Attachment LightSquared-Grant D

LightSquared-Grant D

DECISION submitted by IB, FCC

gr

2010-12-03

This document pretains to SAT-STA-20101025-00224 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010102500224_854855

                                                                                         Fda# 61%519z_oao |045 oozw
$2358        SAT—STA—20101025—00224         1B2010003309
LightSquared Subsidiary LLC
SkyTerra—1                                                                               CaIlSign '61358 GrantDate_12/03/10
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                                                                                         (or other   identifier) Term Dates Peried of   Approved by OMB
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                                                                                                                         "3°©                   3060—0678


 Date & Time Filed: Oct 25 2010 5:53:35:060PM                   Internat    nal Bureau   Approved:        /
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 File Number: SAT—STA—20101025—00224                       se   wu’f\\Cmd\hons                               3. Duail
 Callsign:                                                                                                  Ch\va’relh’fc Pohcd Branch

                                              FEDERAL COMMUNICATIONS COMMISSION
                                    APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                                  FOR OFFICIAL USE ONLY


    APPLICANT INFORMATION
 Enter a description of this application to identify it 0 n the main menu:
  Application for certain IOT authority (SkyTerra 1)
  1. Applicant

             Name:            LightSquared Subsidiary LLC                  Phone Number:                       703—390—2001
             DBA Name:                                                     Fax Number:                         703—390—2770
             Street:          10802 Parkridge Blvd                     E—Mail:                                 jeff.carlisle@lightsquared.com


             City:            Reston                                       State:                              VA
             Country:         USA                                      Zipcode:                                20191
             Attention:       Mr Jeffrey J. Carlisle


                                                  Attachment to Grant
                           IBFS File No. SAT—STA—20101025—00224
                                       Call Signs: $2358
                                                    December 3, 2010

The request of LightSquared Subsidiary LLC (LightSquared) for special temporary authority
(STA), File No. SAT—STA—20101025—00224, is granted. Accordingly, LightSquared is
authorized, for a period of 30 days, to operate with parameters not previously authorized in the
1525—1544/1545—1559 MHz, 10.7—10.95 GHz, and 11.2—11.45 GHz bands (space—to—Earth) and
1626.5—1645.5/1646.5—1660.5 MHz (Earth—to—space) frequency bands for in—orbit testing (IOT)
of the SkyTerra—1 space station (Call Sign $2358) at the 101.3° W.L. orbital location. For
purposes of this temporary authorization, the power flux density limits in Section 25.208(b) of
the Commission‘s rules, 47 C.F.R. §25.208(b), ARE WAIVED. This authorization is granted in
accordance with the terms and technical specifications in the STA application, the Federal
Communication Commission‘s rules not explicitly waived herein, and the following conditions.

    1. All operations shall be on an unprotected and non—harmful interference basis, i.e.,
       Lightsquared shall not cause harmful interference to, and shall not claim protection from
       interference caused by, any other lawfully operating radiocommunication system.

       In the event any harmful interference results from operation pursuant to this STA,
       LightSquared shall cease the interfering operation(s) immediately upon notification of
       such interference and shall immediately inform the Commission, in writing, of the event.

       LightSquared‘s operations pursuant to this STA shall be limited to in—orbit testing and
       shall not include provision of commercial services.

       LightSquared shall coordinate its IOT operations pursuant to this STA with the operators
       of potentially—affected geostationary satellites to ensure that no unacceptable interference
       results from such operation.

       This action is taken pursuant to Section 0.261 of the Commission‘s rules on delegated
       authority, 47 C.F.R. § 0.261, and is effective immediately. Petitions for reconsideration
       under Section 1.106 or applications for review under Section 1.115 of the Commission‘s
       rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date of the public
       notice indicating that this action was taken.


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                                                                          Call Sign 22358 Grant Date 12 /o3/10
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2. Contact


             Name:         Bruce D. Jacobs                      Phone Number:                         202—663—8000
             Company:      Pillsbury Winthrop Shaw Pittman      Fax Number:                           202—663—8007
                           LLP
             Street:       2300 N Street NW                     E—Mail:                               bruce.jacobs@pillsburylaw.com



             City:         Washington                           State:                                DC
             Country:        USA                                Zipcode:                              20037      —
             Attention:                                         Relationship:           .             Legal Counsel


   (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
   3. Reference File Number or Submission ID
  4a. Is a fee submitted with this application?
@, IfYes, complete and attach FCC Form 159. .If No, indicate reason for fee exemption (see 47 C.FR.Section 1.1114).
C Governmental Entity        3 Noncommercial educational licensee
g34 Other(please explain):

4b. Fee Classification    CRY — Space Station (Geostationary)
5. Type Request

{4 Change Station Location                   ‘     {3 Extend Expiration Date                         & Other


6. Temporary—Orbit Location                                                7. Requested Extended Expiration Date


8. Description   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Applicant seeks authority to conduct certain in—orbit testing of SkyTerra 1.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @, Yes              gy No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR
1.2002(b) for the meaning of "party to the application" for these purposes.


10. Name of Person Signing                                                  11. Title of Person Signing
Jeffrey J. Carlisle                                                         Executive Vice President, Regulatory Affairs
12. Please supply any need attachments.
 Attachment 1: Application for STA                  Attachment 2:                                      Attachment 3:


          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you
have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the
Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
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DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This
collection has been assigned an OMB control number of 3060—0678.

THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                 BEFORE THE
                     FEDERAL COMMUNICATIONS COMMISSION
                            WASHINGTON, D.C. 20554


In the Matter of                                   )

LightSquared Subsidiary LLC                        ; File No.

Application for Special Temporary Authority        %

                                        APPLICATION

       By this Application, LightSquared Subsidiary LLC ("LightSquared") seeks Special

Temporary Authority ("STA") beginning November 28, 2010 and continuing for 30 days (i.e.

until December 28, 2010) to conduct certain in—orbit testing ("IOT") of the SkyTerra 1 satellite,

as explained below. Given the imminent launch of the satellite in less than one month,

LightSquared requests that the Commission act expeditiously in granting this application.‘

1.     BACKGROUND

       LightSquared is authorized to launch and operate the SkyTerra 1 satellite at the

101.3°W.L. location." The satellite is authorized to operate its service links on the L—band

frequencies (i.e. 1525—1544/1545—1559 MHz (space—to—Earth) and 1626.5—1645.5/1646.5—1660.5

MHz (Earth—to—space)) coordinated internationally by the United States and its feeder links on

the Appendix 30B Ku—band frequencies (i.e. 10.70—10.95 & 11.20—11.45 GHz (space—to—Earth)

and 12.75—13.25 GHz (Earth—to—Space)). On November 14, 2010, SkyTerra 1 is scheduled to be

‘ Because LightSquared seeks to conduct the tests specified in this application for no more than
30 days, no public notice of this application is necessary. See 47 C.F.R. § 25.120(b)(4).
> In the Matter ofMobile Satellite Ventures Subsidiary LLC, 20 FCC Red 9752 (Int‘l Bur. 2005);
see also File Nos. SAT—MOD—20100405—00064 (filed April 5, 2010) and SAT—AMD—20100908—
00191 (filed September 8, 2010) (seeking an extension of the launch and operate milestone for
SkyTerra 1). The MSAT—2 satellite presently operates at 101.3°W.L., and LightSquared has a
pending application to relocate that satellite to 103.3°W.L. See File Nos. SAT—MOD—20100412—
00075, SAT—AMD—20100514—00101, and SAT—AMD—20100527—00112.


launched from Kazakhstan by ILS International Launch Services, Inc. Beginning November 28,

2010, LightSquared plans to perform certain testing of its communications payload, including

associated telemetry, tracking, and command systems, as discussed below." The IOT will be

performed by employees of LightSquared‘s satellite contractor, Boeing Satellite Systems Inc.

("Boeing"), under LightSquared‘s direction and supervision.*

       The IOT will be performed using LightSquared‘s FCC authorized gateway earth stations

at Napa, CA (EO80030) and Cedar Hill, TX (EO80031), as well as gateway earth stations in

Saskatoon, Saskatchewan and Ottawa, Ontario, which are authorized by Industry Canada to

communicate with SkyTerra 1. The IOT will consist of a number of sequentially performed

tésts. Initially, the satellite‘s bus systems and communication payload will be tested, and basic

functionality will be confirmed. Subsequently, the performance of the components related to

beam—forming will be tested as will the combined payload and Ground—Based Beam Forming

("GBBF") network to confirm that various L—band beams are being formed as specified.

       A portion of the IOT will be performed using signals within the limits permitted under

LightSquared‘s satellite and earth station authorizations. However, for the tests specified below,

LightSquared will exceed its authorized limits and, accordingly, seeks STA to conduct such tests.

The proposed testing of SkyTerra 1 is not expected to cause harmful interference to any other

satellite operator, and as discussed below, LightSquared either has coordinated or expects to


* The communications payload of the SkyTerra 1 satellite consists of two repeater subsystems:
one associated with the forward channel and another one associated with the return channel. The
forward channel refers to the Ku—to—L band signal path that originates from any of
LightSquared‘s Ku—band gateway facility to the satellite, and is transmitted to an L—band
terminal. The return channel refers to the link from an L—band terminal to the satellite and then
to the Ku—band gateway.
* Boeing is also responsible for obtaining any necessary authorizations for launch and early orbit
phase ("LEOP") operations.


complete coordination with all potentially affected satellite operators prior to the launch of

SkyTerra 1.

II.    TEST DESCRIPTIONS

A.     L—Band Power Ramp—up

       The power output of the L—band forward payload will be gradually increased to the

Nominal Operating Point which corresponds to the maximum L—band power that will be used in

operation. The objective of the test is to gradually increase the temperature of coaxial cables to

vent out air and organic gases trapped inside. Table 1 shows the characteristics of the downlink

L—band carrier used during power ramp—up. STA is required for this carrier because its power

and power flux spectral density ("PFSD") exceeds that of any carrier type authorized for

SkyTerra 1. For this test, as well as those discussed below involving the L—band frequencies,

LightSquared has coordinated use of the IOT frequencies and power levels with Inmarsat, the

only potentially affected L—band operator." LightSquared will be in continuous contact with

Inmarsat prior to and during IOT; Inmarsat will be aware of the test schedule and will be able to

alert LightSquared if any harmful interference is detected during testing.

B.     L—Band Forward Payload Health Check

       The objective of this test is to characterize the health of the L—band forward and return

element paths. Signal paths through each solid—state power amplifier will be checked

sequentially, and the total test duration will be 120 minutes. Table 1 shows the characteristics of


° Some of the IOT involve L—band frequencies assigned internationally to Solidaridad—1, which is
no longer in operations. Accordingly, there can be no harmful interference to that satellite from
any of the proposed testing. SkyTerra 1 is also authorized to use the Solidaridad—1 frequencies.
iSee also In the Matter ofSkyTerra Subsidiary LLC, DA 10—356 (Int‘l Bur. March 1, 2010). With
respect to all tests, LightSquared will coordinate internally and with its joint venture partner,
SkyTerra (Canada) Inc., to prevent harmful interference to MSAT—2 at 103.3°W.L. and MSAT—1
at 106.5°W.L., respectively.


the downlink L—band cartier used during the forward payload health check. STA is required for

this carrier because its PFSD exceeds that of any carrier type authorized for SkyTerra 1.

C.     L—Band Forward and Return Antenna Mapping

       Antenna mapping will be performed to confirm the gain and gain roll—off of the forward

L—band beams. Table 1 shows the characteristics of the downlink L—band carriers used during

forward L—Band antenna mapping. These carriers will be received and measured at the gateway

earth stations while the satellite attitude is slewed in elevation and azimuth. STA is required for

this carrier because its PFSD exceeds that of any carrier type authorized for SkyTerra 1. Further,

during portions of the slews, the SkyTerra—1 beams will be aimed beyond authorized boundaries.

       For return L—band antennamapping, LightSquared will uplink CW carriers from its

gateway earth stations. These carriers will be received at the satellite as its attitude is slewed in

elevation and azimuth. STA is required because the carrier will have an EIRP of 15 dBW while

the gateway earth stations are authorized for a maximum carrier EIRP of 9 dBW.

D.     L—Band G/T Check

       A 24—hour G/T check \;vill be conducted over a range of the L—band frequencies by

transmitting test carriers from a beam originating from the Napa, CA gateway earth station. All

test carriers will be within bandwidth limits authorized for use by LightSquared. STA is required

because the carriers will have an EIRP of 15 dBW, which exceeds the maximum carrier EIRP of

9 dBW authorized to the Napa gateway earth station.

E.     Ku—Band Forward and Return Antenna Mapping and Forward EIRP Test

       Antenna mapping will be performed to confirm the gain and gain roll—off of the four

forward and return Ku—band beams. For the forward mapping, a CW carrier within the

authorized frequency parameters will betransmitted from the satellite Ku—band beam under test.

The carriers will be received and measured at the Napa, CA gateway earth station while the


satellite attitude is slewed in elevation and azimuth. The forward EIRP test is vsimilar, except that

the satellite attitude will be fixed for each beam measurement with the beam under test centered

on the Napa, CA gateway and four different frequencies will be used. For the return beam

mapping, a CW carrier within authorized power and frequency parameters will be transmitted

from the Napa, CA gateway earth station, and the level measured at the satellite will be

transmitted back to the Napa, CA station via the telemetry channel. For the forward beam

mapping, four CW carriers within the authorized frequency parameters will be transmitted from

the satellite and will be measured at Napa, CA gateway earth station. STA is required for this

carrier because during portions of the slews, the SkyTerra 1 beams will be aimed beyond

authorized boundaries toward the north and west, and the downlink PFSD will exceed the limits

of 47 C.F.R. § 25.208, as shown in Table 4 below.

       This test is not expected to cause harmful interference. The nearest co—frequency satellite

is TerreStar—1 at 111.0 °W,° and at this minimum 9.8° of minimum separation, the lowest amount

of sidelobe discrimination (for a 2.7m antenna, which is the minimum size for an ITU compliant

AP—30B antenna) is 45 dB. See ITU RR AP—30B Annex 1, paragraph 1.6. Additionally, the test

carriers are widely spaced, and therefore, the average density over the band is low. LightSquared

expects to complete coordination with Terrestar prior to the launch of SkyTerra 1. There are no

other Appendix 30B networks operating within the affected region.




° See supra note 5 (discussing coordination with MSAT—1 and MSAT—2).


       Table 1— Forward L—Band Payload Tests



                   L—band EIRP                    L—band PFSD          Expected
                      (dBW)         Bandwidth     (dBW/m"—Hz)          Duration
 L—Band Power
   Ramp—up
                        579         312.5 kHe          114              6 hours
   Payload
 Health Check            52             CW             —111            2 hours
     — CW
    L—Band
    Antenna                                                         15 minutes/cut
    Mapping              53             cCw            110             x 60 cuts

Note: Corresponding Ku—band carriers will be spread across the authorized band and will be
within authorized levels.

       Table 2— Return L—Band Payload Tests

                   L—band EIRP                        Expected
                      (dBW)         Bandwidth         Duration
                                                            —
 Feed Element
  Gain Check             15             CW           90 minutes
    Payload
 Health Check —          15             CW             2 hours
      CW
                                                        —
    L—Band
    Antenna              15             Cw         15 minutes/cut
                                                      x 60 cuts
    Mappii ng
  L—Band G/T
     Check                15          CW            24 hours
Note: Corresponding Ku—band carriers will be spread across the authorized band and will be
within authorized levels.

       Table 3— Forward Ku—Band Antenna Mapping and EIRP Test

                   Satellite Ku—                                         —
                    band EIRP                    EIRP Density       Expected
                      (dBW)        Bandwidth     (dBW/4 kHz)        Duration
    Ku—Band
    Antenna            32.2          CW              —3.8          40 hours
    Mapping
Note: The test will comprise a number of cuts over 40 hours, but the carriers will not be active
continuously throughout that period.


    Table 4 — Downlink PFSD


                              SkyTerra 1
Maximum PFD    Elevation   Maximum Power
   Limit         Angle       Flux Density   Margin
 (dB(W/m®/4    (degrees) (dB(W/m"/4 kHz))    (dB)
   kHz))
    —150          0             —131.2      —18.8
    —150          5             —131.1      —18.9
    —140          25            —130.6       —9.4
    —140          90            —129.9      —10.1


       For the foregoing reasons, LightSquared requests that the FCC grant this application

expeditiously.



                                                   Respectfully submitted,

                                                   LightSquared Subsidiary LLC



                                                               Is/
                                                   Name: Jeffrey J. Carlisle
                                                   Title: Executive Vice President, Regulatory
                                                          Affairs and Public Policy of
                                                          LightSquared LP
                                                          LightSquared Subsidiary LLC


Bruce D. Jacobs
Tony Lin
Pillsbury Winthrop Shaw Pittman LLP
2300 N Street, NW
Washington, DC 20037—1128
(202) 663—8000
Counselfor LightSquared Subsidiary LLC

October 25, 2010


                                   Technical Certification

      I, Richard Evans, hereby certify under penalty of perjury that:

             I am the technically qualified person responsible for preparation of
             the engineering information contained in this application, that I am
             familiar with Part 25 of the Commission‘s rules, that I have either
             prepared or reviewed the engineering information submitted in this
             application, and that it is complete and accurate to the best of my
             knowledge.                                        '




                                                             Is/
                                                    Richard Evans
                                                    Principal Engineer
                                                    LightSquared Subsidiary LLC
October 25, 2010


                              Certification of Jeffrey J. Carlisle

      I, Jeffrey J. Carlisle, hereby certify under penalty of perjury that:

       1. I am Executive Vice President, Regulatory Affairs and Public Policy of LightSquared
          LP, the managing member of LightSquared Subsidiary LLC, and have authority to file
          this application;

      2. The statements made in this application are true, complete, and correct to the best of
         my knowledge and belief; and

      3. No party to the application is subject to a denial of federal benefits pursuant to Section
         5301 of the Anti Drug Abuse Act of 1988, 21 U.S.C. §853a.




                                                              Is/
                                                      Jeffrey J. Carlisle
                                                      Executive Vice President, Regulatory
                                                              Affairs and Public Policy of
                                                              LightSquared LP
                                                      LightSquared Subsidiary LLC


October 25, 2010



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Document Modified: 2019-04-14 14:12:27

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