Attachment Exhibit A SES-MOD-20150702-00444

Attachment Exhibit A

This document pretains to SES-MOD-20150702-00444 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2015070200444_1094967

$Comtech Mobile Datacom Corporation FCC Form 312 Exhibit A, Page 1 ROUS (E090027) Modification Application –July 2, 2015 Description of Application, Services to Be Provided, Frequencies Requested, and Public Interest Showing – Items 24 and 43 Description of Application By this Application, Comtech Mobile Datacom Corporation (“CMDC”) requests a modification to its existing blanket license, E090027 (the “ROUS” license) to extend the license term, which currently expires on September 10, 2015. CMDC asks that the license be extended for two (2) years. Per Special Provision 90011 in the existing ROUS license, the ROUS license is limited to a two-year term ending September 10, 2015. If CMDC wishes to continue to operate beyond September 10, 2015, Special Provision 90011 requires that CMDC file a modification application, and in that application CMDC must (A) justify its need to continue to operate under a waiver of Footnotes US308 and US315 of the United States Table of Frequency Allocations, 47 CFR § 2.106, Footnotes US308, US315, and Section 25.136(d) of the FCC Rules, 47 CFR § 25.136(d), and (B) submit an analysis of its mobile earth terminal (“MET”) operations in the U.S. showing the number of packets each month having a transmission duration of three (3) seconds or longer since September 2013 (i.e., since the release of the Commission’s authorization in File No. SES-MOD-20130206-00159, which last extended the license term). CMDC’s waiver request is provided in Exhibit D. As discussed in Exhibit D, today only one (1) of CMDC’s MET models, the MTM202, requires a waiver, and only when this terminal is operated outside of the continental U.S. (“CONUS”). There are only about 900 MTM202 METs in existence today, and no additional MTM202s are being built. Worst case, the MTM202 requires only 3.6 seconds to shut down. All CMDC METs other than the MTM202 comply with NTIA’s requirements and thus do not require a waiver of the real-time preemption and priority access requirements. The MTM202 complies with NTIA’s requirements, and thus does not require a waiver, when operated in CONUS. CMDC’s analysis of its MET operations in the U.S. showing the average number of packets each month and day having a transmission duration in excess of three (3) seconds since September 2013 is also provided in Exhibit D. Services to be Provided CMDC will use E090027 as modified to provide the same types of services that CMDC is currently providing under E090027. At present, CMDC provides mobile packet data communications services to government and commercial customers throughout the United States and overseas. DC01\GuyaJ\1380137.3$

$Comtech Mobile Datacom Corporation FCC Form 312 Exhibit A, Page 2 ROUS (E090027) Modification Application –July 2, 2015 CMDC terminals typically are placed on land vehicles or at remote, fixed site locations. The terminals transmit and receive data packets via dedicated channels in the L-band. The packets can be routed over any of several terrestrial data networks, or to other mobile transceivers in the CMDC network. Use of the satellite relay is as a “bent pipe,” meaning that only bandwidth and power are purchased from the satellite relay operator. Network management is provided by CMDC’s 24/7 Network Operations Center in Germantown, MD. CMDC’s system employs a version of CDMA that relies on code phase as opposed to multiple codes to differentiate between overlapping signals. In February 2013, the maximum number of simultaneous transmissions processed was four (4). CMDC developed and has deployed state-of-the-art, next generation, earth station equipment that processes 34 simultaneous transmissions. At present, CMDC has over 100,000 activated terminals in service, of which only a small percentage operate in the U.S. during any given month. The vast majority of CMDC’s terminals have been deployed in support of three (3) applications for the U.S. military and operate outside of the U.S. Frequencies Requested All MESs authorized under this license operate in portions of the L-band (1525- 1544/1545-1559 MHz and 1626.5-1645.5/1646.5-1660.5 MHz). Per Special Provision 502 in CMDC’s current ROUS license, E090027, CMDC’s total number of MESs authorized under E090027, E090029 and E990143 will not exceed the 25,000 unless an increase in CMDC’s total number of authorized MESs has been otherwise authorized by the Commission. (The license with call sign E990143 has expired and those operations were folded into call sign E090027 in 2013.) Public Interest Showing Grant of this Application will serve the public interest, as it will enable CMDC’s customers, including but not limited to the U.S. military, to continue to use the services that CMDC provides with the subject METs on SkyTerra 1, the ISAT satellites, MSAT-1, and MSAT-2. DC01\GuyaJ\1380137.3$

Exhibit A, Annex 1
Comtech Mobile Datacom Corp.
All Site IDs for ROUS (E090027) Post-Grant of July 2015 Mod/Extension
Last Updated:
7/2/2015 Satellites and Coverage Areas
Max Max EIRP
Total Input Max EIRP
EIRP/ Density/ Max Gains Total EIRP
Mod/ Power @ Density Towards
Manuf Carrier Carrier @1.5450, for All Emission
Site ID MET Antenna # Model Number E31 Dia E32 Services E50 Antenna the Horizon ISAT SkyTerra MSAT 1/2 License
E30 (dBW) (dBW/4kHz) @1.6450 Carriers Designator
(see end) Flange (dBW/4kHz) (1.6
(1.6 freq) (1.6 freq) E41 E42 (dBW) E40
(watts) E38 freq) E60
E48 E49

Sensor 0.27 quad Basic1
R-Sky MTM202 9 S65-8282-301 11.2 5.4 3.5, 3.9 5.3 11.2 1.9 270KG7W ALL ROUS
Systems helix +AERO

Sensor 0.27 quad Basic1
R-Inmar MTM202 10 S65-8282-301 11.2 5.4 3.5, 3.9 5.3 11.2 1.9 200KG7W ALL ROUS
Systems helix +AERO

R-CMT 0.1524 circ Basic1 +M, AK, HI &
CMT-500 11 CMT-500 PCTel 10 4.2 4.5,4.5 5.3 10 -3.5 168KG1D ROUS
MSAT patch LMo USTP

R-Old SCI 0.15 quad Basic1 +M,
MT2010 1 MT-2010 internal 10.2 4.4 2.9, 2.9 5.3 10.2 -1 168KG1D USTP ROUS
MSAT Systems helix LMo
R-Old Sensor 0.15 quad Basic1
MT2010 2 S65-8582-101 12.1 6.3 4.3, 4.8 5.3 12.1 1.5 168KG1D USTP ROUS
MSAT Systems helix +AERO
R-Old SCI Basic1 +M,
MT2010 3 MT-2010 external 0.06 patch 11.3 5.5 4.0,4.0 5.3 11.3 -1 168KG1D USTP ROUS
MSAT Systems LMo
R-Old SCI 0.15 quad Basic1 +M,
MT2010 4 MT-2010 r1 Internal 12.3 6.5 5.0, 5.0 5.3 12.3 -1 168KG1D USTP ROUS
MSAT Systems helix LMo
R-Old Sensor 0.27 quad Basic1
MT2011 5 S65-8282-301 11.2 5.4 3.5, 3.9 5.3 11.2 1.9 168KG1D USTP ROUS
MSAT Systems helix +AERO
R-Old Basic1 +M,
MT2011 6 3481IZ-3 PCTel 0.18 patch 11 5.2 3.7,3.7 5.3 11 -1 168KG1D USTP ROUS
MSAT LMo
R-Old Basic1 +M,
MT2011 7 3491IZ-3 PCTel 0.18 patch 13.3 7.5 6.0,6.0 5.3 13.3 -3.5 168KG1D USTP ROUS
MSAT LMo
R-Old Basic1 +M,
MTM203 8 3561AW-1/A PCTel 0.19 patch 11 5.2 3.7,3.7 5.3 11 -1 168KG1D USTP ROUS
MSAT LMo

USTP = US territories and possessions within footprint of satellite
ALL = CONUS, AK, HI, and USTP 1

Document Created: 2015-07-02 16:22:13
Document Modified: 2015-07-02 16:22:13