Attachment 20120306144455.pdf

20120306144455.pdf

COMMENT submitted by NTIA

Comment

2009-01-06

This document pretains to SES-AMD-20080219-00172 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2008021900172_945573

UNITED STATES DEFPARTMENT Or cumms=aue National Telecommunications ard Information Administration Washington, D.C. 20230 JAN 6 2008 Mr. Julius Knapp Chief, Office of Engineering and Technology Federal Communications Commission 445 12th Street SW Washington, DC 20554 Dear Mr. Knapp: The National Telscommunications and Information Administration (NTIA) provides the following comment concerning the New ICO Satellite Services G.P. (ICO) request to waive the Federal . Communications Commission‘s (Commission} rules 47 C.F.R. Sections 25.252(a)(1) and 25.252(a)(6). / These rules provide out—of—band emission (OOBE) limits and a separation distance necessary to protect — federal earth stations in the band 2200—2290 MHz from ancillary terrestrial component (ATC)} operations in the adjacent band 2180—2200 MHz. Specifically, Section 25.252(a)(1) requires an OOBE limit of — 100.6 dBW/4 kHz and Section 25.252(a)(6) requires that ATC base stations be separated by at least 820 meters from federal earth stations. ICO and the affected federal agencies have met and signed an agreement which is enclosed. I am forwarding this agrsement with NTHHA‘s concurrence and requesting the following Ordering Clauses be included in the ICO license: IT IS ORDERED that all ICO ATC operations will be conducted in a manner consistent with the "Operator—to—Operator Agreement between ICO Global Communications and United States Federal Government Agencies Operating Earth Stations in the 2200—2290 MHz Band". IT IS ORDERED that all ICO ATC base stations located within 133 km of an existing federal earth station shall not exceed an EIRP of —100.6 dBW/4 kHz for out—of—channel emissions at the edge of the 2200—2290 MHz band. If you have any questions my point—of—contact on this issue is Edward M. Davison (202—482—5526; edavison@ntia.doc.gov). Sincerely, Karl B. Nebbia Associate Administrator Office of Spectrum Management Enclosure ‘ See IBFS File Nos. SES—AMD—INTR2008—00147 (January 18, 2008) and SES—LIC—INTR2007—02866 (December 3, 2007).

Operator—to—Operator Agreement between iC0 Global Communications and United States Federal Government Agencies Operating Earth Stations in the 2200—2290 MHz Band 1. Introduction In response to an ICO Global Communications {{CO]} request to the Federal Communications Commission {FCC}, made pursuant to Section 25.252{a}(6}) of the Commisstion‘s rules, the National Telecommunications and Information Administration {NTIA) sent a {etter, dated March 8, 2007, to Mr. lultus Knapp, Chief, Office of Engineering and Technology of FCC, identifyingfederal earth stations, operating in the 2200—2290 MHz band, within the United States of America.‘ On October 2, 2007, NTIA provided an updated list of federal earth station facilities." On March 5, 2008, FCC released a Public Notice listing 10CO‘s application for authority to implement an ancilizry terrestrial component ("ATC"}) for 1CO‘s 2 GHz MSS system." in the application ICO seeks to waive specific portions of Section 25.252 of the Commission‘s rules, including Sections 25.252{a)(1)" and 25.252{a)(6)." — Consistent with its ATC request, ICO initiated a consultation process with the federal agencies that operate earth stations in the 2200—2290 MHz band." The federal agencies identified in the NTIA Corrected Letter are: * Letter from Karl 8. Nebbia, Associate Administrator, Office of Spectrum Management, National Telecommunications and Information Administration toJulfus Knapp, Chief, Office of Engineering and Technology, Federal Communications Commission, dated March 8, 2007.° * Letter from Karl 8. Nebbia, Associate Administrator, Office of Spectrum Management, National Telecommuntcations and Information Administration to Julius Knapp, Chief, Office of Engineering and Technology, Federal Communications Commission, dated October 2, 2007. ("NTIA Corrected Letter"). * Federal Communications Commission, Public Notice, Report No. SES—01012 {March 5, 2008) corrected by Public Notice, Report No SES—01014 (March 12, 2008). in its ATC Application, ICO requests waiver of the distance ° restriction in 47 C.F.R. § 25.252{a)}{8} and requests that ATC operators be permitted instead to coordinate with U.S. Earth Station facilities in the 2200—2290 MHz band on a case—by—case basis. See File Nos. SES—LIC—20071203—01546 (ICO ATC Application} at 22—23, Attachment O. * 47 CEB. § 25.252(a)(1); Applicants for an anciliary terrestrial component in these bands must demonstrate that ATC base stations shall not: (1) Exceed an ELRP of —100.6 dBW/4kHz for out—of—channel emission at the edge of the MSS licenses‘s selected assignment. * 47 CER. § 25.252{a)(6); Applicants for an ancillary terrestrial component in these bands must demonstrate that ATC base stations shall not: (6) be located less than 820 meters from a U.S. Earth Station facilfty operating in the 2200—2290 MHz band. In its MSS ATC application, the MSS Hicensee should request a list of operational stations in the 2200—2290 MHz band. * The federal agencies holding the 2200—2290 MHz frequency assignment(s}, under Section 6.08 of the NTIA Manual, and the associated earth station facility authorizations under Section 6.03 of the NTIA Manual have been identified in the NTIA Corrected Letter.

U.S. Department of the Air Force {Air Force} Nattonal Aesronautiecs and Space Administration {(NASA) U.S. Department of Commerce (DOC} U.S. Department of the Navy (Navy} U.S. Department of Energy (Energy) The federal agencies listed above are the points of contact, the responsible antities for this consultation process, and the partiles to this operator—to—operator agreement. The objective of the agreement is to ensure that the FCC‘s grant of the 1CO waiver requests (e.g., Sections 25.252(a){1} and 25.252(a}(6)) would not result in unacceptable interference to the federal earth stations operating in the band 2200—2290 MHz due to tCOQ ATC base station cut—of—hband emissions. Annex A as incorporated into this agreement sets out the technical basis for the agreement, identifies procedures for ICO and federal agencies to follow when coordination is appropriate pursuant to this agreement, and establishes a procedure for addressing observed unacceptable interference. Annex B as incorporated into this agreement provides the locations of the existing federal earth stations. This list has been revised and updated by the responsible federal agenicies frora the list provided in the NTIA Corrected Lotter. 2. Conditions for compatible operation The federal agencies and ICO exchanged potential interference assessments for ICO ATC base station gut—of—band emissions into the federal earth stations in the 2200—2290 MHz band. In order to protect the federal earth stations receiving in the 2200—2290 MHz band, the parties agree to the following operational conditions for the I1CO ATC base stations: 1. All tCO ATC base stations cperating in the band 2180—21980 MHz and located within 133 km of those federal earth stations listed in Annex B shall have an out—of—band emission filter to ensure that the EIRP spectral density shall not exceed —100.6 dBW/4kHz for out—of—band emissions at the edge of the 2200—2290 MHz band. 2. Al ICO ATC base stations operating in the band 2180—2190 MHz and located more than 133 km from those federal earth stations listed in Annex B shail have out—of—band emissions outside of the 1CO frequency band {e.g., 2180—2190 MHz} attenuated at least 43+10log(P) dB, where P is the transmitter power in watts. 3. No ICO ATC base station shall be located less than 820 meters from the federal earth stations Histed in Annex 8 and operating in the 2200—2290 MHz band. 4. For new federal earth stations operating in the 2200—2290 MHz band belonging to the responsible federal agencies listed in this agreement or other federal agencies: t. If the federal earth station is to be located within 3 km of an existing federal earth station (e.g., those contained in Annex B}, this new federal earth station shall betreated as an existing federal earth station, and its electromagnetic compatibifiity analysis ("EMC") protection is conferred by the existing earth station which is within a 3 km distance. 1CO will

not be required to provide additfional EMC protection to this new federal earth station other than the existing obligation for the corresponding federal earth station. > L. If the new federal earth station is to be located more than 3 km from an existing federal earth station (e.g., those contained in Annex B), this new federal earth station shall be protected as follows: A. AlICO ATC base stations operating in the band 2180—2190 MHz and located within 71 _ km of this new federal earth station shall have an out—of—band emission filter to ensure that the EIRP spectral density shall not exceed —100.6 dBW/4kHz for out—of—band emissions at the edge of 2200—2290 MHz band. B. For all 1ICO ATC base stations operating in the band 2180—21980 MHz and located between 71—km and 133—krm from the new federal earth station, tCO shall coordinate the use of the spectrum with the responsible federal agency of the new federal earth station as set out in Annex A to this agreement. 1. _ If the 1CO EMC analysis demonstrates that the protection level is less than 160 d8 of isolation, the corresponding ICO based station shall have an out—of—band emission filter to ensure that the EIRP spectral density shall not exceed —100.6 dBwW/4kHz for out—of—band emissions at the edge of 2200—2290 MHz band. t1. If the ICO EMC analysis demonstrates that the protection level is squal to or more than 160 dB of isolation, the corresponding ICO based station shall have an of out— of—band emission outside of the ICO frequency band (e.g., 2180—2190 MHz) attenuated at teast 43+10log(P) dB, where P is the transmitter power in watts. 5. New federal earth stations aperating in the 2200—2290 MHz band shall not be located closer than 820 meters from any existing ICO ATC base station. 3. Conclusion Subject to the above operating conditions, all parties agree that operations consistent with this agreement should protect the federal earth stations in the band 2200—2290 MHz from potential unacceptable interference due to ICQ ATC out—of—band emissions. Instances of observed unacceptable interference to a federal earth station operating in the 2200~2290'M Hz band will be resolved as set out in Annex A to this agreement. The responsible federal agencies shall convey this agreement to NTIA through the Interdepartment Radio Advisory Committee {IRAC), indicating that they have no objection to the ICO ATC waiver requests as stated in the I1CO ATC application if (CO complies with the conditions of this agreement and its Annexes, and urging NTIA to concur with the ICO ATC waiver requests with the aforementioned limitations in the FCC/NTIA consultation process.

iCO and the responsible federal agancies have each caused this sgreement to be signed by its duly authorized representatives., f&file Ac‘tmg DHHrector, ipectrm Palicy and Fiannmg lCfi National Aecronsutics and Space Administration « — "IRAC Represen:atwe .S Denartment of the Mavy _ Title: Assccsate CIQ for it fixdutecture. / 'ue- Chiet, Office of Radio Frequency Mansegament Panning, and E—Government U,5. Department of Cammercae U.5. Department of Energy

ANNEX A Protection of Existing Federal Earth Stations in the 2200—2290 MHz Band iCO and the federal agencies agree that to protect existing federal earth station sites in the 2200—2290 MHz band, all 1CO ATC base stations operating in the band 2180—2190 MHz and located within 133 km of those receiving earth stations listed in Annex B shall have an out—of—band emission filter to ensure that the EIRP spectral density shall not exceed —100.6 dBW/4kHz for out—of—hand emissions at the edge of the 2200—22%0 MHz band. e The EMC analysis determining the 133 kim distance utifized the NTIAZITS Irregular Terrain Model {ITM} in Area Prediction Mode with the following input assumptions: o The propagation percentage of time and confidence factor * percentage of time= 1.0% and a—_ 10% confidence factor; o The interference budget is based on TU—R SA.1154; o The acceptable interferencethreshold: a 10% of interference budget and 2 simxltancous interferers plus 2 dB correction factor. o Antenna heights: «_ iCO base station: 30 m a federal earth station: 10 m o The terrain irregularity parameter:; a Delta_H=90 m —"average" terrain o The mode of variability @ Individual 0 Radio Climate a—— Continental Temperate Polarization: Y 0 Conductivity of Ground: 0.005 S/m G Surface Refractivity: 301 N—units a Cielectric Constant of Ground: 15 0 A—1

Construction of New Federal Earth Stations in the 2200—2290 MHz Band ICO and the federal agencies agree that for new federal earth station sites in the 2200—2290 MHz band, a basic coordination process will be followed as set out below: 1. The responsible federal agency will notify ICO of the location of a new federal earth station 24 months prior to initial operation, including: ( e coordinates (latitude and longitude} e antenna height above ground level (AGL). ICO will plan to retrofit all existing base stations within 71 km of the proposed earth station with an out—of—band emissfon fiiter that ensures the EIRP spectral density shall not exceed —100.6 dsW/4kHz for out—of—band emissions at the edge of the 2200—2290 MHz band. ICO will run the NTIA trregular Terrain Model (ETM) in Point—To—Point Mode on every existing, unfiltsred site that is between 71 and 133 km of the proposed earth station location, using a terrain database selected by the responsible federeal agency with ICO‘s concurrence. a The federal agency will provide terrain database to ICO within 60 days of notification of the new federal earth station. e Actual antenna heights will be used in the point—to—point analysis. * Other input parameters to the ITM model will be identical to those listed above, as appropriate. x Alf 1COQ basestations between the 71 km and the 133 km radius of a federal garth station that provide fess than 160 dB of isolation to the federal earth station will be identified as sites requiring retrofit with a filter as described in Step 2 above. CQ will send the calculstion results to the responsible federal agency for validation. Upon agreement with the calculations and conclustons, (CO will submit a plan to the responsible federal agancy that outlines the retrofit schedule for all base stations identified as requiring a filter per this process. ' ICO and responsible federasl agency will agree to the propaosed retrofit schedule. Upon completion of the retrofit process, ICO will submit formal notification that all base stations requiring filters per this agreement have been retrofit. Per the agreament, new federal earth stations that are within 3 km of an existing federal earth station will be exermpt from this process. A—2

Observed Unacceptable Interference — In the instence of observed unacceptable interference to a federal earth station operating in the 2200— 2290 MHz band, since there will be multiple transmitters in the bands adjacent to 2200—2290 MHz that may be located in the vicinity of federal earth stations, including those ATC base—stations belonging to ICO and Terrestar, the federal agency observing unacceptable interference must identify the specific ATC base—station antenna causing the unacceptable interference and contact the responsible entity. if {CO is responsible for the identified ATC base—station antenna, (CO will correct the identified ATC base— station transmitter to prevent unacceptable Interference. If ICO‘s actions do not resolve the , unacceptable interference the responsible federal agency will ask NTIA to work with the FCC to obtain satisfactory relief. ICO Point of Contact Alfredo Echeverria Director, Network Systems 11700 Plaza America Drive, Syuite 10180 Reston, VA 20190 703 9654 1400 {office) 703 964 1452 {direct} 443 386 4882 {mobile} A—3

ANNEX B 2200—2290 MHz Feeiera}v Earth Station. <_§._c;c_atian_s LOCATION _ _COORDINATES AGENCY _AK, Fairbanks _ 645838N1473054W _ NASA _ AK, Fairbanks [ 6AS131IN147S12TW NASA AK, Fairbanks _ — |. 6A4S5822N1473004W Commerce AK, Fairbanks _|. 645824N1473007TW_| _ Commerce AK, Fairbanks _| 645826N1473036W_|___ Commerce: __ AK, Fairbanks _ 6§45826N1473021W_|____ Commerce . AK, Fairbanks 645836N1473103W Commerce AK, Fairbanks §45842N1472951W |__ Commerce AK, North Pole 644818M1473000W NASA _ AK, Poker Flat 650705N1472559W _ NASA AK, Poker Flat 650700N1472736W |____ NASA CA, Azusa 341259N117523ZW Air Force CA, Berkeley 375248N1221438W . NASA _ CA, Camp Parks ~374400N1215200W |_ _ Air Force CA, Edwards AFB L 345739N1175441W NASA _CA, Goldstone (BSS—14)._ 352533N1 165322W NASA CA, Goldstone (DSS—15) ___ 352519N1165314W. _ NASA CA, Goldstons (PSS—24). |_352074N1165229W _| NASA CA, Goldstope (DSS—27): 351418NL164644W NASA CA, Lagung Peak 340630N1190354W _ Navy CA, Table Mountain 342256N1174056W NASA CA, Vandenberg AFB 342924N1203154W Air Force: CO, Boulder _ —395926NIOS1SS1W | Commerce CO, Buckley Field —394255N1044629W | Air Force CO, Schriever AFB — 38ATSANLOMA3L2SW Air Force FL, Cape Canaveral ._ 282910N0803434W_|.___ Air Force FL, Merritt Island _ 283030N0804137W__| NASA__ FL, New Smyrna Beach _ 290400N0805447W__|_____NASA Guam, Andersen AFB 133648N1445112E | Air Force Guam, GRGT |_ 133655N1445122E | _. NASA Guam, Marianas | _133655N1445122E _ | NASA . Guam, NCTAMS WESTPAC 133455N1445050E Navy HI, Kaena Point 213418N1581634W Air Force __ _HI, Kamaoa—Puueo 190049N15S53948W NASA HL, Kauai _ 220735N1593954W_|____ NASA HI, Nelba 194332N156433ZW_|_____ NASA HIL, South Point 190449N1553948W NASA _ HL, Wahiawa 2131 1SN1575M6W Commerce MA, Westford 423T2ANOTL291.8SW NASA B— 1

LOCATION _COORDINATES _| AGENCY MD, Blossom Point _ 382MM44N0770500W _| NASA andNayy | MD, Greenbelt _ 385959N0765024W NASA _ MD, Greenbelt 385957NO765116W Commerce | MD, Greeabelt > ©390002N0765020W |_ Commerce _ —_ MD, Laurel 391014N0765334W | NASA MD, Pomonkey _ _ 382548N0770512W | _ Navy ME, Prospect Harbor | 442455N0680150W [ _Navy _ NH, New Boston _ 425654N0713824W Air Force ___ _NM, Albuquerque _ _ 350459N1063900W _ Energy "NM, Kirtland AFB _ 350300NL062400W Air Force NM, Kirtland AFB — 350150N1063245W _ Enesgy _ _ | NM, Las Cruces . _321622N1064438W NASA _ ____NM, Los Alamos ___| 355220N1061937W |____ Enersy ~_NM,White Sands (WSGT) _| 322954N1063631W NASA | NM, White Sands (STGTD) ______|_323240N1063648W _ NASA NM, White Sands (WSGT—TDRS Central) | 323059N1063631W _ NASA NM, White Sands (WSGT—TDRS ) _| 323059N1063631W ____ NASA. NV, Las Vegas_ _ 361245N1151004W |_____NASA PA, Horsham 401210N0751028W _ NASA PA, Horsham 401209N0751029W NASA PTR, Mayaguez 181258N0670802W NASA _ SD, Sioux Falls — 434410N0963721W _ _NASA _ _TX, Houston 293339N095053 1W NASA _ __TX, Kelly AFB (294800N0983600W | Air Force _VA, Chantilly 390045N0772540W NASA VA, Dulles |_390051N0772538W _ NASA VA, Herndon _ 385732N0772234W _NASA VA,. Quartfico 3829SZNO772223W | Navy VA, WalopsIsland 375538N0752831W _ | NASA VA, Waii &Island 375530N0752835W NASA _ , 375644N0752740W Commerce VA, W&fi D s[Isiand {_ 375644N0T73527A44W Commerce VA, WallapsIsland _ 375645NCT52T738W Commerce_ __VA, Wallop§Island _ 375647TNO732738W |_ Commerce VA, WallopsIsland 375647NO7S2T743W Commerce VA, WallopsIsland . 3756A48NO732T3IW Commerce _ VA, Wallops Island_ 375648NQ752T736W _ Commerce VA, WallopsIsland 375650NO0752750W Commerce ____ VA, WEIBLSIsland 375651N0752743W Commerce_ VA, Wallops Island (SWAS)_ 375600N0753000W . NASA wy,Falrmont 392600N0801200W NASA


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