Attachment Narrative

This document pretains to SES-STA-20101213-01550 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010121301550_856798

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) LightSquared Subsidiary LLC ) File No. _____________ ) Application for Special Temporary Authority ) APPLICATION By this application, LightSquared Subsidiary LLC (“LightSquared”) seeks Special Temporary Authority (“STA”), for a period of 30 days, to transmit from the Napa earth station (Call Sign E080030) to SkyTerra 1 in the 12750-12752 MHz band (Earth-to-space) at a higher power than is authorized by the license for the earth station. The application is necessary because LightSquared specified incorrect maximum power levels for the 12750-12752 MHz band in the license application for the Napa earth station, File No. SES-LIC-20080206-00131.1 This frequency band is used as a back-up band for ranging and command transmissions, and higher power is necessary to ensure that the earth station can maintain the link with the satellite under degraded conditions, such as in the event of rain. Additionally, the requested authority is a critical component of the in-orbit-testing for SkyTerra 1, which is currently underway. LightSquared, therefore, requests expedited grant of this application.2 For the earth station’s 7.3-meter antenna and the relevant 11-meter antenna, LightSquared seeks to increase, from 71 dBW to 82.5 dBW and 73.5 dBW to 85 dBW, 1 LightSquared intends to file a modification of license application shortly, seeking regular authority for the temporary authority requested in this filing. 2 Pursuant to the FCC’s rules, the Commission may grant, without public notice of the application, a temporary authorization for a period not to exceed 30 days. See 47 C.F.R. § 25.120(b)(2).

respectively, the authorized maximum output power of its transmissions in the 12750-12752 MHz band. The associated maximum EIRP density will increase to 57.73 dBW/4 kHz and 60.30 dBW/4 kHz, for the 7.3-meter antenna and 11-meter antenna, respectively. As noted above, the 12750-12752 MHz band is used as a back-up band for ranging and command transmissions, which are normally conducted in the 13248-13250 MHz frequency band. The proposed maximum power levels for the 12750-12752 MHz band correspond exactly to the maximum power levels already authorized for transmissions in the 13248-13250 MHz band.3 The requested higher maximum power for transmissions in the 12750-12752 MHz band will allow for greater margin under degraded conditions (such as in the event of rain), increasing the earth station’s ability to maintain the link with the satellite’s pipe/bi-cone antennas during those events. LightSquared has coordinated proposed transmissions up to 77 dBW with TerreStar-1, which is the nearest unaffiliated satellite operating in the 12750-12752 MHz band, and is in the process of completing coordination for proposed transmissions up to 85 dBW. In any event, with respect to operations pursuant to this application, LightSquared will operate on an unprotected and non-interference basis.4 For the reasons stated above, LightSquared requests expedited grant of this application. 3 See License, Call Sign E080030. 4 TerreStar-1 is at 111.0°W. In light of this minimum 9.8° of separation, the lowest amount of sidelobe discrimination is 45 dB. 2

Respectfully submitted, LightSquared Subsidiary LLC /s/ Name: Jeffrey J. Carlisle Title: Executive Vice President, Regulatory Affairs and Public Policy of LightSquared LP LightSquared Subsidiary LLC Bruce D. Jacobs Tony Lin Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, NW Washington, DC 20037-1128 (202) 663-8000 Counsel for LightSquared Subsidiary LLC December 13, 2010 3

Technical Certification I, Richard Evans, hereby certify under penalty of perjury that: I am the technically qualified person responsible for preparation of the engineering information contained in this application, that I am familiar with Part 25 of the Commission’s rules, that I have either prepared or reviewed the engineering information submitted in this application, and that it is complete and accurate to the best of my knowledge. /s/ Richard Evans Principal Engineer LightSquared Subsidiary LLC December 13, 2010

Certification of Jeffrey J. Carlisle I, Jeffrey J. Carlisle, hereby certify under penalty of perjury that: 1. I am Executive Vice President, Regulatory Affairs and Public Policy of LightSquared LP, the managing member of LightSquared Subsidiary LLC, and have authority to file this application; 2. The statements made in this application are true, complete, and correct to the best of my knowledge and belief; and 3. No party to the application is subject to a denial of federal benefits pursuant to Section 5301 of the Anti Drug Abuse Act of 1988, 21 U.S.C. §853a. /s/ Jeffrey J. Carlisle Executive Vice President, Regulatory Affairs and Public Policy of LightSquared LP LightSquared Subsidiary LLC December 13, 2010


Document Created: 2010-12-13 18:08:07
Document Modified: 2010-12-13 18:08:07
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC