Attachment Report

This document pretains to SES-MOD-20110302-00232 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2011030200232_871544

Prepared for the Federal Communications Commission Application for New License Authority tor Earth Stations on Board Vessels CapRock Communications, Inc,

TABLE OF CONTENTS 525.222 (A)(1 )(r)(A-C) SPECTRAL DENSITY LIM 1TS.......... SpecrRRT DENSITY ENVELOPES ...,.,.,,..,..2 525.222 (A)(1)(ilXA) ANTENNA POINTING ERRoR s25.222 (AX1 )(ilr)(A) AUToMATIC SHUT-oFF.... 3 s25.222 (AX3) U,S. CONTACT lN F0RMATION .................. 525.222 (A)(4) VESSEL TRACKING FuNcïoNALrry oF VEssEL TRAcK¡¡o Svsreu. ............... 3 s25.222 (AX5) VESSELS 0F FoREIGN REGISTRY s25.222 (AX6) U.S, CONTROL OF ESV HUB EARTH STATION....... ........................ 4 s25.222 (B)(lXr) E|RP DENSITY TABLES s25.222 (BX1 )(il) CAPROCK CERTIFICATI0N .................. s25.222 (BX1 )(ilr) MANUFACTURER CERTIFICATION 525.222 (B)(3) ESV GEOGRAPHIC AREA 0F 0PERATIoN.. s25.222 (BX4) Po|NT 0F CoNTACT s25.222 (B)(s) RADTATIoN EXPoSURE LlMlrS s25.222 (C) FREQUENCY CO0RDINATI0N ........ 525.222 (D) FREQUENCY COoRDINATIoN APPENDIX B - DECLARATION OF CAPROCK ,.....9 APPENDIX C. USE OF NON.U,S, SATELLITES......... 10 APPENDIX D - FAA N0T1F1CAT10N................... ll

INTRODUCTION CapRock Communications, lnc. ("CAPROCK'), pursuant to 47 C.F.R. S 25.117 of the Rules and Regulations ("Regulations") of the Federal Communications Commission ("Commission"), respectfully requests the modifìcation of an existing license to operate new Ku-Band Earth Station on Vessels ("ESVs") throughout US channels and waterways, the Gulf of Mexico, the Caribbean Sea, the Atlantic Ocean, and the Pacifìc Ocean. The proposed ESVs seek to operate inlhe11.7-12.2GH2 and 14.0-14.5 GHz ("Ku-Band")frequency bands to communicate with already licensed hub stations located in the United States and operated by CAPROCK. The proposed antenna ("Antenna") is: o Seatel 75cm ("Seatel 75cm")- Manufactured by Cobham SATCOM-MaI|ne Systems. The Antenna is capable of providing stabilized tracking. Seatel has performed tests and generated the EIRP spectral density tables and plots here presented. Furthermore, Seatel has declared that if the input power density to the feed of the Antennas is limited to the figures stated below, the Antenna will meet the requirements of Section 25.222 of the Regulations. Antenna Model Maximum EIRP Spectral Densitv . Seatel 75cm -21.6 dBWl KHz This report together with its attachments and exhibits addresses the requirements of Section 25.222 of hhe Regulations as well as the underlying ESV Order and Order on Reconsideration.r 925.222 (aXlXiXA-c) SPECTRAL DENSITY LIMITS ',4n ESV sysfem shall not exceed the off-axis EIRP spectral-density limits and conditions deftned in paragraphs (a)(t)(t)(t) throush (a)(t)(t@) of fhis secfion.' 47 c.F.R 525.222(a)(1)(i)(A). Spectral Densitv Envelopes The spectral density envelopes specifìed in $25.222(a)(1)(i) are as follows:z . 15 - 25log(0) dBW / 4KHz for 1 .5'< e = 7 .0o o -$ dBW / 4KHz for 7.0'< 0 < 9.2o . 18 - 21log9) dBW / 4KHz for 9.2"3 0 < 4Bo . -24 dBW/ KHzfor 4ï'<e<85o . -14 dBW/4KHzfor 85'<0s180o The peak EIRP of an individualsrdelobe may not exceed the envelope o o. For 0 > 7o, the envelope defined above for 0 between 1.5 and 7.0 may be exceeded by no more than 10% of the sidelobes, provided no individual sidelobe exceeds the envelope bv more than 3dB. I In the Matter of Procedures to Govern the tLse of Satellite Earth Stations on Board Vessels in the 5925-6425 MHz/3700-4200 MHz Bands and 14.0-14.5 GH?/I1.7-12.2 GHz Bands, Report and Order, FCC 204-286, Adopted December 15, 2004, Released January 6, 2005; Order on Reconsideration, FCC 09-63, Adopted July 30, 2009, Released July 31,2009. 2 The actual formula in the statute includes a log(N) term which is subtracted from the spectral density. Since in this case, the system is TDMA and N=l for TDMA, the log(l) terms goes to zefo.

The envelope may be exceeded by no more than 10% of fhe slde/obes provided no individual sidelobe exceedsthe gain envelope given above by more than 6dB. The region of the main reflector spillover energy is to be determined as a single lobe and shall not exceed the enveloped more than 6dB. 525.222 (aXlXiiXA) ANTENNA POINTING ERROR "Each ESV transmìtter shall maintain a pointing error of less than or equal to 0.2" between the orbital location of the target satellite and the axis of the main lobe of the ESV antenna." 47 C.F.R 525.222(a)(1)(i¡)(A). According to Seatel, the Seatel 75cm will maintain a stabilization pointing accuracy of better than 0.2 degrees under specified ship motion conditions. See Appendix A - Declaration of Cobham SATCOM, Seatel, lnc,, Paragraph 4. 925.222 (aX1 XiiiXA) AUTOMATIC sHUT-OFF ".,, all emissions from fhe ESV shall automatically cease within 100 mr'l/rseconds if the line angle between the orbital Iocation of the target satellite and the axis of the main lobe of the ESV antenna exceeds 0.5o, and transmission will not resume until such angle is /ess fhan 0.2'.' 47 C.F.R 525.222(a)(1)(¡¡i)(A) According to Seatel, the Seatel 75cm will automatically cease transmissions within 100 milliseconds if the pointing error should exceed 0.5 degrees and will not resume transmissions until the error drops below 0.2 degrees. See Appendix A - Declaration of Cobham SATCOM, Seatel, lnc., Paragraph 5. 525.222 (aX3) U,S. coNTAcT INFORMATION "There shall be a point of contact in the United Sfafes, vvlh phone number and address included with the application, available 24 hours a day, seven days of week, with authority and ability to cease a// emissions from the ESVs, eifher directly or through the facilities of a U. S. Hub or a Hub located in another country with which fhe U. S. has a bilateral agreement that enables such cessafion of emlssions. " 47 C.F.R $25.222(a)(3). CapRock Communications, lnc. Network 0perations Cenler 4400 S. Sam Houston Pkwy. E. Houston, Texas 77048 (832) 668-2300 phone CAPROCK personnel, either via a network port or an outof-band management system, have the authority and capability to remotely access equipment on the ESV to terminate emissions in case of suspected interference. 525.222 (a)(4) VESSEL TRACKING "For each ESV transmitter a record of the ship location (i.e. latitude/longitude), transmit frequency, channel bandwidth and satellite used sha// be time annotated and maintained for a period of nof /ess than 1 year, Records will be recorded at time interuals no greater than every 20 minutes while the ESV ls transmitting. The ESV operator will make this data available upon request to a coordinator, fixed sysfem operator, fixed-satellite sysfem operator, NTIA, or the Commissìon within 24 hours of the request." 47 C.F.R. 525.222 (dØ). Functionalitv of Vessel Trackinq Svstem CAPROCK has designed a system to record the vessel's location, transmit frequency, channel bandwidth and satellite. The system records this information every 20 minutes. This data will be stored locally and will be uploaded to CAPROCK's Network Management System (NMS) on a regular basis. CAPROCK can make this data available within

24 hours of a request by a coordinator, fixed system operator, fìxed-satellite system operator, NTIA, or the Commission. GPS TX Frequency & Bandwidth information Time & Date lnformation Figure 1. Vessel Tracking Network Configuration 925.222 (a)(5) VESSELS 0F FOREIGN REGISTRY "ESV operators communicating vyifh yesse/s of foreign registry must maintain detailed information on each vesse/'s country of registry and a point of contactforthe relevant administration responsible for licensing ESVs.' 47 C.F.R. $25.222 (a)(5). ln the event CAPROCK must operate foreign-registered ESVs, it will maintain detailed information on each vessel as well as a point of contact for the relevant adminiskation responsible for licensing the ESV. 525.222(a)(6) U,S. CONTROL 0F ESV HUB EARTH STAT|ON "ESV operators shall controlal/ ESVs by a Hub eañh station located in the United Stafes, excepf that an ESV on U.S.- registered yesse/s may operate under control of a Hub eafth station location oufside the United States provided the ESV operator maintains a point of contact within the United Sfafes fhaf will have the capability and authority to cause an ESV on a U.S.-regrsfered vesse/ fo cease transmitting if necessary.' 47 C.F.R. $25.222 (a)(6). The Antenna operated by CAPROCK will be conholled by the earth station listed below: Callsion Diameter Location Antenna lD E030279 13.1m Houston, TX* 12.1M E030253 9.3m Houston, TX* 1 -4400 S. Sam Houston Pkwy. E., Houston, TX 77048

T14 (com) Al saun N Vertex 9.3m Seatel 75om E030253 (500 units) Figure 2. Network Diagram — Vertex 9.3m Hub cas gam Vertex 13. 1m Seatel 75m E030279 (500 units) Figure 3. Network Diagram — Vertex 13.1m Hub §25.222 (a)(7) 10.0541.2GHz ‘In the 10.95—11.2 GHz (Eerth—toSpace) frequency bands ESVs shall not claim protection from interference from any authorized terrestrial stations to which frequencies are either already assigned, or may be assigned in the future."

CAPROCK will not claim protection from interference in the 10.95-1 l.2G1zfrom any authorized terrestrial stations to which frequencies are already assigned or may be assigned in the future. s25.222 (b)(r)(i) EIRP DENSITY TABLES "Any ESV appticant fitting an apptication pursuant to paragraph (a)(1) of this section must file three tables showing the off-axis EIRP levet of the proposed earfh station antenna in the dìrection of the place of fhe GSO; the co-polarized E1RP in the etevation ptane, that is, in the ptace perpendicular to the plane of fhe GSO; and cross-polarized EIRP. In each table, the EIRP level must be provided at increments of 0.1" for angles between 0' and 10' off-axis, and at increments of 5'for angles between 10" and 180" off-axis. .' 47 C'F'R 525.222(b)(1)(¡). CAPROCK has provided spectraldensity tables as wellas charts as exhibits to Form 312 of the underlying application. Such tables and charts were generated by Seatel for the Seatel 75cm antenna. s25.222 (b)(1 Xii) CAPRoCK CERTIFICATIoN 'A in Schedule B, that the ESV antenna conforms to the gain pattern criteria of $25.209 (a) and (b), that, ce¡fification, combined with the maximum input power density catculated from the EIRP density /ess fhe antenna gain, which is entered ìn Schedute B, demonstrates that the off-axis EIRP density envelope set forth in paragraphs (a)(l)(t)(l) through (a)(t)(¡)(C) of fhrs sectlon witt be met under the assumpflon that the antenna is pointed to the target satellite." 47 C. F. R 525. 222(b) (1 ) (ii). See Appendix B - Certification of CAPROCK s25.222 (b)(1 )(ii i) MAN U FACTU RER C ERTIFICATIoN "An ESV applicant proposing to imptement a transmitter under paragrapn @0(¡il(4 of fhis sectlon, must provide a ceñification from the equipment manufacturer statíng that the antenna tracking system will maintain a pointing error of /ess fhan or equal to 0.2" between the orbitat location of the target satellite and the axis of the main lobe of the ESV antenna and the antenna tracking sysfem is capabte of ceasing emlssions withinl00 milliseconds in the angle between the orbitat location of the satell'tte and the axis of the main lobe of fhe ESV antenna exceeds 0.5'.' 47 C.F.R s25.222(b)(1)(¡i¡). According to Seatel, the Seatel 75cm will automatically cease transmissions within 100 milliseconds if the pointing enor should exceed 0,5 degrees and will not resume transmissions until the error drops below 0.2 degrees, See Appendix A - Declaration of Cobham SATCOM, Seatel, lnc., Paragraph 5. 925.222(bX3) ESV GEOGRAPHIC AREA 0F oPERATION "There shall be an exhibit inctuded with the application describing the geographic area(s) in which the ESVs w// operate." 47 C.F.R 525.222(b)(3). The geographic area where the ESVs will operate is in US channels and waterways, the Gulf of Mexico, Carlbbean Sea, Atlantic Ocean, and Pacifìc Ocean.

Figure 4, US channels and watenrays, the Gulf of Mexico, Caribbean Sea, Atlantic Ocean, and Pacific Ocean 525.222 (bX4) Po|NT 0F CoNTACT "The point of contact referred to in paragraph (a)(3) of this section and, if applicable paragraph (a)(6) of this secflon must be ìncluded in the application.' 47 C.F.R 525.222(b)(4). lncluded s25.222 (b)(s) RADTATION EXPoSURE LIMITS 'ESVs fhaf exceed the radiation guidelines of 1.1310 of thìs chapter, Radiofrequency radiation exposure limiß, must provide, wtth their environmentalassessmenl a plan for mitigation of radiation exposure to the extent required to meet those guidelines." 47 C.F.R 525.222(b)(5). See Exhibit to Form 312 of the underlying application. 525.222 (c) FREQUENCY COORDINATION "Operations of ESVs in the 14.0-14.2 GHz (Eafthto-space) frequency band within 125 Km of the NASA IDRSS facilities in Guam ... or White Sands, New Mexico... are subject to coordination through the National Telecommunications and lnformation Administration (NTIA) lnterdependent Radio Advisory Commtttee (IRAC). [U]pon pubticnoticefromthe Commlssion, allKu-band ESVoperafors mustceaseoperations...." 47 C.F.R. $25.222(c). The ESVs operated by CAPROCK will not operate within 125 Km of the NASA TDRSS facilities in Guam or White Sands, New Mexico. s25.222 (d) FREQUENCY COORDINATION "Operations of ESVs inthe 14.47-14.5 GHz (Eafth-to-space)frequency band within a) 45Km of the radio observatory on St. Croix, Virgin lslands...; b) 125 Km of the radio obseruatory on Mauna Kea, Hawaii ...; and c) 90 Km of the Arecibo Obseruatory on Pueño Rico ... are subject to coordination through the National Telecommunications and lnformation Administration (NTIA) lnterdepañment Radio Advisory Committee (IRAC).' 47 C.F.R. 525.222 (d). The ESVs operated by CAPROCK will not operate within 48 Km of the radio observatory on St. Croix; within 125 Km of the radio observatory on Mauna Kea; or within 90 Km of the Arecibo observatory on Puerto Rico. ESVs operated by CAPROCK will operate in the Gulf of Mexico, US channels and watenivays, the Caribbean Sea, Atlantic Ocean and Pacific Ocean as described above.

APPENDIX A. DECLARATION OF COBHAM SATCOM, SEATEL, INC. Cobh¡m SATCOM Marine Systems Sea Tel Products 4030 Nelson Ave., Concord Califomi4 94520, USA Ti +l (925) 798-7979 F: +l (92s) 798-7986 Declaration of Cobham SATCOM. Sea Tel. Inc. 1. Cobham SATCOM - Marine Systems, SeaTel Products designs, develops, manufactures and services marine stabilized antenna systems for satellite commrmication at sea. These products are in turn used by our customeni as paú of their Ku-band Earth Station on Vessels (ESV) networks. , FCC regulation 47 C.F.R. ç 25.222 defines the provisions for blanket licensing of ESV antel:nas operating in the Ku Band, This declaration covers the requireme'nts for meeting 925.222 (a)(1)bythe demonstrations outlinedinparagraphs (bX1XÐ and (b)(l)(iü). The requirements for meeting 5 25.222 (aX3)-(aX7) are left to the applicant. The paragraph numbers in this declaration tefer to the2009 version of FCC 47 C.F.R. 5 25.222. J. Sea Tel hereby declares that the ântennas listed below will meet the off-axis EIRP spectral densityrequiremsnts of $ 25.222 (aXtXÐ with an N value of 1, when the foliowing Input Power specfral density limítations are met: 0.6 Meter Ku Band, Models2406 and USAT-Z are limited to -21.6 dBW/4kJIz 0,75 Meter Ku Band, Model USAT-3O is limited to -21.6 dBW/AkIlz 1.0 Meter Ku Band, Models 4003, 4006 and 4009 arç limited to -16'3 dBW/4ffi2 1.2 MeterKu Band, Models 5009 and 4996are limited to -14.0 dBwl{kÍlz 1.5 Meter Ku Band, Models 6006 and 6009 are limited to -14.0 dB'W4kHz 2.4 Meler Ku Band, Model 9797 is limited to -14.0 dBW4kHz Sea Tel hereby declares that the antennas referenced inparagraph 3 above, will maintain a stabilízation pointing alørrzcy of better thân 0.2 degrees under specified ship motion conditions, thus meeting the requirements of $ 25.222 (aXlXiÐ. Sea Tel hereby declares that the antemas referenced inpangraph 3 above, will automatícally cease transmission within 100 milliseconds if the pointing error should exceed 0.5 degrees and will not resume 1¡ansmission until the error drops below 0'2 degrees, tlrus meeting the requirements of $ 25.222 (a)(l)(iü). Sea Tel maintains all relevant test data, which is available upon reqrrest, to verify these declarations. By: Chief Engineer, Sea Tel Products Cobham SATCOM, Marine Systems

APPENDIX B - DECLARATION OF CAPROCK l, David Bunting, VP of Global Technology Development and Planning at CapRock Communications, lnc., certify that the ESV antenna proposed in the underlying application conform to the gain pattern criteria of 47 CFR $25.209 (a)and (b), that, combined with the maximum input power density calculated from the EIRP density less the antenna gain, which is entered in Schedule B of Form 312, demonstrates that the off-axis EIRP density envelope set forth in paragraphs 47 CFR $$25.222(a)(1)(i)(A) through (a)(1)(i)(C) of this section will be met under the assumption that the antenna is pointed to the target satellite. ln addition, the engineering calculations described in this report are true and correct and are satisfactory in light of 47 CFR 525.222. ------7 David Bunting

APPENDIX C. USE OF NON.U.S. SATELLITES CAPROCK specif¡es, pursuant to $ 25,137(a) of the Commission's Rules, that the only non-U,S. licensed satellites to be accessed by the earth station proposed in the instant application are those included on the FCC's Permitted List and eligible for ALSAT designation. 10

APPENDIX D - FAA NOTIFICATION Pursuantto 47 C.F.R. S 17.14 (b)of the Regulations, FederalAviation Administration (FAA)notification is not required because all the antenna shuctures in this application will be less than 6.1m in height, 11


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Document Modified: 2011-02-23 12:13:42
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