Attachment Technical Annex

This document pretains to SES-MFS-20180911-02588 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2018091102588_1529001

                       Globecomm License Sub LLC

                              Technical Annex


A.   Technical Information to Supplement Schedule S

B.   Radiation Hazard Report for 9.3 Meter Earth Station

C.   Frequency Coordination and Interference Analysis Report

D.   FCC Letter to ANATEL


                                     ATTACHMENT A

                  Technical Information to Supplement Schedule S



1        PURPOSE AND SCOPE


The purpose of this Attachment is to provide the Commission with the technical characteristics of
the EUTELSAT 65 WEST A (“E65WA”) satellite. This attachment contains information required
by the Commission that cannot be entered into the Schedule S submission.


2        GENERAL DESCRIPTION


Eutelsat do Brasil LTDA (“Eutelsat”) operates the E65WA satellite at the nominal 65° W.L.
location. The satellite is capable of providing a wide range of FSS services using the C-, Ku- and
Ka-bands. For purposes of this application, U.S. market access is being sought only for the Ku-
bands. Accordingly, only the characteristics of the Ku-band payload are described herein and in
the associated Schedule S form.


The Ku-bands used by the satellite are the Appendix 30B Ku-bands: 12.75-13.25 GHz uplink band
and the 10.75-10.95 GHz and 11.2-11.45 GHz downlink bands. The satellite employs twenty-four
36 MHz Ku-band transponders. There are two Ku-bands beams in both the uplink and downlink
directions: the “South American” beam, which includes coverage of eastern United States, and
the Brazil beam. Twelve transponders are switchable between the South American and Brazil
beams.


3        FREQUENCY AND POLARIZATION PLAN


The E65WA satellite’s Ku-band frequency and polarization plan, including beam connectivity
options, are provided in the associated Schedule S form. The satellite provides full frequency reuse
as required by Section 25.210(f) of the Commission’s rules.



                                                 1


4       SPACE STATION TRANSMIT AND RECEIVE CAPABILITIES


The transmit and receive antenna gain contours of the satellite’s Ku-band beams are provided in
GXT format and are embedded in the associated Schedule S form.


The maximum EIRP and EIRP densities for each of the downlink beams are listed in Table 1. Also
listed are the maximum and minimum saturating flux-density (“SFD”) levels, referenced at the
beam peak, for each of the uplink beams.


Table 1. Maximum Downlink EIRP and EIRP Densities. Maximum and Minimum SFD’s.

                       Maximum         Maximum
                       Downlink        Downlink        Maximum SFD        Minimum SFD
       Beam
                         EIRP         EIRP Density      (dBW/m2)           (dBW/m2)
                        (dBW)          (dBW/Hz)
        Brazil           51.9            -23.0               -70               -92
    South America        50.4            -23.0               -70               -92


In addition, authorized uplink transmissions towards the E65WA satellite will not exceed an input
power density of -47 dBW/Hz. The E65WA satellite network will be operated in a manner
consistent with ITU coordination agreements reached by Brazil.




                                               2


5       ARRANGEMENT FOR TT&C


TT&C will not be conducted from U.S. territory. The satellite control center and primary TT&C
site is located in Brazil. The backup TT&C site is located in Portugal. Information for the satellite
control center and TT&C stations is provided below:


Satellite Control Center and Primary TT&C Station:


Avenida Valville, 450 – Sítio Tanquinho – Santana do Parnaíba
SP CEP 06532-010, Brazil
24/7 contact phone numbers: +55 11 2110-3365 / +55 11 2110-3353 / +55 11 4196-5594


Backup TT&C Station Location:


Zona Franca Industrial da Madeira – Lote 27 B/C 9200-047 Caniçal, Madeira,
Portugal



6       POWER FLUX DENSITY ANALYSIS


The Commission’s Part 25 rules do not contain PFD limits applicable to the Appendix 30B 10.7-
10.95 GHz and 11.2-11.45 GHz bands. However it is noted that Article 21 of the ITU Radio
Regulations includes PFD limits that are applicable to GSO satellites using these bands. The ITU
limits are identical to those of Section 25.208(b) of the Commission’s rules.


Tables 1 and 2 show the PFD levels that will occur at various angles of arrival for the two downlink
beams when transmitting with a maximum downlink EIRP density of -23 dBW/Hz. These two
tables demonstrate compliance with the ITU’s Article 21 PFD limits.




                                                 3


Table 2. Maximum PFD Levels of Beam SADH

               Applicable PFD                                      Worst Case PFD
              Limit for Angle of                                                       PFD Margin
Angle of                           Spreading Loss   Gain Contour   Level at Angle of
Arrival            Arrival           (dBW/m2)           (dB)           Arrival
              (dBW/m2/4 kHz)                                                              (dB)
                                                                   (dBW/m2/4 kHz)

      0°           -150.0              -163.4            -20            -170.4            20.4
      5°           -150.0              -163.3            -19            -169.3            19.3
      10°          -147.5              -163.2            -17            -167.1            19.6
      15°          -145.0              -163.0           -14.8           -164.8            19.8
      20°          -142.5              -162.9           -14.6           -164.5            22.0
      25°          -140.0              -162.8           -14.2           -164.0            24.0
     72.4°
                   -140.0              -162.1           0.0             -149.1            9.1
    (Peak)



Table 3. Maximum PFD Levels of Beams BDH and BDV

               Applicable PFD                                      Worst Case PFD
              Limit for Angle of                                                       PFD Margin
Angle of                           Spreading Loss   Gain Contour   Level at Angle of
Arrival            Arrival           (dBW/m2)           (dB)           Arrival
              (dBW/m2/4 kHz)                                                              (dB)
                                                                   (dBW/m2/4 kHz)

      0°           -150.0              -163.4           -20             -170.4            20.4
      5°           -150.0              -163.3           -19             -166.1            19.3
      10°          -147.5              -163.2           -19             -165.3            21.6
      15°          -145.0              -163.0           -18             -164.2            23.0
      20°          -142.5              -162.9           -17             -163.1            24.4
      25°          -140.0              -162.8           -16             -160.0            25.8
     66.4°
                   -140.0              -162.2           0.0             -149.2            9.2
    (Peak)




7            TWO-DEGREE COMPATIBILITY ANALYSIS


This section demonstrates that the E65WA satellite network’s operations are two-degree
compatible.


Currently there are no operational Ku-band satellites two degrees away from the nominal 65° W.L.
location using the Appendix 30B bands, nor are there any pending applications before the
Commission requesting to use the Ku-bands at a location two degrees or less from the nominal 65°
W.L. location. In order to demonstrate two-degree compatibility, the transmission parameters of
the E65WA satellite network have been used as both the wanted and interfering transmissions.


                                                    4


Table 4 provides a summary of the typical transmission parameters used by the E65WA satellite
network and which were used in the interference analysis.


Table 5 shows the results of the interference calculations in terms of the overall C/I margins. The
interference calculations assume a 1 dB advantage for topocentric-to-geocentric conversion, all
wanted and interfering carriers are co-polarized and all earth station antennas conform to a sidelobe
pattern of 29-25 log(). The C/I calculations were performed on a per Hz basis.


It can be seen that all the C/I margins are positive, thereby demonstrating the two-degree
compatibility of the E65WA satellite network.


Table 4. Typical Transmission Parameters
                                           Tx E/S         Uplink                   Rx E/S
                  Emission Bandwidth                               Downlink EIRP            C/I Criterion
Carrier ID                                  Gain           EIRP                     Gain
                 Designator  (MHz)                                    (dBW)                     (dB)
                                            (dBi)         (dBW)                     (dBi)
      1          49K0G7W      0.0486         42.4          41.0        12.3          56.5       16.5
      2          1M34G7W       1.34          53.9          59.7        30.8          47.2       16.5
      3          6M33G7W       6.33          53.9          67.1        38.2          44.7       17.7
      4          10M0G7W       10.0          57.3          70.1        40.9          44.7       16.5
      5          36M0G7W       36.0          57.3          79.1        48.9          41.1       20.5



Table 5. Summary of the overall link C/I margins (dB).
                             Interfering Carriers
             Carrier
                       1      2        3     4      5
               ID
                1      5.4   10.9   10.2    11.3    8.3
                2      8.5   9.4     8.8     8.4    5.9
  Carriers
  Wanted




                3      7.2   6.7     6.1     5.6    3.1
                4      9.3   8.8     8.1     7.5    5.1
                5      6.3   3.9     3.3     2.6    0.1




                                                          5


8       ORBITAL DEBRIS MITIGATION PLAN


8.1    Spacecraft Hardware Design


Eutelsat can confirm that the satellite will not undergo any planned release of debris during its
operation. Furthermore, all separation and deployment mechanisms, and any other potential
source of debris will be retained by the spacecraft.


In conjunction with Space Systems/Loral, Eutelsat has assessed and limited the probability of the
satellite becoming a source of debris by collisions with small debris or meteoroids of less than one
centimeter in diameter that could cause loss of control and prevent post-mission disposal. Eutelsat
has taken steps to limit the effects of such collisions through shielding, the placement of
components, and the use of redundant systems.


The E65WA satellite includes separate TT&C and propulsion subsystems that are necessary for
end-of-life disposal. The spacecraft TT&C system, vital for orbit raising, is extremely rugged with
regard to meteoroids smaller than 1 cm, by virtue of its redundancy, shielding, separation of
components and physical characteristics. Omni-directional antennas are mounted on opposite
sides of the spacecraft. These antennas are extremely rugged and capable of providing adequate
coverage even if struck, bent or otherwise damaged by a small or medium sized particle. Either
one of the two omni-directional antennas, for both command and telemetry, will be sufficient to
enable orbit raising. The redundant command receivers and decoders and redundant telemetry
encoders and transmitters are located within a shielded area. A single rugged thruster and shielded
propellant tank provides the energy for orbit-raising. Otherwise, there are no single points of
failure in the system.


8.2     Minimizing Accidental Explosions


In conjunction with Space Systems/Loral, Eutelsat has assessed and limited the probability of
accidental explosions during and after completion of mission operations.               The satellite
manufacturer has taken steps to ensure that debris generation will not result from the conversion
of energy sources on board the satellite into energy that fragments the satellite. In particular, the


                                                 6


satellite manufacturer advises that burst tests are performed on all pressure vessels during
qualification testing to demonstrate a margin of safety against burst. Bipropellant mixing is
prevented by the use of valves that prevent backwards flow in propellant lines and pressurization
lines. All batteries and fuel tanks are monitored for pressure and temperature. Excessive battery
charging or discharging is limited by a monitoring and control system which will automatically
limit the possibility of fragmentation. Corrective action, if not automatically undertaken, will be
immediately undertaken by the spacecraft operator to avoid destruction and fragmentation.
Thruster temperatures, impulse and thrust duration are carefully monitored, and any thruster may
be turned off via redundant valves. Consequently, there is no possibility of explosion during the
operating mission. Space Systems/Loral has also conducted a failure mode effects and criticality
analysis as part of the design process.


In order to ensure that the spacecraft has no explosive risk after it has been successfully de-orbited,
all stored energy onboard the spacecraft will be removed. Upon successful de-orbit of the
spacecraft, all propulsion lines and latch valves will be vented and left open. Battery chargers will
be turned off and all batteries will be left in a permanent discharge state.


Regarding the residual helium pressurant, and taking into account that the E65WA satellite is based
on the Space Systems/Loral 1300 model spacecraft, although the helium will be vented as part of
the retirement procedures for the satellite, a regulator on the tanks will prevent complete expulsion
of the helium. The E65WA propulsion subsystem design, in particular the regulator and
downstream check valve characteristics, will ensure that the minimum pressure in the three
interconnected helium tanks (65 liters each) will be no higher than 1.6psia (0.11 bar). The
specification for the minimum inlet pressure below which that regulator cuts off the flow of helium
is 400 psia. Based on that pressure, and assuming a temperature of 298K, the residual helium after
depletion is estimated to be approximately 3.5 grams. The tank pressure of 1.6 psia will be a
fraction of the tanks’ maximum expected operating pressure, which is 4000 psia.


Globecomm seeks a waiver of Section 25.283(c) of the Commission’s Rules with respect to the
residual helium that will remain on the E65WA satellite at end of life to the extent necessary to
grant this application. That section requires that space station operators take steps as part of the
retirement procedures to discharge energy sources on board the satellite, including “relieving
                                                  7


pressure vessels.” 47 C.F.R. § 25.283(c). As discussed above, although the helium will be
substantially depleted as part of the retirement process and virtually undetectable, thus “relieving”
the pressure in these tanks, once the inlet pressure drops below the set point of the regulator it is
impossible to continue to expel the helium. This limitation is part of the design of the spacecraft.
In addition, E65WA is already in orbit. Under these circumstances, grant of a waiver would be
consistent with Commission precedents1,2.


8.3        Safe Flight Profiles


In considering current and planned satellites that may have a station-keeping volume that overlaps
the E65WA satellite, Eutelsat has reviewed the lists of FCC licensed satellite networks, as well as
those that are currently under consideration by the FCC. In addition, satellite networks for which
a request for coordination has been published by the ITU within ±0.2 degrees of 65.2° W.L. have
also been reviewed.


The Brazilian satellite operator Star One operates the STAR ONE C1 satellite at the 65.0° W.L
orbital location. The satellite operates with an east-west station-keeping tolerance of ±0.05°. The
E65WA satellite operates at 65.2° W.L, and with an east-west station-keeping tolerance of ±0.05°,
thereby eliminating the possibility of any station-keeping volume overlap with the STAR ONE C1
satellite.


There are no pending applications before the Commission requesting authorization to use an orbital
location within ±0.2° of 65.2° W.L. and Eutelsat is not aware of any satellite with an overlapping
station-keeping volume with the E65WA satellite that is the subject of an ITU filing and that is
either in orbit or progressing towards launch.




1
    See Gogo LLC Section 1.65 Letter, File No. SES-MFS-20151022-00735 (Call Sign E120106).
2
    See United Teleports Inc. – Section 1.65 Submission, File No. SES-LIC-20160513-00427 (Call Sign E160081)

                                                        8


Based on the preceding, Eutelsat concludes that physical coordination of the E65WA satellite with
another party is not required at the present time.


8.4     Post Mission Disposal Plan


At the end of the operational life of the E65WA satellite, it will be maneuvered to a disposal orbit
with a minimum perigee of 300 km above the normal GSO operational orbit. This proposed
disposal orbit altitude is based on the following calculation, as required by Section 25.283:

       Total Solar Pressure Area “A” = 97.5 m2
       “M” = Dry Mass of Satellite = 2757.5 kg
       “CR” = Solar Pressure Radiation Coefficient = 1.24


Therefore the Minimum Disposal Orbit Perigee Altitude:

               =       36,021 km + 1000 x CR x A/M
               =       36,021 km + 1000 x 1.24 x 97.5/2757.5
               =       36,035 km
               =       279 km above GSO (35,786 km)

To provide margin, the nominal disposal orbit will be increased to 300 km. This will require 10.8
kg of propellant that will be reserved, taking account of all fuel measurement uncertainties, to
perform the final orbit raising maneuvers.


9       ITU FILINGS


The E65WA satellite network operates under the following two Appendix 30B ITU filings:


       B-SAT-3R – AP30B/A6A/254 published in IFIC 2744.


       B-SAT-3R-1 – AP30B/A6A/333 published in IFIC 2774.




                             __________________________________


                                                     9


           CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING
                       ENGINEERING INFORMATION

       I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in this “Attachment A Technical Information to

Supplement Schedule S”, that I am familiar with Part 25 of the Commission’s rules that I have

either prepared or reviewed the engineering information submitted in this “Attachment A

Technical Information to Supplement Schedule S”, and that it is complete and accurate to the

best of my knowledge and belief.




                                                             /s/ Adrián Pérez Zúñiga
                                                             Adrián Pérez Zúñiga
                                                             Satellite Coordination Manager
                                                             Eutelsat
                                                             + 52 (55) 5804 7314


ATTACHMENT B
Radiation Hazard Report                                                           Page 1 of 5


      Analysis of Non-Ionizing Radiation for a 9.3-Meter Earth
                          Station System
This report analyzes the non-ionizing radiation levels for a 9.3-meter earth station system. The
analysis and calculations performed in this report comply with the methods described in the FCC
Office of Engineering and Technology Bulletin, No. 65 first published in 1985 and revised in 1997
in Edition 97-01. The radiation safety limits used in the analysis are in conformance with the FCC
R&O 96-326. Bulletin No. 65 and the FCC R&O specifies that there are two separate tiers of
exposure limits that are dependant on the situation in which the exposure takes place and/or the
status of the individuals who are subject to the exposure. The Maximum Permissible Exposure
(MPE) limits for persons in a General Population/Uncontrolled environment are shown in Table 1.
The General Population/Uncontrolled MPE is a function of transmit frequency and is for an
exposure period of thirty minutes or less. The MPE limits for persons in an
Occupational/Controlled environment are shown in Table 2. The Occupational MPE is a function of
transmit frequency and is for an exposure period of six minutes or less. The purpose of the
analysis described in this report is to determine the power flux density levels of the earth station in
the far-field, near-field, transition region, between the subreflector or feed and main reflector
surface, at the main reflector surface, and between the antenna edge and the ground and to
compare these levels to the specified MPEs.

               Table 1. Limits for General Population/Uncontrolled Exposure (MPE)
                  Frequency Range (MHz)          Power Density (mW/cm2)
                          30-300                              0.2
                         300-1500                  Frequency (MHz)*(0.8/1200)
                       1500-100,000                           1.0

                    Table 2. Limits for Occupational/Controlled Exposure (MPE)
                  Frequency Range (MHz)          Power Density (mW/cm2)
                          30-300                              1.0
                         300-1500                  Frequency (MHz)*(4.0/1200)
                       1500-100,000                           5.0

          Table 3. Formulas and Parameters Used for Determining Power Flux Densities
     Parameter                    Symbol           Formula                 Value          Units
     Antenna Diameter                D               Input                   9.3          m
     Antenna Surface Area          Asurface         π D2 / 4                67.93         m2
     Subreflector Diameter          Dsr              Input                  116.8         cm
     Area of Subreflector           Asr             π Dsr 2/4            10714.59         cm2
     Frequency                       F               Input                 13000          MHz
     Wavelength                      λ              300 / F              0.023077         m
     Transmit Power                  P               Input                 616.50         W
     Antenna Gain (dBi)             Ges              Input                  60.8          dBi
     Antenna Gain (factor)           G              10Ges/10             1202264.4        n/a
     Pi                              π             Constant              3.1415927        n/a
     Antenna Efficiency              η             Gλ2/(π2D2)               0.75          n/a


                                                                                  Exhibit
Radiation Hazard Report                                                           Page 2 of 5




1.      Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the following equation:

     Distance to the Far Field Region                       Rff = 0.60 D2 / λ                   (1)
                                                                = 2248.7 m

The maximum main beam power density in the far field can be determined from the following
equation:

     On-Axis Power Density in the Far Field                 Sff = G P / (4 π Rff 2)             (2)
                                                                = 11.664 W/m2
                                                                = 1.166 mW/cm2

2.      Near Field Calculation

Power flux density is considered to be at a maximum value throughout the entire length of the
defined Near Field region. The region is contained within a cylindrical volume having the same
diameter as the antenna. Past the boundary of the Near Field region, the power density from the
antenna decreases linearly with respect to increasing distance.

The distance to the end of the Near Field can be determined from the following equation:

     Extent of the Near Field                               Rnf = D2 / (4 λ)                    (3)
                                                                = 937.0 m

The maximum power density in the Near Field can be determined from the following equation:

     Near Field Power Density                               Snf = 16.0 η P / (π D2)             (4)
                                                                = 27.229 W/m2
                                                                = 2.723 mW/cm2

3.      Transition Region Calculation

The Transition region is located between the Near and Far Field regions. The power density
begins to decrease linearly with increasing distance in the Transition region. While the power
density decreases inversely with distance in the Transition region, the power density decreases
inversely with the square of the distance in the Far Field region. The maximum power density in
the Transition region will not exceed that calculated for the Near Field region. The power density
calculated in Section 1 is the highest power density the antenna can produce in any of the regions
away from the antenna. The power density at a distance Rt can be determined from the following
equation:

     Transition Region Power Density                        St = Snf Rnf / Rt                   (5)
                                                               = 2.723 mW/cm2


                                                                              Exhibit
Radiation Hazard Report                                                       Page 3 of 5



4.      Region between the Main Reflector and the Subreflector

Transmissions from the feed assembly are directed     toward the subreflector surface, and are
reflected back toward the main reflector. The most    common feed assemblies are waveguide
flanges, horns or subreflectors. The energy between   the subreflector and the reflector surfaces
can be calculated by determining the power density    at the subreflector surface. This can be
determined from the following equation:

     Power Density at the Subreflector                    Ssr = 4000 P / Asr                (6)
                                                              = 230.153 mW/cm2

5.      Main Reflector Region

The power density in the main reflector is determined in the same manner as the power density at
the subreflector. The area is now the area of the main reflector aperture and can be determined
from the following equation:

     Power Density at the Main Reflector Surface      Ssurface = 4 P / Asurface             (7)
                                                               = 36.303 W/m2
                                                               = 3.630 mW/cm2


6.      Region between the Main Reflector and the Ground

Assuming uniform illumination of the reflector surface, the power density between the antenna and
the ground can be determined from the following equation:

     Power Density between Reflector and Ground           Sg = P / Asurface                 (8)
                                                             = 9.076 W/m2
                                                             = 0.908 mW/cm2


                                                                                  Exhibit
Radiation Hazard Report                                                           Page 4 of 5



7.     Summary of Calculations

           Table 4. Summary of Expected Radiation levels for Uncontrolled Environment
                                            Calculated Maximum
                                       Radiation Power Density Level
Region                                              (mW/cm2)               Hazard Assessment
1. Far Field (Rff = 2248.7 m)                   Sff        1.166              Potential Hazard
2. Near Field (Rnf = 937.0 m)                   Snf        2.723             Potential Hazard
3. Transition Region (Rnf < Rt < Rff)           St         2.723              Potential Hazard
4. Between Main Reflector and                   Ssr      230.153             Potential Hazard
    Subreflector
5. Main Reflector                               Ssurface   3.630              Potential Hazard
6. Between Main Reflector and Ground            Sg         0.908            Satisfies FCC MPE

            Table 5. Summary of Expected Radiation levels for Controlled Environment
                                           Calculated Maximum
                                          Radiation Power Density
Region                                        Level (mW/cm2)               Hazard Assessment
1. Far Field (Rff = 2248.7 m)                  Sff         1.166            Satisfies FCC MPE
2. Near Field (Rnf = 937.0 m)                  Snf         2.723            Satisfies FCC MPE
3. Transition Region (Rnf < Rt < Rff)          St          2.723            Satisfies FCC MPE
4. Between Main Reflector and                  Ssr      230.153              Potential Hazard
    Subreflector
5. Main Reflector                              Ssurface    3.630            Satisfies FCC MPE
6. Between Main Reflector and Ground           Sg          0.908            Satisfies FCC MPE

It is the applicant's responsibility to ensure that the public and operational personnel are not
exposed to harmful levels of radiation.



8.     Conclusions

Based on the above analysis it is concluded that the FCC MPE guidelines have been exceeded (or
met) in the regions of Table 4 and 5. The applicant proposes to comply with the MPE limits by one
or more of the following methods.

Radiation hazard signs will be posted while this earth station is in operation.

Due to the secure location of the proposed earth station antenna at the Hauppauge Teleport, the
area of operation around the antenna will be limited to those that have knowledge of the potential
for radiation exposure. The applicant will ensure that no buildings or other obstacles will be in the
areas that exceed the MPE levels.


                                                                                       Exhibit
Radiation Hazard Report                                                                Page 5 of 5


Means of Compliance Controlled Areas

The earth station’s operational staff will not have access to the areas that exceed the MPE levels
while the earth station is in operation.

The transmitters will be turned off during antenna maintenance

The applicant agrees to abide by the conditions specified in Condition 5208 provided below:

        Condition 5208 - The licensee shall take all necessary measures to ensure that the
        antenna does not create potential exposure of humans to radiofrequency radiation
        in excess of the FCC exposure limits defined in 47 CFR 1.1307(b) and 1.1310
        wherever such exposures might occur. Measures must be taken to ensure
        compliance with limits for both occupational/controlled exposure and for general
        population/uncontrolled exposure, as defined in these rule sections. Compliance
        can be accomplished in most cases by appropriate restrictions such as fencing.
        Requirements for restrictions can be determined by predictions based on
        calculations, modeling or by field measurements. The FCC's OET Bulletin 65
        (available on-line at www.fcc.gov/oet/rfsafety) provides information on predicting
        exposure levels and on methods for ensuring compliance, including the use of
        warning and alerting signs and protective equipment for worker.


I HEREBY CERTIFY THAT I AM THE TECHNICALLY QUALIFIED PERSON RESPONSIBLE FOR THE
PREPARATION OF THE RADIATION HAZARD REPORT, AND THAT IT IS COMPLETE AND CORRECT
TO THE BEST OF MY KNOWLEDGE AND BELIEF.




BY: _

Gary K. Edwards
Senior Manager
COMSEARCH
19700 Janelia Farm Boulevard
Ashburn, VA 20147


DATED: August 3, 2018


ATTACHMENT C




 FREQUENCY COORDINATION AND INTERFERENCE
             ANALYSIS REPORT


                       Prepared for
               Globecomm License Sub LLC
                    HAUPPAUGE, NY
                          (AOT10)
                  Satellite Earth Station




                       Prepared By:
                      COMSEARCH
               19700 Janelia Farm Boulevard
                   Ashburn, VA 20147
                   September 11, 2018


                                                      TABLE OF CONTENTS
1. CONCLUSIONS ............................................................................................................................................ 3
2. SUMMARY OF RESULTS ............................................................................................................................ 4
3. SUPPLEMENTAL SHOWING ....................................................................................................................... 5
4. EARTH STATION COORDINATION DATA ................................................................................................ 11
5. CERTIFICATION ......................................................................................................................................... 15




Frequency Coordination and Interference Analysis Report                                             09/11/2018                        Page 2 of 15


1. CONCLUSIONS



An interference study considering all existing, proposed and prior coordinated microwave
facilities within the coordination contours of the proposed earth station demonstrates that
this site will operate satisfactorily with the common carrier microwave environment. Further,
there will be no restrictions of its operation due to interference considerations.




Frequency Coordination and Interference Analysis Report    09/11/2018          Page 3 of 15


2. SUMMARY OF RESULTS


A number of great circle interference cases were identified during the interference study of
the proposed earth station. Each of the cases, which exceeded the interference objective
on a line-of-sight basis, was profiled and the propagation losses estimated using NBS
TN101 (Revised) techniques. The losses were found to be sufficient to reduce the signal
levels to acceptable magnitudes in every case.

The following companies reported potential great circle interference conflicts that did not
meet the objectives on a line-of-sight basis. When over-the-horizon losses are considered
on the interfering paths, sufficient blockage exists to negate harmful interference from
occurring with the proposed transmit-only earth station.


       Company

       <Companies Responding with Cases>



No other carriers reported potential interference cases.




Frequency Coordination and Interference Analysis Report    09/11/2018         Page 4 of 15


3. SUPPLEMENTAL SHOWING
Pursuant to Part 25.203(c) of the FCC Rules and Regulations, the satellite earth station proposed in this
application was coordinated by Comsearch using computer techniques and in accordance with Part 25 of the
FCC Rules and Regulations.

Coordination data for this earth station was sent to the below listed carriers with a letter dated 07/23/2018.

        Company
        3G Wireless, LLC
        AERIAL VIDEO SYSTEMS
        Alascom Inc
        Albany, County of
        Algonquin Gas Transmission, LLC
        American Broadcasting Companies, Inc.
        AMFM Radio Licenses, LLC
        AQ2AT LLC
        Archdiocese of New York Dept of Educatio
        Ascent Media Network Services, LLC
        AT&T Corp.
        Atlantic Telecommunications
        Bellsouth Telecommunications, Inc.
        Bergen, County of
        Bethel CT Police Department
        BFI Licenses, LLC
        BJ'S Wholesale Club, Inc
        Blueline Communications
        Borgeson, Tom R.
        Broadcast Sports Inc.
        Bucks County Dept. of Emergency Comm
        Business Only Broadband, LLC
        Cablevision Systems of Long Island Corp.
        Capital Communications of America
        Capital District Trans. Authority
        Carolina Telephone and Telegraph Co
        Casper, John
        CBS Broadcasting Inc
        CBS Communications Services Inc
        CBS Radio East, LLC.
        Cellco Partnership - (W-NY)
        Cellco Partnership-Northern New Jersey
        Central Hudson Gas & Electric Corp.
        Central Massachusetts Emergency Medical
        CenturyTel of the Southwest, Inc.
        Chicago Comnet Corp
        Cincinnati Bell Wireless LLC
        City of Albany
        City of Bethlehem
        City of Bristol Mayor's Office
        City of Jersey City



Frequency Coordination and Interference Analysis Report                 09/11/2018              Page 5 of 15


       City of New York
       City of Providence RI Public Safety Comm
       City of Springfield Police Department
       City of Westfield
       City of Worcester Emergency Comm Dept
       Citywide News Network, Inc.
       Citywisper LLC
       Clarity Connect, Inc.
       Clearwire Spectrum Holdings III, LLC
       CMEEC
       Columbia, County of
       Community Products, LLC
       Comprehensive Wireless LLC
       Connecticut Public Broadcasting Inc
       Connecticut, State of
       Conterra Ultra Broadband, LLC
       County of Burlington
       County of Burlington, Public Safety Cntr
       County of Camden
       County of Hunterdon
       County of Mercer
       County of Pike
       County of Warren, NJ
       Cowboys Stadium LP
       Cox Radio Inc
       DCI II, INC.
       Direct Broadcast Services, Inc.
       DSRC Networks
       Dutchess County Emergency Response
       East Brunswick, Township of, NJ
       East Hampton Town Police Department
       Eastern MLG LLC
       ECW Wireless, LLC
       Electric Railroad, LLC
       ESPN Inc.
       Essex County Sheriff's Office (NJ)
       Eversource Energy Service Company
       Exelon Generation Company, LLC
       FELHC, Inc.
       Fishers Island Telephone
       Fordham University(WFUV)
       Fox Television Stations LLC - WNYW TV
       Fox Television Stations, LLC
       Frascogna, Carl
       Frontier California Inc.
       Fundamental Broadcasting LLC
       Garden State Transmissions
       GAW High-Speed Internet
       Geodesic Networks LLC
       Glastonbury Police Department
       Global Crossing Telecommunications, Inc.
       Global Telecom & Technology Americas
       Gloucester Township
       Goosetown Network Services, LLC
       Greenwich, Town of (CT)
       GTT America LLC



Frequency Coordination and Interference Analysis Report   09/11/2018   Page 6 of 15


       Hallco Unlimited, Inc.
       Hamilton, Township of
       Hammarlund Research LLC
       HARRIS CORPORATION
       Hawaiian Telcom, Inc.
       Heiden, William
       HF Enterprises, Inc
       High Voltage Communications LLC (CFN)
       Highway Networks, LLC
       Holy Name Hospital
       Hopewell Radiology Group
       Hudson County Prosecutors Office
       HUDSON VALLEY WIRELESS
       Illinois Bell Telephone Company
       Indiana Bell Telephone Company
       Industrial Tower and Wireless, LLC
       Information & Display Systems, Inc.
       Information Super Station, LLC
       International Communications Group, Inc.
       iSignal
       Jackson Twp. Police Department
       Jefferson Microwave, LLC
       Kentucky RSA #3 Cellular General Partner
       Kentucky RSA #4 Cellular General Partner
       Kryptick Technologies
       Lackawanna County Dept. of Emergency Ser
       Lackawanna, County of
       Lake Mohegan Fire District
       Lakewood Municipal Utilities Authority
       LANline Communications, Inc.
       Lehigh, County of
       Local Media TV Philadelphia
       Local TV Pennsylvania License, LLC
       Manchester, Township of
       Marcus Communications
       Massachusetts Commonwealth of
       Massachusetts Water Resources Authority
       Massachusetts, Commonwealth of
       MERCURY COMMUNICATIONS
       Meredith Corporation
       Michigan Bell Telephone Company
       Middlesex, County of
       Middletown, City of
       Mid-Hudson Cablevision
       Mid-Hudson Data Corp
       Monmouth, County of
       Monroe County Control Center (PA)
       Montgomery County Of
       Moreen, Steven K
       Morris, County of
       Nassau County Police Department
       National Grid USA Service Company, Inc
       National Tower Company LLC
       Navajo Communications Company
       NBC Telemundo License LLC
       NCN Data,LLC



Frequency Coordination and Interference Analysis Report   09/11/2018   Page 7 of 15


       New Britain, City of
       New Cingular Wireless PCS LLC - NJ
       New Cingular Wireless PCS LLC - MA
       New Cingular Wireless PCS LLC-DE/NH/RI
       New Cingular Wireless PCS, LLC - PA
       New Cingular Wireless PCS, LLC (NY)
       NEW ENGLAND DIGITAL DISTRIBUTION, INC.
       New Jersey Public Broadcasting Authority
       New Jersey State Police
       New Jersey Transit Rail Operations, Inc.
       New Jersey Turnpike Authority-Pkwy Div
       New Jersey, State of -NJ Transit
       New Line Networks, LLC
       New York City Police Department
       New York City Police TARU
       New York City Transit Authority
       New York Communications Co., Inc
       New York Presbyterian Hospital
       New York SMSA Limited Partnership
       New York SMSA LP (Northern NJ)
       Newark Police Department
       NEXSTAR BROADCASTING, INC.
       Norcom Communications Corp.
       Norfolk County Fire Dispatch
       Northrop Grumman Systems Corp.
       NorthWest Suburbs Community Access Corp
       Norton, Douglas R
       NSM Surveillance
       Nstar Electric Company
       NW Technologies, LLC
       NY Dept of Health and Mental Hygiene
       NYC DOT Staten Island Ferry
       Ocean County of - Div of Wireless Tech.
       Ocean, County of
       Office of Emergency Telecom Services, NJ
       Ohio Bell GTelephone Company
       Onboard Images
       Optiver GT US, LLC
       Orange and Rockland Utilities, Inc.
       Orange County Dept of Emergency Services
       Orangetown, Town of
       Pacific Bell Tel Com dba AT&T California
       Peco Energy Company
       Penn Service Microwave Co., Inc.
       Pennsylvania Turnpike Commission
       PhillieCo, L.P.
       Pierce Broadband, LLC
       Pines Pantry, Inc.
       Piscataway, Township Of
       Plateau Telecommunications, Inc.
       Plum TV, LLC
       Pocono Mountain School District
       Port Authority of New York & New Jersey
       Production & Satellite Services, Inc.
       PSEG Services Corporation
       Putnam County Bureau of Emerg. Services



Frequency Coordination and Interference Analysis Report   09/11/2018   Page 8 of 15


       Qoncept Holdings LLC
       Quick Link Connections Inc.
       Qwest Corporation
       Radiofone, Inc.
       Randy Hermes Production
       RCC Minnesota Inc. - MN NE ND SD
       Remote Broadcasts, Inc.
       REMOTE FACILITIES CONSULTING SERVICES
       Rensselaer County
       RF Central, LLC
       RF Film, Inc
       Ridgefield Police Department
       Rockland, County of
       Sanofi Pasteur
       Saratoga County Office of Emergency Svcs
       Schenectady County Unified Communication
       Setauket Fire District
       Somerset County (M.I.S.)
       Southeastern Pennsylvania Transit Auth
       Southington Town of CT
       Southwestern Bell Telephone L.P.
       Speedshotz, Inc
       Spot On Networks
       Sprint Spectrum L.P.
       Sprintcom, Inc
       St Lukes Hospital
       Stamford, City of
       Standard Backhaul Communications LLC
       Startouch, Inc.
       State of New Jersey
       State of New Jersey Infomation Technolog
       State of New York, Div of State Police
       State of Rhode Island, EMA
       Suffolk County Police Department
       Suffolk, County of
       Sullivan County DPW
       Susquehanna County
       Sussex County Sheriffs Office
       SW Networks
       Telecom Transport Management, Inc
       T-Mobile License LLC
       Toms River Police Department
       Toms River, Township of
       Towerstream Corp.
       Town of Colonie Police Department
       Town of Holden
       Town of Narragansett, Rhode Island
       Town of Smithtown Dept of Public Safety
       Town of Wethersfield
       Town of Woodbridge, Police Department
       Township of Middletown
       Township of Old Bridge
       Townsquare Media Atlantic City III Licen
       Townsquare Media Monmouth-Ocean License
       Townsquare Media Oneonta License, LLC
       Transcontinental Gas Pipeline Corp.



Frequency Coordination and Interference Analysis Report   09/11/2018   Page 9 of 15


       Transwave Communication Systems, Inc.
       TTWN Networks, LLC
       Ulster County of
       Union County New Jersey
       Unisat, Inc.
       United Telephone - Southeast
       Uniti Fiber PEG, LLC
       Verizon Maryland, Inc.
       Verizon New England Inc.
       Verizon New Jersey, Inc.
       Verizon New York, Inc.
       Verizon North Inc.
       Verizon Northwest Inc.
       Verizon Pennsylvania, Inc.
       VERIZON SOUTH INC.
       Verizon Virginia, Inc.
       Verizon Washington DC, Inc.
       Verizon Wireless (VAW) LLC - Northern NJ
       Verizon Wireless (VAW) LLC (NY)
       Verizon Wireless (VAW) LLC-Pennsylvania
       VTel Wireless, Inc.
       Vyvx, LLC
       Wallingford Police Department
       Walpole, Town of
       Wayne County - DHS-EM
       Wayne, Township of
       Webline Holdings LLC
       Westar Satellite Services LP
       Westchester, County of
       Westwood, Town of
       Winged Vision Inc
       Wireless Internetwork LLC
       Wisconsin Bell Telephone Company
       WNET
       Wolfe Air Aviation
       World Class Wireless, LLC
       WPIX, LLC
       WXTV License Partnership, G.P.
       xWave Engineering LLC




Frequency Coordination and Interference Analysis Report   09/11/2018   Page 10 of 15


4. EARTH STATION COORDINATION DATA
This section presents the data pertinent to frequency coordination of the proposed earth station that was
circulated to all carriers within its coordination contours.




Frequency Coordination and Interference Analysis Report            09/11/2018           Page 11 of 15


                                                                COMSEARCH
                                                         Earth Station Data Sheet
                                                19700 Janelia Farm Boulevard, Ashburn, VA 20147
                                                  (703)726-5500 http://www.comsearch.com

Date:                                       07/23/2018
Job Number:                                 180723COMSGE05
Administrative Information
Status                                      ENGINEER PROPOSAL
Call Sign                                   E990402
Licensee Code                               SWSITE
Licensee Name                               Globecomm License Sub LLC
Site Information                            HAUPPAUGE, NY
Venue Name                                  AOT 10
Latitude (NAD 83)                           40° 48' 54.1" N
Longitude (NAD 83)                          73° 14' 17.8" W
Climate Zone                                A
Rain Zone                                   2
Ground Elevation (AMSL)                     33.5 m / 109.9 ft
Link Information
Satellite Type                              Geostationary
Mode                                        TR - Transmit-Receive
Modulation                                  Digital
Satellite Arc                               65° W to 65° West Longitude
Azimuth Range                               167.5° to 167.5°
Corresponding Elevation Angles              42.1° / 42.1°
Antenna Centerline (AGL)                    5.49 m / 18.0 ft
Antenna Information                               Receive - FCC32                          Transmit - FCC32
Manufacturer                                      Vertex                                   Vertex
Model                                             9.3 KPK                                  9.3 KPK
Gain / Diameter                                   59.3 dBi / 9.3 m                         60.8 dBi / 9.3 m
3-dB / 15-dB Beamwidth                            0.20° / 0.40°                            0.16° / 0.32°

Max Available RF Power           (dBW/4 kHz)                                               -15.3
                                 (dBW/MHz)                                                 8.7

Maximum EIRP                     (dBW/4 kHz)                                               45.5
                                 (dBW/MHz)                                                 69.5

Interference Objectives:       Long Term          -156.0 dBW/MHz          20%            -154.0 dBW/4 kHz 20%
                               Short Term         -146.0 dBW/MHz          0.01%           -131.0 dBW/4 kHz 0.0025%
Frequency Information                             Receive 12.0 GHz                         Transmit 13.0 GHz
Emission / Frequency Range (MHz)                  36M0G7W / 10701.0 – 10944.5              36M0G7W / 12751 – 12994.5


Max Great Circle Coordination Distance            233.3 km / 145.0 mi                      123.5 km / 76.7 mi
Precipitation Scatter Contour Radius              100.0 km / 62.1 mi                       100.0 km / 62.1 mi




Frequency Coordination and Interference Analysis Report                           09/11/2018           Page 12 of 15


                                                        COMSEARCH
                                                   Earth Station Data Sheet
                                       19700 Janelia Farm Boulevard, Ashburn, VA 20147
                                          (703)726-5500 http://www.comsearch.com

Coordination Values                  HAUPPAUGE, NY
Licensee Name                        Globecomm License Sub LLC
Latitude (NAD 83)                    40° 48' 54.1" N
Longitude (NAD 83)                   73° 14' 17.8" W
Ground Elevation (AMSL)              33.5 m / 109.9 ft
Antenna Centerline (AGL)             5.49 m / 18.0 ft
Antenna Model                        Vertex 9.3 meter
Antenna Mode                                 Receive 12.0 GHz                    Transmit 14.0 GHz
Interference Objectives: Long Term           -156.0 dBW/MHz    20%               -154.0 dBW/4 kHz 20%
                           Short Term        -146.0 dBW/MHz    0.01%             -131.0 dBW/4 kHz 0.0025%
 Max Available RF Power                                        -15.3 (dBW/4 kHz)

                                                                 Receive 12.0 GHz                   Transmit 14.0 GHz
                Horizon            Antenna                 Horizon         Coordination      Horizon         Coordination
Azimuth (°)     Elevation (°)      Discrimination (°)      Gain (dBi)      Distance (km)     Gain (dBi)      Distance (km)
  0              0.00              136.46                  -10.00          227.19            -10.00           119.95
  5              0.00              135.08                  -10.00          227.19            -10.00           119.95
 10              0.00              133.31                  -10.00          227.19            -10.00           119.95
 15              0.00              131.20                  -10.00          227.19            -10.00           119.95
 20              0.00              128.78                  -10.00          227.19            -10.00           119.95
 25              0.00              126.10                  -10.00          227.19            -10.00           119.95
 30              0.00              123.20                  -10.00          227.19            -10.00           119.95
 35              0.00              120.11                  -10.00          227.19            -10.00           119.95
 40              0.00              116.88                  -10.00          227.19            -10.00           119.95
 45              0.00              113.52                  -10.00          227.19            -10.00           119.95
 50              0.00              110.06                  -10.00          227.19            -10.00           119.95
 55              0.00              106.52                  -10.00          227.19            -10.00           119.95
 60              0.00              102.91                  -10.00          227.19            -10.00           119.95
 65              0.00               99.26                  -10.00          227.19            -10.00           119.95
 70              0.00               95.57                  -10.00          227.19            -10.00           119.95
 75              0.00               91.87                  -10.00          227.19            -10.00           119.95
 80              0.00               88.15                  -10.00          227.19            -10.00           119.95
 85              0.26               84.43                  -10.00          221.80            -10.00           115.60
 90              0.35               80.71                  -10.00          212.63            -10.00           107.92
 95              0.45               77.02                  -10.00          204.84            -10.00           101.07
100              0.23               73.44                  -10.00          223.81            -10.00           117.23
105              0.00               69.96                  -10.00          227.19            -10.00           119.95
110              0.00               66.50                  -10.00          227.19            -10.00           119.95
115              0.00               63.14                  -10.00          227.19            -10.00           119.95
120              0.63               59.58                  -10.00          196.60            -10.00           100.00
125              0.64               56.44                  -10.00          195.82            -10.00           100.00
130              0.32               53.71                  -10.00          215.87            -10.00           110.67
135              0.41               50.94                  -10.00          207.93            -10.00           103.83
140              0.25               48.62                  -10.00          222.08            -10.00           115.83
145              0.00               46.70                   -9.73          228.36             -9.73           120.63
150              0.00               44.92                   -9.31          230.20             -9.31           121.69
155              0.00               43.55                   -8.97          231.71             -8.97           122.54
160              0.00               42.60                   -8.74          232.78             -8.74           123.15
165              0.00               42.12                   -8.61          233.33             -8.61           123.46
170              0.00               42.12                   -8.61          233.34             -8.61           123.46
175              0.43               42.17                   -8.63          211.37             -8.63           105.39
180              0.62               42.95                   -8.82          201.51             -8.82           100.00
185              0.78               44.21                   -9.14          192.26             -9.14           100.00




Frequency Coordination and Interference Analysis Report                 09/11/2018         Page 13 of 15


                                                        COMSEARCH
                                                   Earth Station Data Sheet
                                       19700 Janelia Farm Boulevard, Ashburn, VA 20147
                                          (703)726-5500 http://www.comsearch.com

Coordination Values                  HAUPPAUGE, NY
Licensee Name                        Globecomm License Sub LLC
Latitude (NAD 83)                    40° 48' 54.1" N
Longitude (NAD 83)                   73° 14' 17.8" W
Ground Elevation (AMSL)              33.5 m / 109.9 ft
Antenna Centerline (AGL)             5.49 m / 18.0 ft
Antenna Model                        Vertex 9.3 meter
Antenna Mode                                 Receive 12.0 GHz                    Transmit 14.0 GHz
Interference Objectives: Long Term           -156.0 dBW/MHz    20%               -154.0 dBW/4 kHz 20%
                           Short Term        -146.0 dBW/MHz    0.01%             -131.0 dBW/4 kHz 0.0025%
 Max Available RF Power                                        -15.3 (dBW/4 kHz)

                                                                 Receive 12.0 GHz                   Transmit 14.0 GHz
                Horizon            Antenna                 Horizon         Coordination      Horizon         Coordination
Azimuth (°)     Elevation (°)      Discrimination (°)      Gain (dBi)      Distance (km)     Gain (dBi)      Distance (km)
190              0.94               45.89                   -9.54          182.72             -9.54           100.00
195              1.04               47.98                  -10.00          175.75            -10.00           100.00
200              0.86               50.60                  -10.00          184.55            -10.00           100.00
205              0.69               53.45                  -10.00          193.25            -10.00           100.00
210              1.08               56.17                  -10.00          174.69            -10.00           100.00
215              1.43               59.15                  -10.00          160.44            -10.00           100.00
220              0.93               62.70                  -10.00          180.71            -10.00           100.00
225              0.70               66.21                  -10.00          193.05            -10.00           100.00
230              0.69               69.72                  -10.00          193.57            -10.00           100.00
235              0.79               73.27                  -10.00          188.30            -10.00           100.00
240              0.89               76.91                  -10.00          182.82            -10.00           100.00
245              0.90               80.61                  -10.00          182.60            -10.00           100.00
250              0.90               84.35                  -10.00          182.74            -10.00           100.00
255              1.01               88.11                  -10.00          176.79            -10.00           100.00
260              0.89               91.87                  -10.00          183.32            -10.00           100.00
265              0.89               95.63                  -10.00          183.28            -10.00           100.00
270              0.67               99.34                  -10.00          194.51            -10.00           100.00
275              0.71              103.04                  -10.00          192.20            -10.00           100.00
280              0.83              106.72                  -10.00          186.47            -10.00           100.00
285              0.62              110.24                  -10.00          196.94            -10.00           100.00
290              0.39              113.65                  -10.00          209.94            -10.00           105.58
295              0.21              116.96                  -10.00          226.07            -10.00           119.06
300              0.00              120.10                  -10.00          227.19            -10.00           119.95
305              0.00              123.18                  -10.00          227.19            -10.00           119.95
310              0.00              126.08                  -10.00          227.19            -10.00           119.95
315              0.00              128.76                  -10.00          227.19            -10.00           119.95
320              0.00              131.18                  -10.00          227.19            -10.00           119.95
325              0.00              133.30                  -10.00          227.19            -10.00           119.95
330              0.00              135.08                  -10.00          227.19            -10.00           119.95
335              0.00              136.45                  -10.00          227.19            -10.00           119.95
340              0.00              137.40                  -10.00          227.19            -10.00           119.95
345              0.00              137.88                  -10.00          227.19            -10.00           119.95
350              0.00              137.88                  -10.00          227.19            -10.00           119.95
355              0.00              137.40                  -10.00          227.19            -10.00           119.95




Frequency Coordination and Interference Analysis Report                 09/11/2018         Page 14 of 15


5. CERTIFICATION

I HEREBY CERTIFY THAT I AM THE TECHNICALLY QUALIFIED PERSON RESPONSIBLE FOR THE
PREPARATION OF THE FREQUENCY COORDINATION DATA CONTAINED IN THIS APPLICATION,
THAT I AM FAMILIAR WITH PARTS 101 AND 25 OF THE FCC RULES AND REGULATIONS, THAT I HAVE
EITHER PREPARED OR REVIEWED THE FREQUENCY COORDINATION DATA SUBMITTED WITH THIS
APPLICATION, AND THAT IT IS COMPLETE AND CORRECT TO THE BEST OF MY KNOWLEDGE AND
BELIEF.




BY: _                                                     __________________________

Gary K. Edwards
Senior Manager
COMSEARCH
19700 Janelia Farm Boulevard
Ashburn, VA 20147


DATED: September 11, 2018




Frequency Coordination and Interference Analysis Report           09/11/2018       Page 15 of 15


ATTACHMENT D
FCC Letter to ANATEL




                                   FEDERAL COMMUNICATIONS COMMISSION
                                          INTERNATIONAL BUREAU
                                         WASHINGTON, D.C. 20554

                                   fax: +1 202 418 1208; TWX: 710 822 0160

                                                                                  In reply,refer to:
                                                                                800C2/SEB16174
Telefax message:

To: Agência Nacional de Telecomunicações - ANATEL
     Assessoria Internacional
     SAUS-Quadra 6 - Bloco H - 4th Floor
     70070-940 BRASILIA, DF
     Brazil
     TELEFAX NO.: 011 + 55 61 23122244 C

CC: ITU Radiocommunication Bureau
    Geneva, Switzerland
    Telefax no.: 41 22 730 5785

Date: 27 April 2016

Subject: Agreement under §6.6 of Article 6 of Appendix 30B

References: 1) Special Section AP30B/A6A/333, BRIFIC 2744 dated 22.07.2014, concerning
the
               B-SAT-3R-1 satellite network.
            2) Our letter 800C2/SEB14393, dated 30.10.2014
            3) Your letter CT. n°163/ORER-Anatel dated 25.09.2015

The US administration thanks the administration of Brazil for its request for agreement
regarding the operation of the B-SAT-3R-1 satellite network in the 6725-7025 MHz (Earth to
space) and 4500-4800 MHz (space to Earth), 10.70-10.95 GHz (space to Earth), 11.20-11.45
GHz (space to Earth) and 12.75-13.25 GHz (Earth to space) planned bands of APP30B. The US
administration is pleased to provide its agreement under the provision §6.6 of Appendix 30B
for inclusion of its territory in the service area of the B-SAT-3R-1 satellite network. However,
this agreement does not guarantee market access to the US. Any earth station located within
US territory seeking to communicate with the B-SAT-3R-1 satellite network must first be
licensed in accordance with US laws and regulations. Any operation of the satellites would be
in accordance with international Radio Regulations and relevant provisions. Any such license
application may or may not be granted.

REGARDS
FEDCOMCOM
SATELLITE DIVISION
Direct Fax No.: +1 202 418 1208 (preferred)
          or +1 202 418 0398 (alternative)
Email: IBmail@fcc.gov

Authorized:   J. Payton
              International Bureau/SD
                                   ******
                                             15



Document Created: 2018-09-11 13:37:34
Document Modified: 2018-09-11 13:37:34

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