Attachment Narrative Statement

This document pretains to SES-MOD-INTR2018-00287 for Modification on a Satellite Earth Station filing.

IBFS_SESMODINTR201800287_1332124

Before the Federal Communications Commission Washington, DC 20554 In the Matter of ) ) Kymeta Corporation Application for Blanket ) File No. SES-MOD-________-_____ License to Operate 5,000 Ku-Band ) File No. SES-LIC-20170223-00195 Transmit/Receive Vehicle Mounted Earth ) Call Sign: E170070 Stations (VMESs”), 1,000 Ku-Band ) Transmit/Receive Earth Stations on Vessels ) (“ESVs”) and 5,000 Ku-Band ) Transmit/Receive Fixed Earth Stations ) REVISED APPLICATION FOR MODIFICATION OF BLANKET LICENSE Pursuant to Section 25.117 of the Commission’s Rules, Kymeta Corporation (“Kymeta”) files this revised application for modification of its blanket license to seek authority to operate at a maximum of 16 watts input power to the flange of the antenna. On August 24, 2017, the Commission granted Kymeta a blanket license to operate 5,000 Ku-band transmit/receive vehicle mounted earth stations (“VMES”), 1,000 Ku-band transmit/receive earth stations on vessels (“ESV”) and 5,000 Ku-band transmit/receive fixed earth stations operating in the Fixed Satellite Service. The Commission granted Kymeta authority to operate with a maximum of 8 watts input power. This application for modification seeks authority to operate at a maximum of 16 watts input power to the flange of the antenna, and makes several corresponding changes on FCC Form 312 as follows: E38: Total input power at antenna flange = 16.0 watts (maximum) E40: Total EIRP for all carriers (dBW) = 45.04 dBW (maximum)

Kymeta Corporation Revised Application for Modification of Blanket License Page 2 E48: Maximum EIRP per carrier (dBW): 45.04 dBW E49: Maximum EIRP Density per carrier (dBW/4 kHz): 19.0 Kymeta’s terminal complies with the off-axis EIRP power spectral density (“PSD”) standards (the “off-axis mask”) set forth in Sections 25.222(a)(1)(i) for ESVs, 25.226(a)(1)(i) for VMESs, and 25.218(f) for fixed earth stations. Therefore, compliance with Section 25.209 is not required. Exhibits A and B to the Technical Appendix to the original application (filed in February 2017) consist of comprehensive tables and a series of measured antenna patterns demonstrating compliance with the off-axis mask. Those measurements were calculated based on an input power of 25 watts (corresponding to 47 dBW). Kymeta did not prepare a new analysis or re-submit these Exhibits with the modification application because the input power requested in this modification application is 16 watts (corresponding to 45.04 dBW), which is less than the input power used to calculate the original antenna patterns. 1 The terminal automatically controls input power to maintain compliance with the off-axis mask. Kymeta submits as Exhibit A an RF Safety Analysis for operations at 16 watts input power. The remote control for the earth stations will be located at Kymeta’s headquarters, 12277 134th Court, Redmond, WA 98052, telephone 855-KALONET. 1 In its initial filing for blanket earth station authorization, Kymeta proposed a maximum input power of 25 watts. Subsequently, Kymeta amended its application to reduce the maximum input power to 8 watts. Because Kymeta complied with the off-axis mask with an input power of 25 watts, Kymeta did not submit an amended study for operations at 8 watts.

Kymeta Corporation Revised Application for Modification of Blanket License Page 3 Please contact the undersigned if additional information is needed. Respectfully submitted, Robert S. Koppel Lukas, LaFuria, Gutierrez & Sachs, LLP 8300 Greensboro Drive, Suite 1200 Tysons, VA 22102 703-584-8669 bkoppel@fcclaw.com Counsel to Kymeta Corporation January 30, 2018

Kymeta Corporation Revised Application for Modification of Blanket License Page 4 TECHNICAL CERTIFICATION I, Ryan A. Stevenson, hereby certify that I am: • the technically qualified person responsible for the preparation of the technical information contained in this Revised Application for Modification; • that I am familiar with Part 25 of the Commission’s Rules; and • that I have either prepared or reviewed the technical information submitted in the Amendment and found it to be complete and accurate to the best of my knowledge and belief. Signed: /s/ Ryan A. Stevenson Dated: January 30, 2018 Ryan A. Stevenson Vice President and Chief Scientist Kymeta Corporation


Document Created: 2018-01-30 16:32:03
Document Modified: 2018-01-30 16:32:03
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