Response - v2.pdf

LETTER submitted by Kepler Communications Inc.

Errata

2017-06-26

This document pretains to SAT-PDR-20161115-00114 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2016111500114_1241493

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of ) ) IBFS File No. SAT-LOI-20161115-00114 Kepler Communications Inc., Petition for ) (Call Sign S2981) Declaratory Ruling ) ) ADDITIONAL INFORMATION FOR 140 SATELLITE FILING Kepler Communications Inc. (Kepler) is hereby providing the Commission with further information on its non-geostationary satellite orbit (NGSO) fixed-satellite service (FSS) system, for which market access to the US was requested. 1. Kepler is including for reference the changes made to schedule S. The changes made were to fix errata or further clarify how the system intends to operate based on the request of the International Bureau. Change Type Description Removal of Min / Errata As described in Kepler’s earlier submission Saturation Max Saturation Flux Flux Density is not an applicable parameter since Kepler Density of all Beams does not employ a bent pipe architecture. The inclusion of SFD in the prior Schedule S was an error. Addition of receive Clarification At the request of the Commission these receive beams beams: were added to clarify the capable operating range of the UG1r, UG3, UG4, system. They are used to show both LHCP and RHCP UU2, UU3, UU4, operation, in additional to lower and upper bounds on UU5, UU5r, UU6, operating elevation angles of the system. Note, receive UU6r, UG5, UG5r, beams for gateways are included for completeness UG2, UG2r though at present Kepler does not intend to operate gateways within the United States. 26 June 2017 Kepler Communications Inc. 1 of 6

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 Addition of receive Clarification At the request of the Commission these receive channels channels: were added to show the operating range of Kepler’s UUal, UUah, UUbl, SDR. UUbh, UUcl, UUch, GUal, GUah Correction of G/T at Errata G/T was updated to take into account the elevation angle Max. Gain Point of communication as presented in the service area description. Addition of transmit Clarification At the request of the Commission these transmit beams beams: were added to clarify the capable operating range of the DG2, DU2, DU3, system. They are used to show both LHCP and RHCP DU3r, DG3, DG4, operation, in additional to lower and upper bounds on DU1r, DU2r operating elevation angles of the system. Note, transmit beams for gateways are included for completeness though at present Kepler does not intend to operate gateways within the United States. Should Kepler operate a gateway within the United States in the future it will maintain the same constant EIRP density demonstrated in these transmit beams in order to maintain EPFD compliance. Correction of PFD Errata It was noted that PFD values were incorrectly calculated values for all beams. This was corrected for all beams. Correction of EIRP Errata It was noted that EIRP density was inconsistently density values calculated using different reference bandwidths. This has been recalculated using the same reference bandwidth across all beams to emphasize the use of a constant EIRP density. Correction of Max. Errata Corrected Max. Transmit EIRP to take into consideration Transmit EIRP the elevation angle of communication as presented in the service area description. Addition of transmit Clarification At the request of the Commission these transmit channels channels: were added to clarify the capable operating range of the 26 June 2017 Kepler Communications Inc. 2 of 6

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 DUcl, DUch, DUbl, system. Note, transmit channels for gateways are DUbh, DUal, DUah, included for completeness though at present Kepler does DGb1, DGbh, DGal, not intend to operate gateways within the United States. DGah, Should Kepler operate a gateway within the United States in the future it will maintain the same constant EIRP density demonstrated in these transmit beams in order to maintain EPFD compliance. 2. As noted previously, Kepler’s satellite is designed to maintain a target power-flux density (“PFD”) at the surface of the earth as shown in Figure 5 of Kepler’s petition for declaratory ruling1. For further clarity, this is achieved by maintaining a constant EIRP density across all bands and bandwidths. Ensuring EPFD, and PFD compliance independent of how the SDR parameters2 change to support coordination and customer requirements. As noted in Schedule S, the maximum EIRP density that is maintained across all beams is -50.5 dBW/Hz. This EIRP density is constrained by the software onboard the Kepler SDR, which is preprogrammed prior to launch. The SDR will host a look up table of bandwidth, data rate, and power. This look up table will define the allowable operating parameters of the SDR to ensure a constant EIRP density. In operation, the SDR will select the complimentary parameters from this look up table prior to a transmission. 1 See Kepler Technical Narrative and Kepler’s letter to the Commission date June 8th, 2017 2 Power, bandwidth, and center frequency 26 June 2017 Kepler Communications Inc. 3 of 6

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 3. As requested by the Commission, Kepler is providing the following set of figures that show Kepler’s antenna gain contours overlaid on a plot of the coverage region. Figure 1: Single Kepler satellite beam gain contour visible on the ground. Dashed line represents service area. Figure 2: Zoomed in version of Figure 1 to show gain contour lines more clearly. 26 June 2017 Kepler Communications Inc. 4 of 6

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 Figure 3: Single beam gain contour visible on the ground when steered to a 64 degree off bore-sight angle. Dashed line represents service area. Figure 4: Single beam gain contour visible on the ground if simultaneously steered in every direction. This is the assumption made when computing EPFD for the full satellite constellation. Dashed line represents coverage region. 26 June 2017 Kepler Communications Inc. 5 of 6

Kepler Communications Inc. 675 King Street West, #204 Toronto, ON Canada M5V 1M9 Respectfully submitted, Kepler Communications Inc. - June 26, 2017 By: __/s/ Nickolas G. Spina_ Nickolas G. Spina Manager of Launch and Regulatory Affairs Kepler Communications Inc. 26 June 2017 Kepler Communications Inc. 6 of 6


Document Created: 2017-06-26 11:47:33
Document Modified: 2017-06-26 11:47:33
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