Attachment 312_MOD_Application

This document pretains to SES-MOD-20000420-00658 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2000042000658_426577

                             IRWIN, CAMPBELL & TANNENWALD, P.C.
                                               ATTORNEYS AT LA W
                                        1730 RHODE ISLAND AVENUE, N.W.
                                                      SUITE 200
                                           WASHINGTON, D.C. 20036—3101
                                                    (202) 728—0400
                                                 FAX (202) 728—0354
                                                http://www.ictpe.com



                                        FCC/MELLON          APR 2 0 2000
JASON S. ROBERTS
(202) 728—0401 Ext. 126
jroberts@ictpc.com



                                               April 20, 2000


Federal Communications Commussion
International Bureau—Earth Stations
P.O. Box 358160
Pittsburgh, PA 15251—5160

           RE:         Globecomm Systems,. Inc.
                      Station E990402
                      Application for Modification of License

Dear Sir or Madam:

        Transmitted herewith and filed on behalf of Globecomm Systems, Inc. ("Globecomm")
is an application on FCC Form 312 to modify the license of Station E990402, located at
Hauppague, New York. By this application, Globecomm seeks authority to add the Hispasat .
C—1 satellite as a point of communication to E990402. Globecomm also seeks to correct
information regarding the antenna model and local longitude for this station.

      A check in the amount of one—hundred and thirty—five dollars ($135.00) is included for
payment of the required filing fee.

           Please direct any questions regarding this application to the undersigned.

                                                           Very truly yours,




                                                             sop   S. Roberts

Enclosure
cCo:       Mr. Gerry Johnston, Sr.
           Mr. Milt Goldstein


                                                         FCGC/MELLON                 APR 20 2000

FCC 312
                                                                                                                                                    Approved by CMB
                                                                                                                                                           1060—0678    FCC Use Only
                                                                                                                                                       Est Arg Burden   File Number:
                                                                                                                                                                Hours
Main Form                                                                                                                                          Far Responae 11Hra


                FEDERAL COMMUNICATIONS COMMISSION
                                                                                                                                                                        Call Sign:                  <
  APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATIONS

                                                                                                                                                                        Fee Number:




                                                                                              APPLICANT INFORMATION
 1. Legal Name of Applicant                                                                                                                                             2. Voice Telephone Number
  Globecomm Systems, Inc                                                                                                                                                 (631)— 231—9800 X1279
3. Other Name Used for Doing Business (if any)                                                                                                                          4. Fax Telephone Number
                         N/A                                                                                                                                             (631)— 231—1557
5. Mailing Street Address or P.O. Box                                                                                  6. City
  45 Oser Avenue                                                                                                          Hauppauge
                                                                                                                       7. State/Country (if not U.S.A.)                                      8. Zip Code
ATTENTION: Gerry Johnston Sr                                                                                              New York                                                                11788—3816
9. Name of Contact Representative (Ifother than applicant)                                                                                                              10. Voice Telephone Number
   David A. Irwin                                                                                                                                                       (202)—728—0400
 11. Firm or Company Name                                                                                                                                               12. Fax Telephone Number
     Irwin, Campbell And Tannenwald, P.C.                                                                                                                               (202)—728—0354
 13. Mailing Street Address or P.O. Box                                                                                 14. City
  1730 Rhode Island Avenue, NW. Suite 200                                                                                  Washington
 ATTENTiON: David A. Irwin                                                                                              15. State/Country (if not U.S.A¥.)                                   16. Zip Code
                                                                                                                          DC                                                                  20036—3101


                                                                                            CLASSIFICATION OF FILING
 17. Place an "X"in the box next to the classification that applies to this filing for both questions a. and b. Mark only one box for 17a and only one box for 17b.


                                               D b1. Application for License of New Station                                 D b6. Transfer of Control of License or Registration
             E al. Earth Station                [:] b2. Application for Registration of New                                 D b7. Notification of Minor Modification
                                                            Domestic Receive—Only Station                                   D b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed S\utellite
             D a2. Space Station                                                                                            D b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                D b3. Amendment to a Pending Application
                                                g b4. Modification of License or Registration                               D b10. Other (Please Specific)
                                                D b5. Assignment of License or Registration

 18. If this filing is in reference to an existing station, enter:                                              19. If this filing is an amendment to a pending application enter:
     Call sign of station:                                                                                           (a) Date pending application was filed:             (b) File number of pending application:
    E990402                                                                                                          December 01, 1999                                           SEC—LIC—19990913—01597



                                                                                                                                                                                                        FCC 312, Main Form — Page 1 of 4
                                                                                                                                                                                                                          February, 1998


                                                                                                TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Place an "N" in the box(es) next to all that apply.
    & a. Fixed Satellite                            D c. Radiodetermination Satellite             D e. Direct to Home Fixed Satellite
      D b. Mobile Satellite                              D d. Earth Exploration Satellite             D {. Digital Audi Radio Service              g. Other (please specify)                  a
21. STATUS: Place an "X" in the box next to the applia)le status. Mark only one box.                               22. If earth station applicant, place an "X" in the box(es) next to all that apply.
         D a. Common Carrier             E b. Non—Common Carrier                                                       E a. Using U.S. licensed satellites                    E b. Using Non—U.S. licensed satellites

23. If applicant is providing INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Mark only one box. Are these facilities:
          a. Connected to the Public Switched Network                                                            E b. Not connected the Public Switched Network
24. FREQUENCY BAND(S): Place and "X" in the box(es) next to all applicable frequency band(s).                     ~—
      [_] a. C—Band (4/6 GHz)
      g b. Ku—Band (12/14 GHz)                           (X] c. Other (please specify)    13754—13790 MHz, 13794—13830 MHz, 13834—13870 MHz, 13874—13910 MHz


                                                                                                TYPE OF STATION
25. CLASS OF STATION: Place an "X"in the box next to the class of station that applies. Mark only one box.
    E a. Fixed Earth Station                    D b. Temporary—Fixed Earth Station              D c. 12/14 GlHlz VSAT Network              D d. Mobile Earth Station      D e. Space Station      D £. Other
                                                                                                                                                                                                       (Specify)
    If space station applicant, go to Question 27.
26. TYPE OF EARTH STATION FACILITY Mark only one box.
            E a. Transmit/Receive              D b. Transmit—Only               D c. Receive—Only


                                                                      PURPOSE OF MODIFICATION OR AMENDMENT
27.     ‘The purpose of this proposed modification or amendment is to: Place and "X"in the box(es) next to all that apply.
                                                 E a — authorization to add new emission designator and related service
                                                 D b — authorization to change emission designator and related service
                                                 D c — authorization to increase EIRP and EIRP density
                                                 E d — authorization to replace antenna
                                                 D e — authorization to add antenna
                                                 D f — authorization to relocate fixed station
                                                 g g — authorization to changed assigned frequency(ies)
                                                 E h — authorization to add Points of Communication (satellites & countries)
                                                 D i — authorization to change Points of Communication (satellites & countries)
                                                 D j — authorization for facilities for which environmental assessment and radiation hazard reporting is required
                                                 D k — Other (Please Specify)



                                                                                          ENVIRONMENTAL POLICY
28. Would a Commission grant of any proposal in this application or amendment have a significant environmental impact as defined by 47 C.F.R. 1.1307?
If YES, submit the statement as required by Sections 1.1308 and 1.1311 of the Commission‘s rules, 47 C.F.R. §§ 1.1308 and 1.1311, as an exhibit to this application.                     D YES                          @ NO




                                                                                                                                                                                                  FCC 312, Main Form — Page 2 of 4
                                                                                                                                                                                                                   February, 1998


                                                                                                     ALIEN OWNERSHIP
29. Is the applicant a foreign government or the representative of any foreign government?
                                                                                                                                                                                            YES              NO




                                                                                                                                                                           G |(90 |[0 |[O




                                                                                                                                                                                                  X{ K K K
30. Is the applicant an alien or the representative of an alien?
                                                                                                                                                                                            YES              NO
31. Is the applicant a corporation organized under the laws of any foreign government?
                                                                                                                                                                                            YES              NO
32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or
    voted by aliens or their representatives or by a foreign governnment or representative thereof or by any                                                                                YES              NO
    corporation organized under the laws of a foreign country?
33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than
    one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign                                                                           YES              NO




                                                                                                                                                                           G




                                                                                                                                                                                                  K
    government or representative thereof or by any corporation organized under the laws of a foreign country?
34. If any answerto questions 29, 30, 31, 32 and/or 33 is yes, attach as an exhibit an identification ofthe aliens or foreign
    entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.


                                                                                                 BASIC QUALIFICATIONS
35. Does the applicant request any waivers or exemptions from any of the Commission‘s Rules?
    If Yes, attach as an exhibit, copies of the requests for waivers or exception with supporting documents.                                                                                YES              NO




                                                                                                                                                                            O




                                                                                                                                                                                                  K
36. Has the applicant or any party to this application had any FCC station authorization or license revoked or had
                                                                                                                                                                                            YES              NO




                                                                                                                                                                            0




                                                                                                                                                                                                  M
    any application for an initial, modification or renewal of FCC station authorization, license, or construction
    permit denied by the Cominission? If Yes, attach as an exhibit, any explanation of the circumstances.
37. Has the applicant, or any party to this application, or any party directly or indirectly controlling the
                                                                                                                                                                                            YES              NO




                                                                                                                                                                                                   M
                                                                                                                                                                            0
     applicant ever been convicted of a felony by any state or federal Court? If Yes, attach as an exhibit, an explanation of the
     circumstances.
 38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant, guilty of unlawfully
    monopolizing or atteimpting unlawfully to monopolize radio communication, directly or indirectly, through control of                                                                    YES              NO




                                                                                                                                                                                                   M
                                                                                                                                                                            O
    manufacture or sale of radios apparatus, exclusive traffic arrangement or any other means or unfair methods of competition? If Yes,
     attach as an exhibit, an explanation of the circumstances.
 39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending
                                                                                                                                                                                            YES              NO




                                                                                                                                                                                                   K
                                                                                                                                                                            L
     matter referred to in the preceding two items? If Yes, attach as an exhibit, an explanation of the circumstances.
 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names, addresses and citizenship
     of those stockholders owning of record and/or voting 10 percent or more of the filer‘s voting stock and the percentages so held. In
 the
     case of fiduciary control, indicate the beneficiary(ies) or class of beneficiaries. Also list the names and addresses of the officers and
     directors of the Filer.
 41. By checking Yes, the undersigned certifies, that neither the applicant nor any other party to the applicationis subject to a denial of                                     KET                          NO




                                                                                                                                                                                                   _
      Federal benefits that includes FCC benefits pursuant to Section 5301 or the Anti—Drug Act of 1988, 21 U.S.C. Section 862, because
     of a conviction for possession or distribution of a controlled substance. See 47 C.F.R. 1.2002(b) for the meaning of "party to the application" for these purposes.
 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If yes, answer 42b and attach                                                 YES      B no
      an exhibit providing the information specified in 47 C.F.R. § 25.137, as appropriate.
     If no. proceed to 'question 43. See Schedule B, B2
 42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what
      adiministration has coordinated or is in the process of coordinating the space station?   HISPASAT—1C Satellite @30° W.L
                                                                                                                                                                                                  FCC 312, Main Form— Page 3 of 4
                                                                                                                                                                                                                   February. 1998


    43. Description. (Summarize the nature of the application and the services to be provided).

        Globecomm Systems, Inc. desires to operate the existing uplink in the extended Ku—Band for their earth
        station license under call sign E990402, to provide digital data services to their clients. Globecomm
        also seeks to add the Hispasat C—1 satellite as a point of communication to E990402. In addition, this
        license codification corrects the antenna model and local longitude which was incorrectly referenced
        on the previous license grant for this station.




        Exhibit No.             Identify all exhibits that are attached to this   lication.




                                                                                         CERTIFICATION
       The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the United States because of
       the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this application. The applicant certifies that grant of this
       application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material part hereof
       and are incorporated herein as if set out in full in this application. The undersigned, individually and for the applicant, hereby certifies that all statements made in this
       application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.

    44. Applicant is a (an):        (Place an "X" in the box next to applicable response.)

     [_] a. Individual     [_] b. Unincorporated Association        [_] c. Partnership        d. Corporation [_] e. Governmental Entity [_] {i’gglsirspeci ty
    45. Typed Namme of Person Signing                                                                          46. Title of Person Signing

                                   Kenneth A. Miller                                                                                     President




       Ta seCull
    47. Signature                                                                                                                                    48. Date




          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT
           (U.S. Code, Title18, Section 1001), AND/OR REVOCATIONOF ANY AUTHORIZATION(U.S.Code,Title47,
s


           Section 3li(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).
                                                                                                                                                                FCC 312, Main Form — Page 4
                                                                                                                                                                             February, 1998


FCC 312                                                                                                                                                                             Page 1:; Location
Schedule B                                                         FEDERAL COMMUNICATIONS COMMISSION
                                      APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATION®S
                                                        (Technical and Operational Description)
                                                                                     (Place an "X" in one of the blocks below)

D License of New Station           DRegislration of new Domestic D Amendment to a Pending Application @ Modification of License/Registration D Notification of Minor Modification
                                            Receive—Only Station                                                                             '

B1. Location of Earth Station Site. If temporary—fixed, mobile, or VSAT remote facility, specify area of operation and point of contact. If VSAT hub station, give its location
                                              For VSAT networks attachindividual Schedule B, Page 1 sheets for each hub station and each remote station. Individually provide the
                                              Location, Points of Communications, and Destination Points for each hub and remote station.
Bla. Station Call Sign           Bib. Site identifier (HUB, REMOTE1, etc.)                   Bic. Telephone Number                         B1j. Geographic Coordinates N/S,                Bik. Lat./Lon.
                                                                                              (631)—231—9800 X 1279                              Deg. — Min. — Sec. — E/W                  Coordinates are:
B1d. Mailing Street Address of Station or Area of Operation             Ble. Name of Contact Person
                                                                                                                                           Lar 40° 48‘          __54.4_ N                  [_] nana7
    45 Oser Avenue                                                           Gerry Johnston Sr                                             Lon 738° 14‘         17.8 W                     [X navss
BIf. City                                Big. County                                                        Blh. State     Bli. Zip Code               B1i. Site Elevation (AMSL)
    Hauppauge                                  Suffolk                                                            NY       11788—3816                       33.5 Meters

B2. Points of Communications:                 List the names and orbit locations of all satellites with which this earth station will communicate. The entry "ALSAT" is sufficient to
                                              identify the names and locations of all satellite facilities licensed by the U.S. All non—U.S. licensed satellites must be listed individually.
Satellite Name and Orbit Location                                       Satellite Name and Orbit Location                                  Satellite Name and Orbit Location
HISPASAT—1C @ 30° W.L
ALSAT



B3. Destination points for communications using non—U.S. licensed satellites. For each non—U.S. licensed satellite facility identified in section B2 above, specify the
destination point(s) (countries) where the services will be provided by this earth station via each non—U.S. license satellite system. Use additional sheets as needed.
Satellite Name                                         List of Destination Points
HISPASAT—1C @ 30° W.L                                  Brazil, Colombia, Chile, Peru Guatemala
ALSAT




                                                                                                                                                                            FCC 312, Schedule B — Page 1 of 5
                                                                                                                                                                                              February, 1998


                                                                                                                                                                                                      Page 2: Antennas —
                                                     FEDERAL COMMUNICATIONS COMMISSION
                                        APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATIONS
                                               FCC Form 312 — Schedule B; (Technical and Operational Description)
B4. Earth Station Antenna Facilities: Use additional pages as needed.
      (a) Site ID*                             (b)                              (c)                      (d) Manufacturer                    (e) Model                           (1)                      (g) Antenna Gain
                                          Antenna ID**                       Quantity                                                                                       Antenna Size               Transmit and/or Receive
                                                                                                                                                                              (meters)                 (       dBi at       GHz)
      AOT—11                                                                    1                            VERTEX                         9.0 KPK                            9.0 M                  58.4 dBi at 12 GHz
                                                                                                                                                                                                      60.3 dBi at 14 GHz




             B5. Antenna Heights and Maximum Power Limits: (The corresponding Antenna ID in tables B4 and B5 applies to the same antenna)
                                                                             Maximum Antenna Height                     (e) Building           (f) Maximum               (g) Total Input
                         (a)             (b) Antenna Structure           (c) Above           (d) Above                 Height Above           Antenna Height                Power at              (h) Total EIRP
                       Antenna              Registration No.            Ground Level          Mean Sea Level           Ground Level           Above Rooftop              antenna flange           for all carriers
                        ID**                                              (meters)                (meters)              (meters)***             (meters)***                 (Watts)                   (dBW)

                     AOT—11                                                9.0 M                    39.0                    N/A                     N/A                     118.0                     81.0

                                                                                                                                                                                                                        &




             Notes:        *     If this is an application for a VSAT network, identify the site (Item Blb, Schedule B, Page 1) where each antenna is located. Also include this Site—ID on Schedule B, Page 5.
                   '             Identify each antennain VSAT network or multi—antenna station witha unique identifier, such as HUB,REMOTE1, A1, AZ, TOM, 1T2M,7M, etc. Usethissameantenna1D
                                 throughout tables B4, B5, B6, and B7 when referring to the same antenna.
                         ***     Attach sketch of site or exemption, See 47 CFR Part 17.

                                                                                                                                                                                                FCC 312. Schedule B — Page 2 of5
                                                                                                                                                                                                                     February, 1998


                                                                                                                                                                                                 Page 3; Coordination
                                                 FEDERAL COMMUNICATIONS COMMISSION
                                     APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATIONS
                                            FCC Form 312 — Schedule B: (Technical and Operational Description)
B6. Frequency Coordination Limits: Use additional pages as needed.
     (a)                            (b)                          (c) Range of            (d) Range of             (e) Antenna             (f) Antenna          (g) Earth Station       (h) Earth Station     (i) Maximum EIRP
 Antenna ID*                  Frequency Limits                   Satellite Arc           Satellite Arc          Elevation Angle         Elevation Angle         Azimuth Angle           Azimuth Angle        Density toward the
                                                               Eastern Limit**         Western Limit**           Eastern Limit           Western Limit           Eastern Limit           Western Limit      Horizon (dBW/A4kHz
   AOT—11               13754.00     —13790.00                    2.0° W.L.              130.0°W.L.                  5.4°                    16.2°                 102.5°                 246.8°                  —1.39
                        13794.00     — 13830.00                   2.0° W.L.              130.0°W.L.                  5.4°                    16.2°                 102.5°                 246.8°                  —1.39
                        13834.00     —13870.00                    2.0° W.L.              130.0°W.L.                  5.4°                    16.2°                 102.5°                 246.8°                  —1.39
                        13874.00     —13910.00                    2.0° W.L.              130.0°W.L.                  5.4°                    16.2°                 102.5°                 246.8°                  —1.39
                        11700.00     —12200.00                    2.0° W.L.              130.0°W.L.                  5.4°                    16.2°                 102.5°                 246.8°




               Notes:     *   Provide the ANTENNA—ID from table B4 to identify the antenna to which each frequency band and orbital are range is associated.
                         **   If operating with geostationary satellites, give the orbital are limits and the associated elevation and azimuth angles. If operating with non—geostationarysatellites,
                              give the notation "NON—GEO"for the satellite are and give the iminimum operational elevation angle and the maximumazimuth angle range.




                                                                                                                                                                                                 FCC 312, Schedule B — Page 3 of 5
                                                                                                                                                                                                                   February, 1998


                                                                                                                                                                                   Page 4: Particulars _
                                                  FEDERAL COMMUNICATIONS COMMISSION
                                      APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATION®S
                                             FCC Form 312 — Schedule B:; (Technical and Operational Description)
B7. Particulars of Operation (Full particulars are required for each r.df. carrier); Use additional pages as needed.
      (a)                           (b)                     (c)       {d) Antenna               (e)   (f) Maximum     (g) Maximum                     (h) Description of Modulation and Services
 Antenna ID*                 Frequency Limits               T/R       Polarization        Emission      EIRP per      EIRP Density
                                  (MHz)                    Mode        (H,V,L,R)         Designator   Carrier (dBW)    per Carrier
                                                             **                                                       (dBW/4kHz)

  AOT—11               13754.00      — 13790.00              T           H,   V        15M4G7D           72.0            36.1                   Digital    Data ,   18QAM 7/8 FEC      45,000 kbps
  AOT—11               13794.00      — 13830.00              T           H,   V        15M4G7D           72.0            36.1                   Digital    Data ,   16QAM 7/8 FEC      45,000 kbps
  AOT—11               13834.00      — 13870.00              T           H,   V        15M4G7D           72.0            36.1                   Digital    Data ,   16QAM 7/8 FEC      45,000 kbps
  AOT—11               13874.00      — 13910.00              T           H,   V        15M4G7D           72.0            36.1                   Digital    Data ,   16QAM 7/8 FEC      45,000 kbps
  AOT—11               11700.00      — 12200.00              R           H,   V        15M4GT7D                                                 Digital    Data ,   16QAM 7/8 FEC      45,000 kbps
  AOT—11               13754.00      — 13790.00              T           H,   V        18M0G7D            72.0           35.5                   Digital    Data,    16QAM 3/4 FEC      45,000 kbps
  AOT—11               13794.00      —— 13830.00             T           H,   V        18M0G7D            72.0           35.5                   Digital    Data,    16QAM 3/4 FEC      45,000 kbps
  AOT—11               13834.00       —13870.00              T           H,   V        18M0G7D            72.0           35.5                   Digital    Data,    16QAM 3/4 FEC      45,000 kbps
  AOT—11               13874.00       —13910.00              T           H,   V        18M0G7D            72.0           35.5                    Digital   Data,    16QAM 3/4 FEC      45,000 kbps
  AOT—11               11700.00      — 12200.00              R           H,   V        18M0G7D                                                   Digital   Data,    16QAM 3/4 FEC      45,000 kbps




Notes: *     Providethe ANTENNA—ID from table B4 to identify the anterina to which each frequencyband andemissionis associated. For VSAT networks,include frequencies andemissionsfor all HUB and _   _
             REMOTE units.
      *# *   Indicate whether the earth station transmits or receives in each frequency band.

                                                                                                                                                                                FCC 312, Schedule B — Page 4 of5
                                                                                                                                                                                                   February, 1998


                                                                                                                                                                           Page 5: Questions _
                                                          FEDERAL COMMUNICATIONS COMMISSION
                                  APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATIONS
                                                 FCC Form 312 — Schedule B:; (Technical and Operational Description)


If VSAT Network, provide the SITE—ID (Item B1b) of the station that B8—B13 are in response to (HUB, REMOTE1, etc.): ; ; ; ;.


B8. If the proposed antenna(s) operate in the Fixed Satellite Service (FSS) with geostationary satellites, do(es) the proposed antenna(s)
     comply with the antenna gain patterns specified in Section 25.209(a) and (b) as demonstrated by the manufacturer‘s qualification            m yes                  ) no
     measurements? If NO, provide as an exhibit, a technical analysis showing compliance with two—degree spacing policy.
B9. If the proposed antenna(s) do not operate in the Fixed Satellite Service (FSS), or if they operate in the Fixed Satellite Service
    (FSS) with non—geostationary satellites, do(es) the proposed antenna(s) comply with the antenna gain patterns specified in                   ) ¥Es                  ) no
    Section 25.209(a2) and (b) as demonstrated by the manufacturer‘s qualification measurement?
B10. Is the facility operated by remote control? If YES, provide the location and telephone numberof the control point.
                                                                                                                                                 ) v¥Es                    no
        Remote Control Point Location:
         B10a. Street Address

         BiOb. City                                              B10c. County                                       B10.d. State/Country            BiOQe. Zip Code

         BIOf. Telephone Number                                                           B1l0g. Call Sign of Control Station (if appropriate)



B11. Is frequency coordination required? If YES, attach a frequency coordination report as an exhibit.
                                                                                                                                                 J vEs                  m no
B1J2. Is coordination with another country required? If YES, attach the name of the country(ies)
      and plot of coordination contours as an exhibit.                                                                                           ) vEs                  m no
B13. FAA Notification — (See 47 CFT Part 17and 47 CFT Part 25.113(c))
     Where FAA notification is required, have you attached a copy of a completed FCC Form 854                                                    ) ¥Es                  mJ no
     and/or the FAA‘s study regarding the potential hazard of the structure to aviation?
     FAILURE TO COMPLY WITH 47 CFT PARTS 17 AND 25 WILL RESULT IN THE RETURN OF THIS APPLICATION




                                                                                                                                                                      FCC 312, Schedule B — Page 5 of 5
                                                                                                                                                                                        February, 1998


                          ~ EXHIBIT A




ENTENDED UPLINK KU—BAND


                                              EXHIBIT A

            GLOBECOMM Systems Earth Station (E990402) Hauppauge, New York
       Compliance with FCC Report & Order (FCC9I6—377) for the 13.75 — 14.0 GHz Band
                             Analysis and Calculations

 1.       Background

This Exhibit is presented to show that the proposed satellite earth station application for
Hauppauge, New York is in compliance with the intent of FCC REPORT & ORDER 96—377. It
will show that the proposed earth station will not impact shipboard radiolocation operations
(RADAR) and the NASA space research activities that are also in the 13.75 — 14.0 GHz Band.

                         Table 1. Earth Station Characteristics



e     Coordinates (NAD 83):                      40° 48 54.1" N, 73° 14 17.8" W
e     Ground Elevation:                          110 feet above mean sea level
e     Satellite Location for Earth Station:      Hispasat 1—C, 30° W. L
e     Frequency Band:                            13.75—14.0 GHz for uplink
                                                 11.7 — 12.2 GHz for downlink
e     Polarizations:                             Dual linear, V and H
e     Modulation                                 Eight Carriers, Digital Data 45 Mbps Carrier,
                                                 16QAM, % FEC & 7/8 FEC,
e     Maximum Required Uplink EIRP:              Emission Designator 18M0G7D & 15M4G7D
e     Operational Frequencies                    EIRP per Carrier of 72.0dBW
                                                 13.772 GHz (2), 13.812 GHz (2)
e     Antenna Size:                              13.852 GHz (2), 13.892 GHz (2)
                 — Antenna Type/Model:           9.0—meters in Diameter
                 — Gain:                         Vertex, Ku—Band
      RF power into Antenna Flange:              60.3 dBi
e     Elevation Angle:                           — 27.8 dBW/4 kHz Digital Carrier
e     Side Lobe Antenna Gain:                    25.6° at an Azimuth of 124.8°
                                                 32— 25*log(0), or > —10 dB


Because the above spectrum is shared with the Federal Government, coordination in this band
requires resolution data pertaining to potential interference between the earth station and both
Navy Department and NASA systems. Potential interference from the earth station could impact
with the Navy and/or NASA systems in five areas. These areas are noted in FCC Report and
Order 96—377 dated September 1996, and consist of (1) Radiolocation and radio navigation, (2)
Data Relay Satellites, (3) Precipitation Radar, (4) Altimeters, and (5) Scatterometers.

Summary of Coordination Issues:


1) Potential Impact to Government Radiolocation (Shipboard RADAR)
2) Potential Impact to NASA Data Relay Satellite Systems (TDRSS)
3) Potential Impact to NASA/NASDA Operations (Precipitation RADAR)
4) Potential Impact to NASA Operations (Altimeters)


2.     Potential Impact to Government Radiolocation (Shipboard RADAR)

Radiolocation operations (RADAR) may occur anywhere in the 13.4 — 14 GHz frequency band
onboard ocean going United States Navy ships. The Federal Communication Commission
(FCC) order 96—377 allocates the top 250 MHz of this 600 MHz band to the Fixed Satellite
Service (FSS) on a co—primary basis with the radiolocation operations and provides for an
interference protection level of —167 dBW/M*/4 kHz for the RADAR.

The closest distance to the Atlantic Ocean from the Hauppauge, New York earth station site is
approximately 13.3 miles. The calculation of the power spectral density at this distance is given
in the next two subsections.

The RADAR characteristics used for the calculations are presented in Table 2.

                               Table 2. RADAR Characteristics

                               Transmitter parameters

              Transmitter Power*                 250kWatts
              Frequency Range                    13.40 — 14.00 GHz
             Spectral Density Transmitted at the Tuned Frequency

              Pulse Width** 0.5 usecond             25.8 dBW/4 kHz
              Pulse Width*    1.0 pusecond          28.8 dBW/4 kHz
              Pulse Width** 2.Ousecond               31.8 dBW/4 kHz
              Pulse Rate*                           1200 pulses per second
              Emission Characteristics              SinX/X Roll Off
              Mode of Operation                     Pulse Doppler Detection
                                     Antenna Parameters

              Shape*                                Circular and Parabolic
              Physical Size*                        1.5 M
              Antenna Gain at 14 GHz*               44.3 dB

              Antenna Motion*                360° Rotation in Detection Mode Track
                                             Mode after Target Lock—on and Weapon—on

              Effective Area of Antenna
              Main Beam*                            1.0 M
              Side Lobe Gain *                      —10.0 dB
              Antenna height                        51 feet
                                     Receiver Parameters

              Noise Figure*                         8 dB
              Doppler Filter for Mach 1            31 kHz
              Interference Criteria               —1670BW/AM*/4 kHz


2.1 RADAR Side Lobe to Earth Station Side Lobe
                                                                                  F4



For this analysis the following formula was used to determine the interference signal coupled ‘to
the RADAR receiver.

                         P, = P,*G,*G,*S*A*/(4I*R)
Where,
P, = Earth Station spectral density signal at RADAR receiver front end, dBW/4kHz
P, = Earth Station transmitted spectral density, —27.8 dBW/ 4kHz or 1.66X10° Watts/4
      kHz
G, = Gain of RADAR antenna in direction of the Earth Station antenna, —10 dB or 0.1
G:= Gain of Earth Station antenna in direction of RADAR antenna, —10 dB or 0.1
S = Shielding Factor for berm and buildings in the vicinity of the earth station antenna,
      —15 dB or 0.0316
A     Wavelength of transmitted signal, —16.7 dB/M or 0.0213 meter
R     Minimum separation distance of antennas, meters: 13.3 miles or 21,409 meters

If we assume that the RADAR threshold sensitivity is based on a receiver bandwidth of 1 MHz
and a noise figure of 8 dB, the RADAR receiver sensitivity would be —106 dBm/MHz or —160
dBW/4 kHz. The calculation for the side lobe—to—side lobe antenna orientation for the minimum
separation distance shows that the interference level is well below the sensitivity of the RADAR
receiver. The calculated level is — 204.8 dBW/4 kHz. This level is 44.8 dB below the sensitivity
of the RADAR receiver.

From the results of the calculations and analysis of the RADAR side lobe to Earth Station side
lobe antenna orientation case, it can be concluded that this case will not produce interference to
the RADAR. Also, this case represents the most likely relative antenna orientation.

2.2 RADAR Main Beam to Earth Station Side Lobe

This relative antenna orientation is not very likely but it represents the most difficult to analyze
with respect to the interference criteria as presented in the FCC Report & Order 96—377.
Because of this the Comsearch technical staff reviewed the interference criteria with respect to
the shipboard RADAR. The review led to the conclusion that the interference criteria for
shipboard RADAR had to be evaluated with respect to more than just the levels from the
proposed Earth Station. The evaluation also had to include the electromagnetic environment the
RADAR transmitter was creating at the RADAR receiver from the terrain and objects in the area
of the Earth Station antenna. These RADAR echoes have to be compared with the levels
generated by the proposed Earth Station and the interference criteria of the FCC Report & Order.

In the Hauppauge, New York area the same structures that provide shielding for the signals
generated by the proposed Earth station also create very efficient RADAR targets with large
cross sectional areas. A RADAR antenna beam width of one—degree in the horizontal and
vertical plane will illuminate a target with a circular cross sectional area of 2400 Mat a range of
one mile. The buildings in the vicinity of the proposed Earth Station will produce large
reflections to the RADAR receiver. The RADAR signal reflected back to the RADAR receiver
would far exceed the signal generated from the proposed Earth Station and the interference
criteria of FCC Report & Order 96—377.


Whether the RADAR signals reflected by the terrain and buildings or the signal—generated by the
proposed Earth Station degrade the RADAR performance or produce false alarms is very
doubtful. The RADAR in question has Doppler processing that looks for moving targets with
specific velocity characteristics that both the stationary terrain, buildings and Earth Station
signals will not possess. The RADAR signals reflected and the Earth Station signals are not high
enough to saturate the receiver, effect AGC performance and/or change the front—end noise
characteristics of the system. Therefore, normal performance of the RADAR should be expected
off the coast of Long Island even in the presence of the proposed Earth Station transmissions. _

In order to show a comparison between the Earth Station signal generated toward the ocean,
RADAR reflections and the FCC Report & Order 96—377 criteria, calculations were performed
and presented in graphical form at the end of this Section. The United States Navy RADAR isa
classified system and therefore many of the parameters for the system were not known and could
not be obtained. Therefore, good engineering judgement was used in assuming values. Table2
lists the values used in the calculations. Assumed values used in the calculations are denotéd
with a (*). Values marked (**) were assumed, but not used in the calculations. Parameters used
in the calculation of the radiated Earth Station signals were taken from the values in Table 1 of
this report. Propagation of signals beyond the line—of sight used techniques derived from NBS
Technical Note 101.

To determine the RADAR reflection signal the reflection surface was assumed to be at the Earth
Station location rather than at the shoreline. The following formula was used.

                      P, = P,*G,*G,*A"*~/(410*R
Where,

P, = RADAR reflected spectral density signal at receiver front end, dBW/4kHz
P, = RADAR transmitted spectral density for a 1 usecond pulse width, 28.8 dBW/4kHz
     or 758 Watts/4 kHz
G, = Gain of RADAR transmit antenna, 44.3 dB, or 26,915
G,= Gain of RADAR receive antenna, 44.3 dB, or 26,915
A = Wavelength of transmitted signal, —16.7 dB/M, or 0.0213 meters
2   —= RADAR cross—sectional area of the object causing reflection, 10 dB/ M, or 10
       meter®
R = Range of target to RADAR, dB/M

The level of the Earth Station signal at the RADAR is calculated from the following formula:

                      Pa = (P.*G,)*S*OH/(4D*R)
And,
                      Pre= Pd*fqr


Where,
P,, = Power spectral density at radar receiver from the earth station, dBW/4kHz
A, = Effecl'gve area of RADAR antenna, dB/M" 0 dB for RADAR main beam, or 1
       mete


P4 = Earth Station radiated power spectral density at the RADAR, dBW/M*/4kHz
P. = Earth Station transmitter spectral density, —27.8 dBW/4kHz or 1.66X10° Watts/4
       kHz
G: = Gain of Earth Station antenna in the direction of the ocean, —10 dB or 0.1,
S = Shielding factor measured at each location, —15 dB or 0.0316
OH= Over—the—horizon propagation loss factor from NBS Technical Note 101, dB

Comments on the calculations: The cross—sectional area of the target which is the terrain,
buildings and trees near the earth station site was assumed to be 10 M‘ This is a very
conservative estimate based on the size of the buildings in the areas and the very large surfacge
area that the RADAR antenna would illuminate even at close ranges. At a one mile range the
surface area illuminated would be 2400 M*. The effective area of the antenna was taken to be 1
M this corresponds to a gain of 44.3 dB at 14 GHz and allows the direct comparison of the
received spectrum density of the radar reflection, the earth station radiated signal and the FCC
interference criteria. OH loss is a function of the antenna heights. The heights of the two
antennas used for the OH loss were 20° for the Earth Station and 51° for the radar antenna.

                  Table 3. Interference levels for Main Beam to Side Lobe

       Distance               Shielding      Earth Sta. Signal         RADAR Echo
        Miles                    dB            dBW/4 kHz                dBW/4 kHz
         13.3                    15              —156.7                   —112.0
         15.0                    15              —159.9                   —114.1
         20.0                    15              —167.5                   —119.1

2.3    RADAR Interference Conclusions

The calculations and analysis performed shows that the signal generated by the proposed Earth
Station in the direction of the ocean should have no degrading effect to the operation of RADAR
sharing the same frequency band on board United States Navy Ships. The reason for this
conclusion is two—fold. First, the interference criteria of FCC order 96—377 does not properly
take into account the operation of a RADAR as a transmit and receive system. The criterion as
set up is more appropriate for a system that is a receive—only system. The criterion evaluates the
earth station signal without considering the relative signal strength of the RADAR signal echo
compared to it. As shown in the analysis above for areas like Hauppauge, new York where there
will be terrain and man—made structures in the vicinity of the Earth Station the RADAR echoes
will exceed the earth station signal by orders of magnitude. This is true when the main beam of
the RADAR antenna is directed at the Earth Station. When the main beam of the RADAR is not
directed at the Earth Station, the signal emitted from the Earth Station coupled to the RADAR
receiver will be well below the threshold of the receiver. Second, the RADAR system contains
Doppler processing which will cause the RADAR to ignore stationary targets such as those
produced by the echoes from the buildings and terrain as well as the emissions from the Earth
Station.

The above conclusion presupposes that the RADAR and earth station will both share the 13.75 —
14.0 GHz Band. The RADAR band of operation is 13.40 — 14.0 GHz. By operating the
RADAR in the lower 350 MHz of the band any possibility of interference conflict to the
RADAR is eliminated.


                                      Hauppauge, NY

            —100
            —110
—=          —120
 &
E       *   -1 30                                                                                                        Reflection

 o L#       —140
 § x —150
t & —160
  o
g u. —170
 3           —180
&           1190
            _200                                                                                                  Sateilite Signat


            —210                           hn ns rmnnemn mm anerncmimemmenten nermmnmemean o   viemesmen e   .—             on remmacesaces


                                                    Distance (miles)




3.          Potential Impact to NASA‘s Data Relay Satellite System (TDRSS)

The geographic location of the GLOBECOMM Systems Earth Station (E990402) in Hauppauge,
New York is outside the 390 KM radius coordination contour surrounding NASA‘s White Sands,
New Mexico ground station complex. Therefore, the TDRSS space—to—earth link will not be
impacted by the GLOBECOMM Earth Station at Hauppauge, New York.

The TDRSS space—to—space link (13.772 to 13.778 GHz) band is assumed to be protected if an
earth station produces an EIRP less than 71dBW/6 MHz in this band. The 9.0—meter Earth
Station antenna will have a carrier EIRP of 72 dBW/ 36 MHz, which equates to an EIRP of 64.2
dBW/ 6 MHz. Therefore, no interference to the TDRSS space—to—space link should occur when
the Hauppauge Earth Station is transmitting.

4.          Potential Impact to NASA/NASDA Operations (Precipitation RADAR)

The Tropical Rain Measuring Mission (TRMM) Precipitation RADAR (PR) operates at two
frequencies 13793 and 13805 MHz with a bandwidth of 600 kHz at each frequency. The FCC
Report and Order 96—377 grants NASA protection to the spacecraft borne sensors like those used
for the TRMM in the 13.75 to 14.0 GHz band until January 1, 2000. The 9.0—meter antenna
Earth Station system will have an EIRP of 54.2 dBW/ 600 kHz

The ITU—R SA. 1071 states that the recommended threshold of interference at the two TRMM
frequencies is —150 dBW. The geographic location of the GLOBECOMM earth station antenna
is outside the TRMM PR "ground truth" exclusion zones described in ITU—R SA. 1071. For the
Hauppauge Earth Station antenna location, the antenna coupling to the space borne antennas can
be earth station sidelobe to TRMM PR sidelobe, and earth station side lobe to TRMM PR main


beam. The coupling to the TRMM PR main beam is the worst case; therefore, it will be the one
 calculated. The calculation will be made for an overhead pass of the TRMM PR satellite having
a +17° cross—track scan. The calculation will be made for scan angles of 0°, 8.5° and 17° and an
earth station elevation angle of 25.6° .


                            Table 4. Calculation Parameters for TRMM PR

The parameters for the calculation are:
TRMM Range @OScan Angle:                          350 km
TRMM Range @8.5¢ Scan Angle:                      354 km
TRMM Range @ 17 Scan Angle:                       366 km
TRMM Antenna Gain:                                17.70B1
Earth Station Elevation Angle:                    25.6°
9.0—meter Antenna Gain:                           60.3 dBi
Earth Station Side Lobe Antenna Gain:             32 — 2510g(O) or, > —10 dB
                                                  Where 0 is the angle between the Earth
                                                  Station antenna and the TRMM antenna.
Transmit Power                                    6.0 dBW/600 kHz
FSL* @ 350 km                                     166.2 dB
FSL @ 354 km                                      166.3 dB
FSL @ 366 km                                      166.6 dB

*FSL is free space loss
                                  Table 5. TRMM PR Calculated Results

                      9.0—meter Antenna Transmit Power =— 6.0 dBW/600 kHz

                              Earth Station Antenna Elevation 25.6°

Scan Angle        ES Antenna Gain    TRMM Gain        FSL        Power Received      Margin

      0°              —10.0 dBi        17.7 dBi     166.2 dB       —164.5 dBW       + 14.5 dB
     g. 50            —10.0 dBi        17.7 dBi     166.3 dB       —164.6 dBW       + 14.6 dB
     17.0°            —9.9 dBi         17.7 dBi      166.6 dB      —151.1 dBW       + 14.4 dB

From the calculated results for the TRMM PR the Hauppuage Earth Station will meet the
interference criteria for its planned transmit power. The earth station is within + 55° latitude, and
the elevation angle is 25.6°, which is below the maximum of 71° recommended in the ITU—R
SA.1071.

5.           Potential Impact to NASA Altimeter Operations

There are two types of airborne RADAR altimeters operating in the 13.75 — 14.0 GHz band that
are of concern with respect to interference from earth stations.               They are the TOPEX—
POSEIDON and the ERS—1/2. These RADAR altimeters are downward looking pulsed—RADAR
installed on orbiting spacecraft. These systems are used to very precisely measure range from
the satellite to the surface of the earth. In addition to the operational RADAR in this band, a
number of other systems are planned in the future. The parameters for the operational RADAR
in this band are listed below.


                       Table 6. Altimeter Interference Criteria

RADAR System                   Frequency   of Operation       Interference Criteria
TOPEX—POSEIDON (1)             13.60 GHZ   + 160 MHz          —117 dBW/320 MHz
TOPEX—POSEIDON (2)             13.65 GHz   +160 MHz           —130 dBW/320 MHz
ERS —1/2                       13.77 GHz   +165 MHz           —120 dBW/330 MHz

The orbiting spacecraft, with the RADAR altimeter, is assumed to be at an altitude of 800 km.
The slant range from the earth station to the spacecraft at the antenna elevation angle (25.6°) is
1851 km, when the earth station main beam illuminates the spacecraft. This is the worst case
alignment of the Earth Station antenna and the spacecraft RADAR antenna. It will occur when
the spacecraft travels through the main beam circle formed by the Earth Station antenna. The
time it takes the spacecraft to travel through this circle in space is a function of the 20—dB beam
width of the earth station antennas (the 20—dB beam width is used according to ITU Ap28
calculation methods) and the speed of the of the spacecraft. The spacecraft is traveling at 6.5
km/sec and the 20—dB beam width of the 9.0—meter antenna is estimated to be 0.37°. The
diameter of the circle in space formed by the 9.0—meter antenna at a range of 1851 km is 12 km.
The spacecraft will pass through the beam width of the earth station antenna in less than 2
seconds. During this time there may be a small blip of noise introduced into the RADAR display
output but it would be so transitory it may go unnoticed.

The availability requirement for the NASA altimeter data is 95%, which assumes that the
associated individual outages are brief and randomly dispersed over all observation times and
areas. If the outage were due to only one earth station the 95% availability would not be a
problem. However, the outage caused by multiple earth stations and other causes such as intense
rainfall must be accounted for in determining the net availability of the system. The earth station
interference will occur in a predictable manner for a given area so it cannot be considered
random. Because of its predictability and relatively short time duration, Earth Stations should
have very little impact on the operation of present RADAR altimeter systems, and processing
circuits and/or procedures can be designed in future systems to minimize the effect of the
interference from single or multiple earth stations.

In order to calculate the interference level to the altimeter radar, we will assume that the RADAR
antenna side lobe gain toward the earth station antenna is —10 dB. Since the earth stations signal
is narrow band compared to the RADAR bandwidth, the signals will be totally captured by the
RADAR receiver. The following parameters are used in the calculation:

      FSL for Earth Station Antenna:                      180.7 dB
      Atmospheric Absorption:                               0.2 dB
      EIRP 9.0—meter Earth Station Antenna:                72.0 dBW Digital Carrier


                              Table 7. Altimeter Calculated Results

         Earth Station 25.6° Elevation for 72.0 dBW Digital Carrier
    RADAR Receiver           Interference Level                Margin
TOPEX—POSEIDON (1)               —118.5 dBW                    +1.5 dB
TOPEX—POSEIDON (2)               —118.5 dBW                     —1.5 dB
ERS—1/2                          —118.5 dBW                    —11.5 dB

The comparison of the calculated levels to the interference criteria indicates that there will be
interference coupled to some of the altimeters. The highest interference levels will be to the
ERS—1/2 altimeter. The Earth Station interference effect will occur for less than 2 seconds. Even
though potential interference is predicted to be generated by the Earth Station at Hauppauge the
net result does not prevent the 95% availability of the RADAR altimeter data. The satellites
carrying the altimeters orbit the earth every 2 hours. If we assume that the satellite will pass
through the Earth Station main beam on each orbit, which is extremely unlikely, there will bea
loss of 2 seconds of data every 2 hours (7200 seconds). The loss in data availability for this
condition is .027 %. And the data availability with the Earth Station operating is 99.973%. This
is well above the 95 % data availability required and it is based on the very pessimistic
assumption that the satellite will pass through the earth station main beam on each orbit.

The Hauppauge, New York Earth Station is located outside the TOPEX—POSEIDON critical
exclusion zone as defined in the ITU—R Recommendation SA. 1071. The operational elevation
look angle for the earth station is 25.6°. This elevation angle is below the 71 —elevation angle
limitation required until January 1, 2001 in ITU—R Recommendation SA—1071.

6.      Potential Impact to NASA Scatterometer Operations

Scatterometers are spacecraft borne RADAR type devices that measure the near surface vector
winds over the ocean.     Wind data over the oceans is considered a critical parameter in the
determination of weather patterns and global climate. The overall availability requirement of the
scatterometer system is similar to the altimeter RADAR.        That is, some data loss is tolerable
when interference signals exceed interference thresholds. The scatterometers can lose 1% of the
ocean data from interference occurring systematically or 5% when the interference is occurring
randomly. The scatterometers operate at a center frequency of 13995 MHz + 1.44 MHz. There
are two types of antenna modes of operation, fan beam and spot beam. For fan beam operations
the aggregate interference threshold is — 174 dBW/2 kHz, while for spot beam operations, — 155
dBW/10 kHz. FSS earth stations should not exceed an EIRP density toward the scatterometer
orbit (over the oceans) of 25 dBW in any 2 kHz band between 13.99356 GHz and 13.99644
GHz. The Earth Station at Hauppauge, New York can produce an EIRP that is greater than 25
dBW/2 kHz but not in the scatterometer frequency band. The Earth Station will operate at
frequencies below the scatterometer‘s operational frequencies. Therefore, no interference is
anticipated to the NASA scatterometers.

7.       Coordination Issue Result Summary and Conclusions

The results of the analysis and calculations performed in this exhibit indicate that no interference
will occur between the earth station at Hauppauge, New York and the U.S. Navy RADAR


operations.   The results also show that there will be compatible operations with the NASA
systems. The only potential interference condition occurs to the NASA altimeters but it is shown
in this Exhibit that the data availability requirement of the altimeters will be little effected by the
interference generated.



Document Created: 2005-04-11 08:31:40
Document Modified: 2005-04-11 08:31:40

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