Attachment Response 37 and 42a

This document pretains to SES-MOD-20150123-00036 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2015012300036_1073301

ATTACHMENT 1 RESPONSE TO FCC FORM 312, QUESTION 37 In March 2011, Honeywell International Inc. (“Honeywell”) resolved a U.S. government investigation into permitting and storage issues at its Metropolis, Illinois facility by pleading guilty to one Resource Recovery and Conservation Act felony count in the United States District Court for the Southern District of Illinois (Case No. 4:11-cr-40006-JPG), and agreeing to pay a total of $12 million in fines and performing supplemental environmental projects. The government's allegation involved the storage of a regulated material without a proper permit. The company self-reported the incident. No one was injured as a result of exposure to the regulated material, and there was no environmental impact. Honeywell has since acquired the requisite permit and constructed a new storage facility. In addition, Honeywell reviewed the matter with suspension and debarment officials in 2011. The Army Procurement Fraud Branch led the review and determined that no suspension/debarment action was warranted. The company has finished reprocessing the material, well ahead of the government’s deadline.

ATTACHMENT 2 RESPONSE TO FCC FORM 312, QUESTION 42a The mobile earth station terminals that are the subject of this application will communicate with the Inmarsat satellites on the ISAT list. These satellites are operated by Inmarsat and are licensed in the United Kingdom. The Commission has authorized earth stations licensed in the United States with the “ISAT” designation to communicate with the satellites on the ISAT list. See Inmarsat, Inc., DA 08-2323 (rel. Oct. 21, 2008). Pursuant to the existing license, the Commission has already approved LXE’s access to the Inmarsat satellites. This application does not affect the reasons underlying the Commission’s prior approval of the use of the ISAT satellites. See generally id.

RESPONSE TO FCC FORM 312, QUESTION 43 Pursuant to Section 25.118(a)(2) of the Commission’s rules, LXE LLC (“LXE”) hereby provides notice to the FCC of a minor modification to its Title III authorization to provide certain Inmarsat services to customers in the United States.1 LXE is currently authorized to provide the Inmarsat D service over a total of 25,000 mobile earth terminals (“METs”), model numbers JUE-610 DT, DMR-200, SAT 101, SAT-201, SAT-200/202, SAT-232, and SAT-242. By this filing, LXE provides notice to the FCC of a variant of its SAT-202 MET, the SAT-401. The SAT-401 is manufactured by Honeywell Global Tracking Ltd and is designed as a replacement to the SAT-202. LXE anticipates shipping the first SAT-401 METs to the United States in January 2015, subject to customer requirements. Under Section 25.118(a)(2) of the Commission’s rules, the new model SAT-401 can be added to LXE’s authorization by filing a Notification of Minor Modification within 30 days of the modification. Specifically, 47 C.F.R. § 25.118(a)(2) provides: Except for replacement of equipment where the new equipment is electrically identical to the existing equipment, an authorized earth station licensee may add, change or replace transmitters or antenna facilities without prior authorization, provided: (i) The added, changed, or replaced facilities conform to § 25.209; (ii) The particulars of operations remain unchanged; (iii) Frequency coordination is not required; and (iv) The maximum power and power density delivered into any antenna at the earth station site shall not exceed the values calculated by subtracting the maximum antenna gain specified in the license from the maximum authorized e.i.r.p. and e.i.r.p. density values. As set forth in the accompanying materials and engineering certificate, the SAT-401 fulfills the same functions and meets equivalent technical specifications as the SAT-202 MET 1 See LXE, Inc., Call Sign E020074, IBFS File No. SAT-MOD-10111125-01400 (Jan 9, 2012). LXE Inc. converted its status under Georgia state law to a limited liability corporation as of October 1, 2012 and is now known as LXE LLC. See Secretary of State, Corporations Division, Georgia, Report for Entity ID 1003684, https://cgov.sos.state.ga.us/BizEntity.aspx/ ViewEntityData?entityId=1003684 (accessed Nov. 24, 2014); Secretary of State, Corporations Division, Georgia, Report for Entity ID 4632769, https://cgov.sos.state.ga.us/BizEntity.aspx/ ViewEntityData?entityId=4632769 (accessed Nov. 24, 2014). No change in control took place when LXE Inc. converted its status to LXE LLC. LXE asks that the Commission update its systems to reflect LXE’s new name.

and therefore meets the Section 25.118(a)(2) criteria. Section 25.209 of the rules is not applicable to mobile satellite services. Because the SAT-401 is intended as a replacement for the SAT-202, the particulars of operation of the terminal remain unchanged from the SAT-202, and frequency coordination is not required for the use of the SAT-401. The maximum allowable EIRP under the E020074 authorization is 9 dBW, and with a gain for the SAT-401 of 6 dBi, the input power at the antenna flange for the SAT-401 is 1 W (0 dBW), well within the parameters of 47 C.F.R. § 118(a)(2)(iv). LXE is not seeking to increase the overall number of terminals that it is authorized for; rather, it will use the SAT-401 terminal as part of the 25,000 terminals for which it is already authorized. In addition, the new MET model number SAT-401 complies with all the terms and conditions of LXE’s authorization, including the requirement of having an average shut-down time of 1.35 seconds and maximum shut-down time of 2.6 seconds (condition 3920) in order to protect the Global Maritime Distress and Safety Service (“GMDSS”). Because the SAT-401 is not intended for Ship Security Alert Systems (“SSAS”) services or long range identification and tracking (“LRIT”) uses, it does not need to meet IMO SSAS and LRIT requirements. LXE’s affiliate company, Honeywell Global Tracking Ltd., formerly known as EMS Global Tracking Ltd., offers Inmarsat-D services, which include both the D+ and IsatM2M modes of operation.2 LXE and Honeywell Global Tracking are both subsidiaries of Honeywell International Inc., which acquired control over the affiliates in a transaction approved by the Bureau in August 2011.3 Inmarsat D is a low data-rate, two-way store and forward short messaging and tracking system. Inmarsat-D provides low cost satellite communications for such applications as asset tracking and SCADA. Honeywell Global Tracking provides essential services to government customers, such as the U.S. Coast Guard and the U.S. Navy in connection with their homeland security efforts (e.g., surveillance and warnings for terrorist hijackings of marine vessels), and to private sector customers to track their assets and to monitor sensitive energy facilities, including natural gas well heads, pipelines, shipping containers and service vehicles. The new model SAT-401 adds to the choices and flexibility Honeywell Global Tracking is able to offer its customers. 2 The difference in the two modes of operation is that the IsatM2M mode is capable of longer messages and reduced messaging latency. As a result, there is a difference in the receive modulation for those Inmarsat-D terminals that are capable of operating in the IsatM2M mode. See LXE, Inc., Call Sign E020074, IBFS File No. SES-MOD-20071107-01542 (Mar. 3, 2008). As originally authorized, the license was limited to only the D+ mode of operation. However, after changes implemented by Inmarsat to its network of satellites and corresponding modulation changes requested to its authorization, LXE is now authorized to operate in either mode of the Inmarsat-D service. 3 See FCC, Satellite Communications Services Information: Actions Taken, Public Notice, Report No. SES-01374 (Aug. 17, 2011) (reporting an August 15, 2011 approval of the indirect transfer of control over LXE’s earth station authorization to Honeywell International Inc.).


Document Created: 2015-01-16 11:21:24
Document Modified: 2015-01-16 11:21:24
© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC