Attachment Narrative Statement SES-AMD-20170614-00647

Attachment Narrative Statement

This document pretains to SES-AMD-20170614-00647 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2017061400647_1237504

Before the
Federal Communications Commission
Washington, DC 20554

In the Matter of )
)
Kymeta Corporation Application for Blanket ) File No. SES-AMD-2017____-_____
License to Operate 5,000 Ku-Band ) File No. SES-LIC-20170223-00195
Transmit/Receive Vehicle Mounted Earth ) Call Sign: E170070
Stations (VMESs”), 1,000 Ku-Band )
Transmit/Receive Earth Stations on Vessels )
(“ESVs”) and 5,000 Ku-Band )
Transmit/Receive Fixed Earth Stations

AMENDMENT NO. 2 TO
APPLICATION FOR BLANKET LICENSE

Kymeta Corporation (“Kymeta”) hereby amends its above-referenced application, filed

February 23, 2017, for a blanket license to operate 5,000 Ku-band transmit/receive vehicle

mounted earth stations (“VMES”) and 1,000 Ku-band transmit/receive earth stations on vessels

(“ESV”) operating in Fixed Satellite Service (“FSS”) frequencies (the “Application”). The

Amendment covers the following items:

• Seeks authority for 5,000 Ku-band transmit/receive fixed earth stations, in

addition to the 5,000 VMES and 1,000 ESV earth stations in the Application

• Provides a revised Radiofrequency (“RF”) Safety Hazard Analysis and reduces

maximum power to 8 watts

Authority for 5,000 Fixed Earth Stations

In addition to seeking a blanket license to operate 5,000 Ku-band VMES transmit/receive

earth stations and 1,000 ESV Ku-band transmit/receive earth stations operating in FSS

frequencies, Kymeta amends the Application to also seek authority to operate 5,000 fixed Ku-

Kymeta Corporation
Amendment No. 2 to Application for Blanket License
June 2017
Page 2

band earth stations. 1 The fixed earth stations will be used primarily as IoT terminals to transmit

data from locations not easily served by terrestrial facilities. The VMES, ESV and fixed earth

stations will all be technically identical.

The Amendment complies with Section 25.115, which governs applications for fixed Ku-

band earth stations. The initial Application provides the information required by Section 25.130

(Filing requirements for transmitting earth stations).

The fixed earth stations comply with the off-axis EIRP density values specified in

Section 25.218(f). See Exhibit B to the Application. 2

Revised RF Safety Analysis

Kymeta provides an updated RF Safety Analysis as Exhibit A to the Amendment.

Kymeta also provides the test measurement data from the independent laboratory as Exhibit B.

Kymeta amends the Application to seek authority for a maximum input power of 8 watts

and a maximum EIRP of 43 dBW for all emission designators. The RF Safety Analysis has been

modified accordingly.

***

1
Kymeta notes that the FCC has proposed to revise the definition of “Blanket License” in Section 25.103
to refer to the type of satellite service in which the earth station operates (in this case, Fixed-Satellite
Service), rather than the manner in which the earth station operates (i.e. fixed or mobile). See Notice of
Proposed Rulemaking, Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of
Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in Frequency Bands
Allocated to the Fixed Satellite Service, IB Docket No. 17-95, FCC 17-56 (May 18, 2017) at ¶ 10.
2
Kymeta notes that if an application for blanket authority for the fixed terminals were filed separately, the
fixed terminals would be eligible for routine processing pursuant to Section 25.115(c)(1)(i). See also the
definition of “Routine processing or licensing” in Section 25.103.

TECHNICAL CERTIFICATION

I, Ryan A. Stevenson, hereby certify that I am:

• the technically qualified person responsible for the preparation of the technical

information contained in the Amendment;

• that I am familiar with Part 25 of the Commission’s Rules; and

• that I have either prepared or reviewed the technical information submitted in the

Amendment and found it to be complete and accurate to the best of my knowledge and

belief.

Signed: /s/ Ryan A. Stevenson
Dated: June 14, 2017

Ryan A. Stevenson
Vice President and Chief Scientist
Kymeta Corporation

Document Created: 2017-06-14 11:03:51
Document Modified: 2017-06-14 11:03:51

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