Orbital Debris, 69 Fed. Reg. 54581-54589 (September 9, 2004).
12
   See Mitigation of Orbital Debris, 19 FCC Rcd 11567, at ¶ 78 (2004) (citing Celtronix
   Telemetry, Inc.. v. FCC, 272 F.3d 585, 588 (D.C. Cir. 2001)).
13
   See Stamp Grant, File No. SAT-MOD-20080630-00133, at Condition 3 (September 02, 2008)
   (granting waiver of venting requirement and noting that “Galaxy 12 was launched before
   Section 25.283(c) became effective.”); see also Stamp Grant, File No. SAT-LOA-20090807-
   00085 (granted December 15, 2009) (granting waiver of venting requirement for DIRECTV
   12/RB2-A, a Boeing 702 satellite, given its imminent launch); see also Stamp Grant, File No.
   SAT-LOA-20071221-00183 (granted March 12, 2008) (granting a waiver of venting
   requirement for AMC-14, a Lockheed A2100 satellite, in light of late stage of satellite
   construction); Stamp Grant, File Nos. SAT-MOD-20070628-00090, SAT-AMD-20070731-
   00108 (granted November 30, 2007) (granting waiver of venting requirement for Horizons 2,
   an Orbital Sciences Star satellite, in light of late stage of satellite construction); Stamp Grant,
   File Nos. SAT-MOD-20070207-00027, SAT-AMD-20070716-00102 (granted October 4,
   2007) (granting waiver of venting requirement for INTELSAT-11, an Orbital Sciences Star-2
   satellite, in light of late stage of satellite construction).

                                                   4
401324871v1


          Waiver is also appropriate in this case because grant would not undermine the purpose of

the rule, to reduce the risk of accidental explosion. The amount of the remaining gas in the

helium tanks and the low blanket pressure in those tanks at the satellite end-of-life result in

minimal potential for accidental explosions during and after completion of mission, consistent

with the FCC’s rules. Indeed, the Boeing 601 spacecraft bus (and other spacecraft buses with

similar designs)14 has been in commercial service for more than 15 years without incidents

involving accidental explosions.15




14
     See id.
15
     For a list of Boeing model 601 spacecraft, see http://www.boeing.com/defense-
     space/space/bss/factsheets/601/601fleet.html (last visited April 6, 2010).

                                                  5
401324871v1


                                       Technical Exhibit



                         Feeder Link PFD Compliance Demonstration

        The ITU maintains GSO satellite downlink PFD limits across the entire 10.7-11.7 GHz

frequency band. See Article 21, Table S21-4, ITU Radio Regulation (2001). The Commission’s

rules specify identical PFD limits for GSO satellites operating in the 10.95-11.2 GHz and 11.45-

11.7 GHz bands (47 C.F.R. § 25.114(c)(8)), but do not specify any PFD limits for GSO satellites

operating in the 10.7-10.95 GHz or 11.2-11.45 GHz bands.

        Table A-1 provides the power density for the feeder downlinks for the MSAT-2 carriers.

Table A-2 calculates PFD on the ground based on the maximum density calculated in Table A-1

and compares it with the limits, showing positive margin in each case.

               Table A-1: Feeder Link (Return) EIRP Density (10.7 – 11.7 GHz)

                                                                   EIRP Density
                   Carrier       EIRP (dBW)         BW (kHz)       (dBW/4 kHz)
                    CW                2.7                6             0.9
                    GC-S              2.7                6             0.9
                  QPSK-V              3.7                6             1.9
                    MMS               -5.3               5             -6.3
                  DATA-F              14.6              300            -4.2
                    Data1             -2.8              168           -19.0
                    Data2             -2.8              42            -13.0
                                   Maximum EIRP Density =               1.9




401791491v1


                Table A-2: Feeder Link (Return) PFD Compliance (10.7 – 11.7 GHz)

    Elevation                  Path       MSAT-2 Maximum           Maximum PFD
      Angle        Slant    Spreading     Power Flux Density           Limit              Margin
    (degrees)      (km)    Loss (dB-m2)   (dB(W/m2/4 kHz))        (dB(W/m2/4 kHz))         (dB)
        0         41,680      -163.4            -161.5                 -150                11.5
        5         41,128      -163.3            -161.4                 -150                11.4
       25         39,072      -162.8            -160.9                 -140                20.9
       90         35,787      -162.1            -160.1                 -140                20.1

                                Two-Degree Interference Analysis

         The MSAT-2 feeder links operate in the Ku-band frequencies defined in Appendix 30B

of the ITU Radio Regulations, and the MSAT-2 Telemetry, Tracking, and Command (“TT&C”)

operations are in the standard Fixed Satellite Service (“FSS”) Ku-band frequencies (12/14 GHz).

The respective interference analyses are provided below. The MSAT-2 service links operate in

the L-band frequencies for which a two-degree analysis is not required.1 Additionally, SkyTerra

has coordinated the L-band operations of MSAT-2 at 103.3°W with Inmarsat and SkyTerra

(Canada) Inc., the only potentially affected North American L-band satellite operators.

         Interference Analysis for the Appendix 30B Ku-Band Carriers

         In the Appendix 30B plan,2 the only satellite allotment within two degrees of the nominal

103°W orbital location, other than those of SkyTerra, is that of Ecuador, at 104.0°W.3 However,

the ITU database shows that allotment has not been converted to an assignment or brought into

use. Therefore, the interference analysis has been performed assuming that a hypothetical




1
      See 47 C.F.R.§ 25.150(b); see also Letter to Lon Levin from Bob Nelson, File No. SAT-
      AMD-20031118-00335 (April 23, 2004).
2
      International Telecommunications Union Radio Regulations 2007, Appendix 30B, Article
      10.
3
      MSAT-1 may be relocated to 105.3°W.

                                                 2


satellite with Appendix 30B Ku-band carriers and antenna parameters identical to those of

MSAT-2 will be operating at 105.3°W and SkyTerra 1 will be operating at 101.3°W.4

       The carrier types and power densities for MSAT-2 and SkyTerra 1 are provided in Tables

B-1 and B-2, respectively.

                             Table B-1 MSAT-2 Feeder Link Carriers

                                 Uplink                           Downlink
                     EIRP                  Density       EIRP                   Density
          Carrier   (dBW)      BW (kHz)    dBW/Hz       (dBW)     BW (kHz)      dBW/Hz
          CW         52.5         6          14.7         2.7        6           -35.1
          GC-S       54.5         6          16.7         2.7        6           -35.1
          QPSK-V     52.5         6          14.7         3.7        6           -34.1
          MMS        47.0         5          10.0         -5.3       5           -42.3
          DATA-F     65.5        300         10.7        14.6       300          -40.2
          Data1      55.4        168          3.1         -2.8      168          -55.0
          Data2      53.4        42           7.2         -2.8      42           -49.0
                    Max Uplink Density =    16.7       Max Downlink Density =    -35.1
                    Min Uplink Density =     3.1       Min Downlink Density =    -55.0




4
    See Public Notice, Report No. SPB-207, DA 04-1708 (June 16, 2004); see also supra note 3
    (discussing potential relocation of MSAT-1 to 105.3°W).

                                                   3


                            Table B-2 SkyTerra 1 Feeder Link Carriers

                   Uplink                                                  Downlink

                    EIRP                    Density            EIRP                   Density
   Carrier         (dBW)       BW (kHz)     dBW/Hz            (dBW)        BW (kHz)   dBW/Hz
   WCDMA            71.7         5000         4.7               34.5         5000      -32.5
   cdma2000         66.7         1250         5.7               34.7         1250      -26.3
   GMR               61           200         8.0               20.5          200      -32.5
   WiMax            62.1         1000         2.1               33.5         1000      -26.5
   GMSA-1            65          1250         4.0               -2.7          6.4      -40.8
   GMSA-2            ---          ---         ---                0.6          6.4      -37.5
   GMSA-3            ---          ---         ---               11.6         12.8      -29.5
   GMSA-4            ---          ---         ---               14.1         1250      -46.9
   GMR-3G-1          49         31.25         4.1              -0.03        31.25      -45.0
   GMR-3G-2          52          62.5         4.0               4.85        31.25      -40.1
   GMR-3G-3          52          62.5         4.0               7.16         62.5      -40.8
   GMR-3G-4          56         156.25        4.1               19.4        156.25     -32.5
   MSAT-
   Voice            46.7         4.8           9.9              1.7         4.8         -35.1
   MSAT-Data        40.0         1.2           9.2            -10.3         1.2         -41.1
   Command          68.0        1000           8.0              ---         ---           ---
   Telemetry         ---         ---           ---             20.0         100         -30.0
                    Max Uplink Density =       9.9           Max Downlink Density =     -26.3
                    Min Uplink Density =       2.1           Min Downlink Density =     -46.9

       Relevant feeder link earth station characteristics are shown in Table B-3. Side lobe

antenna gain toward an adjacent satellite is calculated using an angle of 2.2°, an estimate of the

topocentric angle corresponding to 2.0° orbital separation.


               Table B-3 – Feeder Link Earth Station Antenna Characteristics

                               Antenna Transmit Gain (dBi)          61.1
                                    Sidelobe Pattern            29-25Log(θ)

                                 Topocentric Separation             2.2°
                               Sidelobe Gain @ 2.2° (dBi)           20.4
                            Delta Gain Main -Side Lobe (dB)         40.7




                                                     4


                                              Uplink Analysis

         Table B-4a shows the results of the uplink C/I calculations for all pair-wise combinations

of networks. For the interfering network in each case, only the highest density (most interfering)

carrier is considered. For the victim network in each case, only the lowest density (most

sensitive) carrier is considered. Thus, the C/I values calculated represent the worst cases. The

C/I values are calculated using the equation:


C/Iup = CoVup – CoIup + ΔGtI

Where:
         C/Iup = Uplink carrier to interference ratio of the victim carrier caused by the interfering
         carrier

         CoVup = EIRP density of the victim carrier toward the victim satellite

         CoIup = EIRP density of the interfering carrier in the main lobe of its transmitting antenna

         ΔGtI = Difference in gain between the main lobe interfering antenna gain and the gain
         toward the victim satellite.

                   Table B-4a – Uplink Interference Calculation Results (C/I)

                                Uplink Single-Entry Co/Io & ΔT/T
                                      Topocentric Separation = 2.2°

                  Interferer                                           Victim

                  Maximum                                             Minimum
                   Density        Sidelobe                             Density
  Interferer      dBW/Hz          Rejection              Victim       dBW/Hz         C/I        ΔT/T
 SkyTerra 1           9.9          40.7 dB           MSAT-2             3.1        33.9 dB      0.04%
  MSAT
                     16.7          40.7 dB           MSAT-2             3.1        27.1 dB      0.20%
 @105.3°W
  MSAT-2             16.7          40.7 dB        MSAT@105.3°W          3.1        27.1 dB      0.25%

  MSAT-2             16.7          40.7 dB           SkyTerra 1         2.1        26.0 dB      0.25%




                                                     5


         As demonstrated in Table B-4a, all carrier combinations result in very low interference.

The worst case single-entry C/I is 26.0 dB, which corresponds to a ΔT/T value of 0.25%, well

below the coordination threshold value of 6%.

         MSAT-2 would receive interference from both SkyTerra 1 and the hypothetical MSAT

satellite at 105.3°W for a total ΔT/T of: 0.04% + 0.2% = 0.24%, which is below the coordination

threshold value of 6%.

                                          Downlink Analysis

         Table B-4b shows the results of the downlink C/I calculations for all pair-wise

combinations of carriers and networks. For the interfering network in each case, only the highest

density (most interfering) carrier is considered. For the victim network in each case, only the

lowest density (most sensitive) carrier is considered. Thus, the C/I values calculated represent

the worst cases. Thus, the C/I values calculated represent the worst cases. The C/I values are

calculated using the equation:

C/Idown = CoVdown – CoIdown + ΔGrI

Where:
         C/Idown = Downlink carrier to interference ratio of the victim carrier caused by the
         interfering carrier

         CoVdown = EIRP density of the victim satellite carrier toward its earth station

         CoIdown = EIRP density of the interfering satellite carrier toward the victim earth station

         ΔGtI = Difference in gain between the main lobe victim antenna gain and the gain toward
         the interfering satellite.




                                                   6


                 Table B-4b – Downlink Interference Calculation Results (C/I)

                              Downlink Single-Entry Co/Io & ΔT/T
                                   Topocentric Separation = 2.2°

                 Interferer                                         Victim

                 Maximum                                           Minimum
                  Density       Sidelobe                            Density
  Interferer     dBW/Hz         Rejection            Victim        dBW/Hz        C/I        ΔT/T
 SkyTerra 1        -26.3         40.7 dB          MSAT-2             -55       11.9 dB      8.13%
  MSAT
                   -34.1         40.7 dB          MSAT-2             -55       19.7 dB      1.35%
 @105.3°W
  MSAT-2           -34.1         40.7 dB      MSAT@105.3°W           -55       19.7 dB      1.35%

  MSAT-2           -34.1         40.7 dB         SkyTerra 1          -46.9     27.9 dB      0.21%




        The worst case single-entry C/I is 11.9 dB (ΔT/T = 8.13%) for the case of SkyTerra 1

interference to MSAT-2. The total interference to MSAT-2 would include interference from

both SkyTerra 1 and the hypothetical MSAT satellite at 105.3°W, for a total ΔT/T of: 8.13% +

1.35% = 9.48%. This exceeds the coordination threshold value of 6%. However, the

interference is primarily caused by SkyTerra 1, which is also operated by SkyTerra.

Accordingly, the potential interference cases between MSAT-2 and SkyTerra 1 will be resolved

operationally.

        All other carrier combinations result in very low interference. The worst case single-

entry C/I is 19.7 dB, which corresponds to a ΔT/T value of 1.35%, well below the coordination

threshold value of 6%.




                                                 7


          Interference Analysis for the FSS Ku-Band carriers

          In the standard FSS Ku band (12/14 GHz), other satellites operate within two degrees of

MSAT-2, i.e. at the nominal 101°W, 103°W, and 105°W orbital locations. Pursuant to an

agreement with SES Americom, Inc., SkyTerra has coordinated the TT&C Ku-band operations

of MSAT-2 at 103.3°W with AMC-1 at 103.0°W and AMC-15 at 105.05°W. SkyTerra

demonstrates below that the TT&C Ku-band operations of MSAT-2 meet the FCC’s two-degree

spacing requirement with respect to AMC-2 at 101.0°W and AMC-15 at 105.05°W.

          The carrier types and power densities for the TT&C Ku-band operations of MSAT-2 are

provided in Table C.

                            Table C – MSAT-2 12/14 GHz Carrier Parameters

   MSAT-2 at 103.3°W Ku-Band Uplink                              MSAT-2 at 103.3°W Ku-Band Downlink

                    EIRP                     EIRP Density                             EIRP                    EIRP Density
Carrier            (dBW)       BW (kHz)        dBW/Hz       Carrier                  (dBW)      BW (kHz)        dBW/Hz
Command              69          1000            9.0        Telemetry                 17.5        100            -35.1
                      Max Uplink Density =       9.0                                   Max Uplink Density =      -35.1
                      Min Uplink Density =       9.0                                   Min Uplink Density =      -35.1




          The carrier types and power densities for AMC-2 at 101.0°W and AMC-15 at 105.05°W

are provided in Tables D and E, respectively.

                                    Table D AMC-2 Carrier Summary

            AMC-2 at 101.0°W Ku-Band Uplinks                                AMC-2 at 101.0°W Ku-Band Downlink
  Earth Station     Max EIRP     Min EIRP                          Earth Station     Max EIRP     Min EIRP
                     Density      Density        Ant Gain                             Density      Density        Ant Gain
                    (dBW/Hz)     (dBW/Hz)         (dBi)                              (dBW/Hz)     (dBW/Hz)         (dBi)

Antenna Type 1          2            -3                60       Antenna Type 1          -28.9        -28.9           59
Antenna Type 2          5            0                 58
Antenna Type 3          3            -2                55




                                                            8


                                       Table E – AMC-15 Carrier Summary

           AMC-15 at 105.05°W Ku-Band Uplinks                                  AMC-15 at 105.05°W Ku-Band Downlinks
  Earth Station        Max EIRP       Min EIRP                          Earth Station        Max EIRP   Min EIRP
                        Density        Density       Ant Gain                                 Density    Density      Ant Gain
                       (dBW/Hz)       (dBW/Hz)        (dBi)                                  (dBW/Hz)   (dBW/Hz)       (dBi)

Antenna Type A             18           -11.7           60.3        Antenna Type A             -22        -41.5          59
Antenna Type B             18           -11.7           56.6        Antenna Type B             -19        -38.9         55.4
Antenna Type C             18           -11.7           54.1        Antenna Type C             -19        -36.2         52.7
Antenna Type D             15.6         -11.7           50.6        Antenna Type D             -19        -32.8         49.3
Antenna Type E             11.7         -11.7           46.1        Antenna Type E             -19        -32.1         44.6
Antenna Type F             -1.2         -11.7           42.5        Antenna Type F             -19        -31.8         41.3
Antenna Type G             -3.6         -11.7           40.1        Antenna Type G             -19        -31.2         38.7
                                                                    Antenna Type TT&C          -30.1      -33.1          59




        Table F presents the results of uplink C/I calculations between the MSAT-2 command

carriers and the AMC-2 uplink carriers. In all cases, the calculated delta T/T is lower than the

coordination threshold value of 6%. Therefore, there are no apparent interference concerns.

   Table F – Uplink Co/Io Calculations for MSAT-2 at 103.3°W and AMC-2 at 101.0°W

                                       Uplink Co/Io Calculations for MSAT-2 at 103.3°W and
                                                        AMC-2 at 101.0°W
                                                       Topocentric Angle =      2.5 deg
                                                 Interferer                                   Victim
                                  Max EIRP                                                Min EIRP
                                   Density      Earth Station   Sidelobe                   Density
                  Interferer      dBW/Hz        Antenna Gain    Rejection      Victim      dBW/Hz       Co/Io
                   AMC-2             2.0             60          40.9 dB       MSAT-2         9.0        47.9
                   AMC-2             5.0             58          38.9 dB       MSAT-2         9.0        42.9
                   AMC-2             3.0             55          35.9 dB       MSAT-2         9.0        41.9
                   MSAT-2            9.0            61.1         42.0 dB       AMC-2          60.0       93.0
                   MSAT-2            9.0            61.1         42.0 dB       AMC-2          58.0       91.0
                   MSAT-2            9.0            61.1         42.0 dB       AMC-2          55.0       88.0
                                                                                         Min Co/Io =     40.6
                                                                                      Max Delta T/T =   0.01%


        Table G presents the results of downlink C/I calculations between the MSAT-2 telemetry

carriers and the AMC-2 downlink carriers. In all cases, the calculated delta T/T is lower than the

coordination threshold value of 6%. Therefore, there are no apparent interference concerns.




                                                                9


 Table G – Downlink Co/Io Calculations for MSAT-2 at 103.3°W and AMC-2 at 101.0°W

                                Downlink Co/Io Calculations for MSAT-2 at 103.3°W and
                                                 AMC-2 at 101.0°W
                                                   Topocentric Angle =    2.5 deg
                   Interferer                                             Victim
                          Max EIRP                                                       Min EIRP
                           Density                       Earth Station   Sidelobe         Density
           Interferer     dBW/Hz         Victim          Antenna Gain    Rejection        dBW/Hz          C/I
            AMC-2           -28.9        MSAT-2              60.1         38.1 dB          -35.1         31.9
            MSAT-2          -35.1        AMC-2                59          37.0 dB          -28.9         43.2
                                                                                        Min Co/Io =      34.9
                                                                                     Max Delta T/T =    0.03%


       Table H presents the results of uplink C/I calculations between the MSAT-2 command

carriers and the AMC-15 uplink carriers. In all cases, the calculated delta T/T is lower than the

coordination threshold value of 6%. Therefore, there are no apparent interference concerns.

  Table H - Uplink Co/Io Calculations for MSAT-2 at 103.3°W and AMC-15 at 105.05°W

                                 Uplink Co/Io Calculations for MSAT-2 at 103.3°W and
                                                AMC-15 at 105.05°W
                                               Topocentric Angle =       2.2 deg
                                       Interferer                                    Victim
             Interferer     Max EIRP    Earth Station    Sidelobe        Victim    Min EIRP             C/I
                             Density    Antenna Gain    Rejection                   Density
                            dBW/Hz                                                  dBW/Hz
              AMC-15          18.0          60.3            38.3 dB      MSAT-2        9.0              29.3
              AMC-15          18.0          56.6            34.6 dB      MSAT-2        9.0              25.6
              AMC-15          18.0          54.1            32.1 dB      MSAT-2        9.0              23.1
              AMC-15          15.6          50.6            28.6 dB      MSAT-2        9.0              22.0
              AMC-15          11.7          46.1            24.1 dB      MSAT-2        9.0              21.4
              AMC-15          -1.2          42.5            20.5 dB      MSAT-2        9.0              30.7
              AMC-15          -3.6          40.1            18.1 dB      MSAT-2        9.0              30.7
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
              MSAT-2           9.0          61.1            39.1 dB      AMC-15       -11.7             18.4
                                                                                  Min Co/Io =           18.4
                                                                               Max Delta T/T =         1.46%


       Table I presents the results of downlink C/I calculations between the MSAT-2 telemetry

carriers and the AMC-15 downlink carriers. In all cases, the calculated delta T/T is lower than

the coordination threshold value of 6%. Therefore, there are no apparent interference concerns.




                                                          10


Table I – Downlink Co/Io Calculations for MSAT-2 at 103.3°W and AMC-15 at 105.05°W

                             Downlink Co/Io Calculations for MSAT-2 at 103.3°W and
                                             AMC-15 at 105.05°W
                                        Topocentric Angle =            2.2 deg
           Interferer                                                  Victim
                        Max EIRP                                                      Min EIRP
                         Density                    Earth Station     Sidelobe         Density
           Interferer   dBW/Hz         Victim       Antenna Gain      Rejection        dBW/Hz         C/I
            AMC-15        -22.0       MSAT-2            60.1           38.1 dB          -35.1        25.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -19.0       MSAT-2            60.1           38.1 dB          -35.1        22.0
            AMC-15        -30.1       MSAT-2            60.1           38.1 dB          -35.1        33.1
            MSAT-2        -35.1       AMC-15             59            37.0 dB          -41.5        30.6
            MSAT-2        -35.1       AMC-15            55.4           33.4 dB          -38.9        29.6
            MSAT-2        -35.1       AMC-15            52.7           30.7 dB          -36.2        29.6
            MSAT-2        -35.1       AMC-15            49.3           27.3 dB          -32.8        29.6
            MSAT-2        -35.1       AMC-15            44.6           22.6 dB          -32.1        25.6
            MSAT-2        -35.1       AMC-15            41.3           19.3 dB          -31.8        22.6
            MSAT-2        -35.1       AMC-15            38.7           16.7 dB          -31.2        20.6
            MSAT-2        -35.1       AMC-15             59            37.0 dB          -33.1        39.0
                                                                                     Min Co/Io =     20.6
                                                                                  Max Delta T/T =   0.88%


                                                Conclusion

       Accordingly, based on the analysis provided above, operation of MSAT-2 at 103.3°W

complies with the Commission’s technical rules.




                                                      11


                                    Technical Certification

       I, Richard Evans, Principal Engineer, SkyTerra Subsidiary LLC, certify under penalty of

perjury that:

       I am the technically qualified person with overall responsibility for preparation of the

technical information contained in this application. I am familiar with the requirements of Part

25 of the Commission’s rules, and the information contained in the application is true and correct

to the best of my knowledge and belief.


                                                    /s/
                                             Richard Evans

Dated: April 12, 2010



Document Created: 2010-04-12 18:06:11
Document Modified: 2010-04-12 18:06:11

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