Attachment Exhibit A SES-AMD-20140715-00601

Attachment Exhibit A

This document pretains to SES-AMD-20140715-00601 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2014071500601_1053947

Exhibit A

Legal Narrative and Response to Questions 35: Waiver of the Rules

1. Introduction and summary

In this application, Inmarsat, through its subsidiary, ISAT US, Inc. (“ISAT US”), amends its
pending application (IBFS File No. SES-LIC-20140224-00098; Call sign E140029, filed February 14,
2014) (“SeaTel Application”), to add two additional Earth station terminal types that will be mounted
on ships to provide maritime communications (“Additional GX Terminals”) through the GX network.
Like the antennas in the SeaTel Application, these Additional GX Terminals will communicate with
the Inmarsat-5 F2 (“I5F2”) satellite that will operate at the 55º W.L. orbital location, 1 and will be part
of the GX network and integrated global offerings. The area of operations of the Additional GX
Terminals will be U.S. and international waters, including inland waterways within the coverage area
of I5F2. The information in Section 1 of the SeaTel Application regarding the GX network and the
global offerings applies equally to the Additional GX Terminals, and thus, are incorporated by
reference in this amendment.
This amendment adds (i) the Japan Radio Company, Limited (“JRC”) model JUE 60GX –
employing an antenna with a 0.65 meter diameter, and (ii) the Cobham SeaTel model Sailor 100 GX –
employing an antenna with a 1.03 meter diameter. Both JRC and Cobham are global leaders in
maritime communications equipment. The characteristics of these Earth stations are provided in the
FCC Form 312 associated with this amendment application and in Section 3 below.
This amendment also corrects the half-power beam width provided for the GX Terminals in
the SeaTel Application, as required by Section 25.130(f).

2. U.S. Frequency Allocation and Waiver Request

The Additional GX Terminals will operate on the same frequencies as the GX Terminals in
the SeaTel Application: 19.7-20.2 GHz and 29.5-30.0 GHz. ISAT US seeks the same regulatory
status for these additional earth station terminals as requested in the Section 2 of Exhibit A of the
SeaTel Application, or alternatively, seeks a waiver of the U.S. Table of Frequency Allocations, 47
C.F.R. § 2.106. The justifications for granting primary status for mobile terminals in in the FSS and
the alternative waiver request are as stated in the SeaTel Application and apply to the Additional GX
Terminals in this amendment.
Moreover, since filing the SeaTel Application, the ITU Radiocommunication Bureau has
introduced a new class of Earth station in the Preface for Earth stations that operate while in motion
associated with a space station in the FSS in the bands listed in footnote 5.526 of the ITU Radio

1
See Inmarsat Hawaii, Inc., Application for Authority to Operate Gateway Earth Station with I5F2
Satellite at 55º W.L., File No. SES-LIC-20120426-00397-00397, Call Sign E120072 (filed Apr. 26,
2012), as amended (“Lino Lakes Application”).

1

Regulation. 2 The associated ITU filing for the I5F2 satellite, INMARSAT-KA 55W, has received a
favourable finding to operate such Earth stations in Region 2 in the 29.5-30.0 GHz and 19.7-20.2 GHz
bands, for which authority is requested in the SeaTel Application and in this amendment. 3

3. Technical compatibility with other users in the bands

Sections 3.1 and 3.2 provide analysis and an operational description of the JRC JUE60GX
and Cobham Sailor 100 GX Earth stations respectively, including compliance with the Commission’s
two-degree spacing policy for Ka-band GSO FSS systems and Section 25.138 of the Commission’s
rules. As discussed in more detail below, the transmissions from each of the mobile Earth station
terminal types will be consistent with the off-axis EIRP spectral density levels set forth in Section
25.138. In addition, the power flux-density at the earth’s surface produced by emissions from the
I5F2 satellite when communicating with the GX Terminals will be within the -118 dBW/m2/MHz
limit set forth in Section 25.138(a)(6).4
The description of the additional capabilities of the JRC JUE60GX and Cobham Sailor 100
GX regarding the antenna control mechanisms, pointing accuracy, shut-off capabilities and Network
Operations Center are the same as for the GX Terminals described in Section 3.3 of the SeaTel
Application and are incorporated by reference herein.

3.1 JRC JUE60GX Earth Station

The JRC JUE60GX Earth station is a multi-axis stabilized Earth station employing a 0.65
meter diameter antenna. A pictorial of JRC maritime Earth station that consists of the stabilized
antenna and relevant electronics enclosed in a protective radome designed for operation on-board
vessels is shown in Figure 1. For blanket licensing of transmitting Earth stations in the 29.5-30.0
GHz band, the Commission adopted off-axis EIRP spectral density levels contained in Section
25.138(a). As shown in Exhibit F, the JRC JUE60GX Earth stations will operate within these levels
under clear sky conditions. Therefore, its transmissions will not cause any more interference than any
other Earth stations that meet these levels.

2
BR Circular Letter, ITU BR Letter CR/358.
3
ITU-R Special Publication CR/C/2558 MOD-1.
4
Lino Lakes Application, Exhibit A at 7.

2

of the antenna. This symmetry is demonstrated in the patterns provided in Exhibit B, and therefore it
is expected that the cross-polarization elevation EIRP spectral density data for this terminal for -10 to
0 degree pattern will meet the Commission’s rule consistent with the 0 to 10 degree pattern. Since the
patterns for this earth station are relatively symmetrical and antenna measurements for the 0 to 10
degree pattern show that the Commission requirements in Section 25.138(a) will be met and thus
adjacent operations will be adequately protected.

4. National Security

The Additional GX Terminals would be subject to the same national security requirements
described in Section 4 of the SeaTel Application. That discussion is incorporated by reference herein.

5. Government Coordination and Correction for GX Terminals

Inmarsat has been and will continue to engage with the appropriate U.S. Government
agencies and obtain the necessary coordination arrangements pursuant to applicable U.S. Table of
Frequency Allocation footnotes. Specifically, Inmarsat will conduct US334 coordination with the
applicable Federal users in advance of operation of the proposed Earth stations. In accordance with
Section 25.130(f), the half-power beam width of the antenna downlink of the JUE-60GX antenna is
1.70 degrees at 19 GHz, and the half-power beam width of the antenna downlink of the Sailor 100 GX
antenna is 1.07 at 19 GHz.
Inmarsat also amends the information provided in the SeaTel Application regarding the half-
power beam width of the GX Terminals. The half-power beam width of the antenna downlink of the
SeaTel 4012GX antenna is 1.11 degrees at 19 GHz, and the half-power beam width of the antenna
downlink of the SeaTel GX60 antenna is 1.70 at 19 GHz.

6. Conclusion

The GX Terminals and the Additional GX Terminals will advance the Commission’s goals of
facilitating the expanded availability of wireless broadband service and increasing competition. ISAT
US has shown that the maritime Earth stations in this amendment and in the SeaTel Application will
provide appropriate interference protection for other services. Grant of ISAT US’s application as
amended, therefore, is in the public interest, and ISAT US urges the Commission to grant this
application as soon as possible.

5

Document Created: 2014-07-14 15:36:24
Document Modified: 2014-07-14 15:36:24

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC