Attachment Narrative

This document pretains to SES-LIC-20160714-00662 for License on a Satellite Earth Station filing.

IBFS_SESLIC2016071400662_1143617

Exhibit A Page 1 of 3 APPLICATION SES Government Solutions, Inc. (“SES-GS”) hereby seeks a license for an earth station in Bristow, VA to provide ongoing authority for two 1.8 meter antennas to communicate with the O3b Ka-band non-geostationary orbit fixed-satellite service (“NGSO FSS”) satellite fleet. Operations of this earth station have commenced pursuant to special temporary authority (“STA”). 1 SES-GS initially was authorized to communicate with O3b from the Bristow earth station site only using limited O3b frequencies, but more recently received authority to use any band segment within the frequencies authorized for O3b’s operations: 17.8-18.6 GHz, 18.8-19.3 GHz, 27.6-28.4 GHz, and 28.6-29.1 GHz. 2 Because SES-GS is establishing the Bristow, VA site as a long-term locus of operations, it now seeks a permanent license for this location. Grant of the requested authority is in the public interest as it will allow SES-GS to conduct demonstrations of the O3b system’s capabilities to potential government customers. A completed FCC Form 312 is attached, and additional information regarding the Bristow earth station was previously submitted to the Commission in support of SES-GS STA requests for Bristow. In particular, in File No. SES-STA- 20131022-00887, SES-GS submitted frequency coordination reports, a complete set of antenna patterns, link budgets, and a radiation hazard analysis. SES-GS incorporates this supporting information by reference herein. Furthermore, the SES-GS Bristow earth station is located in close proximity to antennas operated by O3b that have been authorized to use all the O3b frequency segments. 3 The Commission also has full details regarding the O3b space stations and granted U.S. market access for the O3b constellation to allow U.S.-licensed earth stations to communicate with the O3b 1 See SES Government Solutions, Inc., File Nos. SES-STA-20131022-00888 (grant- stamped Jan. 6, 2014) & SES-STA-20131022-00887 (grant-stamped Jan. 31, 2014). 2 See SES Government Solutions, Inc., File Nos. SES-STA-20150126-00037 (grant- stamped Mar. 13, 2015); SES-STA-20150730-00481 (grant-stamped Sept. 15, 2015); & SES-STA-20160129-00108 (grant-stamped Mar. 11, 2016). 3 O3b Limited, File Nos. SES-LIC-20130618-00516, SES-AMD-20131122-01187, & SES-AMD-20140814-00653, Call Sign E130107 (granted June 24, 2015).

Exhibit A Page 2 of 3 system. 4 SES-GS has reviewed the O3b Market Access Grant and confirms that the operations proposed by SES-GS pursuant to the requested license will fully comply with the terms and conditions set forth therein. Consistent with the O3b Market Access Grant, the proposed SES-GS operations will provide the required protection to terrestrial operations and geostationary orbit (“GSO”) satellites operating in the O3b spectrum. Specifically, SES-GS will not cause harmful interference to, or seek interference protection from, local multipoint distribution service (“LMDS”) stations in the 27.6-28.35 GHz band, 5 GSO FSS networks in the 18.3-18.6 GHz and 28.35-28.4 GHz bands, or terrestrial Fixed Service operations in the 17.8-18.3 GHz band. SES-GS and O3b have submitted evidence of the compatibility of their networks with terrestrial systems and GSO satellites, and SES-GS incorporates that information by reference herein. 6 As noted above, the proposed SES- GS operations will also comply with the O3b Market Access Grant, which includes 4 See O3b Limited, File Nos. SAT-LOI-20141029-00118 & SAT-AMD-20150115-00004, Call Sign S2935, grant-stamped Jan. 22, 2015 (“O3b Market Access Grant”). 5 The Commission has previously indicated that secondary FSS operations in the 27.6- 28.35 GHz band are “for the purpose of providing limited gateway-type service.” 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 and Fourth Notice of Proposed Rulemaking, 11 FCC Rcd 19005, 19025, ¶ 45 (1996). SES-GS believes that the focus of these Commission’s statements has been on ensuring that FSS operations are compatible with LMDS by limiting the number and ubiquity of FSS terminals permitted to use the spectrum. The proposal by SES-GS to operate at a single site in Bristow, virtually co- located with an O3b facility, is clearly consistent with this underlying rationale. Furthermore, as noted above, LMDS systems in the vicinity of the site have been notified of the proposed SES-GS operations and have not objected. Accordingly, grant of the requested SES-GS license will not undermine the primary spectrum rights of LMDS systems. 6 See SES Government Solutions, Inc., File No. SES-STA-20131022-00887, Narrative at 1-3 (showing regarding compatibility of proposed operations with LMDS systems and GSO operations) & Annex 2 (Comsearch reports regarding notification to 28 GHz common carrier, LTTS, and LMDS operators and with 18 GHz common carrier microwave networks). See also O3b Limited, File No. SES-LIC-20130618-00516, Exhibit 1 at 4-7 (demonstration of O3b’s ability to share with primary terrestrial facilities and GSO satellites); & attached Comsearch reports on compatibility with 18 GHz and 28 GHz terrestrial systems.

Exhibit A Page 3 of 3 explicit conditions to ensure that primary services are not disrupted by communications with the O3b constellation. Furthermore, as noted above, O3b has been operating a Bristow station in close proximity to the SES-GS terminals throughout the O3b spectrum. To SES-GS’ knowledge no complaints of harmful interference have been raised in connection with those operations. SES-GS requests any necessary waiver of the Table of Allocations to permit its proposed use of spectrum in these bands on a non- harmful interference basis. The requested license will allow SES-GS to continue to evaluate and demonstrate the O3b network’s operational capabilities and will not result in harmful interference to other authorized spectrum users. Thus, grant of the license will serve the public interest.


Document Created: 2016-07-14 19:06:48
Document Modified: 2016-07-14 19:06:48
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