Attachment Narrative

This document pretains to SES-MOD-INTR2018-10584 for Modification on a Satellite Earth Station filing.

IBFS_SESMODINTR201810584_1591594

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Application of KVH Industries, Inc. to ) Modify Existing C-band Earth Station ) Call Sign E120061 Onboard Vessels (“ESV”) Blanket ) File No. SES-MOD-____________ License ) APPLICATION FOR LICENSE MODIFICATION By this application, KVH Industries, Inc. (“KVH”) seeks to modify its existing C- band earth station onboard vessel (“ESV”) blanket license, Call Sign E120061,1 by adding an emission designator to its previously licensed TracPhone Model V11 (“V11”) ESV terminal and by including authority for the V11 terminal to operate with satellites on the Commission’s Permitted Space Station List (“Permitted List”).2 I. DISCUSSION Under its current license, KVH is authorized to operate up to 500 V11 terminals to communicate with the INTELSAT 707˚ at 53 W.L. and INTELSAT POR at 180˚ E.L., both U.S.-licensed satellites, in the 5.925-6.425 GHz (Earth-to-space) and 3.7-4.2 GHz (space-to-Earth) bands, using various emission designators.3 Adding the new emission designator and Permitted List authority for the V11 terminal will improve KVH’s operational flexibility to provide maritime communications applications to private, 1 See KVH Industries, Inc., Radio Station Authorization, File No. SES-LIC-20120328-00307 (Call Sign E120061) (“C-Band ESV License”). 2 See Permitted Space Station List (https://transition.fcc.gov/ib/sd/se/permitted.html). 3 See C-Band ESV License.

commercial, and government vessels operating in U.S. waters and beyond. KVH will continue to operate the V11 terminal within the off-axis EIRP spectral density limits specified in Section 25.221(a)(1) of the Commission’s Rules. 4 KVH incorporates by reference the V11 terminal technical information previously submitted with its original ESV blanket license application.5 Pursuant to Section 25.117(c) of the Commission’s Rules,6 KVH provides information regarding operational values that have changed in the attached FCC Form 312 and Schedule B. Out of an abundance of caution, KVH also provides herein an updated radiation hazard study.7 KVH confirms that V11 terminal operations otherwise will be consistent with the terms, conditions and operational parameters that are currently authorized under the C-Band ESV License. Because the V11 terminals will operate in accordance with the C-band off-axis EIRP spectral mask set forth in Section 25.221(a)(1), grant of Permitted List authority in the requested C-band frequencies is permissible.8 The public interest would be served by grant of this modification because it will allow KVH to enhance its operational flexibility and provide improved high-speed satellite broadband services to various U.S. maritime customers. Additionally, because the new emission complies with the Commission’s two-degree spacing requirements and other ESV 4 47 C.F.R. § 25.221(a)(1). 5 See Application for ESV Network License (including FCC Form 312 and Technical Appendix), File No. SES-LIC-20120328-00307 (Call Sign E120061). 6 47 C.F.R. § 25.117(c). 7 See Exhibit 1. 8 See 47 C.F.R. § 25.221(b)(7). 2

rules and policies, there is no material potential for interference and granting this authorization is fully consistent with the public interest. II. CONCLUSION Based on the foregoing, KVH respectfully request that the Commission grant its request to modify its existing C-Band ESV License, Call Sign E120061, by adding a new emission designator for its previously licensed V11 terminal and by adding authority for the terminal to communicate with the Permitted Space Station List. 3

EXHIBIT 1 Radiation Hazard Study 4

Radiation Hazard Analysis KVH Industries V11-HTS ESV This analysis predicts the radiation levels around a proposed earth station complex, comprised of one (reflector) type antennas. This report is developed in accordance with the prediction methods contained in OET Bulletin No. 65, Evaluating Compliance with FCC Guidelines for Human Exposure to Radio Frequency Electromagnetic Fields, Edition 97-01, pp 26-30. The maximum level of non-ionizing radiation to which employees may be exposed is limited to a power density level of 5 milliwatts per square centimeter (5 mW/cm2) averaged over any 6 minute period in a controlled environment and the maximum level of non-ionizing radiation to which the general public is exposed is limited to a power density level of 1 milliwatt per square centimeter (1 mW/cm2) averaged over any 30 minute period in a uncontrolled environment. Note that the worse-case radiation hazards exist along the beam axis. Under normal circumstances, it is highly unlikely that the antenna axis will be aligned with any occupied area since the antenna will be mounted high on a vessel’s superstructure and that would represent pointing toward a vessel deck or towards areas that would block the desired signals, thus rendering the link unusable. Earth Station Technical Parameter Table Antenna Actual Diameter 1 meters Antenna Surface Area 0.8 sq. meters Antenna Isotropic Gain 34.5 dBi Number of Identical Adjacent Antennas 1 Nominal Antenna Efficiency (ε) 67.50% Nominal Frequency 6.138 GHz Nominal Wavelength (λ) 0.0489 meters Maximum Transmit Power / Carrier 22.0 Watts Number of Carriers 1 Total Transmit Power 22.0 Watts W/G Loss from Transmitter to Feed 1.0 dB Total Feed Input Power 17.48 Watts Near Field Limit Rnf = D²/4λ =5.12 meters Far Field Limit Rff = 0.6 D²/λ = 12.28 meters Transition Region Rnf to Rff In the following sections, the power density in the above regions, as well as other critically important areas will be calculated and evaluated. The calculations are done in the order discussed in OET Bulletin 65. 1.0 At the Antenna Surface The power density at the reflector surface can be calculated from the expression: PDrefl = 4P/A = 8.902 mW/cm² (1) Where: P = total power at feed, milliwatts A = Total area of reflector, sq. cm In the normal range of transmit powers for satellite antennas, the power densities at or around the reflector surface is expected to exceed safe levels. This area will not be accessible to the general 1

public. Operators and technicians should receive training specifying this area as a high exposure area. Procedures must be established that will assure that all transmitters are rerouted or turned off before access by maintenance personnel to this area is possible. 2.0 On-Axis Near Field Region The geometrical limits of the radiated power in the near field approximate a cylindrical volume with a diameter equal to that of the antenna. In the near field, the power density is neither uniform nor does its value vary uniformly with distance from the antenna. For the purpose of considering radiation hazard it is assumed that the on-axis flux density is at its maximum value throughout the length of this region. The length of this region, i.e., the distance from the antenna to the end of the near field, is computed as Rnf above. The maximum power density in the near field is given by: PDnf = (16ε P)/(π D²) = 6.009 mW/cm² (2) from 0 to 5.12 meters Evaluation Uncontrolled Environment: Does Not Meet Uncontrolled Limits Controlled Environment: Does not Meet Controlled Limits 3.0 On-Axis Transition Region The transition region is located between the near and far field regions. As stated in Bulletin 65, the power density begins to vary inversely with distance in the transition region. The maximum power density in the transition region will not exceed that calculated for the near field region, and the transition region begins at that value. The maximum value for a given distance within the transition region may be computed for the point of interest according to: PDt = (PDnf)(Rnf)/R = dependent on R (3) where: PDnf = near field power density Rnf = near field distance R = distance to point of interest For: 5.12 < R < 12.3 meters We use Eq (3) to determine the safe on-axis distances required for the two occupancy conditions: Evaluation Uncontrolled Environment Safe Operating Distance,(meters), Rsafeu: 30.7 Controlled Environment Safe Operating Distance,(meters), Rsafec: 6.1 4.0 On-Axis Far-Field Region The on- axis power density in the far field region (PDff) varies inversely with the square of the distance as follows: 2

PDff = PG/(4πR²) = dependent on R (4) where: P = total power at feed G = Numeric Antenna gain in the direction of interest relative to isotropic radiator R = distance to the point of interest For: R > Rff = 12.3 meters PDff = 2.574 mW/cm² at Rff We use Eq (4) to determine the safe on-axis distances required for the two occupancy conditions: Evaluation Uncontrolled Environment Safe Operating Distance,(meters), Rsafeu : See Section 3 Controlled Environment Safe Operating Distance,(meters), Rsafec : See Section 3 5.0 Off-Axis Levels at the FarField Limit and Beyond In the far field region, the power is distributed in a pattern of maxima and minima (sidelobes) as a function of the off-axis angle between the antenna center line and the point of interest. Off-axis power density in the far field can be estimated using the antenna radiation patterns prescribed for the antenna in use. Usually this will correspond to the antenna gain pattern envelope defined by the FCC or the ITU, which takes the form of: Goff = 32 - 25log(Θ) for Θ from 1 to 48 degrees; -10 dBi from 48 to 180 degrees (Applicable for commonly used satellite transmit antennas) Considering that satellite antenna beams are aimed skyward, power density in the far field will usually not be a problem except at low look angles. In these cases, the off axis gain reduction may be used to further reduce the power density levels. For example: At one (1) degree off axis At the far-field limit, we can calculate the power density as: Goff = 32 - 25log(1) = 32 - 0 dBi = 1585 numeric PD1 deg off-axis = PDffx 1585/G = 14.629 mW/cm² (5) 6.0 Off-Axis power density in the Near Field and Transitional Regions According to Bulletin 65, off-axis calculations in the near field may be performed as follows: assuming that the point of interest is at least one antenna diameter removed from the center of the main beam, the power density at that point is at least a factor of 100 (20 dB) less than the value calculated for the equivalent on-axis power density in the main beam. Therefore, for regions at least D meters away from the center line of the dish, whether behind, below, or in front under of the antenna's main beam, the power density exposure is at least 20 dB below the main beam level as follows: PDnf(off-axis) = PDnf /100 = 0.06009 mW/cm² at D off axis (6) 3

See Section 8 for the calculation of the distance vs. elevation angle required to achieve this rule for a given object height. 7.0 Region Between the Feed Horn and Sub-reflector Transmissions from the feed horn are directed toward the subreflector surface, and are confined within a conical shape defined by the feed horn. The energy between the feed horn and subreflector is conceded to be in excess of any limits for maximum permissible exposure. This area will not be accessible to the general public. Operators and technicians should receive training specifying this area as a high exposure area. Procedures must be established that will assure that all transmitters are rerouted or turned off before access by maintenance personnel to this area is possible. 8.0 Evaluation of Safe Occupancy Area in Front of Antenna The distance (S) from a vertical axis passing through the dish center to a safe off axis location in front of the antenna can be determined based on the dish diameter rule (Item 6.0). Assuming a flat terrain in front of the antenna, the relationship is: S = (D/ sin α) + (2h - D - 2)/(2 tan α) (7) Where: α = minimum elevation angle of antenna D = dish diameter in meters h = maximum height of object to be cleared, meters For distances equal or greater than determined by equation (7), the radiation hazard will be below safe levels for all but the most powerful stations (> 4 kilowatts RF at the feed). For D= 1 meters h= 2.0 meters Then: α S 23 10.0 meters 25 3.4meters 30 2.9 meters 35 2.5 meters 40 2.2 meters Suitable barrier and signage should be provided to prevent casual occupancy of the area in front of the antenna within the limits prescribed above at the lowest elevation angle required, although this is highly unlikely given the installation of the antenna high on a vessel’s superstructure. Summary The earth station site will be protected from uncontrolled access with suitable barriers, signage and personnel instruction. There will also be proper emission warning signs placed and all operating personnel will be aware of the human exposure levels at and around the earth station. The applicant agrees to abide by the conditions specified in Condition 5208 provided below: 4

Condition 5208 - The licensee shall take all necessary measures to ensure that the antenna does not create potential exposure of humans to radiofrequency radiation in excess of the FCC exposure limits defined in 47 CFR 1.1307(b) and 1.1310 wherever such exposures might occur. Measures must be taken to ensure compliance with limits for both occupational/controlled exposure and for general population/uncontrolled exposure, as defined in these rule sections. Compliance can be accomplished in most cases by appropriate restrictions such as fencing. Requirements for restrictions can be determined by predictions based on calculations, modeling or by field measurements. The FCC's OET Bulletin 65 (available on-line at www.fcc.gov/oet/rfsafety) provides information on predicting exposure levels and on methods for ensuring compliance, including the use of warning and alerting signs and protective equipment for workers. The following table summarizes all of the above calculations: 5

Table — Summaryof All RadHaz Parameters i esy. Pormeter [Abbe Unis |Formin Dins Euo Antenna Diameter pr 1|_meters Antenna Centerine is 20| meters Antenna Surface Area. Sa 08 meters® |(m*DFY4 Anterna Ground Elevation ce 380| meters Frequency ofOpcration G e138] oif: Wayddengh h 00189 meters_|/F HPA Ouput Power Pres 220| wats HPA to Antenna Loss . 1o| as Transmit Power at Flange o 124]_dBw _|10 * Lor@re)— L« 17.48] wans Antenna Gain G.. 315| ani 2res8| wa ul m 3.1115027 wia Antenna Aperture Eficiency n 6750%) na |G, /@1* DenY 1. Reflector Surface Region Calculations Reflector Surface Power Density |PDas soor) w‘ _|as*Pym*D) 8.902] mWiem® |Does Not Meet Uncontrolled Limits [Does not Meet Controlled Limits 2. On—Axis Near Field Caleulations Extent ofNear Field Re 512] meters_D°/(@ 0 1678] fea Near Field Power Densiy PDat eon9! W‘ las* 1 * 2y m °D 6.009] mWiem® |Does Not Meet Uncontrolled Limits [Does not Meet Controlled Limits 3. On—Axis Transition Region Calculations Extent ofTransiion Region (min) Ire 512] meters_D°/(@ 0 Extent oTransiion Region (min) 1678] fea Extent ofTranstion Region (max) KB 1228]_metes_|(06* D)/A Extent oTransiion Region (max) 1027] fea Worst Case Transtion Region Power Densiy: |PDrr eon9! W‘ las *n *>y* D5 6.009] mWiem® |Does Not Meet Uncontrolled Limits [Does not Meet Controlled Limits Uncontalled Emvironment Safe Operaing DismifRsu 507| m |—PDa)*@abRs Conalled Emironment Safe Operaing DisancdRise 51| m __|—PDab*GabRsc 4. On—Avis Far Field Calculations Distance t the Far Field Resion lee 123| _metes |06*D5 A 1027] x On—Axis Power Densit in the Far Field rog asnal We‘ |G,tP/@+mtR®) 2.574] mWicm" |Does Not Meet Uncontrolled Limits [Meets Controlled Limits 5. OffAxis Levels at the Far Field Limit and Beyond Reflector Surface Power Density pps m.e29| Wir‘ |(G,, * P)/(@ * n * RF)*(GonlGeq) GoalGes at example angle 6 1 degree oses (Goa= 37 — 25tbe® 1.4629| mWiom® |Meets Controlled Limits 6. Off—axis Power Densityin the Near Field and Transitional Regions Calculations Power density 1/100 ofWa for one dameer [pps oeoo We (a6n n *PY D10 ind 0.06009] mWicm" |Meets Uncontrolled Limits 8. OffAxis Safe Distances from Earth Station 5— D‘ma + Ch—D — )Gna @= minimum elevation angle ofantema s3] dx h maximum heightofobject to be ceared, meters 20( m GD = Ground Elevation Dela antema—obstacld Comn clevation angle ss) 100| m 2s 54) m so) 23] m Es 23( m s 22 m Note: Masimum FCC power density limis for 6 GHzis 1 mWiemfor general popultion/incontroled expostre as per ECC OE&T Buletin No. 65, Ediion 97—01 August 1997, Appendx A page 67.


Document Created: 2018-12-19 10:38:14
Document Modified: 2018-12-19 10:38:14
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