Attachment Exhibit 3

This document pretains to SES-MOD-20131112-00965 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2013111200965_1022888

             Exhibit #3: Radio Frequency Radiation Hazard Compliance Analysis.


In compliance with the requirements of 47 C.F.R §1.1310 of the FCC Rules, Inmarsat is submitting an
analysis of the calculated RF radiation levels generated with an assessment of any possible worker or
general public exposure to excessive radiation levels. In order to assure compliance with the FCC
maximum exposure limits, standard analysis procedures were used in accordance with the FCC’s
guidelines as specified in §1.1310 1.

This RF Radiation Hazard Compliance analysis (RFR analysis) is limited in scope to the use of ground
and maritime based satellite dishes using fixed dishes or mobile stabilized Earth Stations on Vessel (ESV)
type antennas. There are three types of antenna installations: large antenna teleport installations, VSAT
fixed installations on ground or locations on offshore oil and gas platforms and mobile stabilized ESV
antennas. Although the construction, design and personnel access control is different for the three types
of antennas, the analysis of the potential hazard for each of these types is identical.

In all of the antenna types, there are common characteristics of antenna gain and antenna design which
require analysis. Under the guidelines of FCC OET Bulletin 65 for satellite dish analysis, the following
antenna radiation areas were analyzed:

As shown in diagram 1, there are three primary areas of radiation with a satellite dish:

The first area is the unfocussed energy of the near field which is characterized by a signal strength which
can reach a maximum power density that doesn’t decrease with distance. The distance from the antenna
surface to the edge of the near field is determined through use of the formulas in the OET 65 document 2.
In Ku and C Band the near field areas extend to the front of the antenna to a distance of 30 or more feet
for the average antenna. This is the area most likely to affect personnel in the vicinity of the antenna and
is the primary focus of the study. Because the power in this area is unfocussed, the result of the near field
analysis is based on the maximum power level within that area 3. Also within the near field is an area of
special interest consisting of the surface of the antenna. The power density at the antenna surface was
calculated based on the OET 65 guidelines. 4

The second area is the far field region where the full gain and directionality pattern is realized for the
antenna. In this area, the signal decreases inversely as a function of the square of the distance. This area
starts typically at a distance of hundreds of feet or more from the surface of the antenna. The far field
radiation is generally directed into sky areas which cannot be easily accessed and this radiation is not as
likely to cause impermissible levels of RFR in personnel areas. In accordance with the guidelines of OET
65, the distance to the closest far field boundary5 and associated power densities within the far field
region 6 were calculated. As an intermediary step to the power density formulas, the antenna dish aperture
efficiency was calculated from manufacturer supplied gain as per formula 14 of the OET document.



1
  This document is based on the guidelines and formulas of OST/OET Bulletin Number 65, “Evaluating Compliance
with FCC-Specified Guidelines for Human Exposure to Radiofrequency Radiation.” (OET Bulletin 65
Edition 97-01, August 1997)
2
  Id. Reference formula (12), page 27
3
  Id. Reference formula (13), page 28.
4
  Id. Reference formula (11), page 27
5
  Id. Reference formula (16) page 29.
6
  Id. Reference formula (18), page 29.
                                                 Page 1 of 5


The transition region is located between the near field and the far field areas and is characterized as a
semi-focused area where the power density decreases inversely with distance from the antenna. As a
matter of characterizing the worst case scenario, the power density was calculated at the boundary
between the near field and the transition zone and also at the boundary of the transition zone with the far
field area, in accordance with the guidelines of OET 65 7.




                                            Diagram 1


Although the majority of the radiated power is contained within a cylinder extending from the surface of
the antenna dish, an additional area of interest is within locations that are off axis from the main radiation
beam and in areas more easily accessed by personnel. According to the guidelines of OET 65, an
estimation of off-axis far field power density can be made using the antenna minimum sidelobe
performance data as defined under §25.209 8. In this analysis, the “first cut” calculations are run using the
worst case far field power density to determine if the main beam radiation exceeds the permissible RFR
power density levels. In the event that the main beam exceeds the RFR standards, only then will the
sidelobe radiation pattern be considered for analysis. If the main beam creates less power than the
maximum permissible exposure level, it is known that the sidelobe radiation will be less than the main
beam and sidelobe radiation will therefore be compliant as well.

In near field areas close to the antenna dish, the OET 65 guidelines indicate that an assumption can be
made in radial distances extending beyond one antenna diameter from the antenna center point. Within
areas of interest outside this “one antenna diameter” boundary it can be presumed that a reduction of 20




7
    Id. Reference formula (17), page 29.
8
    47 C.F.R §25.209 (a),(2)
                                                 Page 2 of 5


dB or more can be calculated as a basis of RFR hazard protection. The analysis results reflect this
calculation as per the guidelines of the OET 65 document 9.

This analysis calculates the RFR compliance of an antenna type which is to be deployed as an ESV
antenna on static platforms and vessels in the coastal and deep water areas of the U.S. In all of the
proposed deployments, the analyzed antennas are to be mounted on elevated pedestals in locations which
are on the top of vessel wheelhouses, flying bridges or quarters areas which are restricted and where only
authorized personnel have access. In this environment, the RFR exposure limits are indicated to be the
Occupational / Controlled Exposure levels. The maximum permissible exposure levels are to not exceed
5 mW/cm^2.

Applying the methods provided in OET 65, using the proposed maximum BUC power specified for these
dishes as a worst case, the results are as follows:

Calculations:

Power density at reflector surface:       S = 4P/A

Calculated antenna efficiency: ɳ = (Gλ^2/4π)/(πD^2)

Maximum power density within near field:          Snf = 16ɳP/πD^2

Maximum power density at transition zone boundary with far field:         Sff = P*G/4πR^2

Distance to boundary of transition zone with far field:   Rff = 0.6 D^2/λ

Power density within the transition region:       St = Snf*Rnf/R

Where:

ɳ = Aperture efficiency.

G = Power gain in direction of interest (isotropic).

λ= Wavelength (cm).

D = Antenna diameter (cm).

P = Power fed to the antenna.

A = Physical area of antenna (cm^2).

Rnf = Extent of near field from antenna surface, Rff = Extent of far field from antenna surface.

Snf = Power density at near field extent distance, Sff = Power density at far field extent distance.

S = Power density at surface.

R = Distance to the point of interest.

9
    Ibid. Page 30.
                                                 Page 3 of 5


Analysis of Seatel 9797 Ku Band Stabilized ESV antenna, using the maximum proposed power and
bandwidth:

                Maximum exposure                      5 m/W cm^2       Occupational


                                                Summary:
                    Dish Model:                                Seatel 9797C Band Stabilized Antenna
                Transmit Frequency                        6.175            GHz
                   Flange power                              30           Watts
                 Antenna Diameter                            2.4          Meters
                   Antenna Gain                              41.7           dBi
                     Efficiency                          61.41%         Calculated
         Power Density at Reflector Surface               2.653         mW/cm ^2      Result: Within Limits
     Maximum Power Density Within Near Field                 1.63       mW/cm ^2      Result: Within Limits
           Distance to Edge of Near Field                 29.64           Meters
     Maximum Power Density at Transition Zone
                                                             0.68       mW/cm ^2      Result: Within Limits
               Boundary with Far Field
  Distance to Boundary of Transition Zone with Far
                                                          71.14           Meters
                        Field
    Power Density at 1 Diameter Distance from
                                                         0.0163         mW/cm ^2      Result: Within Limits
                  Center of Dish.


Compliance Statement:

This antenna is proposed to be used as described on page 3 in an area which has restricted access and only
accessible to authorized personnel. This proposed antenna installation fully complies with the
occupational RF radiation hazard limits, according to the summary of calculations above.




                                               Page 4 of 5


Summary:

According to the calculations presented within this analysis and the access and personnel restrictions as
described in the RF radiation analysis, the proposed antennas comply with the FCC’s RF radiation
guidelines as described in OET Bulletin 65, “Evaluating Compliance with FCC-Specified Guidelines for
Human Exposure to Radiofrequency Radiation”.

Submitted October 29, 2013

/Robert W. Fisher/

Robert W. Fisher

Principal Solutions Development Engineer | FSS/MW
Inmarsat
1201 Louisiana St. Suite 2700
Houston, TX, 77002
USA




                                               Page 5 of 5



Document Created: 2013-11-12 18:57:40
Document Modified: 2013-11-12 18:57:40

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