Attachment Narrative

This document pretains to SES-MFS-20101020-01300 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2010102001300_845993

Exhibit C Description of Application LightSquared Subsidiary LLC (“LightSquared”) seeks modification of its earth station license (Call Sign E080031) to add SkyTerra 2, a Canadian-authorized satellite, as a point of communication. The earth station will communicate with SkyTerra 2 on the Appendix 30B Ku-band frequencies (i.e. 10.70-10.95 & 11.20-11.45 GHz (space-to- Earth) and 12.75-13.25 GHz (Earth-to-Space))1 for feeder-link operations and on the L- band frequencies (i.e. 1525-1544/1545-1559 MHz (space-to-Earth) and 1626.5- 1645.5/1646.5-1660.5 MHz (Earth-to-space)) for space operations functions.2 The technical information for the satellite, including the Schedule S, and the information required for foreign satellites under 47 C.F.R. § 25.137 are provided in a contemporaneously filed application seeking access to SkyTerra 2.3 The relevant information in that application is incorporated herein by reference. No other changes are requested to this earth station license, and LightSquared will continue to operate the facility as conditioned. LightSquared submits that no waiver of footnote NG104 of Section 2.106 of the Commission’s rules is required.4 The Commission has already granted waiver of this requirement in authorizing this earth station to communicate with SkyTerra 1 on the same feeder-link frequencies.5 No additional coordination with terrestrial operations is required for feeder-link operations with SkyTerra 2. The satellite is within the orbital arc (101°W to 107.3°W) previously coordinated and authorized for this earth station, as reflected in the license. 1 The earth station will use only those Appendix 30B frequencies that have been authorized already for use by the station. See Exhibit A. 2 The L-band antennas at the gateway earth station will be used to transmit and receive a relatively low- power beacon signal that the ground-based beam forming system will use for precision spacecraft pointing corrections and will not provide any end-user communications functionality. 3 See File No. SES-MFS-20101015-01297 (filed October 15, 2010). 4 The footnote permits use of the 10.7-11.7 GHz (space-to-Earth) and 12.75-13.25 GHz (Earth-to-space) frequencies for FSS but restricts their use to “international” satellite systems. 47 C.F.R. § 2.106, NG104; see also 47 C.F.R. § 25.202(a)(1) n.2 (restating the restriction). 5 To the extent necessary, LightSquared incorporates by reference its justifications for waiver of 47 C.F.R. §2.106, NG104, submitted in its initial application for earth station authority. See Applications, File Nos. SES-LIC-20080206-00132 (February 6, 2008). Additionally, as explained in that application, the earth station protects the space research service facilities at Goldstone, California (47 C.F.R. § 2.106 US251) and complies with the Commission’s requirement to protect BAS/CARS in the top 100 television markets (47 C.F.R. § 2.106 NG53). 402310423v1

The chart below provides additional information reflecting the operation of SkyTerra 2 in an inclined orbit, which is not otherwise captured by the application:6 Table 1 - Earth Station Pointing Box for SkyTerra 2 Earth Nominal Nominal Minimum Minimum Maximum Maximum Station Elevation Azimuth Elevation Azimuth Elevation Azimuth Cedar 50.48° 198.68° 43.99° 195.68° 56.96° 202.41° Hill 6 Similar information was provided for SkyTerra 1 in the initial earth station application. See File No. SES-LIC-20080206-00132 (February 6, 2008). 2 402310423v1

Certification of Jeffrey J. Carlisle I, Jeffrey J. Carlisle, hereby certify under penalty of perjury that: 1. I am Executive Vice President, Regulatory Affairs and Public Policy of LightSquared LP, the managing member of LightSquared Subsidiary LLC, and have authority to file this application; 2. The statements made in this application are true, complete, and correct to the best of my knowledge and belief; and 3. No party to the application is subject to a denial of federal benefits pursuant to Section 5301 of the Anti Drug Abuse Act of 1988, 21 U.S.C. §853a. /s/ Jeffrey J. Carlisle Executive Vice President, Regulatory Affairs and Public Policy of LightSquared LP LightSquared Subsidiary LLC October 20, 2010 3 402310423v1


Document Created: 2010-10-20 09:52:20
Document Modified: 2010-10-20 09:52:20
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