Attachment Exhibit A SES-LIC-20150402-00188

Attachment Exhibit A

This document pretains to SES-LIC-20150402-00188 for License on a Satellite Earth Station filing.

IBFS_SESLIC2015040200188_1081384

Exhibit A
Legal Narrative and Response to Questions 35 and 42
Section 25.137 Showing; Waiver of the Rules

Inmarsat Mobile Networks, Inc. (“Inmarsat Mobile Networks” and, together with its
affiliates, “Inmarsat”) seeks blanket authority to operate six different types of Earth stations
mounted on-board ships to communicate with the Inmarsat-5 F3 (“I5F3”) satellite at the
nominal 180° E.L. orbital location, which will be launched and operated under the authority
of the United Kingdom. Inmarsat seeks authority in this application for these terminals to
transmit in the 29.5-30.0 GHz band segment and receive in the 19.7-20.2 GHz band segment.
Because this spacecraft has not previously been approved for service to the United States, this
application provides the requisite market access information pursuant to Section 25.137 of
the Commission’s rules and the Commission’s Space Station Licensing Reform Order. 1

The technical information provided in this application is virtually identical to that
provided in a pending application by an affiliate of ISAT US Inc. for authority to use the
same six maritime antenna types to communicate with the Inmarsat-5 F2 satellite at the
nominal 55º W.L. orbital location. 2

I. SERVICE DESCRIPTION AND PUBLIC INTEREST STATEMENT

Inmarsat is a leading provider of satellite services, and operates a global fleet of
spacecraft, including some of the most advanced commercial communications satellites now
in orbit. Examples of the users that rely on Inmarsat services for their critical
communications needs include the U.S. military, the Federal Aviation Administration,
Department of Homeland Security (including the Federal Emergency Management Agency
(FEMA) and the Coast Guard), U.S. Executive Branch officials, the New York City Fire
Department, CNN, ABC, CBS, National Public Radio, the Red Cross, and nearly every major
airline and shipping line throughout the world.

Inmarsat is deploying a global fleet of geostationary orbit (“GSO”) Fixed Satellite
Service (“FSS”) satellites operating in the Ka band, including the Inmarsat-5 F3 (“I5F3”)
satellite that will operate at the nominal 180º E.L. orbital location, to provide global network
coverage. The first two of these satellites have been successfully launched, and I5F3 is
expected to be launched in the second quarter of 2015. All capacity on I5F3 will be made
available to Inmarsat’s direct customers (including Inmarsat affiliates) through individually
negotiated contracts on a non-common carrier basis. These customers may, in turn, will use
this capacity to serve end users on such terms and conditions as the customers may establish.

With the launch of I5F3, Inmarsat’s Global Xpress (“GX”) satellite technology will
offer seamless global broadband communications on land, sea and in the air using state-of-
the-art satellite and earth station technologies. GX is designed to respond to the
exponentially increasing demand for satellite-delivered broadband high-speed data services.

1
See Amendment of the Commission’s Space Station Licensing Rules and Policies,
First Report and Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd
10760, at ¶ 294 (2003) (“Space Station Licensing Reform Order”).
2
See ISAT US, Inc. Applications, IBFS File Nos. SES-LIC-20140224-00098, SES-
AMD-20140715-00601, SES-AMD-20150211-00073, Call Sign E140029 (accepted
for filing public notices Jan. 28, 2015 and Mar. 4, 2015).
1

The GX system will support the provision of affordable high-data rate communications
services, including broadband Internet access and related applications, through Earth stations
that operate at fixed locations and Earth stations in motion mounted on ships, aircraft and
vehicles worldwide.

Maritime communications through the GX network will be a highly integrated global
offering of capabilities tailored to the needs of maritime users. This service complements
Inmarsat’s longstanding commitment to and experience with servicing maritime customers on
a global basis through its existing global L-band satellite network. The GX offerings will
bring a high level of value to various customers, including:

• Enhanced safety, security and cost-savings features: video monitoring, access to real-
time weather and updated navigation charts;

• Ship management: extending state-of-the-art IT features and functions to ships at sea,
including monitoring of cargo and mechanical functions, online access to customs and
port documentation, and access to the same level of connectivity to enterprise
networks as enjoyed by land-based users; and

• Crew welfare: efficient and reliable voice and Internet browsing, training, and
interaction with shore facilities.

The technology and services offered by GX will stimulate growth, create jobs, and
strengthen the economy by enabling companies to compete more efficiently in the global
market. Thus, grant of this application and the requested market access will help further the
Commission’s goals of enhancing competition and promoting the growth and development of
cost-effective satellite service, while also serving the goals of the National Broadband Plan.

II. EARTH STATION TERMINALS

In this application, Inmarsat Mobile Networks seeks a blanket license to operate
stabilized Earth stations that will be mounted on ships to provide maritime communications
(“GX Terminals”) on U.S.-flagged ships through the GX network. This application seeks
authority to operate these Earth stations to transmit in the 29.5-30.0 GHz band and to receive
in the 19.7-20.2 GHz band through the I5F3 satellite at the nominal 180° W.L. location in
order to provide broadband service. 3 This application does not seek authority to provide
direct-to-home (“DTH”) video or audio services, as defined by the Commission.

A. Area of Operations

The area of operations of the proposed GX Terminals will be U.S. and international
waters, including inland waterways within the five-degree coverage contour of the satellite
depicted by the red line in Figure 1 below.

3
These earth stations are also capable of operating in the 29.0-29.5 GHz (space-to-
Earth) and 19.2-19.7 GHz (space-to-Earth) band segments; authority to operate in
those band segments is not sought in this application.
2

FIGURE 1

Global Xpress I5 F3 Satellite Coverage
(5-degree contour in red; 0-degree contour in blue)

B. Earth Stations on Foreign-Registered Ships

The same maritime Earth station terminal types for which authority is sought in this
application also will operate on foreign-registered maritime vessels in U.S. territorial waters,
under the licensing authority of other administrations. Those foreign-licensed Earth stations
will operate within the same network parameters, including band segments, operational
control mechanisms, technical parameters and otherwise subject to the same conditions
designed to ensure non-harmful-interference operations with the FSS as the U.S.-licensed
Earth stations on U.S.-registered maritime vessels for which authority is sought in this
application.

3

Inmarsat recognizes that transmissions from a foreign-flagged ship “while the same is
within the jurisdiction of the United States” are required to be “in accordance with such
regulations designed to prevent interference as may be promulgated under the authority of
this Act.” 4 The Inmarsat network will control the operation of these Earth stations on
foreign-registered vessels while in U.S. territorial waters in the same manner as it will control
the Earth stations operated on U.S.-registered ships.

Inmarsat also recognizes that the Commission previously has considered maritime
Earth station operations in other parts of the Ka band on foreign-registered vessels located in
U.S. territorial waters as requiring a waiver of the U.S. Table of Frequency Allocations and
the Commission’s Ka-band plan. To the extent necessary, and as discussed in more detail
below, Inmarsat Mobile Networks seeks such a waiver with respect to the operations of these
six maritime terminal types in the specified band segments while communicating with I5F3,
(i) in the case of U.S.-registered vessels wherever located, and (ii) in the case of foreign-
registered vessels while operating in U.S. territorial waters.

C. U.S. Frequency Allocation and Waiver Request

The frequency bands requested in this application are subject to the U.S. Table of
Frequency Allocations in Section 2.106 of the Commission’s rules (“U.S. Table”) and the
Ka-band Plan adopted by the Commission. The FCC’s Ka-band plan designates the 19.7-
20.2 GHz band and the 29.5-30.0 GHz band to the GSO FSS on a primary basis. 5 While the
GX Terminals at times will be operated at fixed locations, they also will operate while
moving. While operating at fixed locations, the Earth stations are consistent with the
parameters of Section 25.138, as discussed in more detail below, and thus, are entitled to
primary status.

At the time the Ka-band plan was adopted, the Commission anticipated authorizing
mobile satellite use of the 19.7-20.2 GHz and 29.5-30.0 GHz band segments at such time as
technology allowed both mobile satellite and fixed satellite uses to coexist in a manner
consistent with the Commission’s two-degree-orbital spacing policy. 6 Since that time, the
Commission has determined that today’s earth station technology allows mobile satellite uses
to occur in a manner that is compatible with fixed satellite operations and has adopted rules
for mobile satellite use of the C- and Ku- frequency bands. 7 The same technology that is

4
47 U.S.C. § 306.
5
Rulemaking to Amend Parts 1, 2, 21, and 25 of the 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 and for Fixed Satellite Services, First Report and Order, 11 FCC Rcd 19005
¶¶ 42, 77 (1996) (“28 GHz First Report and Order”).
6
28 GHz First Report and Order at ¶¶ 84-85.
7
See ESV Order; Amendment of Parts 2 and 25 of the Commission’s Rules to Allocate
Spectrum and Adopt Service Rules and Procedures to Govern the Use of Vehicle-
Mounted Earth Stations in Certain Frequency Bands Allocated to the Fixed-Satellite
Service, 24 FCC Rcd 10414 (2009) (“VMES Order”); Revisions to Parts 2 and 25 of
the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft
Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations
4

used in the C- and Ku-bands is being deployed in the GX Terminals under consideration in
this application. When operating while on a moving platform, the GX Terminals will protect
FSS operations of GSO satellites and NGSO systems consistent with the requirements of
Section 25.138, just as they would if they were operating while stationary. 8

For these reasons, and to the extent necessary, Inmarsat Mobile Networks seeks
authority to operate the GX Terminals on a non-conforming, non-interference basis through
waivers of the U.S. Table. 9 The Commission has granted waivers for non-conforming
spectrum uses where a demonstration is made that the non-conforming operations would not
likely cause harmful interference into the services allocated in Section 2.106 and where the
non-conforming operator accepts any interference from conforming spectrum users. 10 The
Commission granted a similar waiver to ViaSat to operate an Earth station on aircraft in the
bands requested in this application. 11

“Good cause” exists for the Commission to grant the requested waivers because such
grant “would better serve the public interest than strict adherence to the general rule.” 12 In
particular, the requested waivers would facilitate users’ ability to have access to new and
innovative high data-rate communications services, including broadband Internet access, as
well as multimedia, voice, and other data applications aboard maritime vessels and in areas
that are currently underserved. Grant of the requested waivers also will allow Inmarsat to
introduce advanced satellite technologies to U.S. users consistent with the Commission’s

Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14.0-14.5 GHz
Frequency Bands, 27 FCC Rcd 16510 (2012) (“ESAA Order”).
8
The Earth stations in this application employ multi-axis directional antennas that are
stabilized with the very latest technology. These antennas are typical fixed Earth
stations that have been mounted on platforms that can move to provide the same
communications services as the public expects at fixed locations. From a technical
perspective, these Earth stations behave as if they were fixed Earth stations from an
interference perspective with respect to other satellite networks. Because of network
controls and monitoring, some of these Earth stations may operate with greater levels
of protection toward other networks than traditional fixed Earth stations that can be
operate while mis-pointed and without central network awareness.
9
In this application, Inmarsat Mobile Networks seeks a waiver to the extent necessary
rather than a determination that the proposed operation of the GX Terminals properly
is treated as an application of the FSS. Cf. ISAT US, Inc. Application, IBFS File No.
SES-LIC-20140224-00098, Exhibit A at 4-5 (filed Feb. 14, 2014) (seeking authority
for maritime mobile terminals communicating with the I5F2 satellite located at the
nominal 55º W.L. orbital location). The vast majority of the coverage area of the
I5F3 satellite is outside of Region 2, and the ITU Radio Regulation allocations are
different in Region 3 for 19.7-20.2 GHz and 29.5-30.0 GHz band segments.
10
See, e.g., Fugro-Chance, Inc., 10 FCC Rcd 2860 ¶ 2 (1995) (waiver of the U.S. Table
of Frequency Allocations appropriate “when there is little potential for interference
into any service authorized under the Table of Frequency Allocations and when the
non-conforming operator accepts any interference from authorized services.”).
11
See ViaSat Ka band Aeronautical Authorization, IBFS File No. SES-LIC-20120427-
00404, Call Sign E120075 (granted July 17, 2013).
12
47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969).
5

objectives of maximizing spectrum deployment for the benefit of the public. This will
facilitate the provision of service to maritime users who will benefit from global availability
of the GX service, such as commercial shipping crews, cruise ship passengers, and
government users. At the same time, grant of the requested waivers will “not undermine the
policy objective of the rule in question and would otherwise serve the public interest.” 13 As
explained below, the operation of the GX Terminals will not cause harmful interference to
other authorized operations in these bands.

D. Technical Compatibility with Other Users in the Bands

This application includes the following Earth station terminal types that will be
mounted on ships to provide maritime communications through the GX network: 14

• Sea Tel model 4012GX (1 meter diameter)
• Sea Tel model GX60 (0.65 meter diameter)
• Japan Radio Company, Limited (“JRC”) model JUE 60GX (0.65 meter
diameter)
• Cobham Sea Tel model Sailor 100 GX (1.03 meter diameter)
• Intellian GX60 (0.65 meter diameter)
• Intellian GX100 (1.03 meter diameter)

Each of the Earth station terminals consists of a stabilized antenna and relevant
electronics enclosed in a protective radome designed for operation aboard vessels.

1. Antenna Performance

The transmissions from each of these mobile Earth station terminal types will be
consistent with the off-axis EIRP spectral density levels set forth in Section 25.138.
Exhibit B contains the EIRP spectral density plots for each of the antennas. For blanket
licensing of transmitting Earth stations in the 29.5-30.0 GHz band, the Commission adopted
off-axis EIRP spectral density levels contained in Section 25.138(a). As shown in Exhibit B,
each of the Earth station terminal types will operate within these levels under clear sky
conditions and will not present any greater interference risk than any other Earth stations that
meet these levels. In addition, the power flux-density at the Earth’s surface produced by
emissions from the I5F3 satellite when communicating with the GX Terminals will be within
the -118 dBW/m2/MHz limit set forth in Section 25.138(a)(6). 15

The Commission adopted Section 25.138(e) for protection of receive Earth stations in
the 19.7-20.2 GHz band from adjacent satellite interference based on the pattern specified in
Section 25.209(a) and (b) or the actual receiving earth station antenna performance. As
shown in Exhibit B, the Sea Tel 4012GX (1.0 meter) and the Intellian GX100 (1.03 meter)
meet the Section 25.209(a) and (b) antenna patterns at all off-axis angles. In the case of the
other four antennas, the antenna patterns do not meet Section 25.209(a) and (b) at all off-axis

13
Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1166 (D.C. Cir. 1990).
14
See ISAT US, Inc. Applications, IBFS File Nos. SES-LIC-20140224-00098, SES-
AMD-20140715-00601, SES-AMD-20150211-00073, Call Sign E140029 (accepted
for filing public notices Jan. 28, 2015; Mar. 4, 2015).
15
See infra, Section III.A.2.
6

transmission” commands for reception by the GX Terminals. The GX Terminals will cease
transmission after reception of a “parameter change” command from the NOC. The NOC
generally will monitor the GX Terminals to ensure that operations are within the prescribed
operational parameters and Inmarsat personnel will be available to address any claims on
interference from the GX Terminal operations.

For each GX Terminal, a record of the ship location (i.e., latitude/longitude), transmit
frequency, channel bandwidth and satellite used will be recorded and maintained for a period
of no less than one year. This information will be recorded at time intervals no greater than
20 minutes while the Earth station is transmitting. Inmarsat will be able to make this data
available to the Commission promptly upon request.

III. SATELLITE INFORMATION

A. DISCO II Showing – Section 25.137(a)

I5F3 will operate under the authority of the United Kingdom. 18 Consequently, the
Commission’s DISCO II framework applies to this application. 19 The DISCO II analysis
includes consideration of a number of factors, such as the effect on competition in the United
States, spectrum availability, eligibility requirements, technical requirements, national

18
The United Kingdom has submitted on behalf of Inmarsat an ITU filing under the
filing name INMARSAT-KA 180E, as published by the ITU on May 3, 2011 (date of
receipt Feb. 6, 2011). See Ofcom Letter, attached as Exhibit H. This United
Kingdom ITU filing covers frequency bands for which authority is sought in this
application, as well as portions of the C-band and the 17.7-19.7 GHz, 27.5-29.5 GHz,
20.2-21.2 GHz and 30.0-31.0 GHz portions of the Ka band, for which authority is not
sought in this application. Consistent with Commission precedent, Inmarsat is
disclosing the ability of Inmarsat-5 F3 to operate in those band segments. Full
technical details will be provided if and when Inmarsat or one of its commercial
customers seeks authority for U.S. service using those additional frequencies. See,
e.g., Telesat Canada, IBFS File No. SAT-PPL-200605016-00061, at 1 n.2 (filed May
16, 2006; granted Jan. 18, 2007) (disclosing existence of Ka-band payload on Anik F3
but not seeking market access using the Ka-band payload and providing only
technical information regarding the C- and Ku-band operations); see also
Establishment of Policies and Service Rules for the Mobile Satellite Service in the 2
GHz Band, Report and Order, 15 FCC Rcd 16127, ¶ 88 (2000) (providing that
technical requirements in market access requests apply only to specific system
components that operate in the United States, and not to system operations outside of
the United States). Inmarsat has an application pending with the UK Space Agency
for obtaining authority to operate this spacecraft under the United Kingdom Outer
Space Act and, as is customary in the UK, Inmarsat expects such authority to be
granted closer to the launch of the spacecraft. Sufficient ties with the United
Kingdom exist to provide the UK Space Agency the basis for issuing an authorization,
because of the procurement of the spacecraft’s launch through an Inmarsat entity
based in the UK, and because an Inmarsat-based UK company will be responsible for
in-orbit activities.
19
Amendment of the Commission’s Regulatory Policies to Allow Non-U.S. Licensed
Satellites Providing Domestic and International Service in the United States, Report
and Order, 12 FCC Rcd 24094, at ¶¶ 30-49 (1997) (“DISCO II”).
9

security, law enforcement, foreign policy and trade concerns. 20 Each of these factors weighs
in favor of granting this application.

1. Effect on Competition in the United States

In DISCO II, the Commission established a rebuttable presumption that it will further
competition in the United States to allow non-U.S. satellites authorized by WTO Members to
provide services covered by the U.S. commitments under the WTO Basic
Telecommunications Agreement. 21 The United Kingdom, the licensing administration for
I5F3, is a WTO Member. Further, Inmarsat seeks to use the requested spectrum to provide
satellite services that are covered by the WTO Basic Telecommunications Agreement. 22
Accordingly, the presumption in favor of entry applies to I5F3.

Allowing Inmarsat to serve the U.S. with I5F3 will help fulfill the promise of the
WTO Basic Telecommunications Agreement with respect to satellite communications
services. Grant of this application will enhance competition in the United States by
facilitating the introduction of Inmarsat’s satellite services, thereby stimulating lower rates,
improving service quality, increasing service options, and fostering technological innovation.
The Commission consistently has relied on these same public interest benefits in granting
similar requests. 23

2. Spectrum Availability and Allocations

As Inmarsat Mobile Networks demonstrates in the attached Technical Annex, 24
Inmarsat’s proposal to serve the United States using I5F3 in the 19.7-20.2 GHz and 29.5-30.0
GHz band segments from the nominal 180° E.L. orbital location (i) is fully compliant with
the Commission’s two-degree spacing requirements, (ii) will not cause harmful interference
to any other authorized user of the spectrum, and (iii) is compatible with future Ka-band FSS
spectrum assignments at adjacent locations that are consistent with the Commission’s rules.
Among other things, the proposed communications over I5F3 will comply with the uplink
off-axis EIRP density and downlink PFD levels specified in Section 25.138 of the
Commission rules, and thus is deemed compatible with FSS satellite systems operating in
these band segments. 25 Therefore, this request is fully consistent with the procedures set

20
See e.g., Telesat Canada, Petition for Declaratory Ruling for Inclusion of Anik F2 on
the Permitted Space Station List, Petition for Declaratory Ruling to Serve the U.S.
Market Using Ka-band Capacity on Anik F2, Order, 17 FCC Rcd 25287, at ¶ 6
(2002).
21
DISCO II at ¶ 39; see also 47 C.F.R. § 25.137(a)(2).
22
This application does not seek authority to provide direct-to-home (“DTH”) video or
audio services, as defined by the Commission.
23
See, e.g., Digital Broadband Applications Corp., 18 FCC Rcd 9455 (2003); Pegasus
Development Corp., 19 FCC Rcd 6080 (2004); DIRECTV Enterprises, LLC, Request
for Special Temporary Authority for the DIRECTV 5 Satellite, 19 FCC Rcd 15529
(2004).
24
See Attachment A, Technical Annex at 11.
25
47 C.F.R. § 25.138.
10

forth by the Commission in the Space Station Licensing Reform Order regarding the
processing of GSO-like services. 26

3. U.S. Government Coordination

Inmarsat will engage with the appropriate U.S. Government agencies and obtain the
necessary coordination arrangements pursuant to application U.S. Table of Allocation
footnotes. Specifically, Inmarsat will conduct US334 coordination with the applicable
Federal users in advance of commencing operations.

4. National Security, Law Enforcement, and Public Safety Matters

Grant of this application is consistent with U.S. national security, law enforcement
and public safety considerations. Inmarsat’s operations in the United States are subject to a
network security agreement between Inmarsat on the one hand and the U.S. Department of
Justice and the Department of Homeland Security on the other, dated September 23, 2008, as
amended (the “Agreement”). Pursuant to the terms of the Agreement, any FCC
authorizations granted to Inmarsat must be conditioned on compliance with the terms of the
Agreement. Inmarsat requests that the Commission adopt the following condition in granting
this application:

This authorization and any licenses related thereto are subject
to compliance with the provisions of the Agreement between
Inmarsat on the one hand and the U.S. Department of Justice
(DOJ) and the Department of Homeland Security (DHS) on the
other, dated September 23, 2008.

B. Legal and Technical Information – Section 25.137(b)

1. Legal Qualifications

Inmarsat’s legal qualifications are set forth in this application and in the attached
Form 312. In addition, this application, the associated Technical Annex, and the attached
Form 312 demonstrate Inmarsat’s satisfaction of the applicable requirements for space station
applicants set forth in Section 25.114 of the Commission’s rules. 27

2. Technical Qualifications

Included with this application are a Technical Annex (including an orbital debris
mitigation showing) and Schedule S for Inmarsat-5 F3 with the required Part 25 technical
information. As discussed in further detail in the Technical Annex, in order to reduce the risk
of in-orbit collisions with other satellites located at the same nominal location, Inmarsat
proposes to operate at an offset location to eliminate any station-keeping volume overlap with
other satellites.

The Technical Annex includes information concerning orbital debris mitigation. In
the case of applications seeking U.S. market access via non-U.S.-licensed space stations, the
Commission has concluded that the orbital debris requirement can be satisfied by showing

26
See Space Station Licensing Reform Order at ¶ 113.
27
See 47 C.F.R. § 25.114.
11

that the satellite system’s debris mitigation plans are subject to direct and effective regulatory
oversight by the satellite system’s national licensing authority. 28 The Commission has
determined that this requirement may be satisfied by referencing an English language version
of the debris mitigation rules or regulations of the national licensing authority and indicating
the current status of the national licensing authority’s review of its debris mitigation plans. 29

The I5F3 satellite will be operated under the authority of the United Kingdom, and
will be subject to the United Kingdom Outer Space Act 1986 (“Outer Space Act”). The
Outer Space Act ensures compliance with the U.K.’s obligations under international treaties
and principles covering the use of outer space and specifies that the U.K. licensing authority
has the power to require licensees to conduct operations in such a manner as to “prevent the
contamination of outer space,” to “avoid any breach of the United Kingdom’s international
obligations,” and to impose conditions “governing the disposal of the payload in outer space
on the termination of operations under the license.” 30 In addition, the UK Space Agency, the
U.K. agency charged with licensing activities in outer space, including the launch and
operation of space objects, has issued published guidance on the Outer Space Act
requirements, which requires applications for a space activities license to provide information
regarding the plans for disposal of the space object at the end of life, including whether the
propellant and pressurant tanks are vented. 31 The UK Space Agency evaluates such
applications pursuant to published standards, including the IADC Space Debris Mitigations
Guidelines.

Inmarsat has submitted the application for launch and operating authority for filing
with the UK Space Agency, which includes a description of the end-of-life plan for I5F3.
Inmarsat submits that the foregoing demonstration of the U.K.’s authority over I5F3 provides
direct and effective regulatory oversight regulation of the space activities of I5F3, and
satisfies the requirements of Section 25.114(d)(14) and Section 25.283(c).

Given the direct and effective oversight of the U.K. over the space operations of I5F3,
Inmarsat submits that the orbital debris requirements of the Commission’s rules are satisfied.

28
Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 ¶¶ 94, 95
(2004) (“Orbital Debris Second Report and Order”).
29
Id. at ¶ 95; see also Globalstar Licensee LLC, GUSA Licensee LLC, GCL Licensee
LLC, Order, DA 11-520 ¶¶ 30-32 (rel. Mar. 18, 2011) (concluding that French Space
Operations law and technical regulations provide for direct and effective regulation of
debris mitigation measures by France, resulting in a finding that Globalstar satisfied
its orbital debris mitigation showing); O3b Limited, IBFS File No. SES-LIC-
20100723-00952, Call Sign E100088, Condition 90045 (granted Sept. 25, 2012)
(determining that O3b’s request for a waiver of Section 25.283(c) for unvented
pressure vessels was unnecessary, finding that O3b is subject to direct and effective
regulation by the United Kingdom concerning orbital debris mitigation) (“O3b
Grant”).
30
Outer Space Act 1986, 1986 Ch. 38, § 5(2)(e) (1986) (U.K.).
31
See Revised Guidance for Applicants, Outer Space Act 1986, Annex A, Section 1.3
available at
https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/320158
/Guidance_for_applicants_-_June_2014.pdf.
12

Out of an abundance of caution, Inmarsat notes that Section 12.2 of the Technical Annex
includes an Accidental Explosion Assessment describing helium tanks that, consistent with
the Boeing 702 bus design, will be used in apogee engine firings during transfer orbit, will be
sealed at the end of transfer orbit and which are expected to maintain an extremely low final
pressure at the end of life of the spacecraft. While Section 25.283(c) requires that a space
station licensee “ensure . . . that all stored energy sources on board the satellite are
discharged, by venting excess propellant, discharging batteries, relieving pressure vessels,
and other appropriate measures,” 32 the Commission has determined where the satellite
operator is subject to direct and effective regulation by another administration, a waiver of
Section 25.283(c) for unvented pressure vessels is unnecessary. 33 To the extent necessary,
Inmarsat respectfully seeks a waiver of Section 25.283(c) as it applies to the helium tanks on
I5F3, given the direct and effective oversight of the U.K. and given that the very low pressure
in the helium tanks at the satellite’s end-of-life and their enclosure in the spacecraft body
makes the potential for release of orbital debris extremely unlikely.

C. Additional Requirements – Section 25.137(d)

1. Milestones and Bond Requirement

Construction of I5F3 has been completed, and the satellite is slated for launch in the
second quarter of 2015. 34 Inmarsat anticipates that the satellite will be launched by the time
this application for market access is granted. Therefore, all milestones established in the
Satellite Licensing Reform Order should have been met and no bond should be required. 35

2. Spectrum Usage

Inmarsat has a pending market access request for the Ka band at the nominal 55º W.L.
orbital location, which is the only pending or granted spectrum reservation request involving
unbuilt spacecraft to which the limits of Section 25.137(d)(5) of the Commission’s rules
would apply.

3. Ownership Information

Inmarsat Mobile Networks, Inc., a Delaware corporation with its principal place of
business in the United States, is wholly owned by Stratos Holdings, Inc., a Delaware
corporation with its principal place of business in the United States. Stratos Holdings, Inc. is
wholly owned by Inmarsat Group Holdings, Inc., a Delaware corporation with its principal
place of business in the United States. Inmarsat Group Holdings, Inc. is wholly owned by

32
47 C.F.R. § 25.283(c).
33
See O3b Grant, Condition 90045.
34
The contract for the construction of I5F3 is the same as the contract for I5F2 that was
submitted as a supplement to Inmarsat’s pending application for market access for
I5F2. See Supplement to Application of Inmarsat Mobile Networks, Inc., IBFS File
Nos. SES-LIC-20120426-00397, SES-AMD-20120823-00781; Request for
Determination of Compliance with Satellite Implementation Milestones and Bond
Reduction (filed Apr. 15, 2013).
35
See 47 C.F.R. § 25.137(d)(4); see also Space Station Licensing Reform Order at
¶ 311.
13

Inmarsat Solutions Ltd. Inmarsat Solutions Ltd. is wholly owned by Inmarsat Finance III
Limited. Inmarsat Finance III Limited is wholly owned by Inmarsat Ventures Ltd., which is
wholly owned by Inmarsat Investments Ltd. Inmarsat Investments Ltd. is wholly owned by
Inmarsat Group Ltd. Inmarsat Group Ltd. is wholly owned by Inmarsat Holding Ltd.
Inmarsat Holding Ltd. is wholly owned by Inmarsat plc. Information about the ownership
and management of Inmarsat plc is on file with the Commission, and Inmarsat Mobile
Networks, Inc. incorporates that information by reference. 36 With the exception of Inmarsat
Mobile Networks, Inc., Stratos Holdings, Inc. and Inmarsat Group Holdings, Inc., each of the
Inmarsat entities described above is formed under the laws of England and Wales and has its
principal place of business in the United Kingdom.

The officers and directors of Inmarsat Mobile Networks, Inc. are as follows:

Name Position(s) Citizenship
Peter Hadinger Director United States
Bruce Henoch Director and President United States
Chris Murphy Director United States

Each of these officers and directors can be reached care of Inmarsat at 1101 Connecticut
Avenue, NW, Suite 1200, Washington, DC 20036.

D. Waiver Pursuant to Section 304 of the Communications Act

In accordance with Section 304 of the Communications Act of 1934, as amended,
Inmarsat hereby waives any claim to the use of any particular frequency or of the
electromagnetic spectrum as against the regulatory power of the United States because of the
previous use of the same, whether by license or otherwise.

IV. CONCLUSION

For the foregoing reasons, granting this application for authority to operate maritime
Earth stations and to access the U.S. market in the 19.7-20.2 GHz and 29.5-30.0 GHz band
segments using a satellite operated under the authority of the United Kingdom at the nominal
180° E.L. orbital location will serve the public interest, convenience and necessity. Inmarsat
Mobile Networks therefore respectfully requests that the Commission promptly grant this
application.

36
See IBFS File No. SES-ASG-20141121-00871 (granted Dec. 2, 2014); IBFS File No.
ISP-PDR-20090818-00006; ULS File No. 0004040346. See also IBFS File No. SES-
LIC-20090217-00184 (granted Oct. 22, 2009), at Exhibit B (requesting a declaratory
ruling that it would serve the public interest to allow up to 100 percent indirect non-
U.S. ownership of Inmarsat Hawaii, Inc., the predecessor to Inmarsat Mobile
Networks, Inc.).
14

Attachment A

TECHNICAL ANNEX

A.1 Scope and Purpose

The purpose of this Attachment is to provide the Commission with the salient technical
characteristics of the Inmarsat-5 F3 satellite, as required by 47 C.F.R. §25.114 and other sections
of the FCC’s Part 25 rules, that cannot be captured by the Schedule S software.

A.2 General Description of Overall System Facilities, Operations and Services
(§25.114(d)(1))

The Inmarsat-5 F3 satellite will operate at the nominal 180° E.L. orbital location and will
provide fixed-satellite service (“FSS”) to earth stations in the Pacific Ocean region (see coverage
diagram in Figure A.2.1). The satellite will be operated at an offset location of 0.3 degrees from
180º E.L. to center the station-keeping box at 179.7º E.L. The satellite will operate in the 27.5-
30.0 GHz band (Earth-to-space) and 17.7-20.2 GHz band (space-to-Earth) portions of the Ka
band. The satellite network will employ two large gateway antennas and will provide service to
widely-deployed, small user antennas.

The gateway antennas will be capable of communicating with the spacecraft throughout
the 27.5-30.0 GHz and 17.7-20.2 GHz bands. One gateway antenna will be located in Auckland,
New Zealand and the other one will be in Warkworth, New Zealand.

TT&C operations will be provided by one of these gateway earth stations. On-station
TT&C transmissions will occur in the Ka band, and the spacecraft also will be capable of using
C-band frequencies for TT&C during transfer orbit and for emergency purposes. Because the
TT&C, feeder link frequencies and gateway antennas are not located in the United States, they
are not the subject of this application.

This application seeks authority to serve the United States using only the 29.5-30.0 GHz
and 19.7-20.2 GHz portions of the Ka band. In this band, the user antennas will operate within
the “Global Payload Beams” or “GP Spot Beams” on the spacecraft. The Global Payload Beams
operate in the 29.5-30.0 GHz and 19.7-20.2 GHz bands and consist of 89 contiguous, fixed spot
beams. A representative depiction of the coverage of these beams is depicted in Figure A.2.1. A
sample Global Payload Beam coverage pattern is shown in Figure A.2.2.

Figure A.2.1. Representative Global Payload Spot Beam Coverage

FT
10.00

5.00
Theta*sin(phi) in Degrees

0.00

-5.00

-10.00

-10.00 -5.00 0.00 5.00 10.00
T heta*cos(phi) in Degrees

2

The spacecraft will be capable of operating in the 29.0-29.5 GHz and 19.2-19.7 GHz
band segments for user terminals, but authority to operate user terminals in those band segments
is not sought in this application. The spacecraft also will be capable of using C-band frequencies
at 4199.0 MHz, 4199.5 MHz, 5926.5 MHz and 6422.5 MHz for TT&C during transfer orbit and
for emergency purposes. Certain of the beams described above will be switchable to also enable
communications in portions of the 20.2-21.2 GHz and 30.0-31.0 GHz bands, which are not
allocated for commercial service in the United States. Operations in these bands would occur
under the authority of Norway, pursuant to ITU filings submitted by the Norwegian
Administration. Authority to serve the United States using the frequency segments described in
this paragraph is not being requested in this application.

A.3 Predicted Space Station Antenna Gain Contours
(§25.114(c)(vi))

The Inmarsat-5 F3 satellite antenna gain contours for the receive and transmit beams, as
required by §25.114(d)(3), are given in GXT format in the GIMS container file included in this
application.

A.4 Frequency and Polarization Plan
(§25.114(c)(4)(i))

Details of the satellite’s Ka-band frequency plan is provided in the associated Schedule S
submission. The GP Spot Beams operate in RHCP on the uplink and LHCP on the downlink.
Consistent with Section 25.210(f), the GP Spot Beams employ an average six-fold frequency re-
use by spatial separation of co-frequency beams.

In the GP Spot Beams, 72 channels are available in the forward link direction and 72 are
available in the return link direction, each with 40 MHz spacing and 32 MHz useful bandwidth.
These 72 channels in each direction are allocated among the 89 GP Spot Beams, with two
channels available in certain beams. The possible channel to beam allocation configurations in
the GP Spot Beams are as shown below.

4

Number of available channels Number of GP Spot Number of channels per GP
Beams Spot Beam
48 channels 48 beams 1 channel (fixed)/beam
24 channels 12 beams 1 or 2 channels/beam
29 beams Up to 1 channel/beam
Total 72 channels 89 beams

A.5 Transponder Configuration

The satellite has a total of 67 simultaneously active TWTAs, excluding TT&C functions.
This consists of 61 active TWTAs in the forward link direction (gateway-to-user) and 6 active
TWTAs in the return link direction (user-to-gateway).

Note that in the associated Schedule S the term “transponder” refers to the useful
bandwidth of each channel (which is 32 MHz for the GP Spot Beams) and not to the number of
active TWTAs.

A.6 Services to be Provided
(§25.114(d)(1))

The Inmarsat-5 F3 satellite will provide a variety of two-way communications services to
small user terminals including broadband Internet access, multimedia, voice and other
applications.

Representative link budgets, which include details of the transmission characteristics,
performance objectives and earth station characteristics, are provided in the associated Schedule
S submission.

A.7 TT&C Characteristics
(§25.114(c)(4)(i))

As noted above in Section A.2, on-station TT&C for Inmarsat-5 F3 will be provided by
gateway earth stations located in New Zealand, and authority for TT&C is not being sought in
this application.

5

A.8 Satellite Transponder Frequency Responses
(§25.114(c)(4)(v))

The predicted receive and transmit channel filter response performance is given in Table
A.8.1 below. The receive response is measured from the satellite receive antenna up to the input
of the TWTA. The transmit response is measured from the input of the TWTA to the satellite
transmit antenna.

Table A.8.1. GP Spot Beam Typical Receiver and Transmitter Filter Responses
Frequency offset from Gain relative to channel Comments
channel center center frequency

(dB)
Receive Transmit

CF +/- 11.2 MHz 1 1 In-Band

Value does not exceed these
CF +/- 12.8 MHz 1.3 1.3 p-p values
CF +/- 14.4 MHz 2 2
CF +/- 16 MHz 3 3
CF +/- 20.8 MHz -1 -1 Out-of-Band
Attenuation is not less than
CF +/- 24 MHz -10 -7 these values
CF +/- 27.2 MHz -25 -20

A.9 Cessation of Emissions
(§25.207)

All downlink transmissions can be turned on and off by ground telecommand, thereby
causing cessation of emissions from the satellite, as required.

A.10 Power Flux Density at the Earth’s Surface
(§25.208(c))

§25.208 does not contain any PFD limits that apply in the 19.7-20.2 GHz band for GSO
satellite networks, and it is noted also that Article 21 of the ITU Radio Regulations does not have
any PFD limits that apply in this band.

6

A.11 Two Degree Compatibility
(§25.138)

Transmissions in the Inmarsat-5 F3 satellite network in the 29.5-30.0 GHz and 19.7-20.2
GHz bands will not exceed the uplink off-axis EIRP density and downlink PFD levels of
§25.138.

§25.138 of the Commission’s rules defines the uplink and downlink parameters that
permit routine blanket licensing of Ka-band earth stations in certain frequency bands which
define the acceptable levels of adjacent satellite interference permitted in the Ka band by the
FCC, absent specific coordination agreements with neighboring satellites.
For the 29.5-30.0 GHz and 19.7-20.2 GHz frequency bands, compliance with the
Commission’s two-degree spacing policy is ensured provided:

• The uplink off-axis EIRP density levels given in §25.138(a)(1) of the Commission’s rules
are not exceeded; and
• The maximum downlink PFD levels given in §25.138(a)(6) of the Commission’s rules
are not exceeded.
The clear sky uplink off-axis EIRP density limits of §25.138(a)(1) are equivalent to a
maximum uplink input power density of -56.5 dBW/Hz for earth stations in compliance with off-
axis transmit gain masks in §25.209(a)(2) and (4).

Table A.11.1 compares the uplink input power densities derived from the uplink link
budgets that are contained in the Schedule S with the clear sky limits of §25.138 (a)(1). It can be
seen that in all cases the clear sky uplink power limits are met.

Table A.11.1. Demonstration of Compliance with the Uplink Power limits of §25.138 (a)(1)
Uplink Antenna Maximum Clear Sky Clear Sky Uplink Margin (dB)
Diameter Uplink Input Power Input Power Density
Density (dBW/Hz) Limit of §25.138
(a)(1) (dBW/Hz)

13.2m -70.0 (*) -56.5 13.5
Typical-60cm -58.4 -56.5 1.9
Typical-100cm -58.5 -56.5 2.0
Typical-150cm -57.9 -56.5 1.4
(*) Note: The Schedule S link budgets show a maximum uplink power density of -67 dBW/Hz
under faded condition from the 13.2 m antenna. Under clear sky condition the uplink power
density will not exceed -70 dBW/Hz.

7

In the band 19.7-20.2 GHz, the maximum downlink EIRP density that the Inmarsat-5 F3
satellite will transmit is 56.1 dBW in an occupied bandwidth of 32 MHz. This translates into 41
dBW in 1 MHz. The shortest distance from the satellite to the Earth is 35,786 km, corresponding
to a spreading loss of 162.06 dB. Therefore the maximum possible PFD at the Earth’s surface at
an elevation angle of 90° will not exceed -121.06 dBW/m2 in 1 MHz (i.e., 41 -162.06).

In summary, all downlink transmissions from the Inmarsat-5 F3 satellite will comply
with the -118 dBW/m2/MHz limit set forth in §25.138(a)(6) of the Commission’s rules.

A.12 Orbital Debris Mitigation Plan
(§25.114(d)(14))

Inmarsat has incorporated the material objectives of §25.114(d)(14) of the Commission’s
Rules into the design of the satellite through the satellite’s Technical Specifications, Statement of
Work and Test Plans. The Statement of Work includes provisions to review orbital debris
mitigation, and compliance with §25.114(d)(14), as part of the preliminary design review
(“PDR”) and the critical design review (“CDR”) and to incorporate its requirements, as
appropriate, into its Test Plan, including a formal Failure Mode Verification Analysis (“FMVA”)
for orbital debris mitigation involving particularly the TT&C, propulsion and energy systems.

A.12.1 Spacecraft Hardware Design
(§25.114(d)(14)(i))

The satellite is based on the heritage Boeing 702 HP flight proven platform.

Inmarsat will ensure that the satellite does not release any debris during its operation.
Furthermore, all separation and deployment mechanisms, and any other potential source of
debris will be retained by the spacecraft or launch vehicle.

In conjunction with the satellite manufacturer, Inmarsat has assessed and limited the
probability of the satellite becoming a source of debris by collisions with small debris or
meteoroids of less than one centimeter in diameter that could cause loss of control and prevent
post-mission disposal. Inmarsat and the satellite manufacturer have taken steps to limit the
effects of such collisions through shielding, the placement of components, and the use of
redundant systems.

8

The Inmarsat-5 F3 satellite includes redundant TT&C and propulsion subsystems to
ensure successful end-of-life disposal. The spacecraft TT&C system, vital for orbit raising, will
be extremely rugged with regard to meteoroids smaller than 1 cm, by virtue of its redundancy,
shielding, separation of components and physical characteristics. The TT&C subsystem will
have no single points of failure. Near-omni-directional antenna coverage is provided through the
use of a combination of independent bicone and forward/aft pipe antennas. These antenna feeds
are extremely rugged and capable of providing adequate coverage even if struck, bent or
otherwise damaged by a small or medium sized particle. The command receivers and decoders
and telemetry encoders and transmitters will be located within a shielded area and will be totally
redundant and physically separated. Two shielded xenon tanks and a redundant pairs of thrusters
provide the energy for orbit-raising.

A.12.2 Accidental Explosion Assessment
(§25.114(d)(14)(ii))

The Inmarsat-5 F3 satellite will be a Boeing 702HP model spacecraft, which is designed
to minimize the potential for accidental explosions through propellant leakage and fuel and
oxidizer mixing or other means. Propellant tanks and thrusters are isolated using redundant
valves, and electrical power systems are shielded in accordance with standard industry practices.
During the mission, batteries and various critical areas of the propulsion subsystem will be
monitored to avoid conditions that could result in explosion. After the Boeing 702HP spacecraft
reaches its final disposal orbit, all on-board sources of stored energy will be removed by
depleting all propellant tanks, venting all (exception to helium as described below) pressurized
systems, discharging batteries, and turning off all active units.

The Boeing 702HP spacecraft uses a bus that has a liquid propulsion system design
consisting of two helium tanks plus two pairs of fuel and oxidizer tanks and uses a xenon ion
propulsion system design consisting of two xenon tanks. Venting of the excess propellant in the
fuel, oxidizer and xenon tanks is performed as part of the end-of-life shutdown operations. The
helium tanks provide proper propellant tank pressurization for apogee engine firings during
transfer orbit. Consistent with Boeing’s practice with respect to a number of its spacecraft buses,
both helium tanks are isolated at the end of transfer orbit by firing pyro-valves. The spacecraft’s
helium system will be sealed when tanks are isolated, resulting in a final pressure of ~230 psi,
which is extremely low relative to the design burst pressure of 5250 psig (actual test performance

9

at 6660 psig). Due to the low pressure at end-of-life in the helium tanks and their enclosure in
the spacecraft body, an explosive event is extremely unlikely (even in the event of a tank rupture,
e.g., a meteorite strike), minimizing the potential of any release of orbital debris. The xenon
tanks are vented by opening latch valves downstream of the tanks to allow cold flow through the
xenon ion thrusters.

A.12.3 Safe Flight Profiles
(§25.114(d)(14)(iii))

In considering current and planned satellites that may have a station-keeping volume that
overlaps the Inmarsat-5 F3 satellite, Inmarsat has reviewed the lists of FCC-authorized satellite
networks, as well as those that are currently under consideration by the FCC. In addition,
networks for which a request for coordination has been published by the ITU within ±0.15° of
179.7° E.L. have also been reviewed.

Intelsat operates the C-/Ku-band Intelsat-18 satellite at 180º E.L. and with an east-west
station-keeping tolerance of ±0.05°. Thus, Inmarsat will locate the Inmarsat-5 F3 satellite at
179.7º E.L. in order to eliminate the possibility of any station-keeping volume overlap with the
Intelsat-18 satellite.

There are no FCC licensed satellite networks nor are there any pending applications
before the Commission to operate a satellite within ±0.15° of 179.7° E.L. With respect to
published ITU filings, there are several networks filed within this sub-arc however other than
Intelsat-18, none are operational. Inmarsat can find no evidence that the other filed networks are
currently being progressed towards launch. Accordingly, Inmarsat concludes that physical
coordination of the Inmarsat-5 F3 satellite with any other party is not required at the present
time.

A.12.4 Post-Mission Disposal
(§25.114(d)(14)(iv))

At the end of the operational life of the Inmarsat-5 F3 satellite, Inmarsat will maneuver
the satellite to a disposal orbit with a minimum perigee of 300 km above the normal GSO
operational orbit. The post-mission disposal orbit altitude is based on the following calculation,
according to §25.283:

Total Solar Pressure Area “A” = 93.1 m2

10

“M” = Dry Mass of Satellite = 3663 kg

“CR” = Solar Pressure Radiation Coefficient = 1.29

Therefore the Minimum Disposal Orbit Perigee Altitude is calculated as:

= 36,021 km + 1000 x CR x A/M

= 36,021 km + 1000 x 1.29 x 93.1/3663

= 36,053.8 km

= 267.8 km above GSO (35,786 km)

To provide adequate margin, the disposal orbit will be increased to at least 300 km. This
will require approximately 1.4 kg of xenon propellant, taking account of all fuel measurement
uncertainties, which will be allocated and reserved in order to perform the final orbit raising
maneuver.

__________________________________

11

ENGINEERING CERTIFICATION

I hereby declare, under penalty of perjury, that the following statements are true and
correct to the best of my information and belief:
(i) I am the technically qualified person responsible for the engineering information
contained in the foregoing Application,
(ii) I am familiar with Part 25 of the Commission's Rules, and
(iii) I have either prepared or reviewed the engineering information contained in the
foregoing Application and found it to be complete and accurate.

/s/

Jonas Eneberg
Vice President,
International Spectrum Management
Inmarsat

Dated: March 27, 2015

12

Document Created: 2015-03-27 10:46:31
Document Modified: 2015-03-27 10:46:31

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