Attachment Dismissed Letter

This document pretains to SES-LIC-20060412-00643 for License on a Satellite Earth Station filing.

IBFS_SESLIC2006041200643_501913

Federal Communications Commission Washington, D.C. 20554 pa o6—1003 May 24, 2006 Christine M. Gill, Esg McDermott Will & Emery LLP 600 Thircenth Street, N.W. Washington, D.C. 200053096 Re:— Call Sign:EO6O134 File No.: SES—LIC—20060412—00643 Dear Ms. Gill On April 12, 2006, Arizona Public Service Company (APS)filed the above—captioned carth station application to operate a Conventional Ku—band‘ VSAT network consisting of a 3.$—meter anterna hub sttion in Sun City West, Arizona and one hundred 0.25—meter remote terminals throughout the United States, n the applications, APS statesthat it intends to use the hub station to communicate with ALSAT—designated satelltes, Pursuant tSection 25.1 12@X1) ofthe Commission‘s rules, 47 CFR.§ 25.112(a)(1), we dismiss the application as defective without prejudice to refling." First, APS did not ls a pointofcommunication fo ts remote terminals, as required in FCC Form 312, Schedule B." Second, we cannot determine the proposed emission power ofthe hub or remote terminals due toinconsistencies among the proposed maximum EIRP density per carrier listed in the application and the average EIRP density calculated from other parameters. Specifically, forthe IM0G7DCC emission, APS indicates the maximum EIRP density per cartier for the hub station is —24.2 dBWtkitz (Question E49). However,we calculate an average value of +20.83 dBWtkHz as derived from the maximum EIRP per carver of 44.8 dBW (Question E48) and 1.0 megaherte necessary bandwidth (Question E47). Similarl, fo the same emission, APS indieates that the maximum EIRP density per carier for the remote stations is —39.5 dBW/AkHdz (Question B49). However,thi value s ess than the average valve of +8.02 dBW/AkHtzas deived from the maximum EIRP per carier of32.0 dBW (Question E48) and 1.0 megahertz necessary bandwidth (Question E47). Further, APS lists the total EIRP for allcariers for the remote stations as 39.5 dBW (Question E40}. Thisisinconsistent with the Toral EIRP o 26 dBW calculated using the proposed transmit antenna gain of26 dBi (Question E4 EA2) with the proposed masimum input power atthe antenna flange of 1 Watt (Question E38). * mmoas oile 5. 1fAPS refilesan applcation identcal o the ondismissed, with the exeeption osupplying the correted information,itneednot pay an applcation fe. See 47 CFR. § 1.1109(4) * Should APS choose to refile th applcation, we notethat onl those fxedsatelite servicecarth sutionstht aretwo—dearee complantand hat operat n the 37004200 Mite,5025—6128 MHz, 1.7—122 GHz,or14.0—14.5 GHtz bands can request ALSAT asa point ofcommunication.

Federal Communications Commission Da 061003 In addition, APS indicated in its application that it plans to use the direct sequence spread spectrum Code Division Multiple Access (CDMA) technique. CDMA is a method of increasing the amount of rafic within a VSAT network by assigning different codes to transtnissions tor from different remote erth stations, sotht trmstnissions can occur simultneously without eausing harmfulinterference to ech other. However,these simultaneous transmissions, when considered together, can result n EIRP levels that exceed the VSAT power limit specifid in the Commission‘s rules. Accordinely, Section 25.134(g)of the Commission‘s rules, 47 C.F.R. § 25.134(w), requires applicantsfor VSAT Hcenses planning to use CDMA to reduce the maximum power of any given individual transmission." However, in Exhibit 3 o ts application, APS sates that ts individual trnsmissions within ts VSAT network willbe as high as those allowed when the VSAT network operator does not plan to use CDMA.® Thus, APS does not meet the requirements of Section 25.134(g)and did not request a waiver othis rule in ts application. Moreover, Section 25.220(c)(1) ofthe Commission‘s ules, 47 C.F.R. § 25,220(e)(1), setsforth a procedure for earth station applicants secking authorty t operate at power levels in excess of those specified elsewhere in Part 25. For the same reason that APS does not comply with Section 25.134(g), it does not comply with Section 25.220(c)(1). Specifically, in Exhibit 3, APS provides a graph showing thatthe off—axis EIRP density level ofa single transmittig terminal meets the off—axis EIRP envelope applicableto the operations ofa single terminal. However, the graph in Exhibit 3 should compare the EIRP density ofAPSs proposed VSAT network operations tan envelope that has been reduced to accountfor tfact that thre will be more than one co— frequency simultaneously trnsmiting earth station in the same satelitereceiving beam. As a resul, the graph in Exhibit 3 does not adequately demonstrate that the proposed earth station operations would appear like those ofa routinely authorized earth station, s required by Section 25.2200)0).¢ Further, in esponse to Question©47, APS isted IMOG7DCC as an emission designator. This does not conform to the Commission‘s emission designator rules. Section 2.201(b) ofthe Commission‘s rules provides that "[A] minimum ofthree symbols are used to describe the basic characterstes ofradio waves. First smbol—type of modulation of the main characte; Second symbol—nature of signal modulaing the main carvier;Thirdsymbol—type of information to be transmitted.". Also, Section 2.202(b)(1)of the Commission‘s rules, 47 CF.R.§ 2.202(b)(1), * Specificallysuch applicans mustreduce thirpower by 10log(N), where N ithe nuriber of simltancous transmissions. * In other words, theapplicant plansto aperat t —14 dBW/ 4 ki instead of~14 — 10log() dBW/4 ui. * Should APS choosetore—fl it application, we resommend that it nclude a spreadchect demnstation containing:(1) the routinely licened inpatpower densty of—14—10 og (N) dBWA kitz; (2) maximum anterns Gain (db) at trnsmit centerfequency of 14.25 GHlz; 3) the Maximum EIRP density for theproposed remoteantenna (dBWkH); (4) nonoutinly sized antenna inut powerdensity (dBWkite; () the co—pol antenna gai under Section25.209G1(1); (6) ofass EIRP densiyreduced by the number ofco—fequency simultncousl trnsmitingremoteearth sution i the same satlite receiving beam under Routin licensing;(7) Non—Routinely sized antenna offaxis anterna Gain (0B9;and (8) masimumoffanis EIRP density onor—routnely ized anna (dBWkiz We also recomment stting the Thea in incrementsof0.1from 1 degreeto 2 degrec; increments o0.5 from 3 degees to 7 deareesincrementsof5 degrecs fom 7 degres to9.2 degrees and from 9.2 degrees t 48degreesand at inerementso20 from 48 degreesto 180 degrees

Federal Communications Commission ba 06—1093 indicates that the necessary bandwidth of the emission designator is to be expressed by three numerals and one letter. Therefore, the lasttwo symbols and the designation of he necessary bandwidth ofthe emission designator do not confarm to he Commission‘s rules While we dismiss the application on the above basis, we take the opportunityto apprise APS of other diserepancieswithin the application that needto be corrected should t chooseto re—fie the application. Specifieally,in response to Question E38, APS listed thetotal nput power at the antenna flange as 0.18 Watts In the Radiation Hazard Report submited with the application, however APS indieated that th input power into the antenna is 4 Watts Also,in response o Questions ES6 through ES on Schedule B, APS listed the minimum antenna elevation angle for te 3.8 meter hub staion and for the 0.25 meter remote terminals as 0 degree Section 25.205 ofe Commission‘s ules, 47 C.F.R. § 25.205, however, statesthat carth station antennas shall not be authorized for trnsmission at an angle that is ess than 5 degrees measured from the horizontal plane to the direction ofe maximum radiation. In light ofthe above, pursuantt Section 25.112(a)(1)"ofthe Commission‘s rules, 47 C.ER. § 25.112G@1), and Section 0.261 ofthe Commission‘s ules on delegations of authonty, 47 C.FR. §.0.261, we dismiss the applicationas defective without prejudice to refling Sincerely, Scott A. Kotler Chief, Systems Analysis Branch Satelite Division International Bureau 1 47 CR § 25.112G)(0. Seealso Echostar Stelite LLC, Order on Reconsideraron, DA 04—1086 (relased December27, 2004)


Document Created: 2006-05-24 14:11:41
Document Modified: 2006-05-24 14:11:41
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