Attachment Narrative

This document pretains to SAT-STA-20181119-00084 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018111900084_1577247

APPLICATION FOR SPECIAL TEMPORARY AUTHORITY Ligado Networks Subsidiary LLC (“Ligado”), pursuant to Section 25.120 of the Commission’s Rules, hereby requests a second extension of its existing special temporary authority (“STA”)1 to conduct telemetry, tracking, and command (“TT&C”) communications with MSAT-2 (AMSC-1) at 106.5° WL during the pendency of its application to modify the MSAT-2 license to relocate the satellite from 103.3° WL to 106.5° WL.2 Ligado requests that the Commission again extend the August STA, with the extended period commencing on December 4, 2018 and ending on February 4, 2019.3 Ligado commenced the drift from MSAT-2’s previous location at 103.3°4 to 106.5° on September 5, 2018, and completed it on September 20, 2018. As noted in its application for the October STA, Ligado needs to continue conducting TT&C communications with the satellite while the Commission considers the MSAT-2 Modification Application. As such, the following repeats information from the August and October STA applications relevant to ongoing operations at the new orbital location. Please also note that, consistent with the MSAT-2 Modification Application, Ligado is requesting continued authorization to operate with an east- west station-keeping range of +/-0.1 degree, under the same conditions as established by the October STA. The August and October STA applications requested authorization to relocate MSAT-2 from 103.3° WL to 106.5° WL, an orbital position under Canadian authority. During and after the relocation, MSAT-2’s communications payload hardware is powered on but is not providing downlink services. During the drift, Telesat Canada Inc. (“Telesat”), Ligado’s contractor for flight operations, is operating only (1) MSAT-2’s telemetry, tracking, and command TT&C payload on 11.701 GHz (primary), 11.7005 GHz (backup), 14.0005 GHz (backup) and 14.4995 GHz (Primary) and (2) MSAT-2’s beacon frequencies at 10.7535 GHz (primary) and 10.751 GHz (backup). MSAT-2 serves as a backup satellite to Ligado’s other U.S. satellite, ST-1 and, as a backup satellite, does not currently carry customer traffic. The orbital location at 106.5° WL is the former location of Ligado’s Canadian satellite, MSAT-1, which was moved from 106.5° WL to 107.5° WL in October, 2015. Innovation, Science & Economic Development (“ISED”) 1 See FCC File No. SAT-STA-20180810-00061 (granted Aug. 28, 2018) (“August STA”); FCC File No. SAT-STA-20180914-0072 (granted Oct. 10, 2018) (“October STA”). 2 See FCC File No. SAT-MOD-20180912-00070 (filed Sept. 12, 2018) (“MSAT-2 Modification Application”). 3 An extension to February 4, 2019 will be a 62 day extension, two days longer that the October STA extension. As a 60 day extension would end on February 2, a Saturday, an additional two days is requested to allow further Commission action on the last day if necessary. 4 See FCC File No. SAT-MOD-20100412-00075 (granted Nov. 8, 2010) (granting authority to move MSAT-2 to 103.3°); FCC File No. SAT-MOD-20171215-00172 (granted Jan. 23, 2018) (extending MSAT-2 operations through Dec. 31, 2018).

Canada is aware of the August STA and subsequent extension.5 Grant of this application is entirely consistent with the Commission’s policy of granting Special Temporary Authority when doing so will not cause harmful interference and will serve the public interest, convenience and necessity.6 The public interest, convenience and necessity is served because MSAT-2’s previous location only allowed operation on a non-interference basis. The relocation of the satellite to 106.5°, without interference or harm to other operators, will result in MSAT-2 being better accommodated in a fully coordinated orbital location, thus providing future certainty for backup MSS operations. With regard to interference, there is no risk of harmful interference from MSAT-2 operating in the new location. As MSAT-2 and MSAT-1 were built to the same design specifications, MSAT-2’s operating characteristics and interference envelope are identical to those of MSAT-1,7 which operated in that location for 20 years without causing any harmful interference to other operators. Moreover, this location has already been coordinated with other L-band operators assuming use by an MSAT-class satellite. Thus, placement of MSAT-2 will not create any new interference risk that has not already been discussed and resolved by the relevant operators. Finally, MSAT-2’s TT&C communications pursuant to the August STA, October STA and this extension have been and will continue to be on a secondary, non- interference basis. The MSAT-2 Modification Application provides further information substantiating the absence of any risk of harmful interference.8 With regard to MSAT-2’s east-west station keeping range, MSAT-2 has adopted an increasingly inclined orbit, which will continue to increase for several years at the new orbital location. Accordingly, to provide necessary flexibility for expected operations for the next five years and to extend MSAT-2 remaining fuel life, Ligado requested in the MSAT-2 Modification Application to change the north-south station-keeping range to +/-13.5 degrees and, pursuant to 47 C.F.R. §25.201(j), requested that the Commission authorize a change to the east-west station-keeping range to +/-0.1 degrees. 5 Ligado requested in the August STA, October STA and the MSAT-2 Modification Application that the Commission indicate to ISED that it consents to relocating MSAT-2 to bring back into use the orbital location at 106.5° WL, and to the extent necessary reiterates that request here. See ITU, Radiocommunication Bureau, WRC-12 decisions included in the Minutes of Plenary meeting relating to space services procedures, Circular Letter CR/333 (2012) at 2 (citing (§3.12 Doc. CMR12/554); see also ITU, Radiocommunication Bureau, Decisions of past WRCs concerning the application of the Radio Regulations, Circular Letter CR/380 (2015) at 3 (same). 6 See e.g., Newcomb Communs., Inc., 8 FCC Rcd. 3631, 3633 (1993); Columbia Comms. Corp., 11 FCC Rcd. 8639, 8640 (1996); Am. Tel. & Tel. Co., 8 FCC Rcd. 8742 (1993). 7 MSAT-2 does differ from MSAT-1 in only one respect: MSAT-2 uses 11.7005 GHz as a backup TT&C frequency, while MSAT-1 uses 11.70275 GHz as a backup. This difference is not material, however, to interference with any other operator. 8 See MSAT-2 Modification Application, Exhibit C, 4-6 and Technical Exhibit.

As explained in the MSAT-2 Modification Application,9 these ranges will not result in any overlap with any neighboring satellites. The nearest existing satellites to the new orbital location are a U.S. Navy satellite located at 105.5°WL and a Telesat satellite located at 107.3°WL, neither of which will overlap with MSAT-2’s station-keeping range. Ligado has also reviewed planned satellites and determined that there will be no overlap with the nearest planned satellites, none of which will be placed into orbit through the duration of the extension requested. As expected, MSAT-2 has operated at the new orbital location since September 20 without any overlap or other operational issues with other satellites. Accordingly, and for good cause shown, Ligado respectfully requests that its STA request be granted. 9 See id., Exhibit C, 2-3.


Document Created: 0320-04-12 00:00:00
Document Modified: 0320-04-12 00:00:00
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