Attachment Narra & 25.222 Compl

This document pretains to SES-MOD-20131108-00955 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2013110800955_1019299

Exhibit 1 – Narrative and Showing of Compliance with Section 25.222

                                      10M0G1W
                           Astrium Services Government, Inc.

                  Application for Modification of License to Add up to
      500 Sinaero 1.2. Meter Flyaway Model SA-1.2TFLY Ku-band Antennas to
           Call Sign KA313 License Ku-band VSAT Network Authorization;
                                          And
   Update the Particulars of Operation, Antenna Facilities and other Specifications for
        Sea Tel Model 6006 1.5 Meter Ku-band Earth Station on Vessel (ESV)
      Remote Antenna Currently Authorized per the KA313 ESV Authorization;
                                          And
                             Add up to 500 Thrane & Thrane
           Model TT-7080A Sailor 800A 0.83 Meter Ku-band Antennas; and
  500 Thrane & Thrane Model TT-7090B Sailor 900B 1.0 Meter Ku-band Antennas to
                          Call Sign KA313 ESV Authorization

                              SES-MFS-20130504-00363

                                      Call Sign KA313

         By this application Astrium Services Government, Inc. (Astrium) seeks authority
to add up to 500 Sinaero 1.2. Meter Flyaway Model SA-1.2TFLY Ku-band antennas to
its call sign KA313 license Ku-band VSAT Network Authorization. This antenna fully
conforms with Commission regulations and is eligible for routine processing. Please see
the 312 main form and schedule B for all required technical parameters.

       Astrium is also requesting by this application that the Particulars of Operation,
Antenna Facilities and other Specifications for the Sea Tel Model 6006 1.5 Meter Ku-
band antenna currently authorized for use to provide ESV service per the KA313 license
be updated. It is requested that all information currently listed in the KA313 license for
the Sea Tel 6006 antenna be completely deleted and then added back in as per the
Schedule B information set forth in the Modification Application. No change is being
made to any other aspects of the KA313 license. No information other than that listed
below for the Sea Tel 6006 antenna is to be deleted. Only the following specifications,
which are all for Sea Tel 6006 antenna, are to be deleted–

       Section A Site Locations: 3)

       Section B Particulars of Operation: 229 – 251

       Section C Frequency Coordination: 14 – 16

       Section D Points of Communication: 9), 10) & 11)

       Section E Antenna Facilities: ESV/6006


Exhibit 1 – Narrative and Showing of Compliance with Section 25.222

       Section F Remote Control: ESV/6006

       The Specifications set forth in the Schedule B for the Sea Tel model 6006, 6009
and 6012 antenna is then to be added back in to the license to complete the update.

        Finally, Astrium requests that the following new ESV remote antennas be added
to the KA313 authorization to provide ESV service:
        Thrane & Thrane Model TT-7080A Sailor 800A 0.83 Meter Ku-band Antennas;
        Thrane & Thrane Model TT-7090B Sailor 900B 1.0 Meter Ku-band Antennas.

        All the remote ESVs – both the currently authorized antenna which is being
updated and the new antennas which are being added to the authorization - will be
located on vessels traveling in U.S. and international waters. They will operate with hub
antennas that are separately licensed and will be utilized to provide ESV service in the
same manner as previously authorized by the Commission and will be operated in full
compliance with the requirements of the Commission’s ESV regulations as set forth in
part 25 of the Rules.

        ASTRIUM’s showing of compliance with Part 25 of the Commission’s Rules
follows herewith and the exhibits required by Section 25.222 are included as attachments
to the application.

        Showing of Compliance with Section 25.222 of the Commission’s Rules

   (a) (1) Comply.

       See the Sea Tel declaration and Exhibits 2, 3 and 4 for the Sea Tel model 6006,
       6009 and 6012 antenna.

       See the Thrane & Thrane declaration and Exhibits 5, 6 and 7 for the Thrane &
       Thrane Model TT-7080A Sailor 800 antenna.

       See the Thrane & Thrane declaration and Exhibits 8, 9 and 10 for the Thrane &
       Thrane Model TT-7090B Sailor 900B antenna.

       All of the ESV antennas listed above use transmitters that have off-axis EIRP
       spectral densities less than or equal to the levels in paragraph 25.222(a)(1)(i) and
       meet the requirements of 25.222 (a)(1)(i)(A-C) with an N value of 1. The
       referenced exhibits provide the detailed demonstration described in paragraph
       25.222 (b)(1). The Sea Tel and Thrane & Thrane declarations also contain the
       certifications that the antennas comply with the pointing requirement in paragraph
       25.222 (a)(1)(ii)(A) and the cessation of emission requirement in paragraph
       25.222 (a)(1)(iii)(A).

   (a) (2) Not Applicable


Exhibit 1 – Narrative and Showing of Compliance with Section 25.222

  (a) (3) Not Applicable

   (a) (4) Comply. The ASTRIUM ESV Compliance Officer has authority and ability
        to cease all emissions from ESVs through the facilities of ASTRIUM teleports or
        through facilities of non-ASTRIUM teleports used to uplink ASTRIUM operated
        ESVs pursuant to telehousing arrangements. This point of contact is available 24
        hours a day, seven days a week via the ASTRIUM Southbury, CT teleport at
        203-262-5010.

  (a) (5) Comply. These records are being collected and maintained as specified.
       Requests to make this data available may be directed to the ASTRIUM ESV
       Compliance Officer via the Southbury teleport at 203-262-5010.

  (a) (6) Comply.

  (a) (7) Comply. The ESVs are controlled by the Hub earth station located at
      ASTRIUM’s Southbury Teleport.

  (a) (8) Agree.

  (b)(1) Comply. The tables described in 25.221(b)(1)(i) are attached as the following
      exhibits:

      Exhibits 2, 3 and 4 for the Sea Tel model 6006, 6009 and 6012 antenna.

      Exhibits 5, 6 and 7 for the Thrane & Thrane Model TT-7080A Sailor 800 antenna.

      Exhibits 8, 9 and 10 for the Thrane & Thrane Model TT-7090B Sailor 900B
      antenna.

      The value N described in 25.222(a)(1)(i)(A) is 1. Exhibits 2, 5 and 8 provide the
      detailed demonstration described in paragraph 25.222(b)(1)(i)(A). Exhibits 3, 6
      and 9 provide the detailed demonstration described in paragraph
      25.222(b)(1)(i)(B). Exhibits 4, 7 and 10 provide the detailed demonstration
      described in paragraph 25.222(b)(1)(i)(C). The certifications from the equipment
      manufacturer stating that the tracking systems meet the pointing and cessation of
      emission requirements of 25.222(b)(1)(iii) are contained in the Sea Tel and
      Thrane & Thrane declarations.

  (b) (2) Not Applicable.

  (b) (3) Not Applicable.

  (b) (4) Comply. See Operations Areas Exhibit.

  (b) (5) Comply. The ASTRIUM ESV Compliance Officer has authority and ability to


Exhibit 1 – Narrative and Showing of Compliance with Section 25.222

     cease all emissions from ESVs through the facilities of ASTRIUM teleports or
     through facilities of non-ASTRIUM teleports used to uplink ASTRIUM operated
     ESVs pursuant to telehousing arrangements. This point of contact is available 24
     hours a day, seven days a week via the ASTRIUM Southbury, CT teleport at 203-
     262-5010.

  (b) (6) See the Radiation Hazard Report Exhibits.
      .
  (c) Comply. ASTRIUM has completed coordination with NASA for ESV
      operations in the 14.0 – 14.2 GHz frequency band within 125 km of NASA
      TDRSS facilities protected per 25.222 (c). The coordination has been filed with
      the Commission for completion of the coordination process. Until the
      coordination process is completed ASTRIUM will continue to comply with
      25.222 (c) by not operating Ku-band ESVs at all in the 14.47 – 14.5 GHz
      frequency band within the specified distances of the protected facilities.

  (d) Comply. Frequencies in the 14.47 – 14.5 GHz frequency band are not currently
      used for ESVs operating in the proximity of any of the locations specified in
      25.222 (d). If at some time in the future frequencies in the 14.47 – 14.5 GHz
      frequency band are used in these areas ASTRIUM will insure that transmissions
      of any ESVs utilizing these frequencies are ceased within the specified distances
      of the protected facilities.



Document Created: 2013-11-06 13:40:59
Document Modified: 2013-11-06 13:40:59

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