Attachment RadhadExhibit

This document pretains to SES-STA-20070530-00734 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2007053000734_570656

                                                   Comtech Mobile Datacom Corporation
                                                            FCC Form 312, Schedule B
                                                                     Exhibit A, Page 1

                        Radiation Hazard Study – Question 28

                         Comtech Mobile Datacom Corporation
                            Mobile Earth Station Terminal
                                   May 30, 2007

                                       Background

Comtech Mobile Datacom Corporation (“CMDC”) designs, manufactures, and is licensed
to operate Mobile Earth Station Terminals (“MESs”) in spectrum allocated to the Mobile
Satellite Service under the Federal Communications Commission guidelines of Part 25,
Title 47 of the Code of Federal Regulations. CMDC is requesting a modification to its
existing blanket license.

Completion of a routine environmental analysis for RF exposure (as described in Federal
Communications Commission Office of Engineering and Technology Bulletin 65
(“Bulletin 65”)) due to emissions from the MES is one of the requirements to modify the
existing blanket license.

Bulletin 65 identifies two parameters relating to equipment type and usage that determine
the appropriate testing methods and limits.

First, devices may be classified as either Mobile or Portable. A Mobile device is
intended for use in other than fixed locations and should be separated from the user or
bystanders by at least 20 centimeters. Portable devices are intended to be operated within
20 centimeters of the user or bystander.

Second, the exposure must be deemed Occupational/Controlled Exposure or General
Population/Uncontrolled Exposure. Occupational/Controlled Exposure applies where
persons are exposed due to their employment or when they have been made aware of the
potential for exposure and are able to exercise control over their exposure. Cases where
the general public is exposed or where workers are not fully aware of the potential for
exposure or are unable to exercise control over the amount of their exposure fall into the
General Population/Uncontrolled Exposure category.

CMDC MESs fit into the Mobile and General Population/Uncontrolled Exposure
categories. As such, the permissible radiation level may be determined using either
Maximum Permissible Exposure or Specific Absorption Rate techniques. CMDC elects
to use a Maximum Permissible Exposure analysis using the limits for General
Population/Uncontrolled Exposure for frequencies above 1500 MHz shown in section B
of the table below.


                                                    Comtech Mobile Datacom Corporation
                                                             FCC Form 312, Schedule B
                                                                      Exhibit A, Page 2




                                     Analysis Method

A Maximum Permissible Exposure analysis will be done using the methods described in
Bulletin 65 and the source-based time-averaging methods described in Title 47 of the
Code of Federal Regulations Part 2.1091.

The source-based averaging allows scaling of the exposure level based on the inherent
duty cycle of the MES. CMDC’s MESs are limited to a maximum transmission duty
cycle of 52% (a 1.552 second transmission burst every 3.0 seconds).

Bulletin 65 offers several methods for calculating the RF Power Density. Three of these
methods seem appropriate for this analysis.

First, the equations below will predict the power density in the antenna far field and will
overstate the density in the near field.


                                                   Comtech Mobile Datacom Corporation
                                                            FCC Form 312, Schedule B
                                                                     Exhibit A, Page 3




Second, the power density may be determined for an antenna close to a ground plane.
The following equation provides this result based on 100% reflection from the ground
plane. The power density determined by this method will be four times that of the
density determined in the far field.




Third, the Environmental Protection Agency has recommended a more realistic
approximation of those results in a power density increase of 2.56 above the far field
case.




This method seems most representative of the typical operating conditions for CMDC’s
MESs and is the method adopted for this analysis.


                                                   Comtech Mobile Datacom Corporation
                                                            FCC Form 312, Schedule B
                                                                     Exhibit A, Page 4

                                        Analysis

The separation distance required to produce an RF power density less than one milliwatt
per square centimeter will be calculated for all possible antennas. The calculations will
be done for the maximum antenna input power of 6 dBW and for a maximum duty cycle
of 52 %. The antennas that are available for use are characterized in the table below.

Antenna                                        Antenna Size           Antenna Gain
                      Type
  ID                                             (meters)                 (dBi)
A1/INT          Quadrafilar Helix                  0.15                    2.9
A2/EXT          Quadrafilar Helix                  0.15                    4.8

A2/EXT                Patch                        0.06                    4.0

 A4/INT         Quadrafilar Helix                  0.15                    5.0
A5/EXT          Quadrafilar Helix                  0.27                    3.9
A6/INT          Quadrafilar Helix                  0.18                    3.7
A7/INT          Quadrafilar Helix                  0.18                     6
A8/EXT          Quadrafilar Helix                  0.18                    3.7


Using the maximum power into the antenna of 6 dBW, a duty cycle of 52% and the
antenna gains from the table above; the minimum separations to achieve one milliwatt
per square centimeter power densities are calculated and listed in the table below.


                                                   Separation distance for 1 mW
       Antenna ID               Type               per square centimeter Power
                                                           Density (cm)
        A1/INT            Quadrafilar Helix                     29
        A2/EXT            Quadrafilar Helix                     36
        A3/EXT                 Patch                            33
        A4/INT            Conformal Patch                       37
        A5/EXT            Quadrafilar Helix                     32
        A6/INT            Quadrafilar Helix                     31
        A7/INT            Quadrafilar Helix                     41
        A8/EXT            Quadrafilar Helix                     31


The typical CMDC MES is installed on the top surface of a land vehicle, ship, or aircraft.
Distances to operating personnel and the general population will be greater than the
separation distances calculated above.


                                                 Comtech Mobile Datacom Corporation
                                                          FCC Form 312, Schedule B
                                                                   Exhibit A, Page 5

The table below indicates the typical CMDC MES mounting location for various
applications and the minimum distance necessary to prevent a hazard to operators and the
general population.


                                 Typical minimum installation     Minimum distance necessary
         Application
                                 separation from people (cm)        to prevent hazard (cm)
          Trucking                            90                              41
            Rail                              300                             41
          Container                           200                             41
           Boats                             >300                             41
          Aviation                            75                              41


                                      Conclusions

The preceding analysis shows that the CMDC MESs meet the Federal Communications
Commission guidelines for RF exposure.



Document Created: 2007-06-01 09:27:07
Document Modified: 2007-06-01 09:27:07

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