Attachment Exhibit A

This document pretains to SES-MOD-20101208-01520 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2010120801520_855912

Comtech Mobile Datacom Corporation FCC Form 312 Exhibit A, Page 1 of 2 E990143 Modification Application Description of Application, Frequencies Requested, Services to Be Provided, Section 25.137 Information, Radiation Hazard Study, and Public Interest Showing — Items 24, 28, 42, and 43 Description of Application; Frequencies Requested By this Application, Comtech Mobile Datacom Corporation ("CMDC") requests authority to modify its existing blanket license E990143. The purpose of this modification is to extend the term of this license, which currently expires on January 18, 2011. CMDC asks that the license be extended for two (2) years or until both MSAT—1 and MSAT—2 cease operation, whichever occurs first. E990143 gives CMDC authority to operate up to 25,000 mobile earth station terminals ("MESs" or "MET‘s") in portions of the L—band (1525—1544/1545—1559 MHz and 1626.5— 1645.5/1646.5—1660.5 MHz) on MSAT—1 and MSAT—2 in CONUS, Alaska and Hawaii.‘ In granting certain modifications to this license, the FCC also granted CMDC temporary waivers concerning Footnotes US308 and US315 of the United States Table of Frequency Allocations and Section 25.136(d) of the FCC Rules. Per the Commuission‘s Order and Authorization in IB File No. SES—AMD—20070907—01251, DA 09—906, rel. May 15, 2009 ("CMDC Order‘), if CMDC wishes to continue to operate the MET‘s on this license beyond January 18, 2011, it must file a new modification application and justify its need to continue to operate under a waiver. CMDC Order at [ 8b. CMDC‘s waiver request is provided in Exhibit B. As discussed in Exhibit B, today only one (1) of CMDC‘s MET models, the MTM202, requires a waiver, and only when this terminal is operated outside of the continental U.S. ("CONUS"). There are only about 900 MTM202 MET‘s in existence today, and no additional MTM202s are being built. Worst case, the MTM202 requires only 3.6 seconds to shut down. This decrease in the number of MET‘s requiring a waiver is the result of (a) the May 13, 2009 determination of the National Telecommunications and Information Administration ("NTIA") that three (3) seconds, not one (1) second, is the minimum time for ceasing transmissions in compliance with the real—time preemptive requirements for aeronautical and maritime emergency communications," and (b) certain modifications CMDC has made to specific MET models. All CMDC MET‘s other than the MTM202 comply with NTIA‘s new requirements and thus do not require a waiver of the real— 1 In addition to E990143, CMDC currently holds two (2) other blanket MET licenses, E090029 and E090027, that give CMDC authority to operate MET‘s in the L—band. The total number of MESs authorized under all three (3) licenses is 25,000. See Letter of Karl B. Nebbia, Associate Administrator, Office of Spectrum Management, U.S. Department of Commerce, NTIA, to Mr. Julius Knapp, Chief, Office of Engineering and Technology, FCC, May 13, 2009 ("NTIA 2009 Letter‘). DCOL/GRIFJ/A29204.3

Comtech Mobile Datacom Corporation FCC Form 312 Exhibit A, Page 2 of 2 E990143 Modification Application time preemption and priority access requirements. The MTM 202 complies with NTIA‘s new requirements, and thus does not require a waiver, when operated in CONUS. The CMDC Order at [ 7 requires CMDC to submit an analysis of its MET operations since the grant of the CMDC Order showing the number of packets each month having a transmission duration of 1 second or longer since the release of the CMDC Order. CMDC is preparing this analysis and expects to submit it within the next two (2) weeks. Services to be Provided CMDC will use its E990143 license to provide the same types of services that CMDC is currently providing under E990143. At present, CMDC provides mobile packet data communications services to government and commercial customers throughout the United States and overseas. The vast majority of CMDC‘s terminals have been deployed in support of several applications for the U.S. military and operate outside of the U.S. In particular, CMDC‘s MET‘s support the U.S. Army Logistics Command‘s Movement Tracking System ("MTS"). MTS is currently being used by U.S. forces in Afghanistan and around the world for near real—time messaging and location tracking of mobile assets. In addition, pursuant to contracts with a major U.S. prime contractor and related subcontractors, as well as contracts with the U.S. Army, CMDC‘s products and services have been integrated into the U.S. Army‘s Force XXI Battle Command, Brigade and Below ("FBCB2") command and control systems, also known as Blue Force Tracking ("BFT"). Section 25.137 Information; Radiation Hazard Study CMDC has previously provided Section 25.137 information (for MSAT—2, which is licensed by Canada) and a radiation hazard study in connection with E990143. There has been no change to this previously provided information and thus CMDC incorporates this information from its prior filings by reference. Public Interest Showing Grant of this Application will serve the public interest, as it will enable CMDC‘s customers, including but not limited to the U.S. Army, to continue to use the services that CMDC provides with these MET‘s on MSAT—1 and MSAT—2. DCOL/GRIFJ/A29204.3


Document Created: 2019-04-11 19:11:53
Document Modified: 2019-04-11 19:11:53
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