Attachment Supplement

This document pretains to SES-STA-20060725-01254 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006072501254_535768

                                                                                                                  @ telenor
                                                                                                                           Keith H. Fagan
                                                                                                                           Senior Counsel




                                                                     November 14, 2006

           Marlene H. Dortch, Secretary
           Federal Communications Commission
           Washington, D.C. 20554

                       To:         International Bureau
                                   Systems Analysis Branch

                       Re:         File No. SES—STA—20060725—01254 (Call Sign E980136)

           Dear Ms. Dortch:

                    Telenor Satellite, Inc. (Telenor) hereby supplements the above—referenced request for
           Special Temporary Authority (STA) in order to submit the following information requested by
           the staff.

                       1. Frequencies. The frequencies listed in Inmarsat‘s Schedule S, and in Telenor‘s
           current license for this antenna, are as follows:

                       C—band uplink: 6454.4 — 6456.6 MHz (nominal center frequency 6455.5 MHz)
                       C—band downlink: 3629.4 — 3631.6 MHz (nominal center frequency 3630.5 MHz)
                       L—band downlink: 1574.4 — 1576.6 MHz (nominal center frequency 1575.5 MHz)

                   Those frequencies correspond to the 2.2 MHz frequency range of the navigation
           transponder on the satellite. However, in the underlying application accompanying this STA
           request (SES—MFS—20060725—01253), Telenor requested authorization for frequency ranges of
           2.2 MHz centered on the actual uplink and downlink frequencies used to provide service to the
           FAA, which are as follows:

                       C—band uplink: 6454.32 — 6456.52 MHz (center frequency 6455.42 MHz)
                       C—band downlink: 3629.32 — 3631.52 MHz (center frequency 3630.42 MHz)
                       L—band downlink: 1574.32 — 1576.52 MHz (center frequency 1575.42 MHz)

                  The reason for this apparent 80 kHz discrepancy is historical. It was originally
          contemplated that the navigation repeaters onboard the Inmarsat—3 satellites would be used to
          relay a signal with two separate components, compatible respectively with GPS and GLONASS.
          A repeater band 2.2 MHz wide and centered on 1575.5 MHz would have been able to
          accommodate both a GLONASS signal at 1575.5625 MHz and the GPS L1 frequency at 1575.42




l   Telenor Satellite Services Holdings, Inc.   Address:                   Telephone:        E—mail:                                        |
                                                1101 Wootton Parkway       +1 301 838 7860   keith.fagan@telenor—usa.com                    |
                                                10th Floor                 Fax:              Web site:                                      |
                                                Rockville, MD 20852 USA    +1 301 838 7752   telenor.com/satellite


MHz. Ultimately, however, there was no need for the GLONASS component. Thus, the only
signal transmitted is the one used for GPS.

         The uplink signal transmitted by Telenor is a 2.2 MHz carrier centered on 6455.42 MHz.
Thus, its frequency range is from 6454.32 to 6456.52 MHz. That signal is split on board the
satellite into a C—band downlink centered at 3630.42 MHz and an L—band downlink centered at
1575.42 MHz. Nominally, those are also 2.2 MHz carriers, but the satellite does not receive
below 6454.4 MHz or transmit below 3629.4 MHz (C—band) or 1574.4 (L—band), so the lower
part of the GPS signal, as received and retransmitted by the satellite, is cut off by 80 kHz.

        As stated above, Telenor initially requested a 2.2 MHz authorization for each link, based
on the actual center frequencies used to provide service to the FAA. That is clearly correct, at
least for the uplink. On the downlink, however, it might be more accurate to specify a 2.2 MHz
band for each link, based on the nominal center frequencies of the satellite transponder (C—band
and L—band). That would result in the following authorization:

       C—band uplink: 6454.32 — 6456.52 MHz (actual center frequency 6455.42 MHz)
       C—band downlink: 3629.4 — 3631.6 MHz (nominal center frequency 3630.5 MHz)
       L—band downlink: 1574.4 — 1576.6 MHz (nominal center frequency 1575.5 MHz)

Needless to say, Telenor will accept whatever determination the Bureau makes in this regard.

        2. Site location. The station license for this antenna specifies a longitude of 119° 4°
21.8" (NAD—27). The frequency coordination report prepared by Comsearch and submitted with
this application was based on a longitude of 119° 4° 25.2" (NAD—83), which corresponds to the
NAD—27 longitude specified in the license. The longitude of 119° 4° 24.9" stated in the
application is also based on NAD—83. The reason for the (very slight) discrepancy is that
Comsearch and Telenor used two different tools to make the conversion from NAD—27 to NAD—
83. For consistency, we will specify the 119° 4° 25.2" figure used by Comsearch.

        3. Use of 1545.8 — 1548.0 MHz band. As a matter of general principle, Telenor
believes that it should be allowed to use any portion of the L—band that Inmarsat is allowed to
use. However, this particular antenna is used only to provide service to the FAA, and that
service does not require the use of the 1545.8 — 1548.0 MHz band. Accordingly, Telenor does
not request the use of that band in this application.

        4. Maximum EIRP. The maximum EIRP per carrier requested in the underlying
application, and specified in Telenor‘s existing license, is 83 dBW. The maximum EIRP
specified in Inmarsat‘s technical description, which corresponds to actual operational figures, is
78 dBW. The reason for the discrepancy is that the FAA demanded an extra margin as a
countermeasure to interference; therefore, the license (and the underlying application) reflected
Telenor‘s capability and not the actual operating level, which is substantially less. In order to
meet FAA requirements, we continue to request a maximum EIRP per carrier of 83 dBW.

       5. Polarization. The L—band polarization requested in the underlying application, and
specified in Telenor‘s existing license, is Left and Right Circular Polarization. The actual


polarization, which is reflected in Inmarsat‘s technical description, is Right Hand Circular
Polarization. The reason for the discrepancy is that we originally sought to license the capability
rather than the actual operation. For consistency, we will specify Right Hand Circular
Polarization.

       In light of the above, Telenor respectfully requests the Bureau to grant its Request for
Special Temporary Authority.

                                             Respectfully submitted,




                                            ie
                                             TELENOR SATELLITE, INC.




                                             Keith H. Fagan
                                             Its Attorney



Document Created: 2019-05-30 04:26:35
Document Modified: 2019-05-30 04:26:35

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