Attachment Report

This document pretains to SES-MOD-20120126-00097 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2012012600097_936306

t Prepared for the Federal Communications Commission Application for Modification of Authority for Earth Stations on Board Vessels Hanis-GapRock Communications, Inc.

TABLE OF CONTENTS CHARTS........ s25.221 (AXIX|XA.C) E|RP DENSTW ......................2 s25,221 (AX1XilXA) PoTNTTNG ERR0R.......... .........3 s25.221 (AX1XilrXA) AUTOMATTC SHUT oFF..... 3 s25.221 (AX3) U,S, CONTACT INFORMATION s 25.221 (AX4) VESSEL TRACKTNG. FUNcTIoNALITY oF VESSEL TRAOKING SYSTEM. 925.221(AXs) VESSELS OF FORETGN REGTSTRY. s25.221 (AX6) U.S. CONTROL OF ESV HUB EARTH STATTON s25,221 (AX7) FREQUENCY C0ORDtNATr0N........... s25,221 (AX8) VESSEL WE|GHT........ s25.221 (AXg) OPERATIONS WHILE DOCKED s25,221 (AX10) PRETECTToN FROM TNTERFERENCE s25,221 (4X11) CoORD|NAT|ON WTTHN 200KM s25.221 (AX1 2) AUTOMATTC CEASE OF TRANSMTSSTONS ........... s25,221 (B)(1Xr) SPECTRAL DENSTTYTABLES s25,221 (BX3) ESV GEOGRAPHTC AREA OF OPERAT|ON.. 7 s25,221 (BX4) PO|NT OF CONTACT 8 s25.22',t (BXs) ANTENNA RADIATION GUIDELINES ....................... 9 APPENDIX A - USE OF NON.U,S, SATELLITES.. ..10

INTRODUCTION Hanis CapRock Communications, lnc. ("Harris-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 modification of an existing license to operate new C-Band Earth Station on Vessels ("ESVs") throughout US channels and watenivays, the Gulf of Mexico, the Caribbean Sea, the Atlantic Ocean, and the Pacific Ocean. The proposed ESVs seek to operate in the 3700-4200 MHz and 5925-6425 MHz ("C-Band") frequencies. Furthermore, ESVs plan to communicate with a licensed hub station located in Houston, Texas and operated by Harris-CapRock. Harris-CapRock is proposing to use the following ESVs: Orbit 7108 Q.an) - C-Band 250 systems Orbit 7109 Q.afi- C-Band 250 systems The Orbit C-Band antennas do not strictly comply with Section 25.209 of the Regulations. Consequently, Harris- CapRock will operate the antennas at reduced transmit power levels so as to decrease the off-axis Effective lsotropic Radiated Power (EIRP) density. At the proposed reduced power levels, the antennas meet the requirements of Section 25.221 of the Regulations as wellas the underlying ESV Orders.t Harris-CapRock now proceeds to address each pertinent part of Section 25.221 of lhe Regulations. 525.221 (aXlXiXA-c) EIRP DENSITY CHARTS "An ESV sysfem sha// not exceed the off-axis EIRP spectral-density limits and conditions defined in paragraphs (4 thro ugh (a) (t ) (¡) (c) of fhr.s secfion. (a) (t ) (D The spectral density envelopes specified in $25.221(a)(1)(|)(A-C) are as follows:2 azímuth . 26.3 - 25log(0) dBW / 4KHz for 1.5'< g < 7.0o . 5.3 dBW / 4KHz for 7 .0 '< 0 < 9.2o . 29.3 - 25log(0) dBW / 4KHz for 9.2o< g < 48o . -12.7 dBW / 4KHz for 48"< 0 < 180o Srde/obes The peak eirp value of an indívidualsidelobe may not exceed the envelope for 0 between 1.5o and 7.0o. For 0 > 70, the envelope may be exceeded by no more than 10% of the srde/obes, provided no indivídualsidelobe exceeds the envelope given above by more than 3dB. Slde/obes The envelope may be exceeded by no more than 10% of the sr'de/obes provided no individual sidelobe exceeds the gain envelope gíven above more than 6dB. I In the Maxer of Procedures to Govern the Use of Satellite Earth Stations on Board Vessels in the 5925-6425 MH?/3700-4200 MHz Bands and 14.0-14.5 Gh?/l1.7-12.2 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 ftom the spectral density. Since in this case, the system is TDMA and N=1 for TDMA, the log(1) terms goes to zero.

525.22't (a)(1)(ii)(A) PoINTING ERROR "Each ESV transmitter shall maintain a pointing enor of /ess than or equal to 0.2o between the orbital location of the target satellite and the axis of the main lobe of the ESV antenna." 47 C.F.R $25.221(a)(1)(¡i)(A) Please refer to manufacturer declaration of conformity provided as an exhibit to the underlying application. S25.221 (a)(1)(iii)(A) AUTOMATIC sHUT oFF "A// emrssions from the ESV sha// automatically cease within 100 mílliseconds if the angle between the orbital location of the target satellite and the axis of the main lobe of the ESV antenna exceeds 0.5o, and fransmrsslon will not resume until such angle is /ess fhan or equalto 0.2o.' 47 C.F.R 525.221(a)(1)(¡i¡)(A) Please refer to manufacturer declaration of conformity provided as an exhibit to the underlying application. 525.221 (a)(3) U,S. CONTACT INFORMATION "There shall be a point of contact in the United Sfafes, øfh phone number and address, available 24 hours a day, seven days of week, with authority and ability lo cease a// emrssions from the ESVs, e/her 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 ernrsslons." 47 C.F.R 525.221(a)(3) Harris-CapRock Communications, lnc, 4400 S. Sam Houston Pkwy. E. Houston, TX77048 (832) 668-2300 Phone Email: NOCHou@Harris.com Harris-CapRock personnel, either via a network port or an oulof-band management system, have the authority and capabilityto remotely access equipment on the ESVs to terminate emissions in case of suspected harmful interference. S 25.221 (a)(a) VESSEL TRACKING "Foreach ESVfransmiffer a record of the ship location (i.e.latitude/longitude),transmitfrequency, channelbandwidth and satellite used shall be time annotated and maintained for a period of not /ess than 1 year. Records will be recorded at time interuals no greater than every 20 ninutes while the ESV ls fransmfifrng, The ESV operator will make this data available upon request to a coordinator, fíxed system operator, fixed-satellite system operato¡ NTIA, or the Commission within 24 hours of the requesf." 47 C.F.R. 525.221 (4U) Functionalitv of Vessel T rackinq Svstem Hanis-CapRock has implemented a system to record the vessel's location, transmit frequency, channel bandwidth and satellite. The system records this information every 20 minutes. Hanis-CapRock can make this data available within 24 hours of a request by a coordinator, fixed system operator, fixed-satellite system operator, NTIA, or the Commission. 1. An external Global Positioning System (GPS) is deployed with every one of Hanis-CapRock's stabilized antennas. The GPS feeds position information to a Terminal Server that also performs a basic logging function. As the Terminal Server receives raw GPS data, it is spooled to a file. 2. The data received from the GPS is in NMEA-0183 standard (National Marine Electronics Association). NMEA-0183 is a voluntary industry standard that defines electrical signal requirements, data transmit

protocol, timing and specific sentence formats for a 4800 baud serial data bus. NMEA has become a standard protocolfor interfacing navigational devices like a GPS, NMEA settings for RS232 interface are: Baudrate: 4800 Data bits: I Stop bits: 1 or 2 Parity: none Handshake: none Also included in the daily file are the satellite name, frequency, channel bandwidth, time and date. The satellite name is manually entered at commissioning and would be updated if the satellite changes. This information is kept at a server located at the Harris-CapRock NOC. The transmit frequency and channel bandwidth are extracted from the satellite modem. The time and date are retrieved from the Terminal Server. Once the file is received at the Hanis-CapRock NOC via File Transfer Protocol (FTP), the date is formatted in a Structured Query Language (SaL) database. This database is backed up daily. GPS Bandwidth information Time & Date lnformation Figure 1. Vessel Tracking Network Configuration S25,221 (aX5) VESSELS OF FOREIGN REGISTRY 'ESV operators communicating wfh yesse/s of foreign registry must maintain detailed information on each vesse/'s country of registry and a point of contact for the relevant administration responsible for licensing ESVs.' 47 C.F.R. $25.221 (a)(5) ln the event Harris-CapRock must operate foreign-registered ESVs, it will maintain detailed information on each vessel as well as a point of contact for the relevant administration responsible for licensing the ESV. 525.221 (a)(6) U.S. CONTROL OF ESV HUB EARTH STATION "ESV operators shall controlal/ ESVs by a Hub eañh station located in the United Sfafes, excepf that an ESV on U,S.- registered vesse/s rnay operate under control of a Hub eafth station location outside the Unifed Sfafes provided the ESV operator maintains a point of contact within the United Sfates fhaf will have the capability and authority fo cause an ESV on a U.S.-regrsfered vesse/fo cease transmifting if necessary." 47 C.F.R, 525.221 (a)(6) The ESVs operated by Harris-CapRock will be conholled by the hub earth station listed below: Callsiqn Diameter Location Antenna lD E030253 8.1m Houston, TX 3

Figure 2. Network Configuration 525.22't (a)(7) FREQUENCY C00RDlNATloN "ESV operators transmitting in the 5925-6425 MHz (Eafth-to-Space) frequency bands to geostationary satellites in the fixed-satellite seMce (FSS) shall not seek fo coordinate, in any geographic location, more than 36 MHz of uplink bandwidth on each of no more than two GSO FSS satellites." 47 C.F.R $25.221 (a)(7). Harris-CapRock is seeking to operate ESVs in the 5925-6425 MHz to geostationary satellites in the FSS. However, Harris-CapRock will not be operating ESVs using these frequencies within 200 Km of the U.S. coastline or within 200 Km of any already coordinated Fixed Service (FS). Therefore, Harris-CapRock did not perform any frequency coordination for purposes of this application, lf operations change in the future, requiring C-Band operations within 200 Km of the U.S. coastline or within 200 Km of any already coordinated Fixed Service, Harris-CapRock will pursue a license modification at that time. 525.22't (a)(8) VESSEL WEIGHT 'ESVs sha// not operate in the 5925-6425 MHz (Eañh-to-Space) and 3700-4200 MHz (space-to-Eafth) frequency bands on vesse/s smaller than 300 gross tons." 47 C.F.R $25.221 (a)(8). Harris-CapRock will not operate ESVs in the C-Band on vessels smaller than 300 gross tons. 525.221 (a)(9) OPERATIONS WHILE DOCKED "ESVs, operating while docked, that complete coordination wtth tenestrial sfaflons in the 3700-4200 MHz band in accordance with $25.251, shall receive protection from such tenestrial sfaflons in accordance with the coordination agreements, for 180 days, renewable for 180 days. 47 C,F,R $25,221 (a)(9). Hanis-CapRock does not currently contemplate any coordination with tenestrial stations in the 3700-4200MH2 band. 525.221 (a)(10) PRETECTION FROM INTERFERENCE 'ESVs rn motion shall not claim protection from harmful interference from any authorized terrestrialslaflons or lawfully operating safe//Íes to which frequencies are either aheady assþned, or may be assþned in the future in the 3700- 4200 MHz (spaceto-eafth)frequency band.' 47 C.F.R.525.221 (a)(10),

Harris-CapRock will not claim protection from interference from harmful interference from authorized terrestrial stations or lawfully operating satellites to which frequencies are already assigned or may be assigned in the future in the 3700- 4200 MHz band. S25.221 (a)(11) COORDINATION WITHN 200KM "ESVs operating within 200 km from the baseline of the United Sfafes, or within 200 km from a fixed seruice offshore installation, shall complete coordination prior to operation. The coordination method and the inteierence criterìa objective shall be determined by the frequency coordinator. The details of the coordination shall be maintained and available at the frequency coordinator, and shall be filed with the Comnission to be placed on Public Notice. Operation of each individual ESV may commence immediately after the Public Notice rs released that identifies the notification sent to the Commission. Continuance of operation of that ESV for the duration of the coordination term shall be dependent upon successful completion of the nornal public notice process. lf , prior to the end of the 30-day comment period of the public notice, any objections are received from U.S. licensed fixed seruice operators that have been excluded from coordination, the ESV /icensee shall immediately cease operation of that pafticular station on frequencies used by the affected U. S. Jlcensed fixed seruice station until the coordination dispute rs reso/yed and the ESV /lcensee informs the Commission of the resolution." 47 C.F.R. $25.221 (a)( 1). Harris-CapRock will not operate within 200Km Írom the baseline of the United States, or within 200 Km from a fixed service offshore installation, Therefore, no coordination is required at this time, lf in the future, Harris-CapRock plans to operate within these areas, it will undergo the proper coordination and submit an application for modification of ESV authority, 525,221 (a)(12) AUTOMATIC CEASE OF TRANSMISSIONS 'ESV operators must automatically cease fransmisslon if the ESV operates in violation of the terms of its coordination, including, but not límited to, conditions related to speed of the vessel or if the ESV fravels outsíde the coordinated area, if within 200 km from the baseline of the United Stafes, or within 200 km from a fixed seruice offshore installation. Iransmlsslons may be controlled by the ESV nefwork. The frequency coordinator may decide whether ESV operators should automatically cease fransrnrssions lf fhe vesse/ falls below a prescribed speed within a prescribed geographic area." 47 C.F.R. $25.221 (a)(12). Harris-CapRock will automatically cease transmissions if the ESV travels within 200Km from the baseline of the United States or within 200Km from a fixed service offshore installation. The system to automatically cease transmissions is based on a GPS reading and a comparison to a database with pre-programmed coordinates for the US coastline as well as fixed microwave sites. When the absolute value of the difference in coordinates reaches 200Km, the satellite modem turns off transmissions. Figure 3. Automatic Location s25,221 (bX1Xi) SPECTRAL DENSITYTABLES 'Any ESV applicantfiling an application pursuantto paragraph (a)(1) of this secflon musf filethreetables showingthe off-axis EIRP level of the proposed earth station antenna in the direction of the plane of fhe GSO; the co-polaized EIRP in the elevation plane, that is, the plane perpendicular to the plane of the GSO; and cross polarized EIRP. ln

each table, the EIRP level must be provided at increments of 0.1o for angles between 0o and 10o off-axis, and at increments of 5o for angles befween 10o and 180o off-axis." 47 C.F.R 525.221(b)(1)(¡) The manufacturer has produced these three tables which are attached to the underlying application. s25.221 (b)(3) ESV GEOGRAPHTG AREA 0F oPERAT|ON "There shall be an exhibit included with the application descrihing the geographic area(s) in which the ESVs r,vil operate." 47 C.F.R 525.221(bN3) The geographic area where the ESVs will operate is in U.S. channels and watenivays, the Gulf of Mexico, Caribbean Sea, Atlantic Ocean, and Pacific Ocean.

l Arttic Oredn cwhiRry Ê¡l :,t¡ rllr (l¡¡c¡rl¡ 'Gulî or Ãløska ^ I¿,hruttu'ïta Oúr¡n Ct!¡rbair .. r¡þ¡do At lunt lr l.lct an gÉôtlltrl l'uti.ïtc 0ttan North Á ñcrlci * fl.íûì¡l G.Þ${¡ . Cili¡¡ 3,0{10J00+ . ç¡irm.0É.?.Ð,40 -, hbmlerú Eo{rdúÊr lÉ.f,¡tspûc (trit¡besn ry#¡f: ,$er¡ Ar!þ¡l .r 0 3;l0 8¡51fla [4--Ll 0 r¡O A¡$ H¡a Figure 4. U.S. channels and waterways, the Gulf of Mexico, Caribbean Sea, Atlantic Ocean, and Pacific Ocean s25.221 (b)(4) Po|NT OF CONTACT "The point of contact information referred to in paragraph (a)(3) of this section and, if applicable, paragraph (a)(6) of fhls secfion, must be included in the application.' 47 C.F.R 525.221(b)(4) Noted.

s25.221 (bX5) ANTENNA RADIATToN GUTDELTNES 'ESVs fhaf exceed the radíation guidelines of 51,1310 of this chapter, Radiofrequency radiation exposure /rmÍs, musf provide, with their environmentalassessmenl a plan for mitigatíon exposure to the ertent required to meet those guidelines." 47 C.F,R. 525.221 (b)(5) A radiation hazard study for the Orbit antennas is attached to the underlying application.

APPENDIXA. USE OF NON'U.S. SATELLITES Hanis-CapRock specifies, 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 B - FAA NOTIFICATION Pursuantto 47 C.F.R. S 17.14 (b)of the Regulations, FederalAviation Administration (FAA) notification is not required because allthe antenna structures in this application will be less than 6,1m in height. 11

APPENDIX C- DECLARATION OF HARRIS.CAPROCK "My name is Steve Wheelis, Chief Engineer for Harris-CapRock Communications, nc, I ærtify that the engineering f calculations described in this report are true and correct and satisfactory in light of the Regulations specifred in 47 c.F.R.25.221; 12


Document Created: 2012-01-18 15:35:50
Document Modified: 2012-01-18 15:35:50
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