Attachment Narrative

This document pretains to SES-MOD-20190225-00191 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2019022500191_1628630

                                     Before the
                       FEDERAL COMMUNICATIONS COMMISSION
                                Washington, DC 20554

    In the Matter of

    Application of Speedcast Communications ) Call Sign: E910609
    Inc. to Modify its Existing Ku-band Very )
    Small Aperture Terminal (“VSAT”)         ) File No. SES-MOD-____________
    Blanket License                          )

                   APPLICATION TO MODIFY BLANKET VSAT LICENSE

        By this application, Speedcast Communications Inc. (“Speedcast”) respectfully seeks to

modify its existing very small aperture terminal (“VSAT”) blanket license, Call Sign E910609,1

by adding authority to operate two (2) new 2.4m earth stations – the Intellian V240M and Intellian

V240MT2 – in conventional Ku-band frequencies from 11.7-12.2 GHz (space-to-Earth) and 14.0-

14.5 GHz (Earth-to-space) bands. In addition, Speedcast seeks to operate the V240MT in

conventional Ka-band frequencies from 18.3-18.8 GHz (space-to-Earth), 19.7-20.2 GHz (space-

to-Earth), 28.35-28.6 GHz (Earth-to-space) and 29.25-30.0 GHz (Earth-to-space) bands.

Speedcast seeks to operate up to ten (10) of each of the V240M and V240MT at fixed locations

within the contiguous United States with any U.S.-licensed or non-U.S. licensed satellite on the

Commission’s Ku-band Permitted Space Station List and Ka-band Permitted Space Station List.

The proposed modification will allow Speedcast to provide more effective support services for its

U.S. customers and improve the overall quality of service for diverse commercial activities.




1
  See Speedcast Communications Inc., File No. SES-RWL-20110901-01016, Call Sign E910609
(“VSAT Blanket License”).
2
 The V240MT is the tri-band iteration of the V240M antenna, and operates with a slightly lower
gain than the V240M. Here, Speedcast seeks to operate the V240MT in conventional Ku-band
and Ka-band frequencies only.

                                                1


      I.       DISCUSSION

            The Commission has previously authorized the 2.4m Intellian V240M antenna for mobile

earth station operations, and the operating parameters proposed herein are consistent with those

previously approved limits.3 In the Ku-band, Speedcast will operate the V240M and V240MT

using the identical previously authorized power levels in Call Sign E090176 and at all times in

compliance with the relevant EIRP spectral density masks in Section 25.218(f) Commission’s

rules. During Ka-band operations, Speedcast will operate the V240MT at a slightly lower

maximum EIRP level due to differences in the Ka-band input power and antenna gain, but will

remain within the limits specified in Section 25.138(a) of the Commission’s rules. Therefore, this

modification application is eligible for routine processing under the Commission’s rules.4

Speedcast provides the FCC Form 312 Schedule B for information relating to the proposed earth

station operations and a radiation hazard analysis for each antenna.

            The addition of the V240M and V240MT to the VSAT Blanket License will serve the public

interest by allowing Speedcast to provide more efficient and flexible services to its customers in

the United States and facilitate its ability to troubleshoot and resolve network or equipment issues.

In addition, operation of the new earth stations will be fully consistent with the Commission’s

spectrum management policies, including two-degree satellite spacing, and will not adversely

affect the operations of other spectrum users.

      II.      CONCLUSION

      Based on the foregoing, Speedcast respectfully requests that the Commission modify the

Blanket VSAT License, Call Sign E910609, by adding authority to operate the V240M and


3
    See Speedcast Communications Inc., File No. SES-MOD20151210-00928, Call Sign E090176.
4
 Although this application is eligible for routine processing, in the interest of completeness,
Speedcast provides Ku-band and Ka-band EIRP spectral density plots for the V240MT
demonstrating compliance with the relevant EIRP spectral density masks in the FCC rules.

                                                  2


V240MT in conventional Ku-band and Ka-band frequencies consistent with the parameters set

forth in this application.




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Document Created: 0590-04-27 00:00:00
Document Modified: 0590-04-27 00:00:00

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