Attachment Spectrum Five - Comm

This document pretains to SAT-PDR-20170411-00063 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2017041100063_1226596

                                  Federal Communications Commission
                                            Washington, D.C. 20554

                                                      May 17, 2017

Mr. David Wilson
1776 K Street, NW
Suite 200
Washington DC 20006

                                                Re:       Spectrum Five LLC
                                                         IBFS File No. SAT—PDR—20170411—00063
                                                         (Call Sign $3013)

Dear Mr. Wilson:

           On April 4, 2017, Spectrum Five, LLC (Spectrum Five) filed the above—captioned petition‘ to
access the U.S. market from the 95.15° W.L. orbital location using the 17/24 GHz Broadcasting—Satellite
Service (BSS) frequencies. To aid in the Commission‘s evaluation of Spectrum Five‘s application, please
provide the information requested below.‘

      1. Please verify that the value for satellite maximum orbital eccentricity given in Schedule S is
           correct. We note that the limit allowed in the Commission‘s rules is 4.7x10*. It is unclear,
           however, whether the entered value of 3.14 was deliberate on Spectrum Five‘s part, or whether it
           resulted from a limitation in the newest version of the Schedule S software.

           In the application narrative, the two oppositely—polarized downlink service beams providing
           coverage to CONUS, Alaska and Hawaii are described with multiple names, i.e., CONUS+,
           CONTR/CONTRL, and CONTR/CONTL. The downlink service beams included in Schedule S
           are named CONR and CONL. Please clarify whether these different names, in fact, all represent
          the same two beams. In addition, the narrative states that telemetry is provided across the
          CONUS+ service area through a CONTR beam." Please clarify whether this is one of the service
          link beams described above, or whether it is a separate, dedicated TT&C beam. If necessary,
          please update the description of the satellite‘s proposed downlink service and telemetry
          transmissions, and provide any missing Schedule S data, as appropriate.

          The application states that command signals will be transmitted to the satellite from a large earth
          station antenna and received by a second a second high—gain spot beam antenna (SWUR) pointed
          toward the southwest U.S. uplink.* Please clarify whether this SWUR beam is the same as the



147 CFR § 25.111(a).—
* Spectrum Five LLC, IBFS File No. SAT—PDR—20170411—00063 (Application), Technical Narrative at pp. 8—9. The
Commission recently modified Section 25.137 of its rules to specify that U.S. market access must be requested
through a petition for declaratory ruling. Accordingly, we change Spectrum Five‘s IBFS file number from a PPL
(petition for permitted list) to a PDR (petition for declaratory ruling).
> Application, Technical Narrative at pp. 10—11.
4 Id. at p. 11.


            SWRR beam included in Schedule S and described elsewhere in the narrative,‘ or whetherit
            represents a different beam altogether. If necessary, please provide the necessary Schedule S
            information for this beam, including antenna gain contour diagrams.‘

        4. Please clarify whether the Curacao TT&C beams CBRR and CBRT discussed in the application
           narrative‘ are the same as the Schedule S beams CRBR and CRBT.

        5. In its application technical narrative, Spectrum Five states that during transfer orbit and on—station
           emergencies, TT&C signals will be received and transmitted by the satellite using a combination
           of antennas that create a near omni—directional gain pattern." Please provide further information
           regarding this antenna gain pattern, including all required Schedule S information, and any
            necessary antenna gain contour diagrams."

            To facilitate the Commission‘s timely evaluation of Spectrum Five‘s application, we ask that you
provide the requested information no later than June 2, 2017. Failure to do so may result in the dismissal
of Spectrum Five‘s application pursuant to Section 25.112(c) of the Commission‘s rules, 47 CFR §
25.112(c).

                                                      Sincerely,




                                               &»@N
                                                  iubqut
                                                      Chief, Satellite Division
                                                      International Bureau




5 Id. at p. 7.
647 CFR § 25.114(c)(4).
" Application, Technical Narrative at p. 10.
* 14.
9 47 CFR § 25.114(c)(4).



Document Created: 2017-05-17 12:55:03
Document Modified: 2017-05-17 12:55:03

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