Attachment Exhibit A

This document pretains to SES-LIC-20180604-01082 for License on a Satellite Earth Station filing.

IBFS_SESLIC2018060401082_1412443

NARRATIVE STATEMENT: EARTH STATION LICENSE APPLICATION By this application, WorldVu Satellites Limited (“OneWeb”), seeks authority to operate twenty-six technically identical CPI 3.5 meter antennas in Talkeetna, Alaska (the “Talkeetna Earth Station”). The Talkeetna Earth Station will provide gateway connectivity to OneWeb’s low earth orbit (“LEO”), non-geostationary (“NGSO”), fixed-satellite service (“FSS”) system, which was granted U.S. market access in June 2017.1 This connectivity is the first step in OneWeb’s ambitious goal of bridging the digital divide in the United States. Grant of this application will serve the public interest by facilitating OneWeb’s ability to deliver ubiquitous, state-of-the-art broadband access to previously unserved and underserved populations. I. Communications with Non-U.S.-Licensed Space Stations OneWeb hereby incorporates by reference the OneWeb U.S. Market Access Grant to demonstrate compliance with the requirements of Section 25.137 of the Commission’s rules for earth station applicants proposing to communicate with non-U.S.-licensed space stations.2 II. Spectrum Use and Sharing The Talkeetna Earth Station will be mounted on fixed platforms. Although the angle at which the antennas point will change with the tracking of OneWeb’s in-orbit satellites, each platform will remain stationary. The Talkeetna Earth Station will communicate with OneWeb’s system in the following frequency bands:  17.8-18.6 GHz (downlink)  27.5-29.1 GHz (uplink)  18.8-19.3 GHz (downlink)  29.5-30.0 GHz (uplink) As illustrated below, OneWeb’s Talkeetna Earth Station will operate in a manner consistent with the Commission’s rules. 1 See WorldVu Satellites Limited, Petition for a Declaratory Ruling Granting Access to the U.S. Market for the OneWeb NGSO FSS System, Order and Declaratory Ruling, 32 FCC Rcd 5366 (2017) (“OneWeb U.S. Market Access Grant”) (granting OneWeb market access for its LEO NGSO FSS satellite constellation). 2 See 47 C.F.R. § 25.137. 1

A. Uplink 1. 27.5-29.1 GHz The Upper Microwave Flexible Use Service (“UMFUS”) has a primary designation in the 27.5-28.35 GHz band in the Commission’s Ka-band Plan, with a secondary designation for FSS.3 FSS earth stations are permitted in the 27.5-28.35 GHz band and are not required to provide interference protection to future UMFUS operators if certain conditions are met.4 The Commission also clarified in the NGSO Order that “NGSO FSS systems must operate on an unprotected, non-interference basis with respect to GSO FSS networks” in the 27.5-28.35 GHz band.5 FSS is primary in the 28.35-28.6 GHz band, and the Ka-band Plan designated NGSO FSS as secondary to GSO FSS in the band.6 In the 28.6-29.1 GHz band, NGSO FSS is primary in the U.S. Table of Frequency Allocations and has a primary designation in the Commission’s Ka-band Plan.7 Terrestrial Coordination. Section 25.136(a)(4) of the Commission’s rules allows earth station licensees in the 27.5-28.35 GHz band to operate in accordance with the terms of their authorization without providing additional interference protection to UMFUS stations when four conditions are met.8 Appendix A to this Narrative Statement demonstrates that the Talkeetna Earth Station will satisfy all four conditions. 3 Update to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related Matters, Report and Order and Further Notice of Proposed Rulemaking, 32 FCC Rcd 7809, App. B (2017) (“NGSO Order”); see also 47 C.F.R. § 25.136(a) (“FSS is secondary to the Upper Microwave Flexible Use Service in the 27.5-28.35 GHz band.”). 4 See 47 C.F.R § 25.136(a); see also Use of Spectrum Bands Above 24 GHz For Mobile Radio Services, Report and Order and Further Notice of Proposed Rulemaking, 31 FCC Rcd 8014, 8036 ¶ 54 (2016) (“Spectrum Frontiers Order”). 5 NGSO Order, 32 FCC Rcd at 7817, ¶ 23. 6 NGSO Order, 32 FCC Rcd at 7850, App. B (“Ka-band Plan”). 7 47 C.F.R. § 2.106, NG165; see also Ka-band Plan. Additionally, in the OneWeb U.S. Market Access Grant, the Commission authorized OneWeb’s uplink operations in this band. OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5366, ¶ 1. 8 See 47 C.F.R. § 25.136(a)(4); see also Use of Spectrum Bands Above 24 GHz for Mobile Radio Services, Second Report and Order, Second Further Notice of Proposed Rulemaking, Order on Reconsideration, and Memorandum Opinion and Order, 32 FCC Rcd 10988, 11080, Appendix A (2017) (“Second Spectrum Frontiers Order”) (adopting changes to this rule section). Because 2

The Comsearch Coordination Report attached separately as Exhibit B9 to this application demonstrates that in the 27.5-28.35 GHz band: (1) OneWeb can operate the Talkeetna Earth Station without causing harmful interference to existing terrestrial deployments, and (2) OneWeb coordinated with existing licensees in compliance with the Commission’s rules. GSO Coordination. OneWeb makes no claim of interference protection from U.S.- licensed GSO FSS systems in the 27.5-28.6 GHz band. The ITU developed uplink equivalent power flux density (“EPFDup”) limits to protect co-frequency GSO FSS operations from unacceptable interference from NGSO FSS systems operating in the same frequencies. Specifically, in accordance with Article 22 of the ITU Radio Regulations, if the applicable EPFDup limits are met, then the Commission will consider the NGSO FSS satellite system to have met its obligations of protecting GSO FSS networks from unacceptable interference.10 OneWeb has demonstrated that it meets the applicable ITU EPFDup limits in all frequency ranges where these limits apply and certifies that its operations will be compliant with Article 22 and Resolution 76 of the ITU’s rules.11 Consequently, the transmissions from the Talkeetna Earth Station will sufficiently protect GSO FSS systems. these rule changes are currently not in effect, OneWeb requests the Commission evaluate this application under the updated Section 25.136(a)(4). Appendix A to this Narrative Statement demonstrates compliance with this updated rule. In the alternative, OneWeb respectfully requests a waiver of the current version of Section 25.136(a)(4) of the Commission’s rules to allow this application to be processed under the updated provision, as set forth in Appendix B to this Narrative Statement. 9 The emission designators provided in the Comsearch Reports in Exhibit B reflect the carrier noise bandwidth (3-dB bandwidth), which is smaller than the necessary bandwidth (typically the 15-dB bandwidth), that has been used for this earth station application and for the OneWeb U.S. Market Access Grant. The difference in bandwidth is less than ten percent. Therefore, this variance has no impact on the data culling function performed by Comsearch and provides a more accurate portrayal of the interference potential of OneWeb’s earth station emissions since the power-spectral density and the receiver noise bandwidth are computed based on the actual noise bandwidth instead of the necessary or occupied bandwidth. 10 See NGSO Order, 32 FCC Rcd at 7820, ¶ 32 (“Any NGSO FSS system operating in compliance with these limits is considered as having fulfilled its obligation under Article 22 of the ITU Radio Regulations not to cause unacceptable interference to any GSO network.”). 11 See WorldVu Satellites Limited, Petition for a Declaratory Ruling Granting Access to the U.S. Market for the OneWeb NGSO FSS System, IBFS File No. SAT-LOI-20160428-00041, Technical Narrative (“Market Access Application Technical Narrative”) at 33-34; A2-9 – A2-12. 3

2. 29.5-30.0 GHz The 29.5-30.0 GHz band is allocated to the FSS on a co-primary basis with the Mobile Satellite Service (“MSS”), with NGSO FSS having a secondary designation to GSO FSS in the Ka-band Plan.12 OneWeb makes no claim of interference protection from U.S.-licensed GSO FSS systems in this band,13 and the transmissions from the Talkeetna Earth Station will sufficiently protect GSO FSS systems because the OneWeb system meets the applicable ITU EPFDup limits in all frequency ranges where these limits apply.14 B. Downlink Federal Coordination. Space-to-Earth operations in the bands between 17.7-20.2 GHz must complete coordination with U.S. Federal systems in accordance with footnote US334 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, prior to being used. Footnote US334 lists several locations where federal space and earth station operations are primary. However, the Talkeetna Earth Station is located outside the areas of concern in US334. Therefore, US334 is not applicable to the instant application. 1. 17.8-18.3 GHz In the NGSO Order, the Commission allocated the 17.8-18.3 GHz band on a primary basis to the terrestrial fixed service (“FS”) and on a secondary basis for FSS, subject to international power flux-density (“PFD”) limits.15 OneWeb previously demonstrated that secondary use of the band for its downlink operations will not cause harmful interference to FS operations because OneWeb’s system meets the ITU PFD limits.16 Consequently, the Commission authorized OneWeb’s space stations to transmit in the band despite being on a non- conforming basis at the time.17 Moreover, the Comsearch Interference Analysis Report attached 12 47 C.F.R. § 2.106; see also Ka-Band Plan. 13 See OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5377, ¶ 23(j). Similarly, OneWeb will operate in this band without seeking protection or causing harmful interference to any co- frequency MSS operations. 14 Market Access Application Technical Narrative at 33-34; A2-1 – A2-6. OneWeb believes that the EPFDup limits associated with the protection of GSO FSS networks would also adequately protect any GSO MSS network. 15 NGSO Order, 32 FCC Rcd at 7812, ¶¶ 7-8. 16 See Market Access Application Technical Narrative at 23-26; see also id. 17 See OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5373, ¶ 16. At the time of this grant, the Commission had not adopted a secondary allocation for FSS. 4

as Exhibit B18 to this application indicates that there will be no restrictions on OneWeb’s operations due to interference considerations in this band. 2. 18.3-18.6 GHz The 18.3-18.6 GHz band is allocated on a primary basis to the FSS, as the NGSO Order amended the Ka-band Plan to “allow NGSO FSS systems to operate on an unprotected, non- interference basis with respect to GSO FSS networks in the 18.3-18.6 GHz . . . band[], subject to international equivalent power flux-density (“EPFD”) limits.”19 The ITU developed downlink EPFD (“EPFDdown”) limits to protect GSO FSS networks from unacceptable interference from NGSO FSS systems operating in the same frequencies. Like the EPFDup limits, if the NGSO FSS system meets the applicable EPFDdown limits, then the Commission will consider the NGSO FSS satellite system to have met its obligations to protect GSO FSS networks from unacceptable interference. OneWeb provided calculations for transmissions in the band showing that the OneWeb system meets the applicable ITU EPFDdown limits in all frequency ranges where these limits apply.20 3. 18.8-19.3 GHz The 18.8-19.3 GHz band is allocated to the FSS on a primary basis, and the Commission recently preserved the primary designation for NGSO FSS systems in the Ka-band Plan.21 The Commission authorized OneWeb’s NGSO FSS system to transmit in this band.22 18 See supra note 9. 19 NGSO Order, 32 FCC Rcd at 7813, ¶¶ 9-10 (citing Section III.D.1). 20 See Market Access Application Technical Narrative at 33-34; A2-1 – A2-8. 21 NGSO Order, 32 FCC Rcd at 7814, ¶ 14. 22 OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5366, ¶ 1. 5

III. Waivers Appendix B to this Narrative Statement requests any necessary waivers of the current Section 25.136(a)(4) rule. IV. Antenna Patterns Appendix C provides for the certification that the Talkeetna Earth Station antenna patterns are in compliance with the relevant sections of Section 25.209. V. Radiation Hazard Report Appendix D is the radiation hazard analysis for the Talkeetna Earth Station. VI. FAA Notification FAA notification is not required as the Talkeetna Earth Station will not exceed 6.1 meters above ground. VII. Conclusion As explained above, grant of OneWeb’s Talkeetna Earth Station application is in the public interest and meets the requirements of the Commission’s rules. Respectfully submitted, WORLDVU SATELLITES LIMITED /s/ Mariah Shuman Mariah Shuman Senior Director, Regulatory Affairs 1400 Key Blvd. Suite 1, Floor A Arlington, VA 22209 1 (703) 731-0691 mariah@oneweb.net 6

APPENDIX A: 47 CFR § 25.136(A)(4) – UMFUS COMPLIANCE The Commission’s rules define four elements that, if met, permit an earth station licensee to operate in accordance with the terms of its authorization without providing additional interference protection to UMFUS stations in the 27.5-28.35 GHz band.23 Based on the following, the Commission should authorize the OneWeb Talkeetna Earth Station without requiring additional protection for future UMFUS licensees in Matanuska-Susitna Borough, Alaska. 1. § 25.136(a)(4)(i) The Talkeetna Earth Station complies with this section of the Commission’s rules because there are no other earth stations in the 27.5-28.35 GHz band in Matanuska-Susitna Borough. 2. § 25.136(a)(4)(ii) Section 25.135(a)(4)(ii) provides that, in a UMFUS license area with a population between 6,000 and 450,000 people, no more than 450 people may be within an earth station’s PFD contour that is equal to or exceeds -77.6 dBm/m2/MHz to avoid having to provide interference protection to future UMFUS operators. The area around the Talkeetna Earth Station falling within this PFD contour is all contained within Matanuska-Susitna Borough, which has a population of just over 100,000 people.24 As demonstrated below, the Talkeetna Earth Station’s PFD contour contains far fewer than 450 people. Using the ITU RR Appendix 7 Time-Variant Gain (TVG) method, each of the 26 antennas of the Talkeetna Earth Station would track a different OneWeb satellite above a minimum elevation angle of 10 degrees.25 A composite (26 antennas) PFD contour was developed via proprietary software and compared with the Visualyse PRO software to ensure consistency. This assessed the cumulative distribution function (CDF or joint probability) of potential interference representing the EIRP towards the horizon and the propagation statistics by performing the convolution of the individual CDFs. As a result, the TVG method calculates the area where the PFD limit could be exceeded, assuming a PFD value that is not exceeded for 99% 23 See 47 C.F.R. § 25.136(a)(4). 24 See QuickFacts Matanuska-Susitna Borough, Alaska, United States Census Bureau (last viewed Mar. 02, 2018), https://www.census.gov/quickfacts/fact/table/matanuskasusitnaboroughalaska/PST045216. 25 In this analysis, the population data for each census block within the Talkeetna Earth Station PFD contour comes from the 2010 U.S. Census data. The propagation model implements a 1-arc second resolution SRTM Digital Terrain Elevation Data (DTED) profile based on the ITU-R Recommendation P.452-15. 7

of the time. The following contains the Talkeetna Earth Station parameters26 and the resulting PFD contour of the analysis:27 Talkeetna Earth Station Parameters ES latitude (NAD 83) 62° 19' 59.1" N° ES longitude (NAD 83) 150° 1' 52.4" W° Ground Elevation (AMSL) 148 m ES antenna size 3.5 m ES input power spectral density -19.0 dBW/MHz ES antenna pattern FCC (§25.209(a)(1)) ES minimum elevation angle 10° Number of antennas at site 26 26 It should be noted that the earth station input power spectral density is 3.4 dB lower than the maximum provided in the Application since the latter includes maximum uplink power control for rain events exceeding 6 dB. The uplink power control is not used for fade levels less than 6 dB and has a range of 3.4 dB, so for this analysis, the clear-sky value is most appropriate. 27 The Talkeetna Earth Station’s PFD contour is displayed using Google Maps and then superimposed on a U.S. Census map to estimate the population within the contour—note that the population counts for each census block are in parentheses. These images are larger on the next page. 8

9

The next table displays the calculated population for each census block that is within the Talkeetna Earth Station PFD contour: Assumed Population of Contour Coverage Proportion Block Include 100% of Population Covered Only Completely ID Partially Pop. in all (estimated) Covered Blocks Covered Blocks Blocks 1000 4 100% 4 4 4 1002 117 20% 0 24 117 1008 26 100% 26 26 26 1009 7 100% 7 7 7 1043 53 100% 53 53 53 1041 93 50% 0 47 93 1481 149 10% 0 15 149 2115 22 20% 0 4 22 2139 127 30% 0 42 127 Total Population 90 222 545 The summation of the population in the Talkeetna Earth Station PFD contour is approximately:  90 people (looking at only the populations of those census blocks that are wholly contained within the contour and assuming that the populations of the partially covered blocks fall outside the PFD contour) or  222 people (using a very conservative summation of the populations in Blocks 1000, 1008, 1009, and 1043—blocks with complete contour coverage—combined with a portion of the population in Blocks 1002, 1041, 1481, 2115, and 2139—blocks with partial contour coverage). Clearly the third column reflects operations that are extremely unlikely to occur, especially for Blocks 1002 and 1481, because only a small portion of their areas are within the interference contour. To verify the population-count in this study, and underscore the conservative assumptions that form the basis of the estimated 222-population value, the interference contour was superimposed on a population distribution grid,28 as depicted in the following figure: 28 See Gridded Population of the World, NASA Socioeconomic Data and Applications Center available at http://sedac.ciesin.columbia.edu/data/collection/gpw-v4/maps/services. 10

The estimated population within the contour is 180 people. Consequently, the conservative estimate of 222 people illustrates that the total population covered by the Talkeetna Earth Station’s PFD Contour is much less than the 450-person limit as set out by this subsection. 3. § 25.136(a)(4)(iii) Based on a search in Google Maps, there are no major event venues, urban mass transit routes, passenger railroads or cruise ship ports within the Talkeetna Earth Station’s PFD contour. Although the PFD contour overlaps with portions of Comsat Road in Matanuska-Susitna Borough, Comsat Road is not identified as an Interstate, Other Freeway and Expressway, or Other Principal Arterial by The Federal Highway Administration Office of Planning, Environment, and Realty Executive Geographic Information System map.29 The only such road is George Parks Highway (Highway 3) which is outside the PFD contour. Therefore, the Talkeetna Earth Station complies with the requirements of this subsection. 4. § 25.136(a)(4)(iv) The Comsearch Coordination Report attached as Exhibit B30 demonstrates that OneWeb completed coordination in compliance with the Commission’s rules. 29 See National Highway System Map, U.S. Department of Transportation, Federal Highway Administration (last visited Mar. 2, 2018), https://hepgis.fhwa.dot.gov/fhwagis/. 30 See supra note 9. 11

Appendix B: 47 CFR § 25.136(a)(4) – Waiver Request OneWeb requests that the Commission consider this application under the newly adopted Section 25.136(a)(4) as OneWeb fully complies with the updated rule as illustrated in Appendix A. In the alternative, since the rule changes are not in effect as of the submission of this application, OneWeb requests any necessary waivers of the current Section 25.136(a)(4) rules. Grant of this waiver request is consistent with Commission precedent.31 First, in the Second Spectrum Frontiers Order, the Commission altered the population limits for earth station coverage specified under Section 25.136(a)(4)(ii) to give satellite operators additional deployment flexibility.32 Second, requiring OneWeb to comply with the current Section 25.136(a)(4) would become unnecessary as soon as the newly adopted Section 25.136(a)(4) comes into effect. Third, grant of this waiver is in the public interest because it will facilitate OneWeb’s ability to build-out the ground infrastructure providing critical support to its LEO constellation in a timely manner. OneWeb notes the Commission recently granted an earth station application that contained a similar waiver request.33 For these reasons, OneWeb respectfully submits that this waiver request is in the public interest. 31 PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (finding that a waiver is appropriate so long as the requested relief “would not undermine the policy objective of the rule in question and would otherwise serve the public interest”). 32 See Second Spectrum Frontiers Order, 32 FCC Rcd at 11029-32, ¶¶ 124-133. 33 See O3b Limited, IBFS File No. SES-LIC-20180122-00053, Call Sign E180005 (granted Mar. 8, 2018). 12

Appendix C: 47 CFR § 25.132 – Antenna Patterns Certification I, Marc Dupuis, Senior Director of Spectrum Affairs for OneWeb, hereby certify that I  reviewed the results of a series of radiation pattern tests for the CPI 3.5 meter antenna performed by the antenna manufacturer on representative equipment in representative configurations, and  found the test results demonstrate that the CPI 3.5 meter antenna meets relevant off-axis gain standards in Section 25.209 of the Commission’s rules, measured in accordance with Section 25.132(b)(1). This certification is dated June 4, 2018 and signed by: /s/ Marc Dupuis Marc Dupuis Senior Director, Spectrum Affairs OneWeb 1400 Key Blvd. Arlington, VA 22209 13

APPENDIX D: RADIATION HAZARD REPORT In accordance with OET Bulletin 65, this Radiation Hazard Report measured radiation exposure levels in seven zones for two cases—general population and occupational. The radiation levels calculated for each zone in Section II are derived from the calculations made in Section I. The results in Section III for OneWeb’s 3.5 meter CPI antenna illustrate any radiation hazard that may exist for the general public and/or occupationally will be mitigated by limited access and various protocols to ensure safe exposure levels. I. Defined Variables for OET Bulletin 65 Calculated Variables OET 65 Calculated Variables Value Unit Formula Value Unit Variables D= λ= Aperture 3.5 Meters c/F 0.0104 Meters Wavelength Diameter d= PI = Subreflector 0.406 Meters Total Antenna Input P*p 114 Watts Diameter Power η= A= Aperture 57% Percentage π(D/2)2 9.62113 Meters2 Area of reflector Efficiency a= FCC Designation Ka Band area of π(d/2)2 0.12946 Meters2 sub-reflector F= G= G= 28750 MHz 630965.68 Linear Frequency Antenna Gain 4πηA/λ2 P= Transmitter 114.1 Watts Antenna Gain dB 10log10(G) 58.00 dBi Power Watts p= Rnf = Number of 1 # Rnf = D2/4λ 293.69 Meters Near-Field Region Transmitters Rua = Closest Point to 15 Meters 293.69 >Meters Uncontrolled Area Transition Region >Rnf <Rff Rua = Elevation angle 10 Degrees 704.86 <Meters at closest point 704.86 Meters Rff = Rff = Meters Far-Field Region 0.6D2/λ 124 AGL 14

II. Radiation Levels in Each Zone Exposure Limits Met General Radiation Analysis Zone Formula Level Value Occupational Public <1mW/cm2 <5mW/cm2 mW/cm 1 Power Sub-reflector 4PI/a 352.48 2 No No mW/cm 2 Antenna Surface 4PI/A 4.74 2 No Yes mW/cm 3 Main Reflector Ground PI/A 1.19 2 No Yes Snf = mW/cm 4 Near-Field 4η(PI/A) 2.69 2 No Yes Power Density Transition mW/cm 5 Snf*Rnf/Rnf 2.69 2 No Yes Max Power Density Far-Field mW/cm 6 PI*G/4πR2 1.15 2 No Yes Max Power Density mW/cm 7 Off-axis Near Field Snf-20dB 0.03 2 Yes Yes III. Results General Public Analysis. OneWeb’s 3.5 meter CPI antennas will be located in an area clearly marked with Radiation Hazard signage with no access by the general public. Zones 1 through 5 create no concern for the general public as they lie behind this signage where only authorized personnel may enter. Likewise, Zone 6—Far Field—also creates no concern for the general public because it develops 124 meters above ground level at a minimum elevation angle of ten degrees where the general public cannot access. Accordingly, there is no risk of radiation exposure beyond the acceptable limits. Occupational Analysis. Only around the Power Sub-reflector are any radiation levels exceeded. This measurement is taken at a point between the feed and the sub-reflector. Power to the transmitters will be turned off remotely whenever work needs to be performed in this Zone. Signage will mark the area for Radiation Hazard and access by qualified personnel only, facilitating awareness and safety. Consequently, there is no risk of radiation exposure beyond the acceptable limits. 15


Document Created: 2018-06-04 19:20:21
Document Modified: 2018-06-04 19:20:21
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