Attachment O3b - Commission req

O3b - Commission req

REQUEST submitted by IB,FCC

Oct 31 2013 Commission letter

2013-10-31

This document pretains to SES-LIC-20130618-00516 for License on a Satellite Earth Station filing.

IBFS_SESLIC2013061800516_1018432

                         Federal Communications Commuission
                                Washington, D.C. 20554


                                               October 31. 2013



  Joslyn Read
  Vice President, Regulatory Affairs
  O3b Limited
  900 17"" St., NW, Suite 300
  Washington, D.C. 20006
                     :                        Re:    O3b Limited
                                                     IBFS File No. SES—LIC—20130618—00516
                                                     Call Sign: E130107

 Dear Ms. Read:

 This letter requests additional information regarding O3b Limited‘s above—referenced application
 for authority to operate a fixed earth station in Bristow, Virginia, that will communicate with
 O3b‘s Ka—band non—geostationary satellite orbit (NGSO) Fixed—Satellite Service (FSS) system
 licensed by the United Kingdom (Bristow Application). In particular, O3b indicates that the earth
 station will consist of two fixed 2.4—meter antennas that will operate in the 17.8—18.3 GHz, 18.3—
 18.6 GHz, and 18.8—19.3 GHz (space—to—Earth), and 27.6—28.35 GHz, 28.35—28.4 GHz, and 28.6—
 29.1 GHz (Earth—to—space) frequency bands. For both the 17.8—18.3 GHz and 18.3—18.6 GHz
 frequency bands, O3b seeks waivers of the Ka—band Plan and Footnote NG164 to Section 2.106 of
 the Commission‘s rules.‘ O3b also seeks waivers of Sections 25.145(c) and 25.210(i)(1) of the
 Commission rules." O3b intends to operate the earth station to monitor the system and to provide
 customer demonstrations."

 The Commission previously authorized O3b to operate two FSS earth stations to communicate
 with O3b‘s NGSO FSS Ka—band system. The first authorization was for a fixed earth station in
 Haleiwa, Hawaii, and the second authorization was for a fixed earth station in Vernon, Texas.*
 Both of these fixed earth stations use 7.3—meter antennas to continuously track visible in—orbit O3b
 satellites, with the Haleiwa, Hawaii, earth station providing gateway and telemetry, tracking and
 command (TT&C) services and the Vernon, Texas, earth station providing gateway and back—up
 TT&C services. O3b explained that if it sought to use U.S. earth stations to provide services to
 customers in the United States, it would file an application for authority to operate such earth




  147 C.F.R. § 2.106, NG164.

  247 C.FR. §§ 25.145 (c) and 25.210(i)(1).
> Bristow Application, Narrative at 1. The earth station will conmmunicate with O3b‘s in—orbit NGSO FSS
 system, designated O3B—A internationally.

  * 03b Limited, IBFS File No. SES—LIC—20130124—00089 (Vernon, Texas, Call Sign E130021), granted
  June 20, 2013 and IBFS File No. SES—LIC—20100723—00952 (Haleiwa, Hawaii, Call Sign E100088),
  granted Sept. 25, 2012.


stations." As a result, the technical waivers and legal issues addressed by the gateway
authorizations were limited to the proposed gateway and TT&C services requested.®

03b also has a pending application for authority to operate earth stations aboard maritime vessels
that will communicate with O3b‘s Ka—band NGSO FSS system (Blanket Application).‘ In
connection with reviewing the Blanket Application, we sent a letter to O3b on September 25,
2013, requesting information about the O3b system design, pursuant to Section 25.111(a) of the
Commission‘s rules.®

Although the information in the Haleiwa, Hawaii, and Vernon, Texas, earth stations, and the
Blanket Application, is useful in understanding O3b‘s NGSO constellation, certain additional
information would facilitate processing of O3b‘s Bristow Application. Accordingly, we request,
pursuant to Section 25.111(a) of the Commission‘s rules," O3b to amend the Bristow Application
to include the following information:

1.   The September 25 letter to O3b regarding the Blanket Application contained a number of
     information requests that are relevant to the Bristow Application. As a result, 03b should
     provide the same kind of information requested in paragraphs 2, 3, 4, 6, 11, and 12 of the
     September 25 letter in its amendment to the Bristow Application.

2.   Please provide a showing that demonstrates that the 03b satellite system complies with No.
     22.5D of the ITU Radio Regulations.

3.   Please provide the measured antenna performance data for the 2.4—meter antenna. Please
     provide a series of radiation pattern measurements, performed on a calibrated antenna range.
     To facilitate processing, we request O3b to provide pattern measurements at the bottom,
     middle, and top frequencies of the 27.6—29.1 GHz (Earth—to—space) frequency band, as
     described in Section 25.138(d) of the Commission‘s rules applicable to GSO FSS earth
     stations.




° Haleiwa, Hawaii Application, Narrative at 5.

° The International Bureau processed both applications as fixed gateway applications and expressly limited
each authorization to such services. Haleiwa, Hawaii Authorization, condition 90033 ("This authorization
is limited to earth station call sign E100088, and does not permit O3b space stations to operate with any
other earth station in the United States."); Haleitwa, Hawaii Authorization and Vernon, Texas
Authorization, condition 90044; Vernon, Texas Authorization condition 90089 ("This authorization is
limited to earth station call sign E130021, and does not permit O3b space stations to operate with any other
earth station in the United States.").

? IBFS File No. SES—LIC—20130528—00455, Call Sign: E130098. In the Blanket Application, O3b requests
a blanket license to operate up to 100 earth stations with 2.2—meter antennas and up to 100 earth stations
with 1.2—meter antennas on U.S.—registered vessels that will operate in U.S. territorial waters, international
waters, and foreign waters.

8 Letter from Jose Albuquerque, Chief, Satellite Division, International Bureau, FCC, to Joslyn Read, Vice
President, Regulatory Affairs, 03b Limited (dated September 25, 2013).

°47 CFR. § 25.111(a).


      4.    O3b seeks to operate in the 27.6—28.35 GHz band on a secondary basis. The Commission
           has indicated that FSS operations in this band are limited to gateway—like operations.""
           Please explain how O3b‘s operations are consistent with the Commission‘s statements
           regarding this band.

      5.    Based on our review of O3b‘s Hawaii application, portions of which O3b incorporates by
           reference in the Bristow Application, it appears that there is a possibility that O3b space
            stations could receive signals from terrestrial Fixed Service stations operating in the 03b
           uplink frequency bands and retransmit these signals in the 03b downlink frequency bands
           that are used by other Fixed Service systems. Please provide an interference analysis that
           demonstrates that retransmission of Fixed Service signals by O3b space stations will not
           occur or will not cause unacceptable interference to any potentially—affected
           radiocommunication systems. One method of satisfying this request would be to explain
           whether 03b can shut off transponders transmitting in the 17.8—18.3 GHz frequency band in
           any beams that are illuminating geographic areas from which the satellite is at a low
           elevation angle.

      Please submit the requested information by December 2, 2013. Failure to do so may result in the
      dismissal of O3b‘s pending application pursuant to Section 25.112(c) of the Commission‘s rules,
      47 C.E.R. § 25.112(c).


                                                   Sincerely,




                                         '7491    Jose Albuquerque
                                                  Chief, Satellite Division
                                                  International Bureau

CC.   Joseph A. Godles
      Goldberg Godles Weiner & Wright LLP
      1229 19°" Street, NW
      Washington, DC 20036—2413




       10 Rulemaking To Amend Parts 1, 2, 21, and 25 ofthe Commission‘s Rules to Redesignate the 27.5—29.5
       GHz Frequency Band, to Reallocate the 29.5—30.0 GHz Frequency Band, to Establish Rules and Policies
      for Local Multipoint Distribution Service andfor Fixed Satellite Services, CC Docket No. 96—311, First
      Report and Order and Fourth Notice of Proposed Rulemaking, 11 FCC Red 19005, 19025, «[ 45 (indicating
      that in the 27.5—28.35 GHz band NGSO FSS operations will be "for the purpose of providing limited
      gateway—type service."). See also, Rulemaking To Amend Parts 1, 2, 21, and 25 ofthe Commission‘s Rules
      to Redesignate the 27.5—29.5 GHz Frequency Band, to Reallocate the 29.5—30.0 GHz Frequency Band, to
      Establish Rules and Policies for Local Multipoint Distribution Service andfor Fixed Satellite Services, CC
      Docket No. 92—297, Third Report and Order, 12 FCC Red 22310, 22317, « 42 (1997).
                                                      3



Document Created: 2013-10-31 14:36:51
Document Modified: 2013-10-31 14:36:51

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