Attachment Exhibit A SES-LIC-20120227-00219

Attachment Exhibit A

This document pretains to SES-LIC-20120227-00219 for License on a Satellite Earth Station filing.

IBFS_SESLIC2012022700219_940618

Exhibit A

Compliance with 47 C.F.R. Ch. 1 §25.222 (2011 version)

The table below details how GCI Communication Corp (“GCI”) meets each of the requirements in 47 C.F.R. Ch. 1
§25.222 (2011 version) either by stating how GCI will comply or by referencing the appropriate exhibit in this
application demonstrating such compliance.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement Compliance
(a) The following ongoing requirements govern all ESV licensees and GCI affirms that it will
operations in the 10.95–11.2 GHz (space‐to‐Earth), 11.45–11.7 GHz operate the ESV system
(space‐to‐Earth), 11.7–12.2 GHz (space‐to‐Earth) frequency bands and associated with this
14.0–14.5 GHz (Earth‐to‐space) bands transmitting to GSO satellites in the application in compliance
fixed‐satellite service. ESV licensees must comply with the requirements with the requirements set
in either paragraph (a)(1) or (a)(2) of this section and all of the forth in (a)(1) for which the
requirements set forth in paragraphs (a)(3) through (a)(7) of this section. off‐axis EIRP spectral
Paragraph (b) of this section identifies items that must be included in the densities are lower than or
application for ESV operations to demonstrate that these ongoing equal to the levels in
requirements will be met. (a)(1)(i) of this section.
(1) The following requirements shall apply to an ESV that uses Please see response to (a)
transmitters with off‐axis effective isotropically radiated power (EIRP) above and Exhibit C of this
spectral‐densities lower than or equal to the levels in paragraph application.
(a)(1)(i)(A) of this section. An ESV, or ESV system, operating under this
section shall provide a detailed demonstration as described in paragraph
(b)(1) of this section. The ESV transmitter also must comply with the
antenna pointing and cessation of emission requirements in paragraphs
(a)(1)(ii) and (a)(1)(iii) of this section.
(i) An ESV system shall not exceed the off‐axis EIRP spectral‐density limits Please see response to (a)
and conditions defined in paragraphs (a)(1)(i)(A) through (a)(1)(i)(D) of above and Exhibit C of this
this section. application.
(A) The off‐axis EIRP spectral‐density emitted from the ESV, in the plane Please see response to (a)
of the GSO as it appears at the particular earth station location, shall not above and Exhibit C of this
exceed the following values: application.
15-10log(N)-25logΘ ... dBW/4 kHz ... for ... 1.5° ≤ Θ ≤ 7°
-6-10log(N) .......... dBW/4 kHz ... for ... 7° < Θ ≤ 9.2°
18-10log(N)-25logΘ ... dBW/4 kHz ... for ... 9.2° < Θ ≤ 48°
-24-10log(N) ......... dBW/4 kHz ... for ... 48° < Θ ≤ 85°
-14-10log(N) ......... dBW/4 kHz ... for ... 85° < Θ ≤ 180°
Where theta (Θ) is the angle in degrees from the line connecting the focal point
of the antenna to the orbital location of the target satellite, the plane of the GSO
is determined by the focal point of the antenna and the line tangent to the arc of
the GSO at the orbital location of the target satellite. For ESV networks using
frequency division multiple access (FDMA) or time division multiple access
(TDMA) techniques, N is equal to one. For ESV networks using multiple co‐
frequency transmitters that have the same EIRP, N is the maximum expected
number of co‐frequency simultaneously transmitting ESV earth stations in the
same satellite receiving beam. For the purpose of this section, the peak EIRP of
an individual sidelobe may not exceed the envelope defined above for Θ
between 1.5° and 7.0°. For q greater than 7.0°, the envelope may be exceeded by
no more than 10% of the sidelobes, provided no individual sidelobe exceeds the
envelope given above by more than 3 dB.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement (Cont’d) Compliance
(B) In all directions other than along the GSO, the off‐axis EIRP Please see response to (a)
spectraldensity for co‐polarized signals emitted from the ESV shall not above and Exhibit C of this
exceed the following values: application.
18-10log(N)-25logΘ .... dBW/4 kHz ... for ... 3.0° ≤ Θ ≤ 48°
-24-10log(N) .......... dBW/4 kHz ... for ... 48° < Θ ≤ 85°
-14-10log(N) .......... dBW/4 kHz ... for ... 85° < Θ ≤ 180°
Where Θ and N are defined in paragraph (a)(1)(i)(A) of this section. This off‐axis
EIRP spectral‐density applies in any plane that includes the line connecting the
focal point of the antenna to the orbital location of the target satellite with the
exception of the plane of the GSO as defined in paragraph (a)(1)(i)(A) of this
section. For the purpose of this section, the envelope may be exceeded by no
more than 10% of the sidelobes provided no individual sidelobe exceeds the gain
envelope given above by more than 6 dB. The region of the main reflector
spillover energy is to be interpreted as a single lobe and shall not exceed the
envelope by more than 6 dB.
(C) In all directions, the off‐axis EIRP spectral‐density for cross‐polarized Please see response to (a)
signals emitted from the ESV shall not exceed the following values: above and Exhibit C of this
5-10log(N)-25logΘ .... dBW/4 kHz ... for ... 1.8° ≤ Θ ≤ 7.0° application.
-16-10log(N) ......... dBW/4 kHz ... for ... 7.0° < Θ ≤ 9.2°
Where Θ and N are defined as set forth in paragraph (a)(1)(i)(A) of this section.
This EIRP spectral‐density applies in any plane that includes the line connecting
the focal point of the antenna to the target satellite.
(D) For non‐circular ESV antennas, the major axis of the antenna will be Please see response to (a)
aligned with the tangent to the arc of the GSO at the orbital location of above and Exhibit C of this
the target satellite, to the extent required to meet the specified off‐axis application.
EIRP spectral‐density criteria.
(ii) Each ESV transmitter must meet one of the following antenna pointing Please refer to the
requirements: Declaration of
(A) Each ESV transmitter shall maintain a pointing error of less than or Conformance by Cobham
equal to 0.2° between the orbital location of the target satellite and the SATCOM / Sea Tel
axis of the main lobe of the ESV antenna, or (Paragraph #’s 4 and 5) that
(B) Each ESV transmitter shall declare a maximum antenna pointing error is attached as Exhibit C of
that may be greater than 0.2° provided that the ESV does not exceed the this application.
off‐axis EIRP spectral‐density limits in paragraph (a)(1)(i) of this section,
taking into account the antenna pointing error.
(iii) Each ESV transmitter must meet one of the following cessation of Please refer to the
emission requirements: Declaration of
(A) For ESVs operating under paragraph (a)(1)(ii)(A) of this section, all Conformance by Cobham
emissions from the ESV shall automatically cease within 100 milliseconds SATCOM / Sea Tel
if the angle between the orbital location of the target satellite and the (Paragraph #’s 4 and 5) that
axis of the main lobe of the ESV antenna exceeds 0.5°, and transmission is attached as Exhibit C of
will not resume until such angle is less than or equal to 0.2°, or this application.
(B) For ESV transmitters operating under paragraph (a)(1)(ii)(B) of this
section, 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 the
declared maximum antenna pointing error and shall not resume
transmissions until such angle is less than or equal to the declared
maximum antenna pointing error.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement (Cont’d) Compliance
(2) The following requirements shall apply to an ESV that uses off‐axis GCI affirms that it *** will
EIRP spectral‐densities in excess of the levels in paragraph (a)(1)(i) of this not *** operate the ESV
section. An ESV, or ESV system, operating under this section shall file system associated with this
certifications and provide a detailed demonstration as described in application in compliance
paragraph (b)(2) of this section. with the requirements set
(i) The ESV shall transmit only to the target satellite system(s) referred to forth in (a)(2) for which the
in the certifications required by paragraph (b)(2) of this section. off‐axis EIRP spectral
(ii) If a good faith agreement cannot be reached between the target densities are in excess of
satellite operator and the operator of a future satellite that is located the levels in (a)(1)(i) of this
within 6 degrees longitude of the target satellite, the ESV operator shall section.
accept the power‐density levels that would accommodate that adjacent
satellite.
(iii) The ESV shall operate in accordance with the off‐axis EIRP spectral
densities that the ESV supplied to the target satellite operator in order to
obtain the certifications listed in paragraph (b)(2) of this section. The ESV
shall automatically cease emissions within 100 milliseconds if the ESV
transmitter exceeds the off‐axis EIRP spectral‐densities supplied to the
target satellite operator.
(3) There shall be a point of contact in the United States, with phone GCI details contact
number and address, available 24 hours a day, seven days a week, with information in Exhibit F of
authority and ability to cease all emissions from the ESVs, either directly this application.
or through the facilities of a U.S. Hub or a Hub located in another country
with which the United States has a bilateral agreement that enables such
cessation of emissions.
(4) For each ESV transmitter, a record of the ship location (i.e., GCI details records storage
latitude/longitude), transmit frequency, channel bandwidth and satellite in Exhibit G of this
used shall be time annotated and maintained for a period of not less than application.
1 year. Records will be recorded at time intervals no greater than every 20
minutes while the ESV is transmitting. The ESV operator will make this
data available upon request to a coordinator, fixed system operator,
fixed‐satellite system operator, NTIA, or the Commission within 24 hours
of the request.
(5) ESV operators communicating with vessels of foreign registry must GCI details contact
maintain detailed information on each vessel’s country of registry and a information in Exhibit F and
point of contact for the relevant administration responsible for licensing records storage in Exhibit G
ESVs. of this application.
(6) ESV operators shall control all ESVs by a Hub earth station located in GCI details contact
the United States, except that an ESV on U.S.‐registered vessels may information in Exhibit F of
operate under control of a Hub earth station location outside the United this application.
States provided the ESV operator maintains a point of contact within the
United States that will have the capability and authority to cause an ESV
on a U.S.‐registered vessel to cease transmitting if necessary.
(7) In the 10.95–11.2 GHz (space‐to‐Earth) and 11.45–11.7 GHz (space‐to‐ GCI details the details of
Earth) frequency bands ESVs shall not claim protection from interference ESV Operating Frequencies
from any authorized terrestrial stations to which frequencies are either in Exhibit E of this
already assigned, or may be assigned in the future. application.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement (Cont’d) Compliance
(b) Applications for ESV operation in the 14.0–14.5 GHz (Earth‐to‐space) The applicable technical
band to GSO satellites in the fixed‐satellite service must include, in demonstrations and other
addition to the particulars of operation identified on Form 312, and affirmations are contained
associated Schedule B, the applicable technical demonstrations in in the FCC Form 312 and
paragraphs (b)(1) or (b)(2) of this section and the documentation Exhibits associated with
identified in paragraphs (b)(3) through (b)(5) of this section. this application.
(1) An ESV applicant proposing to implement a transmitter under Please refer to Exhibit C of
paragraph (a)(1) of this section must demonstrate that the transmitter this application for the
meets the off‐axis EIRP spectral‐density limits contained in paragraph applicable technical
(a)(1)(i) of this section. To provide this demonstration, the application demonstrations and
shall include the tables described in paragraph (b)(1)(i) of this section or affirmations associated
the certification described in paragraph (b)(1)(ii) of this section. The ESV with this part.
applicant also must provide the value N described in paragraph (a)(1)(i)(A)
of this section. An ESV applicant proposing to implement a transmitter
under paragraph (a)(1)(ii)(A) of this section must provide the certifications
identified in paragraph (b)(1)(iii) of this section. An ESV applicant
proposing to implement a transmitter under paragraph (a)(1)(ii)(B) of this
section must provide the demonstrations identified in paragraph (b)(1)(iv)
of this section.
(i) Any ESV applicant filing an application pursuant to paragraph (a)(1) of Not required. Please see
this section must file three tables showing the off‐axis EIRP level of the Exhibit C of this application
proposed earth station antenna in the direction of the plane of the GSO; for a certification of
the co‐polarized EIRP in the elevation plane, that is, the plane antenna performance in
perpendicular to the plane of the GSO; and cross polarized EIRP. In each accordance with (b)(1)(ii) of
table, the EIRP level must be provided at increments of 0.1° for angles this section.
between 0° and 10° off‐axis, and at increments of 5° for angles between
10° and 180° off‐axis.
(A) For purposes of the off‐axis EIRP table in the plane of the GSO, the off‐ Please see response to
axis angle is the angle in degrees from the line connecting the focal point (b)(1)(i) above and Exhibit C
of the antenna to the orbital location of the target satellite, and the plane of this application.
of the GSO is determined by the focal point of the antenna and the line
tangent to the arc of the GSO at the orbital position of the target satellite.
(B) For purposes of the off‐axis co‐polarized EIRP table in the elevation Please see response to
plane, the off‐axis angle is the angle in degrees from the line connecting (b)(1)(i) above and Exhibit C
the focal point of the antenna to the orbital location of the target of this application.
satellite, and the elevation plane is defined as the plane perpendicular to
the plane of the GSO defined in paragraph (b)(1)(i)(A) of this section.
(C) For purposes of the cross‐polarized EIRP table, the off‐axis angle is the Please see response to
angle in degrees from the line connecting the focal point of the antenna (b)(1)(i) above and Exhibit C
to the orbital location of the target satellite and the plane of the GSO as of this application.
defined in paragraph (b)(1)(i)(A) of this section will be used.
(ii) A certification, in Schedule B, that the ESV antenna conforms to the Please see the FCC Form
gain pattern criteria of § 25.209(a) and (b), that, combined with the 312 and Exhibit C this
maximum input power density calculated from the EIRP density less the application.
antenna gain, which is entered in Schedule B, demonstrates that the off‐
axis EIRP spectral density envelope set forth in paragraphs (a)(1)(i)(A)
through (a)(1)(i)(C) of this section will be met under the assumption that
the antenna is pointed at the target satellite.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement (Cont’d) Compliance
(iii) An ESV applicant proposing to implement a transmitter under Please refer to the
paragraph (a)(1)(ii)(A) of this section, must provide a certification from Declaration of
the equipment manufacturer stating that the antenna tracking system will Conformance by Cobham
maintain a pointing error of less than or equal to 0.2 between the orbital SATCOM / Sea Tel
location of the target satellite and the axis of the main lobe of the ESV (Paragraph #’s 4 and 5) that
antenna and that the antenna tracking system is capable of ceasing is attached as Exhibit C of
emissions within 100 milliseconds if the angle between the orbital this application.
location of the target satellite and the axis of the main lobe of the ESV
antenna exceeds 0.5°.
(iv) An ESV applicant proposing to implement a transmitter under Please refer to the
paragraph (a)(1)(ii)(B) of this section must: Declaration of
(A) Declare, in their application, a maximum antenna pointing error and Conformance by Cobham
demonstrate that the maximum antenna pointing error can be achieved SATCOM / Sea Tel
without exceeding the off‐axis EIRP spectral‐density limits in paragraph (Paragraph #’s 4 and 5) that
(a)(1)(A) of this section; and is attached as Exhibit C of
(B) Demonstrate that the ESV transmitter can detect if the transmitter this application.
exceeds the declared maximum antenna pointing error and can cease
transmission 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 the declared maximum antenna
pointing error, and will not resume transmissions until the angle between
the orbital location of the target satellite and the axis of the main lobe of
the ESV antenna is less than or equal to the declared maximum antenna
pointing error.
(2) An ESV applicant proposing to implement a transmitter under GCI affirms that it *** will
paragraph (a)(2) of this section and using off‐axis EIRP spectral‐densities not *** operate the ESV
in excess of the levels in paragraph (a)(1)(i) of this section shall provide system associated with this
the following certifications and demonstration as exhibits to its earth application in compliance
station application: with the requirements set
(i) A statement from the target satellite operator certifying that the forth in (a)(2) for which the
proposed operation of the ESV has the potential to create harmful off‐axis EIRP spectral
interference to satellite networks adjacent to the target satellite(s) that densities are in excess of
may be unacceptable. the levels in (a)(1)(i) of this
(ii) A statement from the target satellite operator certifying that the section.
power‐density levels that the ESV applicant provided to the target
satellite operator are consistent with the existing coordination
agreements between its satellite(s) and the adjacent satellite
systems within 6° of orbital separation from its satellite(s).
(iii) A statement from the target satellite operator certifying that it will
include the power‐density levels of the ESV applicant in all future
coordination agreements.
(iv) A demonstration from the ESV operator that the ESV system is
capable of detecting and automatically ceasing emissions within 100
milliseconds when the transmitter exceeds the off‐axis EIRP spectral‐
densities supplied to the target satellite operator.
(3) There shall be an exhibit included with the application describing the Please see Exhibit D of this
geographic area(s) in which the ESVs will operate. application.
(4) The point of contact referred to in paragraph (a)(3) of this section and, Please see Exhibit F of this
if applicable paragraph (a)(6) of this section, must be included in the application.
application.

47 C.F.R. Ch. 1 §25.222 (2011) Requirement (Cont’d) Compliance
(5) ESVs that exceed the radiation guidelines of § 1.1310 of this chapter, Please see Exhibit B of this
Radiofrequency radiation exposure limits, must provide, with their application.
environmental assessment, a plan for mitigation of radiation exposure to
the extent required to meet those guidelines.
(c) Operations of ESVs in the 14.0–14.2 GHz (Earth‐to‐space) frequency Please see Exhibit D of this
band within 125 km of the NASA TDRSS facilities on Guam (located at application.
latitude: 13°36′55″ N, longitude 144°51′22″ E) or White Sands, New
Mexico (latitude: 32°20′59″ N, longitude 106°36′31″ W and latitude:
32°32′40″ N, longitude 106°36′48″ W) are subject to coordination through
the National Telecommunications and Information Administration (NTIA)
Interdepartment Radio Advisory Committee (IRAC). When NTIA seeks to
provide similar protection to future TDRSS sites that have been
coordinated through the IRAC Frequency Assignment Subcommittee
process, NTIA will notify the Commission that the site is nearing
operational status. Upon public notice from the Commission, all Ku‐band
ESV operators must cease operations in the 14.0–14.2 GHz band within
125 km of the new TDRSS site until after NTIA/IRAC coordination for the
new TDRSS facility is complete. ESV operations will then again be
permitted to operate in the 14.0–14.2 GHz band within 125 km of the
new TDRSS site, subject to any operational constraints developed in the
coordination process.
(d) Operations of ESVs in the 14.47–14.5 GHz (Earth‐to‐space) frequency Please see Exhibit D of this
band within (a) 45 km of the radio observatory on St. Croix, Virgin Islands application.
(latitude 17°46′ N, longitude 64°35′ W); (b) 125 km of the radio
observatory on Mauna Kea, Hawaii (at latitude 19°48′
N, longitude 155°28′ W); and (c) 90 km of the Arecibo Observatory on
Puerto Rico (latitude 18°20′46″ W, longitude 66°45′11″ N) are subject to
coordination through the National Telecommunications and Information
Administration (NTIA) Interdepartment Radio Advisory
Committee (IRAC).

Document Created: 2012-02-13 10:03:11
Document Modified: 2012-02-13 10:03:11

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