Attachment Narrative

This document pretains to SES-MFS-20181213-03453 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2018121303453_1590210

                                      Before the
                        FEDERAL COMMUNICATIONS COMMISSION
                                 Washington, DC 20554

    In the Matter of

    Application of Intelsat License LLC to Modify             Call Sign E170121
    its Existing Ku-band Earth Stations Aboard
    Aircraft and Vehicle-Mounted Earth Stations               File No. ___________________
    Blanket License to Add New Terminals and
    New Satellite Points of Communication

                 APPLICATION FOR BLANKET LICENSE MODIFICATION

          By this application, Intelsat License LLC (“Intelsat”) seeks to modify its existing Ku-

band earth stations aboard aircraft (“ESAA”) and vehicle-mounted earth stations (“VMES”)

blanket license, Call Sign E170121.1 Specifically, Intelsat seeks to add authority to operate up to

1000 of each of two new terminal types—the SkyTech Model BB30Ku (“BB30”) and the

SkyTech Model BB45Ku (“BB45”)—on private, commercial, and government aircraft in U.S.

and international airspace, and on stationary and in-motion vehicles within the United States,

pursuant to Section 25.226 and Section 25.227 of the Federal Communication Commission’s

(“FCC” or “Commission”) rules.2 Intelsat also seeks to add four additional satellites to its

Blanket License as authorized points of communication for ESAA terminals operating at power

above two-degree spacing level but consistent with the coordinated levels of the satellites.

          The modifications sought herein will improve Intelsat’s operational flexibility and

enhance the offerings of the IntelsatOne® Flex network, thus facilitating U.S. leadership in

satellite-based mobile broadband services. Grant of the requested authority would be consistent




1         See Intelsat License LLC, File No. SES-MOD-20180220-00148, Call Sign E170121
     (granted July 25, 2018) (the “Blanket License”).

2         47 C.F.R. § 25.226 and 47 C.F.R. § 25.227.


with Commission rules and precedent and would serve the public interest by promoting

competition in the mobile broadband connectivity market.

         Intelsat will operate its terminals with existing and additional satellite points of

communication in accordance with the Commission’s rules governing Ku-band ESAAs3 and

VMESs,4 future rules governing such operations,5 and applicable international requirements.

Pursuant to Section 25.117(c) of the Commission’s rules,6 Intelsat provides in the FCC Form 312

Schedule B and Technical Appendix information pertaining to the requested modification.

I.       BACKGROUND

         Intelsat is a world leader in providing innovative broadband satellite services and currently

holds numerous FCC licenses to operate geostationary satellite orbit (“GSO”) fixed-satelitte

service (“FSS”) satellites and earth station facilities. The IntelsatOne® Flex network aggregates

Intelsat’s global wide beam and Intelsat EpicNG® high throughput satellite (“HTS”) fleet and the

IntelsatOne® terrestrial network into a simplified ecosystem that enables Intelsat and its



3        See 47 C.F.R. § 25.227; see also Revisions to Parts 2 and 25 of the Commission’s Rules
     to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite
     Service Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7
     GHz, 11.7-12.2 GHz and 14.0-14.5 GHz Frequency Bands, IB Docket No. 12-376, Notice of
     Proposed Rulemaking and Report and Order, FCC 12-161, 27 FCC Rcd 16510 (2012).

4        See 47 C.F.R. § 25.226; see also Amendment of Parts 2 and 25 of the Commission’s Rules
     to Allocate Spectrum and Adopt Service Rules and Procedures to Govern the Use of Vehicle-
     Mounted Earth Stations in Certain Frequency Bands Allocated to the Fixed-Satellite Service,
     IB Docket No. 07-101, Order on Reconsideration, FCC 13-1, 28 FCC Rcd 488 (2013).

5        See Amendment of Parts 2 and 25 of the Commission’s Rules to Facilitate the Use of
     Earth Stations in Motion Communicating with Geostationary Orbit Space Stations in
     Frequency Bands Allocated to the Fixed Satellite Service, IB Docket No. 17-95, Report and
     Order and Further Notice of Proposed Rulemaking, FCC 18-138 (rel. Sep. 27, 2018).

6        See 47 C.F.R. § 25.117(c).



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distribution partners to easily and cost effectively scale service delivery capability to meet

customer demand. Intelsat’s ESAA/VMES network is an integral part of its global IntelsatOne®

Flex offering. Intelsat has fully described the network in its prior submissions and hereby

incorporates by reference the technical showing regarding the control functionality and other

operational characteristics previously submitted.7

         Under the original ESAA blanket license,8 the FCC International Bureau (“Bureau”)

authorized Intelsat to operate two terminals (Rantec and TECOM terminals) with specific

Intelsat satellites and any U.S.-licensed or non-U.S.-licensed satellite on the Commission’s

Permitted Space Station List (“Permitted List”). 9 Subsequently, the Bureau approved Intelsat’s

modification of its license to include additional antennas (the HR129 and HR6400), as well as

VMES operating authority for all the terminals.10

         Here, Intelsat seeks to add the BB30 and BB45 terminals to its Blanket License for

regular ESAA and VMES commercial operations.11 In addition, Intelsat seeks authority for all



7        See Intelsat License LLC, File Nos. SES-LIC-20170626-00682 and SES-MOD-
     20180220-00148, Call Sign E170121, at Technical Descriptions.

8
         See Intelsat License LLC, File No. SES-LIC-20170626-00682, Call Sign E170121.

9          See Approved Space Station List (last updated on Nov. 9, 2018, available at:
     https://www.fcc.gov/approved-space-station-list). Permitted List authority is available in
     specified frequencies at routine power levels with satellites on the Approved Space Station
     List.

10       See supra n.1.

11        The BB30 and BB45 terminals have previously operated under experimental authority
     and the BB45 terminal has also operated under commercial ESAA authority granted by the
     Commission. See UltiSat, Inc., File No. SES-LIC-20180726-02089 (Nov. 21, 2018), Call
     Sign E181298; UltiSat, Inc., File Nos. SES-STA-20180621-01477, and SES-STA-20180724-



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ESAAs in its network to communicate with four additional specific satellite points of

communication at higher, coordinated power levels. Below, Intelsat provides an overview of the

proposed operations and demonstrates that they will be conducted in accordance with the

Commission’s ESAA and VMES requirements.

II.       DISCUSSION

          A.     BB30 & BB45 Terminal Operations

          The BB30 and BB45 ESAA terminals are stabilized antenna systems that provide high-

quality broadband satellite communications for aeronautical and ground-based mobile satellite

applications. They are designed to operate in Ku-band frequencies to provide mission-critical

delivery of voice, video, and data communications; employ mechanically steerable, circular

parabolic antennas; and, with the exception of antenna size, have the same basic design and

functional characteristics.

          Intelsat seeks authorization to operate the BB30 and BB45 terminals with Permitted List

satellites under the provisions of Sections 25.226(a)(1) and 25.227(a)(1) of the Commission’s

rules,12 applicable to VMES and ESAA terminals that use transmitters with off-axis EIRP

spectral densities (“ESDs”) lower than or equal to the levels in paragraph (a)(1)(i) of each

section.13 In the Technical Appendix, Intelsat provides the off-axis ESD plots pursuant to

Section 25.115(g)(1) of the Commission’s rules, 47 C.F.R. § 25.115(g)(1).




      01969; see also UltiSat, Inc., File No. 0201-EX-ST-2018; UltiSat, Inc., File No. 1930-EX-ST-
      2018.

12
          47 C.F.R. §§ 25.226(a)(1) and 25.227(a)(1).

13        The Commission’s off-axis ESD masks applicable to ESAAs and VMESs are identical.


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        The BB30 and BB45 terminals use a circular parabolic antenna with no compliance

issues in the plane perpendicular to the geostationary arc (as is the case with many low-profile

terminals). The charts show that the ESD remains below permitted limits in all cases, and

Intelsat will operate the BB30 and BB45 terminals at off-axis ESD levels that are compliant with

the Commission’s two-degree spacing policy to prevent adjacent satellite interference and

facilitate Ku-band ESAA and VMES operations in a two-degree spacing environment.

        For ESAA operations outside the United States with certain satellite points of

communication, Intelsat will operate authorized ESAA terminals under Sections 25.226(a)(2)

and 25.227(a)(2) of the Commission’s rules.14 The relevant satellites are enumerated in Section

II.B, below. Intelsat will operate all ESAA terminals in accordance with the coordinated power

levels of the serving satellites.

        In addition, the BB30 and BB45 terminals fully meet the pointing accuracy requirements

of Section 25.226(a)(1)(ii)(A) and 25.227(a)(1)(ii)(A) with a pointing accuracy of less than or

equal to 0.2º between the orbital location of the target satellite and the axis of the main lobe of

the ESAA and VMES antennas. Moreover, in accordance with Section 25.226(a)(1)(iii)(A) and

25.227(a)(1)(iii)(A), the BB30 and BB45 terminals’ design ensures that all emissions from

ESAAs and VMESs 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 or VMES antenna

exceeds 0.5°, and transmission will not resume until such angle is less than or equal to 0.2°.

        The Commission has previously examined the technical characteristics of Skytech ESAA

terminals in granting STA and long-term operating authority to both the BB30 and BB45




14      47 C.F.R. §§ 25.226(a)(2) and 25.227(a)(2).



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terminals.15 In the Technical Appendix and Form 312 Schedule B, Intelsat provides additional

information on the operational characteristics of the BB30 and BB45 terminals, and

demonstrates that it will operate in compliance with the Commission’s ESAA and VMES rules

and policies. The BB30 and BB45 terminals have operated pursuant to Commission

authorizations without any reported interference and in compliance with the rules embodied in

Sections 25.226 and 25.227. Thus, operation of the BB30 and BB45 terminals as part of the

IntelsatOne® Flex network will not increase the potential for interference to other lawfully

operating spectrum users.

       B.       Points of Communication

       Intelsat seeks authority to add four (4) aditional satellites as points of communication for

all ESAA terminals in its Blanket License. Uplink from the terminals will occur in portions of

the 14.0-14.5 GHz band and downlinks will occur in portions of the 10.95-11.2 GHz and 11.45-

12.2 GHz bands, as described in the following table.

                            Table 1. New Satellite Points of Communication

 Satellite      FCC Call      Orbital            Downlink          ITU Region       Service to
                Sign          Location           Freq. (GHz.)                       U.S.
 Intelsat 33e   S2939         60° E.L.           10.95-11.2        1, 3             No
                                                 11.45-11.7
                                                 11.7-12.2
 Galaxy 16      S2687         43.15° W.L.        11.7-12.2         2                Yes

 Galaxy 18      S2733         60° E.L.           11.7-12.2         2                Yes

 Intelsat 905   S2409         335.5° E.L.        10.95 - 11.20     1, 2             Yes
                                                 11.45-11.7




15     See supra n. 11.


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         Intelsat requests authority to operate the BB30, BB45, and previously authorized ESAA

terminals with these satellites at their coordinated power level, as well as with all satellites on the

Permitted List. In addition, Intelsat requests authority for the BB30 and BB45 terminals to

communicate with certain previously authorized satellites in the 12.2-12.75 GHz band for ESAA

receive operations on an unprotected, non-harmful interference basis outside the United States,16

subject to any necessary authorizations from foreign administrations, and in accordance with

existing conditions in the Blanket License.17 Intelsat provides a complete list of satellite points

of communication and associated gateways in the Technical Appendix, as well as BB45 and

BB30 operating parameters in Form 312 Schedule B.

         C.     Permitted List Authority

         In addition to the above-mentioned specific satellite points of communication at higher

powers, Intelsat is also requesting authority to operate the BB30 and BB45 terminals with all

U.S.-licensed and non-U.S. licensed satellites on the Permitted List.18 Permitted List authority is

appropriate because Intelsat will operate the terminals with these satellites in permissible

portions of the Ku-band at power levels compliant with the Commission’s rules, and otherwise in

accordance with operational conditions imposed by the Commission. Permitted List authority

for the BB30 and BB45 terminals will provide Intelsat with operational flexibility to provide

services throughout the coverage area of its global satellite fleet.




16       The 12.5-12.75 GHz band is allocated for FSS downlinks in ITU Region 1 and the 12.2-
     12.75 GHz band is allocated for FSS downlinks in ITU Region 3.

17
         See supra n.1.

18       See supra n.11.


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       D.      Ground Segment

       The Ground Segment consists of gateway earth stations located at Intelsat and

commercial teleport facilities that facilitate network control and connection to the terrestrial

telecommunications network. A complete table reflecting all satellites and gateways in the

Intelsat network is included in the Technical Appendix. The gateway information for the new

satellite points of communication is provided below.


                             Table 2. Gateway Earth Stations Information

 Satellite        Gateway       Gateway Earth           Country           FCC Call Sign
                  Operator      Station Location
 IS-33e           Intelsat      Fuchsstadt              Germany           N/A
                                Kumsan                  Korea             N/A
                                Johannesburg            South Africa      N/A

 G16              Intelsat      Hagerstown, MD          United States     E030051

 G18              Intelsat      Atlanta, GA             United States     E990433
 IS-905           Intelsat      Fuchsstadt              Germany           N/A



       Control and monitoring of the Intelsat network will be provided by the information

security operations center (“ISOC”) in Ellenwood, Georgia, United States, on a 24/7 basis. The

primary points of contact at the ISOC facility have been previously provided to the Commission.

       E.      Non-Conforming, Non-Interference ESAA Downlink Operations

       The FCC’s Table of Frequency Allocations (“Table of Allocations”), Section 2.106 of the

Commission’s rules,19 permits use of the 10.95-11.2 GHz and 11.45-11.7 GHz (space-to-Earth)

bands on an unprotected basis, and the 11.7-12.2 GHz (space-to-Earth) and 14.0-14.5 GHz




19     47 C.F.R. § 2.106.



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(Earth-to-space) bands on a primary basis for ESAA operations. 20 As discussed, in this

application Intelsat also seeks authority for the BB30 and BB45 to communicate with certain

previously authorized satellites in the 12.2-12.75 GHz downlink band for ESAA operations, as

shown in the Technical Appendix accompanying this Application. Intelsat seeks to utilize this

additional downlink capacity on an unprotected, non-harmful interference basis outside the

United States, under the same conditions that are currently contained in the Blanket License.

       Intelsat requests that the Commission permit ESAA operations using the BB30 and BB45

in the 12.2-12.75 GHz band under the same conditions that currently apply to the other terminals

authorized under the Blanket License.21 Such authority would serve the public interest because

use of this downlink (receive) spectrum is essential to Intelsat’s broadband mobility offerings in

Ku-band spectrum and presents a negligible risk of interference to other spectrum users.

III.   PUBLIC INTEREST STATEMENT

       Grant of the requested modification to add the two new terminal types and the four new

satellite points of communication to the Blanket License will serve the public interest by


20     See id., n. NG52 and NG55; 47 C.F.R. § 25.227.

21     The Blanket License includes the following conditions:

       900414 Reception of downlink transmissions is on a non-interference, non-protected basis from the
              following geostationary orbit space stations: IS-17 (Call Sign: S2814) at 66º E.L. in the 12.2-
              12.75 GHz frequency band; IS-18 (Call Sign: S2817) at 180º E.L. in the 12.25-12.75 GHz
              frequency band; IS-20 (Call Sign: S2847) at 68.5º E.L. in the 12.5-12.75 GHz frequency band;
              IS-22 (Call Sign: S2846) at 72.1º E.L. in the 12.25-12.75 GHz frequency band; and IS-37 (Call
              Sign: S2972) at 18º W.L. in the 12.5-12.75 GHz frequency band. When receiving transmissions
              from these satellites in these frequency bands, the ESAA operations authorized herein must
              accept interference from any authorized user of the band.

       900415 Reception of downlink transmissions in ITU Region 2 is on a non-interference, non-protected
              basis from the following geostationary orbit space stations: Horizons 3e (S2947) at 169° E.L.
              in the 12.2-12.75 GHz frequency band; IS-19 (Call Sign: S2850) at 166º E.L. in the 12.25-
              12.75 GHz frequency band; IS-33e (Call Sign S2939) at 60.0° E.L. in the 12.5- 12.6 GHz
              frequency band. Operations are not authorized in these bands over the U.S. and its territories.



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extending the coverage and increasing the capacity and operational flexibility of Intelsat’s global

ESAA and VMES network. This will provide a direct benefit to U.S. satellite mobility

customers, including the U.S. government, and will further enhance U.S. leadership in mobile

broadband services.

       Grant of this modification application will also serve the public interest by promoting

competition in the market for mobile broadband connectivity services to the benefit of travelers

in the United States and internationally. In particular, users of the ESAA and VMES services on

Intelsat’s network will enjoy increased productivity, operational efficiencies, and other benefits

from expanded access to mobile broadband connectivity. This in turn will enhance competition

in the air- and ground-transportation market by enabling aircraft and vehicles equipped with

Intelsat ESAAs and VMESs to compete with other operators offering terrestrial and satellite-

based connectivity to passengers.

       Intelsat has provided the technical and operational information necessary for the

Commission to grant this modification pursuant to Sections 25.226 and 25.227 of the

Commission’s rules. Intelsat has established that its terminals can operate with the proposed

satellite points of communication consistent with applicable coordination agreements and that its

proposed operations are compatible with other co-frequency services. Thus, grant of the

requested modification would be consistent with Commission rules, policies and precedent

facilitating Ku-band VMES and ESAA operations, and would serve the public interest.

IV.    CONCLUSION

       For the foregoing reasons, Intelsat requests that the Commission grant this modification

application to add four new satellite points of communication and the BB30 and BB45 terminals

to its Blanket License for ESAA and VMES operations as described herein.




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Document Created: 2018-12-13 21:18:13
Document Modified: 2018-12-13 21:18:13

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