Attachment Narrative

This document pretains to SES-MOD-INTR2018-10585 for Modification on a Satellite Earth Station filing.

IBFS_SESMODINTR201810585_1591606

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of Application of KVH Industries, Inc. to ) Modify Existing Ku-band Earth Station ) Call Sign E090001 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 Ku- band earth station onboard vessel (“ESV”) blanket license, Call Sign E090001,1 by adding an additional emission designator for 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, among several other antenna types, 500 V11 TracPhone terminals using various emission designators in the 14.0-14.5 GHz (Earth-to-space), 10.95-11.2 GHz (space-to-Earth), 11.45-11.7 GHz (space-to-Earth) and 11.7-12.2 GHz (space-to-Earth) bands.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 KVH Industries, Inc., Radio Station Authorization, File No. SES-MOD-20180314-00221 (Call Sign E090001) (“Ku-Band ESV License”). 2 See Permitted Space Station List (at https://transition.fcc.gov/ib/sd/se/permitted.html). 3 See Ku-Band ESV License. Other antenna types in the Ku-Band ESV License have Permitted List authority.

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 25.222(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 the attached FCC Form 312 and Schedule B for information that is changing as a result of the requested modification. Out of an abundance of caution, KVH also provides herein an updated radiation hazard study.7 KVH confirms that the V11 terminal operations otherwise will be consistent with the terms, conditions and operational parameters that are currently authorized under the Ku-Band ESV License. Because the V11 terminals will operate in accordance with the Ku-band off-axis EIRP spectral mask set forth in Section 25.222(a)(1), grant of Permitted List authority in the requested Ku-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. § 25.222(a)(1). 5 See KVH Industries, Inc., File No. SES-MOD-20120104-00005 (Call Sign E090001) at Application (including FCC Form 312 and Technical Appendix). 6 47 C.F.R. § 25.117(c). 7 See Exhibit 1. 8 See 47 C.F.R. § 25.222(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 Ku-Band ESV License, Call Sign E090001, 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 that would represent a blockage to the desired signals, thus rendering the link unusable. Earth Station Technical Parameter Table Antenna Actual Diameter 1.0 meters Antenna Surface Area 0.9 sq. meters Antenna Isotropic Gain 42.4 dBi Number of Identical Adjacent Antennas 1 Nominal Antenna Efficiency (ε) 70.00% Nominal Frequency 14.25 GHz Nominal Wavelength (λ) 0.0211 meters Maximum Transmit Power / Carrier 3.0 Watts Number of Carriers 1 Total Transmit Power 3.0 Watts W/G Loss from Transmitter to Feed 0.7 dB Total Feed Input Power 2.58 Watts Near Field Limit Rnf = D²/4λ =13.09 meters Far Field Limit Rff = 0.6 D²/λ = 31.42 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 = 1.192 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 public. Operators and technicians should receive training specifying this area as a high exposure 1

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) = 0.834 mW/cm² (2) from 0 to 13.09 meters Evaluation Uncontrolled Environment: Meets Uncontrolled Limits Controlled Environment: Meets 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: 13.09 < R < 31.4 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: 10.9 Controlled Environment Safe Operating Distance,(meters), Rsafec: 2.2 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: 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 2

R = distance to the point of interest For: R > Rff = 31.4 meters PDff = 0.357 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 Far Field 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 = 0.330 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 = 0.00834 mW/cm² at D off axis (6) See Section 8 for the calculation of the distance vs. elevation angle required to achieve this rule for a given object height. 3

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= 1.05 meters h= 2.0 meters Then: α S 23 3.8 meters 25 3.5meters 30 2.9 meters 35 2.5 meters 40 2.2 meters Suitable fencing or other barrier 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. Summary The earth station site will be protected from uncontrolled access with suitable fencing and other barrier walls. 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: 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 4

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 worker. The following table summarizes all of the above calculations: 5

Table 1 Summaryof All RadHaz Parameters [KVH Industries Pormeter [Abbe Unis |Formin Dins Hub Antenna Diameter pr 10| _meters Antenna Centerine is 100| _meters Antenna Suface Area Sa 09 meters® |(m * DF)Y/4 Antenna Ground Elevaton ce 380| _meters Frequency ofOpcration G 125| oi Wayddengh h 00211|_metes _|e/f HPA Ouput Power Pres 30| wars HPA to Antenna Loss . o7|__as Transmit Power at Flange o 41]_aBw _|10 * LorPred—Ls 258| wans Antenna Gain G.. 423) am I7is28] wa P m 31415027] wa Antenna Aperture Eficiency n 70.00%| nia |G, /@1* DeMY" T. Reflector Surface Region Calculations Reflector Surface Power Densiy |PDas 1191 w _|as*Pym*D) 1.194] mWiem* |Does Not Meet Uncontrolled Limits [Meets Controlled Limits 2. On—Axis Near Field Calculations Extent ofNear Field Re 13.07) meters D*( *) 4286| fex Near Field Power Density PDat EkG las* 1 * 2y m °D 0.836] mWiem‘ |Meets Uncontrolled Limits [Meets Controlled Limits 3. On—Axis Transition Region Calculations Extent of Transiion Resion (nin) Inw 1307 meters_|DV/@*%) Extent oTransiion Resion (min) 4286| fex Extent ofTranstion Resion (man) KB 3136] mtes_|(06* D9 /A Extent oTransiion Resion (man) 10287| fe Worst Case Transtion Resion Power Densty |PDir s36| We‘ _|as*»*P/°D) 0.836| mWiem‘ |Meets Uncontrolled Limits [Meets Controlled Limits Uncontalled Environment Safe Operaing Dista Rou 103| m __|—PDa)*@abRsw Conalled Emironment Safe Operating Distaned sc 22| m __|—PDa)*@aDRsc 4. On—Avis Far Field Caleulations Distance t the Far Field Region lee 314)_meters_|0.6* D5 A 10287| fe On—Axis Power Densit in the Far Field rog ase| W‘ |G)*P/G*mtRO 358| mWicm" |Meets Uncontrolled Limits [Meets Controlled Limits 5. OffAxis Levels at the Far Ficld Limit and Beyond Reflector Surface Power Densiy pps 0331| Win‘ |(G, * P)/(4 * Tt * R®)*(GoalGes) GoalGes at example angle 0 1 degrec 0052 (Goa= 37 — 25tbe® 00331] mWiem‘ |Meets Controlled Limits 6. Off—axis Power Density in the Near Field and Transitional Regions Calculations Power density 1/100 ofWa for one diameter [pps nouse as * 1 +2) on D3py100 ind o.oosse [Meets Uncontrolled Limits 8. OffAxis Safe Distances from Earth Station 5— D‘ma + Ch—D — 3@ @= minimum elevation angle ofantemna 5 h = maximum heightoobjectto be cleared. meters 2o GD = Ground Elevation Deita antemna—obstacld oo clevation angle 5 is o a7 is 5s 20) 44 2s 35 Note: Masimum FCC power densit linits for 6 GHzis 1 mW/omfor general population/incontraled expostre as per ECC OE&T Buletin No. 65, Edtion 9701 August 1997, Append A page 67.


Document Created: 2018-12-19 10:40:23
Document Modified: 2018-12-19 10:40:23
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