Attachment Equant/OBS ESV Narra SES-AMD-20130916-00811

Attachment Equant/OBS ESV Narra

This document pretains to SES-AMD-20130916-00811 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2013091600811_1010608

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

____________________________________
)
)
In the Matter of )
)
Equant, Inc. ) File No. SES-LIC-2011____-_____
)
Application for the Authority to Operate a ) Call Sign_________
Network of Earth Stations onboard Vessels )
In the Ku-band )
)
____________________________________)

APPLICATION FOR AUTHORITY

Equant, Inc., (“Equant”), through this application, requests authorization from the

Federal Communications Commission (“FCC” or “Commission”) to operate a network of

very small aperture terminal (“VSAT”) earth stations onboard vessels (“ESVs”) that use

the 10.95-12.75 GHz and 14.0-14.5 GHz (“Ku-band”) frequency bands to communicate

with an already authorized network hub station located in Manassas, Virginia. The

network will deliver voice and data service.

I. DESCRIPTION OF NETWORK AND SCOPE OF OPERATIONS

Through the development of its ESV network, Equant will be able to serve

customers that include off-shore petroleum installations and transoceanic shippers

delivering cargo foreign owned facilities and flagged-vessels.

The data and voice services that Equant will provide will permit its customers to

supplement and improve their existing communications systems affording improvement

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to their operations, as well as providing their employees or crew members an improved

and more effective means for offshore communications.

As permitted by the Commission’s rules, Equant seeks ALSAT authority for its

ESV network. Equant will offer Ku-band services using the SES-4 satellite located at

22° W.L. and the T-11N satellite located at 37.5° W.L. The network will use an iDirect

Network Management System that will operate and control the ESV network as it

operates on board customer vessels and facilities in the off-shore waters of the east coast

of the United States, the Gulf of Mexico, Brazil and the Atlantic Ocean.

Equant will use the VSAT network hub antennas previously licensed by the FCC

under the registration number E020071. The hub station consists of one 13 meters fixed

earth stations located at Manassas, Virginia. Network access, control and maintenance is

controlled and managed by the hub station. The hub station will consist of a network

management system operated from the Network Operations Center (“NOC”) providing

time division multiplexing (“TDM”) modulation. All remotes will receive this TDM

carrier and transmit in Time Division Multiple-Access (“TDMA”) mode. All the activity,

including registrations, bandwidth allocations, and bandwidth increases are recorded and

logged at the NOC. The network hub will also monitor every ESV remote terminal for

terminal status, location, satellite in use and frequency in use. All this information will

be stored on a server at the NOC as well as on a network management system (“NMS”)

at the hub station. All such information will be available, as required by the

Commission’s rules, to the FCC or an FSS space station operator within twenty-four

hours of being requested.

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Equant’s network remote antennas are the Sea Tel Models 4006 and 4009. Both

models have 1.0 meter antennas. Also, both models provide stabilized tracking as the

antenna communicates with the Ku-band satellite. The main lobes of the antennas meet

the standards specified in Sections 25.209 (a-b) of the Commission’s rules. Exhibit D

demonstrates how Equant’s ESV network’s transmit power will meet the Commission’s

off-axis EIRP requirements for its hub facility. Exhibit E provides the antenna patterns

and off-axis emissions that meet the FCC’s ESV off-axis spectral density requirements.

Equant’s customers, when operating an ESV in international waters will operate

in accordance with Commission’s procedures concerning FCC-licensed ESV’s operating

in international waters and near the coasts of other countries.

II. COMPLIANCE WITH THE COMMISSION’S ESV RULES

The table below details how Equant meets each of the FCC’s ESV requirements

by either stating how Equant will comply or references an exhibit that demonstrates

compliance.

Section 25.222 Requirements

FCC Section 25.222 Compliance

(a) Particulars of Operation – All Ku-band ESV Equant chooses to comply
licensees must comply with the requirements in either with the requirements of
paragraph (a)(1) or (a)(2) of this section and all of the (a)(1).
requirements set forth in paragraph(a)(3)-(a)(7) of this
section.
(1) The following requirements shall apply to an ESV Equant will use transmitters
that uses transmitters with off-axis EIRP spectral that comply with this
densities lower than or equal to the level in paragraph section.
(A) of this subsection.
(i) An ESV system shall not exceed the off-axis EIRP Equant will comply with the
spectral density limits and the conditions defined in conditions and limits as
paragraph (A)-(D) of this subsection. described below.

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FCC Section 25.222 Compliance
Exhibit C, EIRP Density
(A) The off-axis EIRP spectral-density emitted from the Tables, demonstrate how
ESV, in the plane of the GSO as it appears at the Equant meets the
particular earth station location, shall not exceed the requirements.
following values: 15 – 10log(N) -25logθ dBW/4 kHz
for 1.5° ≤ θ ≤ 7°
-6 -10log(N)dBW/kHz for 7°< θ ≤ 9.2°
18 -10log(N) -25logθ dBW/4 kHz for 9.2°< θ ≤ 48°
-24 -log(N) dBW/4 kHz for 48° < θ ≤ 85°
-14 -l0log(N) dBW/4 kHz for 85° < θ ≤ 180°
(B) In all directions other than along the GSO, the off- Exhibit D, Antenna Patterns,
axis EIRP spectral-density for co-polarized signals demonstrates how Equant
emitted from the ESV shall not exceed the following meets this requirement.
values:
18 -10log(N) -25logθ dBW/4 kHz for 3.0° ≤ θ ≤ 48°
-24 -10log(N) dBW/4 kHz for 48° < θ ≤ 85°
-14 -10log(N) dBW/4 kHz for 85° < θ ≤ 180°
(C) In all directions, the off-axis EIRP spectral-density Exhibit D, Antenna Patterns,
for cross-polarized signals emitted from the ESV shall demonstrates how Equant
not exceed the following values: meets this requirement.
5 -10log(N) -25logθ dBW/4 kHz for 1.8° ≤ θ ≤ 7.0°
-16 -10log(N) dBW/4 kHz for 7.0° < θ ≤ 9.2°
(D) For non-circular ESV antennas, the major axis of Equant’s system does not
the antenna will be aligned with the tangent to the arc of include non-circular ESVs.
the GSO at the orbital location of the target satellite, to
the extent required to meet the specified off-axis EIRP
spectral-density criteria.
(ii) Each ESV transmitter must meet one of the Exhibit B, Declaration of
following antenna pointing requirements: Peter Blaney, Chief
(A) Each ESV transmitter shall maintain a pointing Engineer of Cobham
error of less than or equal to 0.2° between the orbital SATCOM, Sea Tel, Inc.,
location of the target satellite and the axis of the main demonstrates compliance
lobe of the ESV antenna or, with subsection A of this
(B) Each ESV transmitter shall declare a maximum requirement.
antenna pointing error that may be greater than 0.2°
provided that the ESV does not exceed the off-axis
EIRP spectral-density limits in paragraph (a)(1)(i) of
this section.

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FCC Section 25.222 Compliance
(iii) Each ESV transmitter must meet one of the Exhibit B, Declaration of
following cessation of emission requirement: Peter Blaney, Chief
(A) For ESVs operating under paragraph (a)(1)(ii)(A) of Engineer of Cobham,
this section, all emissions from the ESV shall SATCOM, Sea Tel Inc.,
automatically cease within 100 milliseconds if the angle demonstrates compliance
between the orbital location of the target satellite and with subsection A of this
the axis of the main lobe of the ESV’s antenna exceeds requirement.
0.5°, and the transmission will not resume until such
angle is less than or equal to 0.2°, or
(B) For ESV transmitters operating under paragraph
(a)(1)(ii)(B) of this section, all emissions from the ESV
shall automatically cease within 100 milliseconds if the
angle between the main lobe of the ESV antenna
exceeds the declared maximum antenna pointing error.
(2) Requirments applicable to an ESV that uses off-axis This section does not apply
spectral-densities in excess of the levels in paragraph to Equant, as its system does
(a)(1)(i) of this section. not use off-axis EIRP
spectral-densities in excess
of the levels in paragraph
(a)(1)(i).
(3) There shall be a point of contact in the United NOC/Washington Media
States, with phone number and address, available 24 Port 8000
hours a day, 7 days a week, with authority and ability to Gainsford Ct., Bristow, VA.
cease all emissions from the ESVs. 20136
Tel: 703-330-3305
Fax: 703-330-3302
Email: noc@sesnewskies.com
(4) For each ESV transmitter, a record of the ship ESV data will be stored at
location (i.e., latitude and longitude), transmit the NOC Washington Media
frequency, channel bandwidth and satellite used shall be Port 8000
time annotated and maintained for a period of not less Gainsford Ct., Bristow, VA.
than 1 year. Records will be recorded at time intervals 20136
no greater than every 20 minutes while the ESV is Tel: 703-330-3305
transmitting. The ESV operator will make this data Fax: 703-330-3302
available upon request to a coordinator, fixed-satellite Email: noc@sesnewskies.com
system operator, NTIA, or the Commission within 24
hours of the request.
(5) ESV operators communicating with vessels of This data will be kept by
foreign registry must maintain detailed information on Ivana Kriznic, 13775
each vessel’s country of registry and a point of contact McLearen Road, Oak City,
for the relevant administration responsible for licensing VA, 20171
ESVs.

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FCC Section 25.222 Compliance
(6) ESV operators shall control all ESVs by a hub All ESV remote stations
station located in the United States. will be controlled by the
NOC located in Washington
Media Port 8000
Gainsford Ct., Bristow, VA.
20136 and the hub station in
Manassas.
(7) In the 10.95-11.2 GHz (space-to-Earth) and 11.45- Equant shall claim no
11.7 GHz (space-to-Earth) frequency bands ESVs shall protection when operating in
not claim protection from interference from any the extended Ku-bands.
authorized terrestrial stations to which the frequencies
are either already assigned, or may be assigned in the
future.
(b) Application Requirements
(1) An ESV applicant proposing to implement a The certifications are
transmitter under paragraph (a)(1) must provide certain provided in the FCC Form
certifications and demonstrations as exhibits to its earth 312 and the exhibits.
station application.
Antenna Data – (i) Any ESV applicant must file three Exhibit C, EIRP Density
tables showing the off-axis EIRP level of the proposed Tables, demonstrates how
earth station antenna in the direction of the plane of the Equant meets this
GSO; the co-polarized EIRP in the elevation plane, that requirement.
is, the plane perpendicular to the plane of the GSO; and
the cross polarized EIRP. In each table, the EIRP level
must be provided at the increments of 0.1° for the
angles between 0° and 10° degrees off-axis, and at
increments of 5° for angles between 10° off-axis and
180° off-axis.
(A) for purposes of the off-axis EIRP table in the plane
of the if the GSO, the off-axis angle is the angle in
degrees from the line connecting the focal point of the
antenna to the orbital location of the target satellite, and
the plane of the GSO is determined by the focal point of
the antenna and the line tangent to the arc of the GSO at
the orbital position of the target satellite.
(B) For purposes of the off-axis co-polarized EIRP table
in the elevation plane, the off-axis angle is the angle in
degrees from the line connecting the focal point of the
antenna to the orbital location of the target satellite, and
the elevation plane is defined as the plane perpendicular
to the plane of the GSO defined in paragraph
(b)(1)(i)(A) of this section.
(C) For purposes of the cross-polarized EIRP table, the
off-axis angle is the angle in degrees from the line
connecting the focal point of the antenna to the orbital

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FCC Section 25.222 Compliance
location of the target satellite and the plane of the GSO
as defined in paragraph (b)(1)(i)(A) of this section will
be used.
(ii) A certification, in Schedule B, that the ESV antenna FCC Form 312, Schedule B,
conforms to the gain pattern criteria of § 25.209(a) and Question E-15 provides this
(b), that, combined with the maximum input power certification.
density calculated from the EIRP density less the
antenna gain, which is entered in Schedule B,
demonstrates that the off-axis EIRP spectral-density
envelope set forth in paragraphs (a)(1)(i)(A) through
(a)(1)(i)(C) of this section will be met under the
assumption that the antenna is pointed at the target
satellite.
(iii) An ESV applicant proposing to implement a Exhibit B, Declaration of
transmitter under paragraph (a)(1)(ii)(A) of this section, Peter Blaney, Chief
must provide a certification from the equipment Engineer of Cobham
manufacturer stating that the antenna tracking system SATCOM, Sea Tel, Inc.
will maintain a pointing error of less than or equal to verifies compliance with
0.2° between the orbital location of the target satellite this requirement.
and the axis of the main lobe of the ESV antenna and
that the antenna tracking system is capable of ceasing
emissions within 100 milliseconds if the angle between
the orbital location of the target satellite and the axis of
the main lobe of the ESV antenna exceeds 0.5°
(iv) An ESV applicant proposing to implement a Not applicable. Equant
transmitter under paragraph (a)(1)(ii)(B) of this section complies with paragraph
must provide certain data. (a)(1)(ii)(A)
(2) An ESV applicant proposing to implement an Not applicable. Equant does
transmitter under paragraph (a)(2) of this section and not propose to use a
using off-axis EIRP spectral-densities in excess of the transmitter under paragraph
levels in paragraph (a)(1)(i) of this section must provide (a)(2).
certain certifications and demonstrations as the exhibits
to its earth station application.
(3) There shall be an exhibit included with the Exhibit E, ESV Operating
application describing the geographic area(s) in which Regions.
the ESVs will operate.

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FCC Section 25.222 Compliance
(4) The point of contact referred to in paragraph (a)(3) His point of contact is
and, if applicable paragraph (a)(6) of this section, must provided in this table and in
be included in the application. FCC Form 312, Schedule B.
(a)(3) There shall be a point of contact
in the United States, with phone number
and address, available 24 hours a NOC/Washington Media
day, seven days a week, with authority Port 8000
and ability to cease all emissions from Gainsford Ct., Bristow, VA.
the ESVs, either directly or through 20136
the facilities of a U.S. Hub or a Hub located Tel: 703-330-3305
in another country with which Fax: 703-330-3302
the United States has a bilateral agreement Email: noc@sesnewskies.com
that enables such cessation of
emissions.
(a)(6) ESV operators shall control all ESVs
by a Hub earth station located in
the United States, except that an ESV
on U.S.-registered vessels may operate
under control of a Hub earth station location
outside the United States provided
the ESV operator maintains a
point of contact within the United
States that will have the capability
and authority to cause an ESV on a
U.S.-registered vessel to cease transmitting
if necessary
(5) ESVs that exceed the radiation guidelines of Section Exhibit A demonstrates
1.1310 Radiofrequency radiation exposure limits must Equant’s compliance with
provide, with their environment assessment, a plan for the radiation guidelines.
mitigation of radiation exposure to the extent required
to meet those guidelines.
(c) Operations of ESVs in the 14.0-14.2 GHz (Earth-to- This requirement is not
space) frequency band within 125km of the NASA applicable to Equant as its
TDRSS facilities on Guam (located at latitude:13° 36ʹ′ operations do not come
55ʺ″ N, longitude 144° 51ʹ′ 22ʺ″ E) or White Sands, New within the specified
Mexico (latitude: 32° 20ʹ′ 59ʺ″ N, longitude 106° 36ʹ′ 31ʺ″ locations. Exhibit E details
W and latitude: 32° 20ʹ′ 40ʺ″ N, longitude 106° 36ʹ′ 48ʺ″ Equant’s proposed area of
W) are subject to coordination through the National operations.
Telecommunications and Information Administration
(“NTIA”) Interdepartment Radio Advisory Committee
(“IRAC”). When NTIA seeks to provide similar
protection to future TDRSS sites that have been
coordinated through the IRAC Frequency Assignment
Subcommittee process, NTIA will notify the
Commission that the site is nearing operational status.

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FCC Section 25.222 Compliance
Upon public notice from the Commission, all Ku-band
ESV operators must cease operations in the 14.0-14.2
GHz band within 125 km of the new TDRSS site until
NTIA/IRAC coordination for the new TDRSS facility is
complete. ESV operations will then again be permitted
to operate in the 14.0-14.2 GHz band within 125 km of
the new TDRSS site, subject to any operational
constraints developed in the coordination process.
(d) Operations of ESVs in the 14.47-14.5 GHz (Earth- To the extent that Equant
to-space) frequency band within 45km of the radio operates within 45km of the
observatory on St. Croix, Virgin Islands (latitude: 17° St. Croix radio observatory
46ʹ′ N, longitude: 64° 35ʹ′ W); 125 km of the radio and 90 km of the Arecibo
observatory on Mauna Kea, Hawaii (latitude: 19° 48ʹ′ N, Observatory, it will
longitude: 155° 28ʹ′ W); and 90 km of the Arecibo coordinate through IRAC.
Observatory on Puerto Rico (latitude 18° 20ʹ′ 46ʺ″ W,
longitude: 66° 45ʹ′ 11ʺ″ N) are subject to coordination
through the National Telecommunications and
Information Administration (NTIA) Interdepartment
Radio Advisory Committee (IRAC).

In addition to the Form 312 and this narrative, the attached exhibits demonstrate

that Equant’s proposed ESV system will comply with Commission’s rules and

particularly the requirement of 47 C.F.R. § 25.222. These Exhibits are:

Exhibit A – Radiation Hazard Analysis
Exhibit B – Declaration of Peter Blaney, Chief Engineer of Cobham SATCOM,
Sea Tel, Inc.
Exhibit C – EIRP Density Tables
Exhibit D – Antenna Patterns
Exhibit E – ESV Operating Regions
Exhibit F – Operating Frequencies

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III. CONCLUSION

Because the operation of this proposed ESV network will serve the public interest

and comply with all applicable rules and regulation, Equant respectfully requests the

grant of its application for the authority to operate a network of ESV stations.

Repectfully submitted,

Equant, Inc.

__________/s/_________
Ivana Kriznic
13775 McLearen Road
Oak Hill, VA 20171

January XX, 2012

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Document Created: 0850-04-09 00:00:00
Document Modified: 0850-04-09 00:00:00

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