Attachment Q35_WaiverRequest

This document pretains to SES-LIC-20100817-01141 for License on a Satellite Earth Station filing.

IBFS_SESLIC2010081701141_831785

Waiver Request We request that the FCC waive1 certain technical requirements of the following rulings: • 47CFR25.209 Antenna Performance Standards • 47CFR2.106 Table of Frequency Allocations • Any other of the Commission’s rules required to grant our application Similar waivers have been requested by others2. Per 47CFR1.925: “The Commission may grant a request for waiver if it is shown that: (i) The underlying purpose of the rule(s) would not be served or would be frustrated by application to the instant case, and that a grant of the requested waiver would be in the public interest; or (ii) In view of unique or unusual factual circumstances of the instant case, application of the rule(s) would be inequitable, unduly burdensome or contrary to the public interest, or the applicant has no reasonable alternative.” Public Interest Broadband, small, on-the-move satellite earth stations are greatly needed by the US Army and US Marines for use in current national defense operations. There are no such systems that have been granted a permanent license for operation in United States at this time. In order to meet the size, weight, and communications performance objectives specified by the Government, an antenna of diameter less than one meter is required. Government procurement of such systems both has occurred and is currently underway (eg. CONDOR, MBCOTM programs). Granting the requested waivers would serve the public interest and would comply with the intent of the rulings. Non-Compliance with 47CFR25.209 Antenna Performance Standards The gain performance of an antenna diameter less than one meter in diameter is typically not compliant with 25.209. By managing the transmitted power spectral density3, we can comply with the off-axis or adjacent satellite emissions objectives bound by 47CFR25.209 and 47CFR 25.2124 (and ITU-R S.728-1). 1 Per section 47 CFR 1.3 and 1.925 of the Commission’s rules. 2 Raysat, File Number: SES-LIC-20060629-01083, Call Sign E060101, also OmniTRACS 3 On-The-Move SATCOM Permanent Licensing, Document No. 20060920M01 filed with this license application. 4 47CFR25.212 Narrowband transmissions in the 12/14 GHz GSO Fixed-Satellite Service

Non-Compliance with 47CFR2.106 Table of Frequency Allocations The table does not provide an allocation for MSS in the Ku-Band downlink frequencies (11.7 to 12.2 GHz). We request a wavier of Section 2.106 to permit the use of the 11.7 to 12.2 GHz downlink band for MSS. Management of transmitted power spectral density including automatic shut-down mechanisms5 will ensure that operation of our system can be authorized without causing interference to other authorized users of the Ku-Band, including FSS users of the Ku Band downlink frequencies. We will accept interference into our system from any authorized user of this band. 5 On-The-Move SATCOM Permanent Licensing, Document No. 20060920M01 filed with the license application.


Document Created: 2010-07-27 16:38:53
Document Modified: 2010-07-27 16:38:53
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