Attachment Exhibit B

This document pretains to SES-MOD-20100524-00636 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2010052400636_819072

                                              Exhibit For
                                      Vitacom Services Corporation
                                             Miami, Florida
                                Andrew Corporation 4.6 Meter Earth Station
                                           Call Sign: E090157

          Compliance with FCC Report & Order (FCC96-377) for the 13.75 - 14.0 GHz Band
                                   Analysis and Calculations

1.       Background

This Exhibit is presented to demonstrate the extent to which the Vitacom Services Corporation satellite
earth station in Miami, Florida is in compliance with FCC REPORT & ORDER 96-377. The potential
interference from the earth station to US Navy shipboard radiolocation operations (RADAR) and the
NASA space research activities in the 13.75 - 14.0 GHz Band is addressed in this exhibit. The parameters
for the earth station are as follows:

                          Table 1. Earth Station Characteristics

     •   Coordinates (NAD83):                     25° 55’ 25.7” North, 80° 13’ 04.6” West

     •   Satellite Location for Earth Station:     Telestar 11N at 37.5° W.

     •   Frequency Band:                           13750.0 – 14000.0 GHz

     •   Polarizations:                            Linear and Circular

     •   Emissions:                                5M00G7D

     •   Modulation:                               Digital

     Maximum Aggregate Uplink EIRP:               72.0 dBW

     •   Transmit Antenna Characteristics
            Antenna Size:                          4.6 meters in Diameter
            Antenna Type/Model:                    Andrew Corporation ESA46-124
            Gain:                                  55.0 dBi

     •   RF power into Antenna Flange:             17.0 dBW or 10.0 dBW/ MHz:
                                                   or -14.0 dBW/4 kHz (Maximum)

     •   Minimum Elevation Angle:
         Miami, Florida                            34.2° @ 115.3° Az. (Telestar 11N).

     •   Side Lobe Antenna Gain:                   32 - 25*log(θ)


Because the above uplink 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 two areas. These areas are noted in FCC Report and Order 96-377 dated
September 1996, and consist of (1) Radiolocation and radio navigation and (2) Data Relay Satellites.

Summary of Coordination Issues:

2) Potential Impact to Government Radiolocation (Shipboard Radar)
3) Potential Impact to NASA Data Relay Satellite Systems (TDRSS)


2.     Potential Impact to Government Radiolocation (Shipboard Radar)

Radiolocation operations (RADAR) may occur anywhere in the 13.4 - 14 GHz frequency band aboard
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/m2/4 kHz.

The closest distance to the shoreline from the Miami, Florida earth station is approximately 9.70 km east
toward the Atlantic Ocean. The calculation of the power spectral density at this distance is given by


       1.   Clear Sky EIRP:                   72.0 dBW
       2.   Carrier Bandwidth:                5.0 MHz
       3.   Transmit Antenna Gain:            -14.0 dBW/4 kHz
       4.   Antenna Gain Horizon:             FCC Reference Pattern
       3.   Antenna Elevation Angle:           34.2°

The proposed earth station will radiate interference toward the ocean according to its off-axis side-lobe
performance. A conservative analysis, using FCC standard reference pattern, results in off-axis antenna
gains of -6.2 dBi towards the Atlantic Ocean.


The calculated signal density at the shoreline, through free space is:

PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-
m2).
      = -14.0 dBw/4 kHz + (-6.2 dBi) – 10*log[4Π(9700m)2]
      = -110.9 dBW/m2/4 kHz + Additional Path Losses (~ 25.3 dB)
      = -136.2 dBW/ m2/4 kHz

Our calculations show additional path losses of approximately 25.3 dB including absorption loss and earth
diffraction loss for the actual path profiles from the proposed earth station to the nearest shoreline.


In an effort to analyze the effects of earth station transmissions on naval radar systems, power flux
densities were calculated from the earth station to the shipboard radars in increments from 6.0 miles to 60
miles (See Table 2). The calculation of interference level to the RADAR sidelobes was made at the initial
distance of 6.0 miles. A distance of 6.0 miles (9.7 Km.) was used as the initial increment because it is the
distance from the earth station site to the shoreline. This is the worst case condition. If the interference
level is below the criteria at this range, it will be below the criteria at all of the greater ranges. A power
flux density was also calculated from the shipboard radars to the shoreline and the reflection of the radar
transmissions back to the radar. Since this flux density concerns the transmission from the ship to shore
and back to the ship the mileage number is doubled. The power flux densities are based on the following
formulas:


Earth Station to Naval Radars

     PFD = PESGES   /   4p r²


 Where: PFD = Power Flux Density
        PES = Power of Earth Station (-14.0 dbW/4 kHz)
        GES = Worst Case Earth Station Gain Toward the Shipboard Radars
               (-6.2 dB)
         4p = 10Log(4p) = -11.0
          r = Distance from ES to radars in Meters [Used 20Log(r)]




Naval Radars to Shore and Reflection back to the Radar Source

   PFD =    PTGT / 4p (2r)² * (0.01 m²)


  Where: PFD = Power Flux Density
          PT = Power of Radar (Used 56.0 dBW for 1 MHz or 32 dBW for 4 kHz)
          GT = Gain of Radar (Used 44 dB)
            4p = 10Log(4p) = -11.0
            2r = Distance to Shoreline and Reflection back to Radar Source
        0.01m² = Size of the Radar Sectional Area of Target

Based upon calculations from the above formulas, it was determined that reflections of the radar
transmissions from the shoreline and back to the radar were 75.5 dB higher than the earth station
transmissions into the radar.

These calculations are presented in the tables below. This being the case, it can be concluded that in the
main beam, earth station operations should not be a problem for naval radar operations.


                                      Table 2

                              Flux Density
Distance from          Interference    Desired Radar Return    Radar Signal
 ES to Radar             From ES        from (0.01m)² Target   ES Interference
   (Miles)           (dBW/4 kHz/m²)        (dBW/4 kHz/m²)          (dB)

      6.0                -136.2                 -60.7               75.5
      8.0                -138.7                 -63.2               75.5
     10.0                -140.6                 -65.1               75.5
     15.0                -144.2                 -68.7               75.5
     20.0                -146.7                 -71.2               75.5
     30.0                -150.2                 -74.7               75.5
     40.0                -152.7                 -77.2               75.5
     50.0                -154.6                 -79.1               75.5
     60.0                -156.2                 -80.7               75.5

The calculated PFD for the 5 MHz emissions, which include 25.3 dB of additional path losses to the
shoreline location is –136.2 dBW/m2/4 kHz. If off axis, side lobe considerations are made, 44 dB was
used as the gain of the radar and -10.0 dBi was the radar antenna side lobe gain toward the direction of
the earth station. This additional -54.0 dB will create an equivalent PFD of -190.2 dBW/m2/4 kHz, which
is 23.2 dB lower than the –167 dBW/m²/4 kHz interference criteria of R&O 96-377.

Therefore, there should be no interference to the US Navy RADAR from the Miami earth station in both
the main beam and side lobe of the radar.




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

The geographic location of the Vitacom Services Corporation, Miami, Florida earth station 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 Vitacom Services
Corporation earth station in Miami, Florida.

The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if an earth
station produces an EIRP less than 71 dBW/6 MHz in this band. The maximum EIRP for the 5 MHz
carriers is 72.0 dBW, and the equivalent EIRP per 6 MHz segment for a 5 MHz carrier will remain at 72.0
dBW/6 MHz. Therefore, there will be interference to the TDRSS space-to-space link.

The applicant will need to avoid transmissions on frequencies 13.772 to 13.778 GHz in the transmit
spectrum.


4. Coordination Issue Result Summary and Conclusions

The results of the analysis and calculations performed in this exhibit indicate that compatible operations
between the earth station at the Miami, Florida facility, and the US Navy is likely.

However, potential interference into NASA’s systems will preclude operations on frequencies 13772.0 to
13778.0 MHz.

                                                 Table 3

            Excluded Frequency Range for Vitacom Services Corporation Earth Station

              System                        Frequency Restriction
              TDRSS                         13.772-13.778 GHz (see Note 1)


Note 1: In order to meet the 71 dBW/6 MHz interference criteria, the earth station would have to be
limited to a maximum total EIRP of 71.0 dBW. Since the earth station does not meet that requirement,
operations between frequencies 13772.0 and 13778.0 MHz will not be permitted.

No interference to US Navy RADAR operations from the Miami, Florida earth station will occur.



Document Created: 2019-04-18 15:33:22
Document Modified: 2019-04-18 15:33:22

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