Attachment Narrative SES-LIC-INTR2019-02413

Attachment Narrative

This document pretains to SES-LIC-INTR2019-02413 for License on a Satellite Earth Station filing.

IBFS_SESLICINTR201902413_1730097

Application for Blanket Earth Station Authorization

Overview

Swarm Technologies, Inc. (“Swarm”) is a U.S. corporation that has applied to launch and

operate an innovative constellation of 150 small two-way communications satellites in the non-

voice, non-geostationary (“NVNG”) Mobile-Satellite Service (“MSS”). 1 Swarm’s proposed

satellite constellation will provide global data services to industry, government, nonprofit, and

research and development users. By leveraging advances in small satellite technology and the

increased availability of launch opportunities, the Swarm constellation will be deployed rapidly

and will provide connectivity at far lower costs than have been previously possible.

In this application, Swarm seeks a blanket authorization pursuant to 47 C.F.R. § 25.115(d)

for operation of up to 1,000,000 Customer Mobile Earth Station (“CMES”) devices that end users

will employ to communicate with Swarm’s satellite constellation. The devices will operate on

frequencies in the 148-149.95 MHz (uplink) and 137-138 MHz (downlink) bands, consistent with

Swarm’s space station application. 2 Swarm seeks authorization for CMES devices to be deployed

and operated throughout the continental United States, Alaska, Hawaii, Puerto Rico, Guam, the

U.S. Virgin Islands, all U.S. territories and possessions, and all U.S. territorial waters. CMES

devices may use one of several antennas, depending on the application. The characteristics of each

proposed terminal are provided in the accompanying Schedule B, as is the quantity to be licensed

for each terminal type.

In the following narrative and in the accompanying Form 312, Swarm demonstrates that

the proposed devices comply with all technical and operational requirements and that grant of this

1
Swarm Technologies, Inc., Application for Authority to Launch and Operate Non-Voice, Non-Geostationary
Lower Earth Orbit Satellite System in the Mobile-Satellite Services, IBFS File No. SAT-LOA-20181221-00094
(filed Dec. 21, 2018) (“Space Station Application”).
2
Space Station Application Narrative Exhibit at 9.

1

Emission Characteristics

Swarm proposes to operate CMES devices on multiple channels within the uplink and

downlink frequencies provided in Table 1. Both the Swarm satellites and CMES devices are

capable of operating with a variety of emissions designators to meet the diverse needs of

customers, and Swarm may vary, within the range specified in this application, the bandwidth of

channels on which CMES devices transmit and receive to best serve customer needs and maximize

spectral efficiency. Consistent with 47 C.F.R. § 25.275, Swarm specifies in Schedule B only those

carriers with the highest Effective Isotropic Radiated Power (“EIRP”) density, narrowest

bandwidth, and largest bandwidth, and will transmit using emissions not specifically listed only if

doing so would “not exceed the highest EIRP, EIRP density, and bandwidth prescribed for any

listed emission.” 4 For completeness, information regarding the characteristics of additional

emissions designators and their corresponding power, EIRP, and EIRP density levels is provided

in Table 2 below. In each case, the assigned bandwidth includes an appropriate frequency

allowance to account for Doppler shift and frequency tolerance. Emissions specified in Schedule

B are highlighted in blue and define the maximum bandwidth, EIRP, and EIRP density with which

CMES terminals will transmit. Swarm notes that the maximum power level requested for CMES

terminals differs from the power level assumed in the reverse link budget that Swarm provided for

illustrative purposes in the narrative to its space station application. 5 There have been no changes

to the link budget for the space to ground link at issue in that application.

4
47 C.F.R. § 25.275(c).
5
Space Station Application, Narrative at 27-28.

3

Additionally, in the 148-149.9 MHz band, the CMES devices that are the subject of this

application will operate using the following technical parameters: (1) 1% duty cycle within any

15-minute period, (2) a maximum duration of 450 ms per transmission, and (3) a minimum of 15

seconds of separation between consecutive transmissions on the same frequency. 8

CMES devices will employ techniques to avoid transmitting on frequencies in active use

by terrestrial fixed and mobile stations. As a result, the -16 dBW/4 kHz power density limit and

0.25% duty cycle limitations provided in footnote US323 will not apply. Specifically, Swarm

CMES devices use a Carrier-Sense Multiple Access (CSMA) media access control (MAC)

protocol with Collision Avoidance (CSMA/CA). This “listen-before-talk” protocol verifies the

absence of other traffic before a transmission is initiated on a given channel. If the carrier-sensing

mechanism of a Swarm CMES device determines that another transmission is in progress, the

transmitter waits for the transmission in progress to end before initiating its own transmission.

Using this CSMA protocol, multiple carriers on the ground, including both Swarm CMES

devices and non-Swarm devices, can operate on the same frequencies with a minimal probability

of interference to either system. There is also an inherently low probability of signal collision

because of the low duty cycle and distributed geography of the anticipated customer deployments.

Service Limitation (47 C.F.R § 25.142(b)(1))

Pursuant to 47 C.F.R § 25.142(b)(1), Swarm will not provide voice services.

Coordination with Federal Government Users (47 C.F.R. § 25.142(b)(2))

As explained above, Swarm CMES devices will comply with technical parameters

intended to protect federal users from NVNG MSS ground to space operations. In addition, to

ensure that Swarm does not cause unacceptable interference for federal users, Swarm will

8
See 47 C.F.R § 2.106 at footnote US323.

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coordinate with federal government operations through the process established by NTIA and the

Interdepartment Radio Advisory Committee, as specifically contemplated by

47 C.F.R. § 25.142(b)(2). Swarm will provide any additional information requested by the

Commission required for coordination with federal users. 9

Coordination with Other NVNG MSS Systems (47 C.F.R. § 25.142(b)(3))

Swarm does not request authority to operate in any spectrum assigned on a primary basis

to the sole NVNG MSS incumbent, ORBCOMM. As a result, upon approval of Swarm’s pending

Part 25 satellite system authorization, Swarm will be the only authorized commercial satellite

operator in the frequency bands shown in Table 1. 10 In addition, as explained above, Swarm’s

devices will comply with the applicable out-of-band emissions requirements in Section 25.202(f),

thereby protecting operations in neighboring bands. Pursuant to Section 25.142(b)(3), Swarm is

willing to coordinate its proposed frequency usage with ORBCOMM, which should be a very

straightforward process given the absence of any frequency overlap and Swarm’s compliance with

Section 25.202(f). Swarm also will work to coordinate in good faith with future NVNG MSS

operators to ensure efficient use of radio spectrum.

Grant of this Application Would Serve the Public Interest

The grant of this application would serve the public interest by permitting end users to

access a new generation of NVNG MSS services that will be provided by Swarm’s proposed

9
See 47 C.F.R. §25.142(b)(2)(ii).
10
See Consolidated Opposition and Response of Swarm Technologies, Inc. at 2-10, IBFS File No. SAT-LOA-
20181221-00094 (filed Apr. 15, 2019) (“Consolidated Opposition and Response”) (explaining that ORBCOMM
must terminate any use of the spectrum requested by Swarm once Swarm commences operations because none
of Swarm’s requested frequencies overlap with ORBCOMM’s primary assignments); see also Applications by
ORBCOMM License Corp., Order and Authorization, 23 FCC Rcd. 4804, 4808, 4812-13 ¶¶ 11, 22, 23 (Int’l Bur.
and Office of Eng’g & Tech. Mar. 21, 2008) (conditioning any use of spectrum by ORBCOMM outside of its
primary assignments on ORBCOMM’s “operating using only frequency bands assigned to it on a primary basis .
. . upon commencement of operations by another U.S.-licensed non-voice, non-geostationary mobile satellite
system”).

8

Authorization of Swarm’s network also will help to ensure that U.S. companies lead the

way in a new era of innovation enabled by small satellite technology. Swarm is prepared to deploy

its satellite constellation upon approval of its pending space station authorization, and to begin

offering services to commercial users shortly thereafter. Approval of the blanket earth station

application will enable significant numbers of new satellite users to benefit from Swarm’s low-

cost satellite technology and bring IoT connectivity to new verticals and rural communities. For

these reasons, expeditious grant of this application would serve the public interest and ensure that

services can be provided to end users without delay.

Respectfully submitted,

Swarm Technologies, Inc.

By: _/s/ Sophie Arlow______
Dr. Sophie Arlow
Lead Program Manager

Dr. Sara Spangelo
Chief Executive Officer

Kalpak Gude
General Counsel

Swarm Technologies Inc.
845 Madonna Way
Los Altos, CA 94024

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Document Created: 2019-06-14 09:49:22
Document Modified: 2019-06-14 09:49:22

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