Attachment Tech Appendix III

This document pretains to SES-MFS-20161003-00823 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2016100300823_1152764

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HR129 EIRP Co—pol PSD Against 25.227 Mask 10 7 ~Az E—Plane 14.0 ~—— Az E—Plane 14.25 ~—— Az E—Plane 14.5 ~——Az H—Plane 14.0 s q0 + ~——Az H—Plane 14.25 § ~——Az H—Plane 14.5 Bs + ~—— El E—Plane 14.0 &5 El E—Plane 14.25 —20 ~ El E—Plane 14.5 ~~ El H—Planel 14.0 25 + ~ El H—Plane 14.25 ~~ El H—Plane 14.5 30 7 ~25.227 (a)(1)(i}(A) GEO Arc ==25.227 (a)(1)(i}(A) Sidelobe Mask 35 ~25.227 (a)(1)(I}B) All Other Directions —40 * —180 —160 —140 —120 —100 —80 —60 40 —20 0 20 40 60 80 100 120 140 160 180 Angle (degrees) HR129 EIRP PSD Against 25.227 Mask 10 5 Plot Area aE—Plane ——Az E—Pl 14.0 ——Az E—Plane 14.25 o ——Az E—Plane 14.5 ——Az H—Plane 14.0 ——Az H—Plane 14.25 —5 ——Az H—Plane 14.5 z —— El E—Plane 14.0 3 —10 ; —— El E—Plane 14.25 5 —— El E—Plane 14.5 a. 45 & —— El H—Planel 14.0 i —— El H—Plane 14.25 —20 El H—Plane 14.5 ~———AzE 14.0 xp 25 ——AzE 14.25 xp ~——AzE 14.5 xp «#0 ——aAzH 14.0xp ~——AzH 14.25xp 35 ——AzH 14.5xp ~——El £14.0 xp ~40 ——El E1425xp —180 —160 —140 —120 —100 —80 —60 —40 —20 0 20 40 60 B0 100 120 140 160 180 Angle (degrees)

—— Az—Cut E—Plane 14.25 GHz ~ Az—Cut H—Plane 14.25 GHz El—CutE—Plane 14.25 GHz El—Cut H—Plane 14.25 GHz 20 39 Leorbernnbronebronehoondhborndhbernhernnhronnbrannhranet borolonheanheraokeed 400 00 80 Of 600060 4004 2 P 00 q o2 30 40 §%0 60 7 o8 90 10 Angle (degrees) HR129 Antenna Gain Measure at Power Amplifier Output 30 20 6 ——Az—Cut E—Plane 14.0 GHz 10 —— Az—Cut E—Plane 14.25 GHz ——Az—Cut E—Plane 14.5 GHz 3 / ——Az—Cut H—Plane 14.0 GHz o s ——Az—Cut H—Plane 14.25 GHz s o o / ——Az—Cut H—Plane 14.5 GHz —— El—Cut E—Plane 14.0 GHz ——El—Cut E—Plane 14.25 GHz 10 ——El—Cut E—Plane 14.5 GHz ——El—Cut H—Plane 14.0 GHz ——El—Cut H—Plane 14.25 GHz —20 —— El—Cut H—Plane 14.5 GHz —30 41000 80 P 6050 400B 2 P 00 1 2 30 40 50 60 7 o8 90 10 Angle (degrees)

_HR129 Antenna Gain Measure at Power Amplifier Output 30 20 —— Az—Cut E—Plane 14.25 GHz 0 =— Az—Cut H—Plane 14.25 GHz El—Cut E—Plane 14.25 GHz E1—Cut H—Plane 14.25 GHz —10 20 44 30 + —180 —160 —140 —120 —100 —80 .60 40 —20 0 20 40 60 80 100 120 140 160 180 Angle (degrees) HR129 Antenna Gain Measure at Power Amplifier Output 30 20 ——Az—Cut E—Plane 14.0 GHz ——Az—Cut E—Plane 14.25 GHz 10 ——Az—Cut E—Plane 14.5 GHz —— Az—Cut H—Plane 14.0 GHz Gain (dBi) r\ ——Az—Cut H—Plane 14.25 GHz ° —— Az—Cut H—Plane 14.5 GHz —— El—Cut E—Plane 14.0 GHz A ——El—Cut E—Plane 14.25 GHz a0 \4.’!'“.{ J"ll ——El—Cut E—Plane 14.5 GHz l ‘ '\'; iw \ ——El—Cut H—Plane 14.0 GHz fi‘\ l|| \ ——El—Cut H—Plane 14.25 GHz 20 x/ \\/ —— El—Cut H—Plane 14.5 GHz —30 —180 —160 —140 —120 —100 —80 —60 —40 —20 0 20 40 60 80 100 120 140 160 180 Angle (degrees)

IV. FCC RF Hazard Compliance Analysis In connection with a license application by Astronics AeroSat, Inc. for operation of a 0.29 Meter Ku-band aircraft remote antenna, the following assessment is provided of compliance with the FCC limits for maximum permissible exposure (MPE) to RF fields. Based on the mathematical analyses described herein, the potential RF exposure levels in the areas of possible interest for antenna operation can be considered in compliance with the applicable FCC limits for controlled or occupational exposure (access to the earth station antenna is restricted to trained personnel) and for protection of the general population. The proposed operation is therefore in compliance with the FCC regulations and exposure limits. The sections that follow provide the analysis and conclusions regarding compliance. 1 Operational Data The relevant data for the subject operation is summarized as follows: Transmitting Frequency Band: 14.0 – 14.5 GHz Antenna Manufacturer / Model: Astronics Aerosat / HR 129 Antenna Type: Fresnel Lens Antenna Dimension: 0.29 meters (diameter) (11.4 inches) Antenna Efficiency: 70 % Net Power Input to Antenna (at 7.6 Watts flange): Antenna Height AGL: 7.5 meters (24.6 feet) 2 Applicable MPE Limits The MPE limits are described in the FCC Rules and Regulations. For the frequency range of interest here, the applicable limit for acceptable, continuous exposure of the general population is 1.0 milliwatt per square centimeter (mW/cm2), and for “controlled” occupational exposure, it is 5.0 mW/cm2. As is the case for all antennas in the Astronics AeroSat aircraft network, access to the antenna is restricted to trained personnel, and thus the latter limit is generally applicable. However, it is possible that untrained members of the general population could be within certain distances from the aircraft. Therefore, the MPE limit for the general population has also been examined. 3 FCC Formulas and Calculations FCC Bulletin OET 65 provides standardized formulas for calculating the power density in the areas of interest here. Using the formulas from Bulletin OET 65, we report the exposure levels (1) directly in front of the antenna, (2) in the main beam at the transition from near to far field, and (3) farther away but still in the main beam where the MPE limit is met for both controlled and general population exposure; and (4) to the side of the antenna. Each area of interest will be addressed below and the results of the calculations are given.

3.1 Potential exposure level directly in front of the antenna The worst-case possible exposure occurs right at the surface (aperture) of the antenna. According to Bulletin OET 65, the applicable formula for power density, S, at the antenna surface is as follows: S = 4* P/ A Where:P represents the antenna input power; and, A is the surface area of the antenna. In this case, with 7.6 Watts antenna of input power at the flange, an antenna diameter of 0.29 m (11.4 inches), the power density at the antenna surface is 46.25 mW/cm2, which exceeds the 5.0 mW/cm2 MPE limit for controlled access. However, there is no way to approach this close to the antenna when the aircraft is in flight. Furthermore, the antenna will be switched off completely (i.e. unpowered) when a technician needs to perform work in this area (which is more than 24 feet above ground level). Standard RF safety procedures will be applied and the power to the antenna will be removed during the period of the work. The formula for near-field, on-axis power density, directly in front of the antenna is as follows: S = 16 *  * P / (pi * D²) Where: P represents the antenna input power  represents the antenna illumination efficiency; and, D is the antenna diameter. In this case, when we apply an illumination efficiency of 70 %, the result of the calculation is 32.56 mW/cm2, which exceeds the occupational MPE limit. This is the exposure level directly in front of the antenna at a distance of 1 m. For the reasons stated above, there is no way for a technician or the general public to approach this close to the antenna while it is transmitting. We can calculate the distance at which the antenna emissions would meet the MPE limits for controlled access and for the general population using the following formula: R MPE = (G * P) / (4 * pi * MPE) Where: G represents the Gain of the antenna; P represents the antenna input power: and, MPE represents the maximum permissible exposure limit. The results of the analysis show that the MPE for controlled access are met at 4.0 m (13 feet) directly in front of the antenna. The MPE for the general population is met at 8.9 m (29 feet) directly in front of the antenna. The results of this calculation are also used in the analysis of potential exposure to the immediate side of the antenna, which is addressed in the subsection that follows.

3.2 Potential exposure level to the side of the antenna The near-field power density drops off dramatically outside the imaginary cylinder extending from the surface along the axis of the main beam of an aperture antenna. According to Bulletin OET 65, if the point of interest is at least one antenna diameter removed from the center of the main beam, the power density at that point would be at least a factor of 100 lower (20 dB) than the value calculated for the equivalent distance in the main beam. In this particular case, the antenna is mounted 7.5 m (29 feet) above the ground. Therefore, the closest that ground personnel and passengers could approach an operational antenna would be at the very least 26 antenna diameters below the main beam. The previous calculation of the power density immediately in the near field in front of the antenna) resulted in a value of 32.56 mW/cm2, Using the analysis provided in Bulletin OET 65, standing more than 26 antenna diameters off axis would decrease the exposure level by at least 34 dB to where the power density on the ground below the tail mounted antenna was less than 2.5 % of the MPE for the general population. It is highly unlikely that the general population would ever be permitted to approach the tail of an operational aircraft that closely. Even so, the exposure level at that distance complies with the MPE requirements. At any greater distance (such as boarding the aircraft), the exposure level would be lower still. 4 Compliance Conclusion Astronics AeroSat will observe standard safety precautions with respect to operations and maintenance of the HR129 antenna, including powering the antenna off in advance of maintenance activities. In addition, given the location of the antenna on the top of the T-tail of business jets, there is no possibility that members of the general public will be located in regions where MPE values may be exceeded. Based on the result of the analysis with regard to the potential exposure levels in all respects – directly in front of the antenna, to the side of the antenna, and at ground level – and taking into account the access restrictions for both trained and un-trained persons and standard safety procedures, we conclude that the operation of the Astronics AeroSat 0.29 meter Ku-band antenna as a tail-mounted aircraft antenna satisfies the MPE compliance requirements in the FCC regulations. Report prepared by Dr. Robert Hanson LMI Advisors, LLC

V. FCC §25.227 Compliance Matrix Rule Text Application Citation § 25.227 § 25.227 Blanket licensing provisions for ESAAs operating with GSO FSS space stations in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz, and 14.0-14.5 GHz bands. § 25.227(a) (a) The following ongoing requirements govern all ESAA licensees and operations in the 10.95-11.2 GHz See File Nos. SES-LIC- (space-to-Earth), 11.45-11.7 GHz (space-to-Earth), 11.7-12.2 GHz (space-to-Earth) and 14.0-14.5 GHz 20140902-00688 & (Earth-to-space) frequency bands receiving from and transmitting to geostationary orbit satellites in the Fixed - SES-AMD-20141117- Satellite Service. ESAA licensees shall comply with the requirements in either paragraph (a)(1), (a)(2) or 00858 (prior grant for (a)(3) of this section and all of the requirements set forth in paragraphs (a)(4)-(a)(16) and paragraphs (c), (d), HR6400 Ku-band and (e) of this section. Paragraph (b) of this section identifies items that shall be included in the application for terminal); Technical ESAA operations to demonstrate that these ongoing requirements will be met. Appendix. § 25.227(a)(1) (1) The following requirements shall apply to an ESAA that uses transmitters with off-axis EIRP spectral- N/A. Authority densities lower than or equal to the levels in paragraph (a)(1)(i) of this subsection. ESAA licensees operating requested under under this subsection shall provide a detailed demonstration as described in paragraph (b)(1) of this section. § 25.227(a)(2) (satellite The ESAA transmitter also shall comply with the antenna pointing and cessation of emission requirements in operator certification). paragraphs (a)(1)(ii) and (a)(1)(iii) of this subsection. § 25.227(a)(1)(i) (i) An ESAA licensee shall not exceed the off-axis EIRP spectral-density limits and conditions defined in Id. paragraphs (a)(1)(A)-(D) of this subsection.

§ 25.227(a)(1)(i)(A) (A) The off-axis EIRP spectral-density for co-polarized signals emitted from the ESAA, in the plane of the Id. geostationary satellite orbit (GSO) as it appears at the particular earth station location, shall not exceed the following values: 15 - 25 log10θ dBW/4 kHz For 1.5° ≤ θ ≤ 7° -6 dBW/4 kHz For 7° < θ ≤ 9.2° 18 - 25 log10θ dBW/4 kHz For 9.2° < θ ≤ 19.1° -14 dBW/4 kHz For 19.1° < θ ≤ 180° where theta (θ) is the angle in degrees from the line connecting the focal point of the antenna to the orbital location of the target satellite in the plane of the GSO. The plane of the GSO is determined by the focal point of the antenna and the line tangent to the arc of the GSO at the orbital location of the target satellite. For ESAA networks using frequency division multiple access (FDMA) or time division multiple access (TDMA) techniques, N is equal to one. For ESAA networks using multiple co -frequency transmitters that have the same EIRP density, N is the maximum expected number of co-frequency simultaneously transmitting ESV earth stations in the same satellite receiving beam. For the purpose of this subsection, the peak EIRP density of an individual sidelobe shall not exceed the envelope defined above for θ between 1.5° and 7.0°. For θ greater than 7.0°, the envelope shall be exceeded by no more than 10% of the sidelobes, provided no individual sidelobe exceeds the envelope given above by more than 3 dB. § 25.227(a)(1)(i)(B) (B) In all directions other than along the GSO, the off-axis EIRP spectral-density for co-polarized signals Id. emitted from the ESAA shall not exceed the following values: 18 - 25log log10θ dBW/4 kHz For 3.0° ≤ θ ≤ 19.1° -14 dBW/4 kHz For 19.1 < θ ≤ 180° where θ and N are defined in (a)(1)(i)(A). This off-axis EIRP spectral-density applies in any plane that includes the line connecting the focal point of the antenna to the orbital location of the target satellite with the exception of the plane of the GSO as defined in paragraph (a)(1)(i)(A) of this section. For the purpose of this subsection, the envelope shall be exceeded by no more than 10% of the sidelobes provided no individual sidelobe exceeds the EIRP density envelope given above by more than 6 dB. The region of the main reflector spillover energy is to be interpreted as a single lobe and shall not exceed the envelope by more than 6 dB. 2

§ 25.227(a)(1)(i)(C) (C) The off-axis EIRP spectral-density for cross-polarized signals emitted from the ESAA shall not exceed the Id. following values: In the plane of the geostationary satellite orbit as it appears at the particular earth station location: 5 - 25log10θ dBW/4kHz For 1.8° < θ ≤ 7° where θ and N are defined in (a)(1)(i)(A). § 25.227(a)(1)(ii) (ii) Each ESAA transmitter shall meet one of the following antenna pointing requirements: Id. (ESAAs comply) (A) Each ESAA transmitter shall maintain a pointing error of less than or equal to 0.2° between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna; or (B) Each ESAA transmitter shall declare a maximu m antenna pointing error that may be greater than 0.2° provided that the ESAA does not exceed the off-axis EIRP spectral-density limits in paragraph (a)(1)(i) of this section, taking into account the antenna pointing error. § 25.227(a)(1)(iii) (iii) Each ESAA transmitter shall meet one of the following cessation of emission requirements: Id. (A) For ESAAs operating under paragraph (a)(1)(ii)(A) of this section, all emissions from the ESAA shall automatically cease within 100 milliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna exceeds 0.5°, and transmission shall not resume until such angle is less than or equal to 0.2°, or (B) For ESAA transmitters operating under paragraph (a)(1)(ii)(B) of this section, all emissions from the ESAA shall automatically cease within 100 milliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna exceeds the declared maximu m ant enna pointing error and shall not resume transmissions until such angle is less than or equal to the declared maximu m antenna pointing error. 3

25.227(a)(2) (2) The following requirements shall apply to an ESAA, or ESAA system, that uses off-axis EIRP spectral- Astronics AeroSat densities in excess of the levels in paragraph (a)(1)(i) of this section. An ESAA, or ESAA network, operating complies, see Technical under this subsection shall file certifications and provide a detailed demonstration as described in paragraph Appendix; see also (b)(2) of this section. Section 25.227(b)(2). (i) The ESAA shall transmit only to the target satellite system(s) referred to in the certifications required by paragraph (b)(2) of this section. (ii) If a good faith agreement cannot be reached between the target satellite operator and the operator of a future satellite that is located within 6 degrees longitude of the target satellite, the ESAA operator shall accept the power-density levels that would accommodate that adjacent satellite. (iii) The ESAA shall operate in accordance with the off-axis EIRP spectral-densities that the ESAA supplied to the target satellite operator in order to obtain the certifications listed in paragraph (b)(2) of this section. The ESAA shall automatically cease emissions within 100 milliseconds if the ESAA transmitter exceeds the off- axis EIRP spectral-densities supplied to the target satellite operator and transmission shall not resume until ESAA conforms to the off-axis EIRP spectral densities supplied to the target satellite operator. (iv) In the event that a coordination agreement discussed in paragraph (b)(2)(ii) of this section is reached, but that coordination agreement does not address protection from interference for the ea rth station, that earth station will be protected from interference to the same extent that an earth station that meets the requirements of §25.209 of this title would be protected from interference. § 25.227(a)(3)(i) (3) The following requirements shall apply to an ESAA system that uses variable power-density control of N/A individual simultaneously transmitting co-frequency ESAA earth stations in the same satellite receiving beam. An ESAA system operating under this subsection shall provide a detailed demonstration as described in paragraph (b)(3) of this section. (i) The effective aggregate EIRP density from all terminals shall be at least 1 dB below the off-axis EIRP density limits defined in paragraph (a)(1)(i)(A)-(C), with the value of N=1. In this context the term “effective” means that the resultant co-polarized and cross-polarized EIRP density experienced by any GSO or non-GSO satellite shall not exceed that produced by a single transmitter operating 1 dB below the limits defined in paragraph (a)(1)(i)(A)-(C). The individual ESAA transmitter shall automatically cease emissions within 100 milliseconds if the ESAA transmitter exceeds the off-axis EIRP density limits minus 1 dB specified above. If one or more ESAA transmitters causes the aggregate off-axis EIRP-densities to exceed the off-axis EIRP density limits minus 1dB specified above, then the transmitter or transmitters shall cease or reduce emissions within 100 milliseconds of receiving a command from the system's network control and monitoring center. An ESAA system operating under this subsection shall provide a detailed demonstration as described in paragraph (b)(3)(i) of this section. 4

§ 25.227(a)(3)(ii) (ii) The following requirements shall apply to an ESAA that uses off-axis EIRP spectral-densities in excess of Id. the levels in paragraph (a)(3)(i) of this section. An ESAA system operating under this subsection shall file certifications and provide a detailed demonstration as described in paragraphs (b)(3)(ii) and (b)(3)(iii) of this section. (A) If a good faith agreement cannot be reached between the target satellite operator and the operator of a future satellite that is located within 6 degrees longitude of the target satellite, the ESAA shall operate at an EIRP density defined in (a)(3)(i) of this section. (B) The ESAA shall operate in accordance with the off-axis EIRP spectral-densities that the ESAA supplied to the target satellite operator in order to obtain the certifications listed in paragraph (b)(3)(ii) of this section. The individual ESAA terminals shall automatically cease emissions within 100 milliseconds if the ESAA transmitter exceeds the off-axis EIRP spectral-densities supplied to the target satellite operator. The overall system shall be capable of shutting off an individual transmitter or the entire system if the aggregate off-axis EIRP spectral-densities exceed those supplied to the target satellite operator. (C) The ESAA shall transmit only to the target satellite system(s) referred to in the certifications required by paragraph (b)(3) of this section. § 25.227(a)(4) (4) An applicant filing to operate an ESAA terminal or system and planning to use a contention protocol shall Id. certify that its contention protocol use will be reasonable. § 25.227(a)(5) (5) There shall be a point of contact in the United States, with phone number and address, available 24 hours a See Technical day, seven days a week, with authority and ability to cease all emissions from the ESAA. Appendix, I. § 25.227(a)(6) (6) For each ESAA transmitter, a record of the vehicle location (i.e., latitude/longitude/altitude), transmit See Technical frequency, channel bandwidth and satellite used shall be time annotated and maintained for a period of not less Appendix, V. than one year. Records shall be recorded at time intervals no greater than one (1) minute while the ESAA is transmitting. The ESAA operator shall make this data available, in the form of a comma delimited electronic spreadsheet, within 24 hours of a request from the Commission, NTIA, or a frequency coordinator for purposes of resolving harmful interference events. A description of the unit s (i.e., degrees, minutes, MHz . . .) in which the records values are recorded will be supplied along with the records. § 25.227(a)(7) (7) In the 10.95-11.2 GHz (space-to-Earth) and 11.45-11.7 GHz (space-to-Earth) frequency bands ESAAs Applicable regulatory shall not claim protection from interference from any authorized terrestrial stations to which frequencies are status and protection either already assigned, or may be assigned in the future. provisions. Astronics AeroSat complies. § 25.227(a)(8) (8) An ESAA terminal receiving in the 11.7-12.2 GHz (space-to-Earth) bands shall receive protection from Applicable regulatory interference caused by space stations other than the target space station only to the degree to which harmful status and protection interference would not be expected to be caused to an earth station employing an antenna conforming to the provisions. Astronics referenced patterns defined in paragraphs (a) and (b) of section 25.209 and stationary at the location at which AeroSat complies. any interference occurred. § 25.227(a)(9) (9) Each ESAA terminal shall automatically cease transmitting within 100 milliseconds upon loss of reception See Technical of the satellite downlink signal or when it detects that unintended satellite tracking has happe ned or is about to Appendix, V. happen. 5

§ 25.227(a)(10) (10) Each ESAA terminal should be subject to the monitoring and control by an NCMC or equivalent facility. Id. Each terminal must be able to receive at least “enable transmission” and “disable transmission” commands from the NCMC and must automatically cease transmissions immediately on receiving any “parameter change command”, which may cause harmful interference during the change, until it receives an “enable transmission” command from its NCMC. In addition, the NCMC must be able to monitor the operation of a n ESAA terminal to determine if it is malfunctioning. § 25.227(a)(11) (11) Each ESAA terminal shall be self-monitoring and, should a fault which can cause harmful interference to Id. FSS networks be detected, the terminal must automatically cease transmissions. § 25.227(a)(12) (12) Unless otherwise stated all ESAA system that comply with the off-axis EIRP spectral-density limits in Applicant does not seek (a)(1)(i) may request ALSAT authority. Permitted List authority at this time. § 25.227(a)(13) (13) ESAA providers operating in the international airspace within line-of-sight of the territory of a foreign See File No. SES-LIC- administration where fixed service networks have primary allocation in this band, the maximu m power flux 20140902-00688, density (pfd) produced at the surface of the Earth by emissions from a single aircraft carrying an ESAA Narrative and Technical terminal should not exceed the following values unless the foreign Administration has imposed other Appendix. conditions for protecting its fixed service stations: -132+0.5 · θ dB(W/(m2 · MHz)) For θ ≤ 40° -112 dB(W/(m2 · MHz)) For 40° < θ ≤ 90° Where: θ is the angle of arrival of the radio-frequency wave (degrees above the horizontal) and the aforementioned limits relate to the pfd and angles of arrival would be obtained under free -space propagation conditions. § 25.227(a)(14) (14) All ESAA terminals operated in U.S. airspace, whether on U.S.-registered civil aircraft or non-U.S.- Id. registered civil aircraft, must be licensed by the Commission. All ESAA terminals on U.S.-registered civil aircraft operating outside of U.S. airspace must be licensed by the Commission, except as provided by Section 303(t) of the Communications Act. § 25.227(a)(15) (15) For ESAA systems operating over international waters, ESAA operators will certify that their target space See Technical station operators have confirmed that proposed ESAA operations are within coordinated parameters for Appendix, V. adjacent satellites up to 6 degrees away on the geostationary arc. § 25.227(a)(16) (16) Prior to operations within the foreign nation’s airspace, the ESAA operator will ascertain whether the Astronics AeroSat relevant administration has operations that could be affected by ESAA terminals, and will determine whether complies (no specific that administration has adopted specific requirements concerning ESAA operations. When the aircraft enters certification required). foreign airspace, the ESAA terminal would be required to operate under the Commission’s rules, or those of the foreign administration, whichever is more constraining. To the extent that all relevant administrations have identified geographic areas from which ESAA operations would not affect their radio operations, ESAA operators would be free to operate within those identified areas without further action. To the extent that the foreign administration has not adopted requirements regarding ESAA operations, ESAA operators would be required to coordinate their operations with any potentially affected operations. § 25.227(b) (b) Applications for ESAA operation in the 14.0-14.5 GHz (Earth-to-space) band to GSO satellites in the See File Nos. SES-LIC- 6

Fixed-Satellite Service shall include, in addition to the particulars of operation identified on Form 312, and 20140902-00688 & associated Schedule B, the applicable technical demonstrations in paragraphs (b)(1), (b)(2) or (b)(3) and the SES-AMD-20141117- documentation identified in paragraphs (b)(4) through (b)(8) of this section. 00858 (prior grant for HR6400 Ku-band terminal); Technical Appendix. § 25.227(b)(1) (1) Applications for ESAA operation in the 14.0-14.5 GHz (Earth-to-space) band to GSO satellites in N/A the FSS shall include, in addition to the particulars of operation identified on FCC Form 312, and associated Schedule B, the applicable technical demonstrations in paragraphs (b)(1), (b)(2), or (b)(3), and the documentation identified in paragraphs (b)(4) through (b)(8) of this section. § 25.227(b)(1)(i) Id. Reserved. § 25.227(b)(1)(ii) Reserved. N/A 7

§ 25.227(b)(1)(iii) (iii) An ESAA applicant proposing to implement a transmitter under paragraphs (a)(1)(ii)(A) of this section Id. shall: (A) demonstrate that the total tracking error budget of their antenna is within 0.2º or less between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna. As part of the engineering analysis, the ESAA applicant must show that the antenna pointing error is within three sigma (б) from the mean value, i.e., that there is a 0.997 probability the antenna maintains a pointing error within 0.2º; and (B) demonstrate that the antenna tracking system is capable of ceasing emissions within 100 milliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna exceeds 0.5°. § 25.227(b)(1)(iv) (iv) An ESAA applicant proposing to implement a transmitter under paragraph (a)(1)(ii)(B) of this section Id. shall: (A) declare, in its application, a maximu m antenna pointing error and demonstrate that the maximu m antenna pointing error can be achieved without exceeding the off-axis EIRP spectral-density limits in paragraph (a)(1)(i) of this section; and (B) demonstrate that the ESAA transmitter can detect if the transmitter exceeds the declared maximu m antenna pointing error and can cease transmission within 100 milliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna exceeds the declared maximu m antenna pointing error, and will not resume transmissions until the angle between the orbital location of the target satellite and the axis of the main lobe of the ESAA antenna is less than or equal to the declared maximu m antenna pointing error. § 25.227(b)(2) (2) An ESAA applicant proposing to operate with off-axis EIRP density in excess of the levels in See Technical paragraph (a)(1)(i) or (a)(3)(i) of this section must provide the following in exhibits to its earth station Appendix, II. application: (i) off-axis EIRP density data pursuant to §25.115(g)(1); (ii) the certifications required by §25.220(d); and (iii) a detailed showing that each ESAA transmitter in the system will automatically cease or reduce emissions within 100 milliseconds after generating EIRP density exceeding specifications provided to the target satellite operator; and (iv) a detailed showing that the aggregate power density from simultaneously transmitting ESAA transmitters will be monitored at the system’s network control and monitoring center; that if simultaneous operation of two or more ESAA transmitters causes the aggregate off-axis EIRP density to exceed the off-axis EIRP density specifications supplied to the target satellite operator, the network control and monitoring center will command those transmitters to cease emissions or reduce the aggregate EIRP density to a level at or below those specifications; and that those transmitters will comply within 100 milliseconds of receiving the command. § 25.227(b)(3) N/A (3) An applicant proposing to implement an ESAA system subject to paragraph (a)(3) of this section must provide the following information in exhibits to its earth station application: 8

(i) off-axis EIRP density data pursuant to §25.115(g)(1); (ii) a detailed showing of the measures that will be employed to maintain aggregate EIRP density at or below the limit in paragraph (a)(3)(i) of this section; (iii) a detailed showing that each ESAA terminal will automatically cease or reduce emissions within 100 milliseconds after generating off-axis EIRP density exceeding the limit in paragraph (a)(3)(i) of this section; and (iv) a detailed showing that the aggregate power density from simultaneously transmitting ESAA transmitters will be monitored at the system’s network control and monitoring center; that if simultaneous operation of two or more transmitters in the ESAA network causes aggregate off-axis EIRP density to exceed the off-axis density limit in paragraph (a)(3)(i) of this section, the network control and monitoring center will command those transmitters to cease emissions or reduce the aggregate EIRP density to a level at or below that limit; and that those transmitters will comply within 100 milliseconds of receiving the command. § 25.227(b)(4) (4) There shall be an exhibit included with the application describing the geographic area(s) in which the See Technical ESAA will operate. Appendix, I. § 25.227(b)(5) (5) Any ESAA applicant filing for an ESAA terminal or system and planning to use a contention protocol shall N/A include in its application a certification that will comply with the requirements of paragraph (a)(4) of this 9

section. § 25.227(b)(6) (6) The point of contact referred to in paragraph (a)(5) of this section shall be included in the application. See Technical Appendix, I. § 25.227(b)(7) (7) Any ESAA applicant filing for an ESAA terminal or system shall include in its application a certification See Technical that will comply with the requirements of paragraph (a)(6), (a)(9), (a)(10), (a)(11) of this section. Appendix, V. § 25.227(b)(8) (8) All ESAA applicants shall submit a radio frequency hazard analysis determining via calculation, See Technical simulation, or field measurement whether ESAA terminals, or classes of terminals, will produce power Appendix, IV. densities that will exceed the Commission’s radio frequency exposure criteria. ESAA applicants with ESAA terminals that will exceed the guidelines in Section 1.1310 for radio frequency radiation exposure shall provide, with their environmental assessment, a plan for mitigation of radiation exposure to the exte nt required to meet those guidelines. All ESAA licensees shall ensure installation of ESAA terminals on aircraft by qualified installers who have an understanding of the antenna’s radiation environment and the measures best suited to maximize protection of the general public and persons operating the vehicle and equipment. An ESAA terminal exhibiting radiation exposure levels exceeding 1.0 mW/cm² in accessible areas, such as at the exterior surface of the radome, shall have a label attached to the surface o f the terminal warning about the radiation hazard and shall include thereon a diagram showing the regions around the terminal where the radiation levels could exceed 1.0 mW/cm². § 25.227(c) (c) (1) Operations of ESAAs in the 14.0-14.2 GHz (Earth-to-space) frequency band in the radio line-of- sight See File No. SES-LIC- of the NASA TDRSS facilities on Guam (latitude 13° 36' 55'' N, longitude 144° 51' 22'' E) or White Sands, 20140902-00688, New Mexico (latitude 32° 20' 59'' N, longitude 106° 36' 31'' W and latitude 32° 32' 40'' N, longitude 106° 36' Astronics AeroSat 48'' W) are subject to coordination with the National Aeronautics and Space Administration (NASA) through Corporation Section the National Telecommunications and Information Administration (NTIA) Interdepartment Radio Advisory 1.65 Letter Update on Committee (IRAC). Licensees shall notify the International Bureau once they have completed coordination. Coordination Status Upon receipt of such notification from a licensee, the International Bureau will issue a public notice stating (filed on February 2, that the licensee may commence operations within the coordination zone in 30 days if no party has opposed 2015). the operations. (2) When NTIA seeks to provide similar protection to future TDRSS sites that have been coordinated through the IRAC Frequency Assignment Subcommittee process, NTIA will notify the Commiss ion’s International Bureau that the site is nearing operational status. Upon public notice from the International Bureau, all Ku - band ESAA licensees shall cease operations in the 14.0-14.2 GHz band within radio line-of-sight of the new TDRSS site until the licensees complete coordination with NTIA/IRAC for the new TDRSS facility. Licensees shall notify the International Bureau once they have completed coordination for the new TDRSS site. Upon receipt of such notification from a licensee, the International Bureau will issue a public notice stating that the licensee may commence operations within the coordination zone in 30 days if no party has opposed the operations. The ESAA licensee then will be permitted to commence operations in the 14.0-14.2 GHz band within radio line-of-sight of the new TDRSS site, subject to any operational constraints developed in the coordination process. 10

§ 25.227(d) (d) (1) Operations of ESAA in the 14.47-14.5 GHz (Earth-to-space) frequency band in the radio line-of- sight See File No. SES-LIC- of radio astronomy service (RAS) observatories observing in the 14.47-14.5 GHz band are subject to 20140902-00688, coordination with the National Science Foundation (NSF). The appropriate NSF contact point to initiate Astronics AeroSat coordination is Electromagnetic Spectrum Manager, NSF, 4201 Wilson Blvd., Suite 1045, Arlington VA Corporation Section 22203, fax 703-292-9034, email esm@nsf.gov. Licensees shall notify the International Bureau once they have 1.65 Letter Update on completed coordination. Upon receipt of the coordination agreement from a licensee, the International Bureau Coordination Status will issue a public notice stating that the licensee may commence operations within the coordination zone in (filed on February 2, 30 days if no party has opposed the operations. 2015). (2) A list of applicable RAS sites and their locations can be found in 25.226(d)(2) Table 1. (3) When NTIA seeks to provide similar protection to future RAS sites that have been coordinated through the IRAC Frequency Assignment Subcommittee process, NTIA will notify the Commission’s International Bureau that the site is nearing operational status. Upon public notice from the International Bureau, all Ku - band ESAA licensees shall cease operations in the 14.47-14.5 GHz band within the relevant geographic zone of the new RAS site until the licensees complete coordination for the new RAS facility. Licensees shall notify the International Bureau once they have completed coordination for the new RAS site and shall submit the coordination agreement to the Commission. Upon receipt of such notification from a licensee, the International Bureau will issue a public notice stating that the licensee may commence operations within the coordination zone in 30 days if no party has opposed the operations. The ESAA licensee then will be permitted to commence operations in the 14.47-14.5 GHz band within the relevant coordination distance around the new RAS site, subject to any operational constraints developed in the coordination process. 11

VI. SECTION 25.227 CERTIFICATIONS Astronics AeroSat Corporation (“Astronics AeroSat”), pursuant to Section 25.227 of the FCC’s Rules, hereby certifies the following: 1. In accordance with Section 25.227(a)(15), as the operator of an ESAA system operating over international waters, Astronics AeroSat has confirmed with its target space station operators that its existing and proposed operations are within coordinated parameters for adjacent satellites up to six degrees away (+/- 6°) on the geostationary arc. 2. In accordance with Section 25.227(b)(7), Astronics AeroSat certifies that its existing and proposed operations comply with the following requirements of Section 25.227: Per Section 25.227(a)(6), for each ESAA transmitter, Astronics AeroSat will time annotate and maintain a record for a period of not less than one year of the vehicle location (i.e., latitude/longitude/altitude), transmit frequency, channel bandwidth and satellite used. Records will be recorded at time intervals no greater than one (1) minute while the ESAA is transmitting. Astronics AeroSat will make this data available in the requisite format within 24 hours of a request from the Commission, NTIA, or a frequency coordinator for purposes of resolving harmful interference events. Per Section 25.227(a)(9), each ESAA terminal will automatically cease transmitting within 100 milliseconds upon loss of reception of the satellite downlink signal or when it detects that unintended satellite tracking has happened or is about to happen. Per Section 25.227(a)(10), each ESAA terminal will be subject to the monitoring and control by an NCMC. Each terminal will be able to receive “enable transmission” and “disable transmission” commands from the NCMC and must automatically cease transmissions immediately on receiving any “parameter change command”, which may cause harmful interference during the change, until it receives an “enable transmission” command from its NCMC. In addition, the NCMC will be able to monitor the operation of an ESAA terminal to determine if it is malfunctioning. Per Section 25.227(a)(11), each ESAA terminal shall be self-monitoring and, should a fault which can cause harmful interference to FSS networks be detected, the terminal will automatically cease transmissions. By: s/ Frank Blanda a Frank Blanda Astronics AeroSat Corporation Chief Technical Officer October 3, 2016

VII. Technical Certification I, Frank Blanda, hereby certify that I am the technically qualified person responsible for the preparation of the technical information contained in the Astronics AeroSat blanket license application for ESAA operating authority and the accompanying Technical Appendix, that I am familiar with Part 25 of the Commission’s Rules (47 C.F.R. Part 25), and that I have either prepared or reviewed the technical information submitted in this application and found it to be complete and accurate to the best of my knowledge and belief. By: s/ Frank Blanda a Frank Blanda Astronics AeroSat Corporation Chief Technical Officer October 3, 2016


Document Created: 2016-10-03 15:46:43
Document Modified: 2016-10-03 15:46:43
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