Attachment Grant

This document pretains to SES-STA-20090410-00439 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2009041000439_709282

                                              SES—STA—20090410—00439       1B2009000986
                                     E090029
                                     COMTECH MOBILE DATACOM CORP.




                                                                                                                     Approved by OMB
                                                                                                                            3060—0678

                            APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
ASDR/ASDR—O STA request (Domingus Hills)
 1. Applicant

           Name:        COMTECH MOBILE                 Phone Number:                           240—686—3300
                        DATACOM CORP.
           DBA Name:                                   Fax Number:                             240—686—3301
           Street:      20430 Century Boulevard        E—Mail:                                 david.ulanow@comtechmobile.
                                                                                               com


           City:        Germantown                     State:                                   MD
           Country:     USA                            Zipcode:                                20874          —
           Attention:   Mr David A Ulanow




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                                Comtech Mobile Datacom Corp.
                           IBFS File No. SES—STA—20090410—00439
                                      Call Sign E090029

The request of Comtech Mobile Datacom Corp. (Comtech) for special temporary authority
(STA) IBFS File No. SES—STA—20090410—00439 IS GRANTED. Accordingly, Comtech is
authorized for a period of 60 days, beginning May 1, 2009, to operate up to 100 full—duplex data
mobile earth terminals (MET‘s) (Call Sign EO90029) using any ISAT satellite in the 1525—1544
MHz, 1545—1559 MHz, 1626.5—1645.5 MHz. and 1646.5—1660.5 MHz frequency bands.
Operations shall be in accordance with the terms, conditions, and technical specifications set
forth in the Commission‘s rules, this document, and its STA request File No. SES—STA—
20090410—00439.
1. All operations shall be on an unprotected and non—harmful interference basis, i.e., Comtech
   shall not cause harmful interference to, and shall not claim protection from, interference
   caused to it by any other lawfully operating station.
2. In the event of any harmful interference as a result of Comtech‘s operations, Comtech shall
   cease operations immediately upon notification of such interference, and shall inform the
   Federal Communications Commission (FCC), in writing, immediately of such an event.
3. Comtech‘s operation of its 100 MET‘s is on a secondary basis to safety and distress
   communications of those stations operating in the Aeronautical Mobile [R] Service and the
   Global Maritime Distress Satellite Service.
4. Comtech‘s operations must comply with the out—of—band emission limits for mobile earth
   terminals set forth in 47 C.E.R. § 25.216.
5. Comtech may only operate on frequencies not shared with aeronautical or maritime distress
   services.
6. Grant of this STA is without prejudice to any action that the Commission may make
   regarding Comtech‘s pending application to operate the above—referenced MESs (as well as
   certain other MESs) (IBFS File No. SES—LIC—20090211—00171).
7. This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated
   authority, 47 C.F.R. § 0.261, and is effective immediately. Petitions for reconsideration
   under Section 1.106 or applications for review under Section 1.115 of the Commission‘s
   rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date of the public notice
   indicating that this action was taken.

8. This authorization is not one relating to an "activity of a continuing nature" for purposes of
   Section 1.62 of the Commission‘s rules and Section 558(c) of the Administrative Procedure
   Act. Continuation of operations beyond the 60 day term of this authorization will require
   prior affirmative authorization by the FCC.


2. Contact


             Name:         Joan M. Griffin                     Phone Number:                         202—342—8573
             Company:      Kelley Drye & Warren LLP            Fax Number:                           202—342—8451
             Street:       3050 K Street NW                    E—Mail:                               jgriffin@kelleydrye.com
                           Suite 400
             City:         Washington                          State:                                 DC
             Country:      USA                                 Zipcode:                              20007      —=
             Attention:                                        Relationship:                          Legal Counsel


(If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
3. Reference File Number or Submission ID

  4a. Is a fee submitted with this application?
@, IfYes, complete and attach FCC Form 159.        If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
{j. Governmental Entity      53 Noncommercial educational licensee
C Other(please explain):

4b. Fee Classification    CGB — Mobile Satellite Earth Stations

5. Type Request

@ Use Prior to Grant                              3 Change Station Location                          C Other



6. Requested Use Prior Date
      05/01/2009
7. City                                                                   8. Latitude
                                                                          (dd mm ss.s h)    0O   0   0.0


9. State                                                                   10. Longitude
                                                                           (dd mm ss.s h)     0   0   0.0
11. Please supply any need attachments.
Attachment 1: STA request                         Attachment 2: Exhibit A                             Attachment 3: Exhibits B, C, and D


12. Description.   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Comtech requests an STA to operate up to 100 full duplex L—band METs throughout the US on
     ISAT for a 60—day period starting 5/1/09




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is               Yes        £34 No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name of Person Signing                                                  15. Title of Person Signing
  Greg Handermann                                                              EVP & CTO
           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


                                                            Comtech Mobile Datacom Corporation
                                                                        ISAT—ASDR STA Request
                                                                                       Page 1



                                     Description of STA Request

       Comtech Mobile Datacom Corporation ("CMDC") requests special temporary authority
{("STA"), pursuant to Section 25.120(b)(2) of the Commission‘s Rules, to operate up to 100 full—
duplex data mobile earth terminals ("METs") in portions of the L—band (1525—1544/1545—1559
MHz and 1626.5—1645.5/1646.5—1660.5 MHz) in CONUS, Alaska, Hawaii, and any U.S.
territory or possession within the footprint of an ISAT satellite. The METs CMDC proposes to
operate pursuant to the requested authority are CMDC‘s ASDR and ASDR—O METs. Proposed
particulars of operation for these MET‘s are as described in CMDC‘s blanket MET license
application in File No. SES—LIC—20090211—00171 (the "CONUS Application," E0900029) under
Site ID "ISAT—ASDR." The CONUS Application encompasses the authority sought in this STA
request.

       In support of this STA request, CMDC provides the following information:

               Exhibit A: excerpts from FCC Form 312, Schedule B to the CONUS Application.
               Exhibit B: Radiation Hazard Study,
               Exhibit C: Section 25.137 information.
               Exhibit D: letter from INMARSAT regarding CMDC‘s use of dedicated channels.

       CMDC asks that the Commission grant this authority beginning May 1, 2009 for a
minimum of 60 days and preferably until such time as the Commission acts on the CONUS
Application. CMDC notes that the public notice period for the CONUS Application will end on
or about April 17, 2009‘ and thus that the CONUS Application will be ripe for grant before May
1. Should the Commission grant the CONUS Application on or before May 1, CMDC will
withdraw this STA request.

       Section 25.120(b)(1) of the Commission‘s Rules provides that the Commission may grant
a temporary authorization only upon a finding that there are extraordinary circumstances
requiring temporary operations in the public interest and that delay in the institution of these
temporary operations would seriously prejudice the public interest. CMDC submits that such
extraordinary circumstances exist here. CMDC is requesting an STA to satisfy the needs of one
of its current customers, the U.S8. Army, for a demonstration of CMDC‘s ASDR and ASDR—O
METs. Grant of this STA request will serve the public interest in that it will allow the Army to
evaluate these terminals and associated services, whichare more spectrally efficient and thus
more cost effective than existing terminals and services.

         At the same time, CMDC‘s operations pursuant to the authority requested herein will not,
in all likelihood, result in any harm to the public interest. CMDC notes that since the proposed
terminals are full—duplex, CMDC‘s operation pursuant to this STA request will fully comply with
the requirements of Section 25.136(d) of the FCC Rules and NTIA‘s requirements regarding the

I      See Report No. SES—01121, rel. Mar. 18, 2009.


                                                           Comtech Mobile Datacom Corporation
                                                                       ISAT—ASDR STA Request
                                                                                           Page 2

protection of maritime and aeronautical mobile—satellite service distress and safety
communications.

       CMDC acknowledges that any grant of this STA request is without prejudice to, and will
be conditioned on, the Commission‘s final action on any CMDC application. CMDC‘s
operations will comply with any applicable conditions for the operation of MET‘s with satellites
on the ISAT list.

       For the reasons set forth above, CMDC respectfully requests that this STA be granted no
later than May 1, 2009, if the CONUS Application cannot be granted on or before that date.


                                      VERIFICATION


       1, David A. Ulanow, am Director of Contracts of Comtech Mobile Datacom Corporation

("CMDC"). I am authorized to represent CMDC and to make this verification on its behalf. The

statements in the foregoing document relating to CMDC are true and correct to the best of my

knowledge and belief.

       I declare under penalty of perjury that the foregoing is true and correct.




Subscribed and sworn to before me this eighth day of
April, 2009.

          a         "                3

&          =                                A. HOWARD
Notary Public                           NOTARY PUBLIG
                                     MONTGaomEeRy countty
                                          MARYLAND
                               My Commission Expires July 11, 2011
My Commission expires:



Document Created: 2019-04-17 04:49:36
Document Modified: 2019-04-17 04:49:36

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