Attachment Exhibit A

This document pretains to SES-LIC-20190422-00538 for License on a Satellite Earth Station filing.

IBFS_SESLIC2019042200538_1662472

                 NARRATIVE STATEMENT: EARTH STATION LICENSE APPLICATION

        By this application, WorldVu Satellites Limited (“OneWeb”) seeks authority to operate
twenty technically identical CPI 3.5 meter antennas in Santa Paula, CA (the “Santa Paula Earth
Station”). The Santa Paula 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 OneWeb’s first six production satellites were
successfully launched on February 27, 2019. 2

        The Santa Paula Earth Station will allow OneWeb to expand its coverage and service in
the United States. Additional gateway facilities are a critical part of OneWeb’s network
infrastructure as it prepares to begin commercial service. 3 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 in the United States.

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. 4

II.       Spectrum Use and Sharing

       The Santa Paula 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 Santa Paula 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)

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 Caleb Henry, OneWeb’s first six satellites in orbit following Soyuz launch, SPACENEWS
(Feb. 27, 2019), https://spacenews.com/first-six-oneweb-satellites-launch-on-soyuz-rocket/.
3
 OneWeb filed applications for three gateway earth stations in the United States in 2018. See
IBFS File Nos. SES-LIC-20180604-01082, Call Sign E180260 (filed June 4, 2018); SES-LIC-
20180727-02075, Call Sign E181293 (filed July 27, 2018); SES-LIC-20180727-02076, Call Sign
E181294 (filed July 27, 2018).
4
     See 47 C.F.R. § 25.137.


                                                 1


       As illustrated below, OneWeb’s Santa Paula Earth Station will operate in a manner
consistent with the Commission’s rules.

        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. 5 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. 6

       The Commission 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. 7

       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 this band. 8

       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. 9

        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



5
  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 (2017) (“NGSO Order”); NGSO Order, 32 Rcd at 7850, App. B (“Ka-band Plan”); 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.”).
6
  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).
7
    NGSO Order, 32 FCC Rcd at 7817, ¶ 23.
8
    See Ka-band Plan.
9
  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.


                                              2


conditions are met. 10 Appendix A to this Narrative Statement demonstrates the Santa Paula
Earth Station will satisfy all four conditions.

       The Comsearch Coordination Report attached separately as Exhibit B 11 to this
application demonstrates that in the 27.5-28.35 GHz band: (1) OneWeb can operate the Santa
Paula 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. 12
OneWeb has demonstrated that it meets the applicable ITU EPFDup limits in all frequency ranges
where these limits apply and certifies its operations will be compliant with Article 22 and
Resolution 76 of the ITU’s rules. 13 Consequently, the transmissions from the Santa Paula Earth
Station will sufficiently protect GSO FSS systems.



10
   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).
11
   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 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.
12
   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.”).
13
  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. 14

         OneWeb makes no claim of interference protection from U.S.-licensed GSO FSS systems
in this band, 15 and the transmissions from the Santa Paula 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. 16

          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 Santa Paula 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. 17 Before the NGSO Order was implemented,
OneWeb demonstrated that secondary use of this band for its downlink operations will not cause
harmful interference to FS operations because OneWeb’s system meets the ITU PFD limits. 18
Consequently, the Commission authorized OneWeb’s space stations to transmit in this band
despite being on a non-conforming basis at the time, before implementation of the NGSO


14
     47 C.F.R. § 2.106; see also Ka-Band Plan.
15
   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.
16
  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.
17
     NGSO Order, 32 FCC Rcd at 7812, ¶¶ 7-8.
18
     See Market Access Application Technical Narrative at 23-26; see also id.


                                                  4


Order. 19 Moreover, the Comsearch Interference Analysis Report attached as Exhibit B 20 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.” 21 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 this band showing that the
OneWeb system meets the applicable ITU EPFDdown limits in all frequency ranges where these
limits apply. 22 The Commission authorized OneWeb’s NGSO FSS system to transmit in this
band. 23

                 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. 24 The
Commission authorized OneWeb’s NGSO FSS system to transmit in this band. 25




19
  See OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5373, ¶ 16, 23. At the time of this
grant, the Commission had not adopted a secondary allocation for FSS.
20
     See supra note 11.
21
     NGSO Order, 32 FCC Rcd at 7813, ¶¶ 9-10 (citing Section III.D.1).
22
     See Market Access Application Technical Narrative at 33-34; A2-1 – A2-8.
23
     OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5366, ¶¶ 16, 23.
24
     NGSO Order, 32 FCC Rcd at 7814, ¶ 14.
25
     OneWeb U.S. Market Access Grant, 32 FCC Rcd at 5366, ¶ 1.


                                                5


III.   Antenna Patterns

       Appendix B certifies the Santa Paula Earth Station antenna patterns are in compliance
with the relevant sections of Sections 25.132 and 25.209 of the Commission’s rules.

IV.    Radiation Hazard Report

       Appendix C provides the radiation hazard analysis for the Santa Paula Earth Station.

V.     FAA Notification

       FAA notification is not required as the Santa Paula Earth Station will not exceed 6.1
meters above ground.

VI.    Conclusion

        As explained above, grant of OneWeb’s Santa Paula 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
                                                    Head of Regulatory Affairs, Americas
                                                    1785 Greensboro Station Place
                                                    Tower 3, Floor 8
                                                    McLean, VA 22102
                                                    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. 26 Based on the
following analysis, the Commission should authorize the OneWeb Santa Paula Earth Station
without requiring additional protection for future UMFUS licensees in Ventura County,
California.

      1. § 25.136(a)(4)(i)

       The Santa Paula Earth Station complies with this section of the Commission’s rules
because there are only two other earth stations in the 27.5-28.35 GHz band in Ventura County,
California. 27

      2. § 25.136(a)(4)(ii)

        Section 25.135(a)(4)(ii) provides that, in a UMFUS license area with a population greater
than 450,000 people, no more than 0.1 percent of the population 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 Santa Paula Earth
Station falling within this PFD contour 28 is fully contained within Hendry County which has a
population of just over 854,000 people. 29 As demonstrated below, the Santa Paula Earth
Station’s PFD contour contains far fewer than 854 people.

       Using the ITU RR Appendix 7 Time-Variant Gain (TVG) method, each of the 20
antennas of the Santa Paula Earth Station would track a different OneWeb satellite above a



26
     See 47 C.F.R. § 25.136(a)(4).
27
  See IBFS File Nos. SES-MOD-20170920-01039, Call Sign E160022 (granted Dec. 6, 2017)
(“SES Earth Station”); SES-LIC-20170807-00888, Call Sign E170163 (filed Aug. 7, 2017)
(“HNS Earth Station”).
28
   The PFD contour of the Santa Paula Earth Station was first computed using existing terrain
features. As explained in Section 3 below, these would not be sufficient to comply with the PFD
limit in Section 25.136(a)(4)(iii). To comply with the PFD limit, an additional earth berm
(illustrated in Section 3 below) will be built at the site and the results described herein assume
this additional feature will be present.
29
  See QuickFacts Hendry County, Florida, United States Census Bureau (last viewed Feb. 15,
2019), https://www.census.gov/quickfacts/fact/table/venturacountycalifornia/PST045217.


                                                7


minimum elevation angle of 5 degrees. 30 A composite (20 antennas) PFD contour was
developed via proprietary software and compared with the Visualyse PRO software to ensure
consistency. This composite 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% of the time. The following contains the Santa Paula Earth Station
parameters 31 and the resulting PFD contour of the analysis: 32


                            Santa Paula Earth Station Parameters
             ES latitude (NAD 83)                34° 24' 7.2"
             ES longitude (NAD 83)               119° 4' 23.5"
             Ground Elevation (AMSL)             232.18 m
             ES antenna size                     3.5 m
             ES input power spectral density     -19.0 dBW/MHz
             ES minimum elevation angle          5°
             Number of antennas at site          20




30
  In this analysis, the population data for each census block within the Santa Paula 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.
31
   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 clear sky value is the most appropriate calculation for this
analysis because uplink power control is not used for fade levels less than 6 dB.
32
  The Santa Paula 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.


                                                 8


                                    mA
                                   unevveb
                                     ACCESS FOR EVERYONE




                  ow
             [20
Pss        4Wt t D
 (0)         At     4
Santa Paula complete berm
                    |uptr
                  W f{(D)

                        PakC
                            hn d


       The next table displays the calculated population for each census block within the Santa
Paula 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          93            5%                0                  5            93
   4004          17            5%                0                  1            17
   4000           0           50%                0                  0             0
   4001           0           75%                0                  0             0
   4002           0           50%                0                  0             0
   4003           0           50%                0                  0             0
   4028           0           75%                0                  0             0
   4021           0           25%                0                  0             0
   4022           0           75%                0                  0             0
   4026           4           25%                0                  1             4
   4031           0           75%                0                  0             0
   4040           5           50%                0                  3             5
   4041           0           80%                0                  0             0
   4044           0           10%                0                  0             0
   4036           0           50%                0                  0             0
   4034           0           10%                0                  0             0
   2002           0           50%                0                  0             0
   2004          50           25%                0                 13            50
   1040           6           25%                0                  2             6
   1037           1           10%                0                  1             1
   1007          31           25%                0                  8            31
   1048          20            5%                0                  1            20
   1027           0           10%                0                  0             0
   1009           0           25%                0                  0             0
   1030           0            5%                0                  0             0
   1050          11            5%                0                  1            11
           Total Population                      0                 36           238

The summation of the population in the Santa Paula Earth Station PFD contour is approximately:
   • 0 people (accounting for only the populations of those census blocks that are wholly
      contained within the contour and assuming the populations of the partially covered blocks
      fall outside the PFD contour);
   • 36 people (accounting for a very conservative proportion of the population of all the
      census blocks wholly and partially contained within the PFD contour, where in the blocks
      with partial contour coverage, a very conservative proportion of the blocks is calculated


                                               10


        based on the estimated geographical area of the block within the PFD contour over its
        total area); or
    • 238 people (accounting for the total population of all blocks touched by the PFD
        contour).
The third column in the above table would likely never occur because the interference contour
only covers a portion of the land area of all the blocks. Regardless, even assuming this
population, 238 people is far less than the 854-person limit.
        To verify the population-count in this study and underscore the conservativeness of the
estimated 238-population value, the interference contour was superimposed on a population
distribution grid, 33 as depicted in the following figure:




The estimated population within the contour is 83 people. Consequently, the conservative
estimate of 238 people illustrates that the total population covered by the Santa Paula Earth
Station’s PFD Contour is much less than the 854-person limit as set out by this subsection. As
noted above, two other earth stations are located in Ventura County. According to OneWeb’s
calculations, the SES Earth Station covers census blocks with a total population of 81, and when
applying the percentage of the area in the contour, a calculated population of 20 people are



33
    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. Note that
due to the low population density in the area surrounding this planned earth station, no data point
in the graph even has a population of 1 person.


                                                11


within the contour. 34 The HNS Earth Station contour does not cover any population. 35
Therefore, even in a most conservative estimate, only 319 people could be counted as within the
contour of an earth station in the area, far less than the 854-person limit.

      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 Santa Paula Earth Station’s PFD
contour. The PFD contour was calculated based on the existing terrain profile (illustrated in blue
in the figures below) showing overlap with portions of North Ojai Road (i.e., Route 150 or Ojai
Santa Paula Road)—which is identified as an Other Principal Arterial by The Federal Highway
Administration Office of Planning, Environment, and Realty Executive Geographic Information
System map. 36 Nevertheless, UMFUS deployments will not be impacted by the Santa Paula
Earth Station because OneWeb will build a berm (illustrated in red in the on the next page)
resulting in a PFD contour (illustrated in green in the figures below) that will not overlap with
any portion of North Ojai Road (i.e., Route 150 or Ojai Santa Paula Road), thus complying with
the requirements of this subsection.




34
     See SES Earth Station.
35
     HNS Earth Station, Exhibit B at #12.
36
 See National Highway System Map, U.S. Department of Transportation, Federal Highway
Administration (last visited Mar. 27, 2019), https://hepgis.fhwa.dot.gov/fhwagis/.


                                               12


13


        OneWeb plans to build a 3-meter high earth berm around the location of the proposed
earth station antennas (roughly centered as depicted by the push pin in the above figures). The
berm (illustrated in red in the figure below) would follow the south and west property lines (as
shown in thin red lines in the figure below). Should the Commission approve this application,
the berm will be constructed and its impact in terms of signal attenuation will be measured at the
site before commencing transmissions.




                                                14


       Therefore, the Santa Paula Earth Station complies with the requirements of this
subsection.

      4. § 25.136(a)(4)(iv)

      The Comsearch Coordination Report in Exhibit B 37 demonstrates that OneWeb
completed coordination in compliance with the Commission’s rules.




37
     See supra note 11.


                                               15


            APPENDIX B: 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 April 22, 2019 and signed by:


                                                      /s/     Marc Dupuis

                                                     Marc Dupuis
                                                     Senior Director, Spectrum Affairs
                                                     WorldVu Satellites Limited
                                                     1785 Greensboro Station Place
                                                     Tower 3
                                                     McLean, VA 22102




                                                16


                                  APPENDIX C: 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
                            25     Meters                                                 293.69   >Meters
        Uncontrolled
                 Area                               Transition Region      >Rnf <Rff
                 Rua =
      Elevation angle        5     Degrees                                                704.86   <Meters
      at closest point
                                                                                          704.86   Meters
                                                                 Rff =         Rff =
                                                                                                   Meters
                                                     Far-Field Region       0.6D2/λ        61.67
                                                                                                   AGL




                                                       17


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 61.67 meters above ground level at a minimum elevation
angle of five 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.




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Document Created: 2019-04-22 17:44:23
Document Modified: 2019-04-22 17:44:23

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