Attachment ESV letter

This document pretains to SES-LIC-20020611-00939 for License on a Satellite Earth Station filing.

IBFS_SESLIC2002061100939_443909

                                  Federal Communications Commission
                                           Washington, DC 20554
International Bureau




                                                    July26, 2005

       Michelle A. McClure
       Irwin, Campbell & Tannenwald, P.C.
       1730 Rhode Island Avenue, NW., Suite 200
       Washington, DC 20036—0354

                                                            Re:   Call Sign: E020160
                                                                  File No. SES—LIC—20020611—00939

       Dear Ms. McClure:

                 On June 11, 2002, L3 Communications IEC (L3) filed the above—captioned
       application. For the reasons stated below, we request L3 to amend the subject
       application.

               L3 seeks authority to operate a VSAT network on the Fixed—Satellite Service
       11.7—12.2 GHz and 14.0—14.5 GHz Ku—band spectrum. The VSAT network consists of a
       mobile hub station onboard a U.S. naval ship operating in U.S.— and adjacent waters, and
       remote terminals in various military base locations throughout the United States. We
       note that L3‘s proposed use of the 14.0—14.2 GHz band, which is shared with the
       Government space research service, has been successfully coordinated through NTIA.
       L3 also provided information in response to a Systems Analysis Branch inquiry.

               On December 15, 2004, the Commission adopted a number of new rules
       applicable to the type of operations contemplated under L3‘s application, known as the
       operation of Earth Stations on Vessels (ESVs).‘ The substantive requirements of these
       rules took effect on March 2, 2005 and June 15, 2005." Specifically, we request that L3
       demonstrate compliance, pursuant to Section 25.222 of the Commission‘s rules, with the
       following Ku—band ESV requirements:

       e    Ku—band ESV operators must meet an off—axis EIRP spectral density envelope as
            described in 47 C.F.R. § 25.222(a)(1) through (5). Therefore, we request a
            demonstration as required by 47 C.F.R. § 25.222(b)(1), (2), or (3).

       ‘   Procedures to Govern the Use of Satellite Earth Stations on Board Vessels in the 5925—6425
       MHz/3700—4200 MHz Bands and 14.0—14.5 GHz/11.7—12.2 GHz Bands, Report and Order, IB Docket No.
       02—10, FCC 04—286, 20 FCC Red 674 (2005).

       *    See 70 F.R. 4775 (Jan. 31, 2005) and 70 F.R. 34665 (June 15, 2005).


e   All emissions from the ESV shall automatically cease 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 degrees, and transmission will not resume until such
    angle is less than 0.2 degrees (see 47 C.F.R. § 25.222(a)(7)). We request that L3
    demonstrate how the proposed operation will comply with this requirement.

       In addition, we advise that, pursuant to Section 25.116, major amendments to a
pending application, such as the supplemental changes requested by L3 on January 27,
2005, are to be filed electronically through the International Bureau Filing System (IBFS)
and are subject to the public notice requirements.

        Further action on the subject application will be withheld in order to provide L3
an opportunity to respond to this letter. L3 is required to respond, by amendment to the
subject application, by August 10, 2005. Failure to do so will cause the Commission to
promptly dismiss the application without prejudice pursuant to Section 25.112(c) of the
rules. See 47 C.F.R. § 25.112(c).


                                               Sincerely,



                                              DoA Kot!t~
                                               Scott A. Kotler
                                               Chief, Systems Analysis Branch
                                               Satellite Division



Document Created: 2005-07-26 14:08:52
Document Modified: 2005-07-26 14:08:52

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