Attachment Part 25 Compliance

This document pretains to SES-MFS-20130504-00363 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2013050400363_995214

Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222


                          Astrium Services Government, Inc.

                  Application for Modification of License to Add up to
            500 Sea Tel Model 9707/9797/9711 2.4 Meter C-band Antennas;
                 500 Intellian Model v240 2.4 Meter C-band Antennas;
                              500 Sea Tel Model 9711QOR
             Combination 2.4 Meter C-band/1.2 Meter Ku-band Antennas;
               500 Intellian Model v100 1.06 Meter Ku-band Antennas;
               500 Intellian Model v130 1.25 Meter Ku-band Antennas;
           500 Mitsubishi Model MVA60 0.60 Meter Ku-band Antennas; and
             500 Mitsubishi Model MVA120 1.2 Meter Ku-band Antennas
                   To Call Sign KA313 License ESV Authorization

                            SES-MOD-20111109-01345

                                   Call Sign KA313

         By this application applicant Astrium Services Government, Inc. (Astrium) seeks
authority to add up to 500 Sea Tel Model 9707/9797/9711 2.4 Meter C-band Antennas;
500 Intellian Model v240 2.4 Meter C-band Antennas; 500 Sea Tel Model 9711QOR
Combination 2.4 Meter C-band/ 1.2 Meter Ku-band Antennas; 500 Intellian Model v100
1.06 Meter Ku-band Antennas; 500 Intellian Model v130 1.25 Meter Ku-band Antennas;
500 Mitsubishi Model MVA60 0.60 Meter Ku-band Antennas; and 500 Mitsubishi
Model MVA120 1.2 Meter Ku-band Antennas to its call sign KA313 license
authorization for Earth Station on Vessel (ESV) service. The application requests
authority for the remote C-band antennas to communicate via the SES-4 and NSS-9
satellites and for the remote Ku-band antennas to communicate with any satellite on the
Permitted Space Station List (ALSAT) to provide ESV service. These remote ESVs will
be located on vessels traveling in U.S. and international waters. They will operate with
hub antennas that are separately licensed by the Commission and will be utilized to
provide ESV service as previously authorized by the Commission. As with the other
antennas previously authorized for ESV service, operation of these antennas will be in
full compliance with the requirements of the Commission’s ESV regulations as set forth
in part 25 of the Rules.

       ASTRIUM’s showing of compliance with Part 25 of the Commission’s Rules
follows herewith and the exhibits required by Sections 25.221 and 25.222 are included as
attachments to the application.

            Showing of Compliance with Part 25 of the Commission’s Rules

Section 25.221

   (a) (1) Comply.


Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222

     See the Sea Tel and ASTRIUM Sea Tel declarations and Exhibits 2, 3 and 4 for
     the Sea Tel model 9707, 9797 and 9711 C-band antennas and the C-band side of
     the Sea Tel model 9711 QOR antennas.

     See the Intellian and ASTRIUM Intellian declarations and Exhibits 5, 6 and 7 for
     the Intellian model v240 C-band antennas.

     All of the ESV antennas listed above use transmitters that have off-axis EIRP
     spectral densities less than or equal to the levels in paragraph 25.221(a)(1)(i) and
     meet the requirements of 25.221 (a)(1)(i)(A-C) with an N value of 1. The
     referenced exhibits provide the detailed demonstration described in paragraph
     25.221 (b)(1). The Sea Tel declaration also contains the certification that the
     antennas comply with the pointing requirement in paragraph 25.221 (a)(1)(ii)(A)
     and the cessation of emission requirement in paragraph 25.221 (a)(1)(iii)(A).

  (a) (2) Not Applicable

     (a) (3) Comply. The ASTRIUM ESV Compliance Officer has authority and
     ability to cease all emissions from ESVs through the facilities of ASTRIUM
     teleports or through facilities of non-ASTRIUM teleports used to uplink
     ASTRIUM operated ESVs pursuant to telehousing arrangements. This point of
     contact is available 24 hours a day, seven days a week via the ASTRIUM
     Southbury, CT teleport at 203-262-5010.

  (a) (4) Comply. These records are being collected and maintained as specified.
      Requests to make this data available may be directed to the ASTRIUM ESV
      Compliance Officer via the Southbury teleport at 203-262-5010.

  (a) (5) Comply.

  (a) (6) Comply. The ESVs are controlled through Astrium teleports located in the
      United States or non-ASTRIUM teleports located in the United States used to
      uplink ASTRIUM operated ESVs pursuant to telehousing arrangements.

  (a) (7) Comply.

  (a) (8) Comply.

  (a) (9) Comply. ASTRIUM is not seeking protection for docked ESVs at this time.
      In the event that ASTRIUM finds it necessary to do so in the future, it will be
      accomplished in accordance with the terms of this §25.221 (a) (9).

  (a) (10) Agree.


Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222

  (a) (11) Comply. The C-band ESVs which are the subject of this application will not
      operate within 200 Km of the U.S. coastline or fixed service offshore facilities
      unless prior coordination has been completed. It is noted that numerous C-band
      ESV interference studies and frequency coordinations have been completed for
      ASTRIUM by Comsearch and Skjei Telecom and Notifications Concerning
      Completion of the Coordinations were filed with the Commission (under the
      WB36 and KA249 licenses) as specified in the Commission’s Public Notice DA
      05-1671, Released: June 15, 2005 and the Notifications placed on Public Notice.
      Other coordinations may be completed as-needed and if so, Notifications for same
      will be filed with the Commission for Public Notice as they are completed.

  (a) (12) Comply. Vizada has developed and deployed hardware and software which
      continuously monitors the location of each ESV and its operating frequency;
      compares this information with data containing mapping coordinates for areas in
      which ESV operation is (and is not) permitted and coordination information and
      terms for same; and which will automatically cease the transmissions of the ESV
      if it is in an area for which coordination is required and operation would be in
      violation of the terms of coordination.

  (b) (1) Comply. The tables described in 25.221(b)(1)(i) are attached as the following
      exhibits:

     Exhibits 2, 3 and 4 for the Sea Tel model 9707, 9797 and 9711 C-band antennas
     and the C-band side of the 9711 QOR antennas;

     Exhibits 5, 6 and 7 for the Intellian model v240 C-band Antennas.

     The value N described in 25.221(a)(1)(i)(A) is 1. Exhibits 2 and 5 provide the
     detailed demonstration described in paragraph 25.221(b)(1)(i)(A). Exhibits 3 and
     6 provide the detailed demonstration described in paragraph 25.221(b)(1)(i)(B).
     Exhibits 4 and 7 provide the detailed demonstration described in paragraph
     25.221(b)(1)(i)(C). The certifications from the equipment manufacturers stating
     that the tracking systems meet the pointing and cessation of emission
     requirements of 25.221(b)(1)(iii) are contained in the Sea Tel and Intellian
     declarations.

  (b) (2) Not Applicable.

  (b) (3) Comply. See SES-4 and NSS-9 maps in the Operations Areas Exhibit.

  (b) (4) Comply. The ASTRIUM ESV Compliance Officer has authority and ability to
      cease all emissions from ESVs through the facilities of ASTRIUM teleports or
      through facilities of non-ASTRIUM teleports used to uplink ASTRIUM operated
      ESVs pursuant to telehousing arrangements. This point of contact is available 24
      hours a day, seven days a week via the ASTRIUM Southbury, CT teleport at 203-
      262-5010.


Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222

    (b) (5) Comply. See the Radiation Hazard Report Exhibits.

Section 25.222

   (a) (1) Comply.

       See the Sea Tel and ASTRIUM SeaTel declarations and Exhibits 8, 9, and 10 for
       the Ku-band side of the Sea Tel model 9711 QOR antennas.

       See the Intellian and ASTRIUM Intellian declarations and Exhibits 11, 12 and 13
       for the Intellian model v100 Ku-band antennas.

       See the Intellian and ASTRIUM Intellian declarations and Exhibits 14, 15 and 16
       for the Intellian model v130 Ku-band Antennas.

       See the Mitsubishi and ASTRIUM Mitsubishi declarations and Exhibits 17, 18,
       and 19 for the Mitsubishi model MVA60 Ku-band antennas.

       See the Mitsubishi and ASTRIUM Mitsubishi declarations and Exhibits 20, 21,
       and 22 for the Mitsubishi model MVA120 Ku-band antennas.

       All of the ESV antennas listed above use transmitters that have off-axis EIRP
       spectral densities less than or equal to the levels in paragraph 25.222(a)(1)(i) and
       meet the requirements of 25.222 (a)(1)(i)(A-C) with an N value of 1. The
       referenced exhibits provide the detailed demonstration described in paragraph
       25.222 (b)(1). The Intellian, Mitsubishi and Sea Tel declarations also contain the
       certifications that the antennas comply with the pointing requirement in paragraph
       25.222 (a)(1)(ii)(A) and the cessation of emission requirement in paragraph
       25.222 (a)(1)(iii)(A).

   (a) (2) Not Applicable

   (a) (3) Comply. The ASTRIUM ESV Compliance Officer has authority and ability to
        cease all emissions from ESVs through the facilities of ASTRIUM teleports or
        through facilities of non-ASTRIUM teleports used to uplink ASTRIUM operated
        ESVs pursuant to telehousing arrangements. This point of contact is available 24
        hours a day, seven days a week via the ASTRIUM Southbury, CT teleport at
        203-262-5010.

   (a) (4) Comply. These records are being collected and maintained as specified.
        Requests to make this data available may be directed to the ASTRIUM ESV
        Compliance Officer via the Southbury teleport at 203-262-5010.

   (a) (5) Comply.


Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222

  (a) (6) Comply. The ESVs are controlled by the Hub earth station located at
      ASTRIUM’s Southbury Teleport.

  (a) (7) Comply.

  (b)(1) Comply. The tables described in 25.221(b)(1)(i) are attached as the following
      exhibits:

     Exhibits 8, 9, and 10 for the Ku-band side of the Sea Tel model 9711 QOR
     antennas.

     Exhibits 11, 12 and 13 for the Intellian model v100 Ku-band antennas.

     Exhibits 14, 15 and 16 for the Intellian model v130 Ku-band Antennas.

     Exhibits 17, 18, and 19 for the Mitsubishi model MVA60 Ku-band antennas.

     Exhibits 20, 21, and 22 for the Mitsubishi model MVA120 Ku-band antennas.

     The value N described in 25.222(a)(1)(i)(A) is 1. Exhibits 8, 11, 14, 17 and 20
     provide the detailed demonstration described in paragraph 25.222(b)(1)(i)(A).
     Exhibits 9, 12, 15, 18 and 21 provide the detailed demonstration described in
     paragraph 25.222(b)(1)(i)(B). Exhibits 10, 13, 16, 19 and 22 provide the detailed
     demonstration described in paragraph 25.222(b)(1)(i)(C). The certifications from
     the equipment manufacturer stating that the tracking systems meet the pointing
     and cessation of emission requirements of 25.222(b)(1)(iii) are contained in the
     Intellian, Mitsubishi and Sea Tel declarations.

  (b) (2) Not Applicable.

  (b) (3) Comply. See Operations Areas Exhibit.

  (b) (4) Comply. The ASTRIUM ESV Compliance Officer has authority and ability to
      cease all emissions from ESVs through the facilities of ASTRIUM teleports or
      through facilities of non-ASTRIUM teleports used to uplink ASTRIUM operated
      ESVs pursuant to telehousing arrangements. This point of contact is available 24
      hours a day, seven days a week via the ASTRIUM Southbury, CT teleport at 203-
      262-5010.

  (b) (5) Comply. See the Radiation Hazard Report Exhibits.
      .
  (c) Comply. ASTRIUM has completed coordination with NASA for ESV
      operations in the 14.0 – 14.2 GHz frequency band within 125 km of NASA
      TDRSS facilities protected per 24.222 (c). The coordination has been filed with
      the Commission for completion of the coordination process. Until the
      coordination process is completed ASTRIUM will continue to comply with


Exhibit 1 - Showing of Compliance with Sections 25.221 and 25.222

     25.222 (c) by not operating Ku-band ESVs at all in the 14.47 – 14.5 GHz
     frequency band within the specified distances of the protected facilities.

  (d) Comply. ASTRIUM does not operate any ESVs in the 14.47 – 14.5 GHz
      frequency band.



Document Created: 2013-05-02 21:06:46
Document Modified: 2013-05-02 21:06:46

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