Attachment Waiver Request

This document pretains to SES-LIC-20170407-00374 for License on a Satellite Earth Station filing.

IBFS_SESLIC2017040700374_1204260

                                                                                  FCC Form 312
                                                                                        Exhibit 1
                                                                              Response to Item 35

                                        Waiver Request

               By this application, SES Americom, Inc. (“SES Americom” or “SES”) seeks a

license to operate a new earth station antenna in Mt. Airy, Maryland to communicate with U.S.-

and foreign-licensed satellites included on the Commission’s Permitted Space Station List. SES

Americom’s affiliate, New Skies Satellites B.V. (“NSS”), has been authorized to use the SES-10

satellite to provide service into the United States, and has asked SES Americom to provide earth
                                                             1
station service to support market access in the United States. The earth station will operate in

the below bands and as further described in Schedule B to the attached Form 312.
                                                                  2
                         Transmit                13.75-14.0 GHz
                         Transmit                14.0-14.5 GHz
                         Receive                 10.95-11.2 GHz
                         Receive                 11.45-11.7 GHz
                         Receive                 11.7-12.2 GHz


               SES requests limited waiver of Section 2.106 footnote NG52 to permit the

reception of U.S. domestic services in the 10.95-11.2 GHz and 11.45-11.7 GHz bands on an

unprotected, non-interference basis. Grant of this waiver is consistent with Commission policy:

                      The Commission may waive a rule for good cause shown.
                      Waiver is appropriate if special circumstances warrant a
                      deviation from the general rule and such deviation would
                      better serve the public interest than would strict adherence
                      to the general rule. Generally, the Commission may grant a

1
  See New Skies Satellites B.V. Market Access Application, File No. SAT-PPL-20160117-00005
(“SES-10 Petition”), granted on June 23, 2016 (“SES-10 Grant”). The authorization was
subsequently modified to operate the satellite at 66.9° W.L. pursuant to the Commission’s
expedited process set out in Section 25.117(h)(1). New Skies Satellites B.V. Modification, Call
Sign S2950, File No. SAT-MPL-20170108-00002, granted May 24, 2017.
2
  As demonstrated in Attachment 1, operations in the 13.75-14.0 GHz band will not cause
harmful interference to U.S. Navy radar stations or NASA TDRSS stations.


                             waiver of its rules in a particular case if the relief requested
                             would not undermine the policy objective of the rule in
                             question and would otherwise serve the public interest.3

                      The Commission has granted a waiver for SES-10 to provide domestic service in
                  4
these bands. Footnote NG52 was intended to preserve access to the 10.7-11.7 GHZ spectrum

for terrestrial fixed service (“FS”) stations by limiting FSS use of the band to international
                       5
operations only. SES-10 will meet the power flux density limits on the ground to protect FS
              6
operations, and the number of antennas that will be used to communicate in these bands will be

limited, thereby ensuring protection of FS services. Moreover, because SES seeks authority to

receive in this spectrum on an unprotected basis, FS use of the band will not be constrained.

Therefore, grant of the requested waiver will not undermine the purpose of the rule.

                      For the foregoing reasons, SES Americom requests that the above waiver request

be granted.




3
    PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted).
4
    Id. at 1-2, ¶ 3.
5
 See 47 C.F.R § 2.106, Footnote NG52. This policy was previously codified in footnote
NG104.
6
    See SES-10 Grant, Attachment to Grant at 1-2, ¶ 3.


                                                                 FCC Form 312
                                                                       Exhibit 1
                                                             Response to Item 35

                                Attachment 1
Compliance with FCC Report & Order (FCC 96-377) for the 13.75-14.0 GHz Band
       Analysis and Calculations for 9 Meter Antenna at Woodbine, MD


                                           Exhibit For
                                      SES Americom, LLC
                                      Woodbine, Maryland
                             Vertex Corporation 9 Meter Earth Station

     Compliance with FCC Report & Order (FCC96-377) for the 13.75 - 14.0 GHz Band
                              Analysis and Calculations

1.       Background

This Exhibit is presented to demonstrate the extent to which the SES Americom, LLC satellite
earth station in Woodbine, Maryland is in compliance with FCC REPORT & ORDER 96-377.
The potential interference from the earth station to US Navy shipboard radiolocation operations
(RADAR) and the NASA space research activities in the 13.75 - 14.0 GHz Band is addressed in
this exhibit. The parameters for the earth station are:

                          Table 1. Earth Station Characteristics

     •   Coordinates (NAD83):                     39° 22’ 38.8” N, 77° 04’ 52.9” W

     •   Satellite Location for Earth Station:    SES-10     (68.5° W)


     •   Frequency Band:                           13.75-14.0 GHz for uplink

     •   Polarizations:                            Linear

     •   Emissions:                                N0N, 100KG7W, 1M00G7W, 36M0G7W and 54M0G7W


     •   Modulation:                               Digital

     •   Maximum Aggregate Uplink EIRP:           46.1 dBW for the N0N Carrier
                                                  60.0 dBW for the 100 kHz Carriers
                                                  70.0 dBW for the 1 MHz Carriers
                                                  85.0 dBW for the 36 MHz Carriers
                                                  85.0 dBW for the 54 MHz Carriers
     •   Transmit Antenna Characteristics
            Antenna Size:                          9.0 meters in Diameter
            Antenna Type/Model:                    Vertex Corporation
            Gain:                                  60.1 dBi

     •   RF power into Antenna Flange:             No Modulation (N0N)
                                                   -14.0 dBW or -14.0 dBW/4 kHz (Maximum)


     •   RF power into Antenna Flange         100 kHz
          (Continued)                         -0.1 dBW
                                               or -14.0 dBW/4 kHz

                                               1 MHz
                                               9.9 dBW
                                               or -14.0 dBW/4 kHz (Maximum)

                                               36 MHz
                                               24.9 dBW
                                               or –14.6 dBW/4 kHz (Maximum)

                                               54 MHz
                                               24.9 dBW
                                               or –16.4 dBW/4 kHz (Maximum)

     •   Minimum Elevation Angle:
          Woodbine, Md                          43.6° @ 166.6° Az. (SES 10) at 68.5° W


     •   Side Lobe Antenna Gain:                32 - 25*log(θ)


Because the above uplink spectrum is shared with the Federal Government, coordination in this
band requires resolution data pertaining to potential interference between the earth station and
both Navy Department and NASA systems. Potential interference from the earth station could
impact with the Navy and/or NASA systems in two areas. These areas are noted in FCC Report
and Order 96-377 dated September 1996, and consist of (1) Radiolocation and radio navigation,
(2) Data Relay Satellites.


Summary of Coordination Issues:

1) Potential Impact to Government Radiolocation (Shipboard Radar)
2) Potential Impact to NASA Data Relay Satellite Systems (TDRSS)



2.       Potential Impact to Government Radiolocation (Shipboard Radar)

Radiolocation operations (RADAR) may occur anywhere in the 13.4 - 14 GHz frequency band
aboard ocean going United States Navy ships. The Federal Communication Commission (FCC)
order 96-377 allocates the top 250 MHz of this 600 MHz band to the Fixed Satellite Service
(FSS) on a co-primary basis with the radiolocation operations and provides for an interference
protection level of -167 dBW/m2/4 kHz.


The closest distance to the shoreline from the Woodbine earth station is approximately 65.9 km
Southeast toward the Chesapeake Bay. The calculation of the power spectral density at this
distance is given by:
                                          N0N         100 kHz     1.0 MHz       36.0 MHz   54 MHz

       1.   Clear Sky EIRP (dBW):          46.1        60.0         70.0          85.0     85.0
       2.   Carrier Bandwidth:            CW Signal     100 kHz      1 MHz        36 MHz   54 MHz
       3.   PD at antenna Input:          -14.0        -14.0         -14.0        -14.6    -16.4
            (dBW/4 kHz)
       4.   Transmit Antenna Gain:                          60.1 dBi
       5.   Antenna Gain Horizon:                       FCC Reference Pattern
       6.   Antenna Elevation Angle:                        43.6°

The proposed earth station will radiate interference toward the Chesapeake Bay according to its
off-axis side-lobe performance. A conservative analysis, using FCC standard reference pattern,
results in off-axis antenna gains of -10.0 dBi toward the Chesapeake Bay.

The signal density at the shoreline, through free space is:

N0N Carriers (CW Carrier)
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).

       = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2]
       = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB)
       = -194.4 dBW/m2/4 kHz


100 kHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).

       = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2]
       = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB)
       = -194.4 dBW/m2/4 kHz


1 MHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).

       = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2]
       = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB)
       = -194.4 dBW/m2/4 kHz


36 MHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = -14.6 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2]
      = -131.9 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB)
      = -194.9 dBW/m2/4 kHz

54 MHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = -16.4 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2]
      = -133.8 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB)
      = -196.8 dBW/m2/4 kHz

Our calculations identified additional path losses of approximately 63.0 dB including absorption
loss and earth diffraction loss for the actual path profiles from the earth station to the nearest
shoreline.

The worst case calculated PFD including additional path losses to the closest shoreline location is
–194.4 dBW/m2/4 kHz for the CW, 100 kHz and 1 MHz carriers and -194.9 dBW/m2/4 kHz for
the 36 MHz carriers and -196.8 dBW/m2/4 kHz for the 54 MHz. All carriers are a minimum of
27.4 dB below the –167 dBW/ m2/4 kHz interference criteria of R&O 96-377. Therefore, there
should be no interference to the US Navy RADAR from the Woodbine earth station due to the
distance and the terrain blockage between the site and the shore.

3.     Potential Impact to NASA’s Data Relay Satellite System (TDRSS)

The geographic location of the SES Americom earth station in Woodbine, Maryland is outside the
390 km radius coordination contour surrounding NASA’s White Sands, New Mexico ground
station complex. Therefore, the TDRSS space-to-earth link will not be impacted by the SES
Americom earth station in Woodbine, Maryland.

The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if
an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 9 meter earth
station antenna will have an EIRP less than 71 dBW/6 MHz for both the CW carrier, 100 kHz and
1 MHz carriers in this band. The total EIRP for the CW Carrier is 46.1 dBW and the equivalent
EIRP per 6 MHz segment will remain at 46.1 dBW/6 MHz. The total EIRP for the 100 kHz,
carriers is 60.0 dBW. The equivalent EIRP per 6 MHz segment will remain at 60.0 dBW/6 MHz.
The total EIRP for the 1 MHz, carriers is 70.0 dBW. The equivalent EIRP per 6 MHz segment
will remain at 70.0 dBW/6 MHz. Therefore, there should not be interference to the TDRSS space-
to-space link for the CW carriers or the 100 kHz and 1 MHz carriers. For the 36 MHz and 54
MHz carriers, the total EIRP of 85.0 dBW (36 MHz), and 85.0 dBW (54 MHz) equate to an EIRP
per 6 MHz of 79.0 dBW/6 MHz and 76.0 dBW/6 MHz, respectively. To avoid interference to the
TDRSS space-to-space link the 36 MHz and 54 MHz carriers will not be used for the transmit
spectrum of 13.772 to 13.778 GHz by this earth station.


4.   Coordination Issue Result Summary and Conclusions

The results of the analysis and calculations performed in this exhibit indicate that compatible
operation between the earth station at the Woodbine facility and the US Navy and NASA systems
space-to-earth link are possible for all of the proposed carriers. Operations in NASA systems
space-to-space link (13772.0 to 13778.0 MHz) will also be permitted for all of the carriers with
the exception of the 36 MHz and 54 MHz emissions.



Document Created: 2017-04-07 14:48:39
Document Modified: 2017-04-07 14:48:39

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