Attachment FCCDismissLtr

FCCDismissLtr

LETTER submitted by FCC

FCC Letter dismissing STA request without prejudice.

2007-09-27

This document pretains to SES-STA-20070612-00794 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2007061200794_595849

                           Federal Communications Commission
                                 Washington, D.C. 20554

                                                                                                 DA 07-4077

                                            September 27,2007

Robert W. Swanson
1101 Wootton Parkway
10th Floor
Rockville, MD 20852

                                                       Re: Call Sign KB34
                                                           File No. SES-STA-20070612-00794

Dear Mr. Swanson:

                                                                 '
          On June 12, 2007, Vizada Satellite, Inc. (Vizada) filed the above-captioned request for
Special Temporary Authority (STA) to allow its Santa Paula, CA earth station to communicate
with the United Kingdom's Inmarsat 3F4 satellite at the 142" W.L. orbital location. On August
20, 2007, Vizada submitted a supplement to update its STA to clarify that it requests authority to
operate a 10.4 meter earth station and transmit in the 641 7.5-6456.7 MHz band and receive in the
3600.0-363 1.5 MHz band. On August 30, 2007, Vizada filed a second supplement to indicate
that the proposed feeder link will be used to provide both International and Domestic Service. On
September 20,2007, Vizada filed a third supplement containing a Schedule S for Inmarsat-3F4.
For the reasons stated below, we dismiss the STA application as defective without prejudice to
refiling.

         Section 25.1 12 of the Commission's rules, 47 C.F.R. tj 25.1 12, requires the Commission
to return, as unacceptable for filing, any earth station application that is not substantially
complete, contains internal inconsistencies, or does not substantially comply with the
Commission's rules. Vizada's STA application contains several omissions and inconsistencies,
and does not comply with the Commission's rules, rendering it subject to dismissal. These
omissions and discrepancies are as follows:

            ( 1 ) Footnote US245 of Section 2.106 of the Commission's rules, 47 C.F.R. Cj 2.106,
states that non-Federal fixed-satellite service operations in the 3600-3650 MHz band are limited
to international inter-continental operations. Vizada's August 30 supplement indicates its
proposed feeder link for the Inmarsat 3F4 satellite will be providing, among other things,
domestic GPS correction capability in the 3600-3650 MHz band. Vizada did not request a waiver
of a Footnote US245 of Section 2.106 of the Commission's rules to permit the proposed domestic
service in this band.

           (2) In response to item S2 of Schedule S, Vizada indicates the frequency band limits
for Inmarsat-3F4 are 6425-6454, 6454.4-6456.6, 3600-3629, and 3629.4-363 1.6 MHz. This is
inconsistent with the proposed earth station operating bands of 641 7.5-6456.7 and 3600.0-363 1.5
MHz. In addition, based on Vizada's response to item S9 of Schedule S, we calculate the band
limits for channels CUR and CUL to be 6410.5-6468.5 MHz. This band is wider than the band
                ~   ~~~




'This application was initially filed by Telenor Satellite, Inc. Telenor Satellite, Inc. changed its name to
Vizada Satellite, Inc.


                                    Federal Communications Commission                        DA 07-4077


limits listed in response to item S2 of Schedule S. Thus, we cannot determine the exact bands in
which the earth station will operate.

         (3) Vizada seeks to operate using a 1K65G2D emission designator. This proposed
emission designator is inconsistent with the designators listed in the link budgets and S11 of
Schedule S, which indicate that the emission designator used by the Inmarsat-3F4 satellite is
classified as G1 D.2 Thus, we cannot determine which emission designator the earth station will
use.

        Further, while not a ground for dismissal, we request Vizada to provide, in any refiling, a
case-by-case electromagnetic compatibility analysis to demonstrate its compatible operations, as
indicated in Footnote US245 of Section 2.106 and Section 2.108 of the Commission’s rules, 47
C.F.R. $5 2.106 and 2.108.

          Finally, pursuant to Section 25.1 1 1(a) of the Commission’s rules, 47 C.F.R. 5 25.1 1 1(a),
in any refiling we request Vizada to certify that it has completed an EMC analysis according to
US245 for its operations in the 3625-3700 MHz band, based on the NTIA TR-99-361 Report,
Technical Characteristics of Radiolocation Systems operating in the 3.1-3.7 GHz Band and
Procedures for assessing EMC with Fixed Earth Station Receivers (available at
h tt p://www .nt ia.doc.gov/osmhoi~ie/reports. htm 11, has determined the potential for unacceptable
interference that may be caused to its receiving earth station, and agrees to accept such
interference. Vizada should also certifL that it is aware that use of a RF filter ahead of the low
noise amplifier (LNA) would limit potential out-of-band interference to the receiving earth
stat ion.

        Accordingly, pursuant to Section 25.1 12(a)(1) of the Commission’s rules, 47 C.F.R.
525.1 12(a)( l), and Section 0.26 1 of the Commission’s rules on delegations of authority, 47
C.F.R. 50.261, we dismiss the above-captioned application without prejudice to refiling.


                                                     Sincerely,



                                                     Scott A. Kotler
                                                     Chief, Systems Analysis Branch
                                                     Satellite Division
                                                     International Bureau




’  According to Section 2.201 of the Commission’s rules, the second symbol “ 1 ” of an emission denotes a
single channel containing quantized or digital information without the use of a modulating sub-carrier,
excluding time-division multiplex. The second symbol “2” of an emission denotes a single channel
containing quantized or digital information with the use of a modulating sub-carrier, excluding time-
division multiplex.


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Document Created: 2007-09-27 15:00:09
Document Modified: 2007-09-27 15:00:09

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