Attachment 20110816154800.pdf

20110816154800.pdf

DECISION submitted by IB/FCC

Granted STA with conditions

2011-08-16

This document pretains to SES-STA-20110711-00819 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011071100819_912747

                                     KA25        SES—STA—20110711—00819     182011003512
                                     Inmarsat Hawaii Inc.




                                                                                                                       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:
STA— Paumalu, HI 19m Antenna (LEOP)
 1. Applicant


           Name:        Inmarsat Hawaii Inc.                Phone Number:                       202—248—5155
           DBA Name:                                        Fax Number:                         202—248—5186
           Street:      1101 Connecticut Avenue NW          E—Mail:                             diane_cornell@inmarsat.com
                        Suite 1200
           City:        Washington                          State:                              DC
           Country:     USA                                 Zipcode:                            20036       =
           Attention:   Diane J Cornell



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Conditions of Grant of Inmarsat SES—STA—20110711—00819


Inmarsat Hawaii Inc is authorized to operate a 19 meter antenna at Paumalu, Hawaii for
 telemetry, tracking, and control communications with the Express AM4 spacecraft (to
operate at 80 ° E. L.) during its Launch and Early Orbit Phases (LEOP) beginning August
17, 2011 for a period of 30 days on frequencies 6535.0 MHz Earth—to—Space and 4199.5
MHz space—to—Earth within the parameters defined in application SES—STA—20110711—
00819 under the following conditions.

1. All operations shall be on an unprotected and non—harmful interference basis, i.e.,
Intelsat 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 that there is a report of interference, Intelsat must immediately terminate
transmissions and notify the FCC in writing.



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                                ie#   sSEs—STA —20il0"¢ir —00813




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                                                Exhibit A

                         DESCRIPTION OF STA REQUEST
                                    AND
               PETITION FOR WAIVER OF SECTIONS 25.137 AND 25.114


L.      DESCRIPTION OF STA REQUEST

        Inmarsat Hawaii Inc. ("Inmarsat Hawait") hereby requests special temporary authority
("STA") to use its 19 meter earth station antenna located in Paumalu, Hawaii and operated
pursuant to Call Sign KA25 (the "19m Antenna") to permit C—band telemetry, tracking, and
control ("TTAC") communications with the Express AM4 spacecraft during its Launch and
Early Orbit Phases (LEOP).‘ Operations of the 19m Antenna during this LEOP period would
be consistent with the technical parameters of the existing license for KA25, although
Express AM4 is not currently a licensed point of communication for the 19m Antenna.

       The Express AM4 satellite will be launched by a Proton launch vehicle from the
Baikonur facility in Kazakhstan. Inmarsat Hawaii and its affiliates will provide a network of
ground stations around the globe that will provide communication with the spacecraft during
the LEOP. The Inmarsat Hawaii facility at Paumalu, Hawaii will form part of the Inmarsat
Hawaii ground station network for this launch support using the 19m Antenna. Launch is
currently scheduled for August 17"", 201 1.

        Inmarsat Hawaii has contracted with Astrium (France) to support the LEOP portion of
the launch using the C—band portion of the satellite prior to its commercial operation. The
mission control center will be located at the Astrium premises in Toulouse, France and all the
mission operations will be conducted, under Astrium‘s control. It is expected that the 19m
Antenna will be used intermittently during the first three or four days of support for limited
periods when the spacecraft is visible from the Paumalu station.

        The final geostationary operational location for Express AM4 will be at or near 80.0°
E.L. No on—station operations with Express AM4 will be possible from the Paumalu ground
station once the satellite is operational given the lack of visibility to the final orbital location.
Therefore, Inmarsat Hawaii‘s support to Astrium using the Paumalu station and 19 m
Antenna will be limited to the LEOP portion of the mission only.

IL.     TO THE EXTENT THEY APPLY, GOOD CAUSE EXISTS FOR AWAIVER
        OF CERTAIN PORTIONS OF SECTIONS 25.137 AND 25.114

       Inmarsat Hawaii is providing the following legal and technical information to support
this STA request and certain waiver requests that are necessary in order to communicate from
the 19m Antenna to the Express AM4 spacecraft as the spacecraft is not listed as a point of
communications on Inmarsat Hawaii‘s license for the antenna.




* The Express AM4 satellite is an EADS Astrium Eurostar 3000 C—, L—, Ku— and Ka—band satellite designed for
operation from the 80.0° E.L. orbital location.


        Pursuant to Section 25.137 of the Federal Communications Commission‘s
("Commission" or "FCC") rules, the same technical information required by Section 25.114
for U.S.—licensed space stations, and certain legal information, must be submitted by earth
station applicants "requesting authority to operate with a non—U.S. licensed space station to
serve the United States..."" Inmarsat Hawaii seeks authority to support the needed TTAC
during the LEOP of the Express AM4 spacecraft from shortly after launch to low earth and
transfer orbits. Inmarsat Hawaii does not request authority to provide commercial service to
the United States, and thus believes that Section 25.137 does not apply.

         To the extent the Commission determines, however, that Inmarsat Hawaii‘s request
for authority to provide LEOP on a special temporary basis is a request to serve the United
States with a non—U.S—licensed satellite, Inmarsat Hawaii respectfully requests a waiver of
Sections 25.137 and 25.114 of the Commission‘s rules, to the extent that Inmarsat Hawaii has
not herein provided the information required by these rules." The Commission may grant a
waiver for good cause shown." A waiver is therefore appropriate if special circumstances
warrant a deviation from the general rule, and such a deviation will serve the public interest.

        In this case, good cause for a waiver of portions of Section 25.114 exists. Inmarsat
Hawaii seeks authority only to conduct LEOP support for Express AM4. Thus, any
information sought by Section 25.114 that is not relevant to the LEOP —e.g., antenna
patterns, energy and propulsion and orbital debris — and Inmarsat Hawaii does not have such
information. In addition, Inmarsat Hawaii would not easily be able to obtain such
information because Inmarsat Hawaii is not the operator of the Express AM4 satellite, nor is
Inmarsat Hawaii in contractual privity with that operator. Rather, Inmarsat Hawaii has
contracted with Astrium to support the LEOP portion of the campaign using a small portion
of the C—band capacity of the satellite prior to its commercial operation.

        As evidenced by Inmarsat Hawaii‘s license for the 19m Antenna, Inmarsat Hawaii has
the requisite authority to perform the LEOP of the Express AM4 satellite, except for the point
of communication. Moreover, as with any STA, Inmarsat Hawaii will conduct the operations
on an unprotected, non—interference basis.

         Because it is not relevant to the service for which Inmarsat Hawaii seeks
authorization, and because obtaining the information would be a hardship, Inmarsat Hawaii
seeks a waiver of all the technical and legal information required by Section 25.114, to the
extent it is not provided herein. As noted above, Inmarsat Hawaii has provided the required
information to the extent that it is relevant to the LEOP service for which Inmarsat Hawaii
seeks authorization.

       Good cause also exists to waive portions of Section 25.137, to the extent the
information required is not herein provided. Section 25.137 is designed to ensure that "U.S.—
licensed satellite systems have effective competitive opportunities to provide analogous
services" in other countries. Here, there is no service being provided by the satellite;
Inmarsat Hawaii is simply providing TTAC facilities while the satellite is in transfer orbit on
the way to its final geostationary orbital location. Thus, the purpose of the information
required by Section 25.137 is not implicated here. For example, Section 25.137(d) requires


* 47 C.F.R. § 25.137(a).
3 47 C.F.R. §§25.137 and 25.114.
* 47 C.F.R. §1.3.


earth station applicants requesting authority to operate with a non—U.S.—licensed space station
that is not in orbit and operating to post a bond." The underlying purpose in having to post a
bond —i.e., to prevent warehousing of orbital locations by operators seeking to serve the
United States — would not be served by requiring Inmarsat Hawaii to post a bond in order to
conduct a limited period of LEOP support of the Express AM4 satellite.

        Inmarsat Hawaii understands that Express AM4 is licensed by RSCC (Russian
Satellite Communications Company) of the Russian Federation. Express AM4 is a
commercial communications satellite primarily supporting communications services to the
Russian Federation and CIS countries. The spacecraft is not meant to serve the United States.
Thus, the purpose of Section 25.137 — to ensure that U.S. satellite operators enjoy "effective
competitive opportunities" to serve foreign markets and to prevent warehousing of orbital
locations serving the United States —— will not be undermined by grant of this waiver request.

         Finally, Inmarsat Hawaii notes that it expects to communicate with the Express AM4
satellite using the 19m Antenna for a maximum period of 10 days under nominal launch
conditions. Requiring Inmarsat Hawaii to obtain technical and legal information from an
unrelated party, where there is no risk of interference and the operation will normally cease
within 10 days would pose undue hardship without serving underlying policy objectives.
Given these particular facts, Inmarsat Hawaii believes that the waiver sought herein is
appropriate.

                             MISSION TECHNICAL PARAMETERS

Earth Station

       Inmarsat Hawaii provides the following technical parameters for information only.
The operations contemplated in this request fall within the existing license parameters for the
19m Antenna.


EARTH—to—SPACE:

Transmit Frequency: 6535.0 MHz
Transmit Polarisation: Circular LH and RH
Maximum EIRP : 89 dBW
Modulation: PCM (NRZ—L)/PSK/FM (800KFXD)
Minimum Elevation for Transmission: 10 degrees


SPACE—to—EARTH:

Receive Frequency: 4199.5 MHz
Receive Polarisation: Circular LH and RH
Maximum Spacecraft EIRP: 0 dBW within +/— 70 degrees
Modulation: PCM (Biphase—L)/BPSK/PM (800KFXD)


Azimuth Range: 360 degrees

* 47 C.F.R. §25.137(d)(4).


Duration of Communications: Once or twice a day for a period of a few hours for about three
to ten days assuming a nominal launch scenario.

Space Station Coordination

        The coordination of communications for the support of the launch of the Express
AM4 spacecraft with existing spacecraft operators during LEOP operations is the
responsibility of Astrium, who are the satellite operator during the campaign. Astrium has
undertaken coordination of communications for the support of the launch of Express AM4
with other spacecraft operators that may be potentially affected during LEOP operations.

        Astrium has informed Inmarsat Hawaii that all the preparatory activities and contacts
for such coordination have been made and all issues have been satisfactorily resolved.
Astrium also has undertaken to review the need for coordination based on any changed
circumstances that may occur. In accordance with normal industry practices,
communications with other operators will be kept open in the period leading to and
throughout the LEOP activities, to ensure that the LEOP will be conducted on a non—
interference basis.



       Grant of the requested STA will serve the public interest, convenience and necessity
because it will enable Inmarsat Hawaii to provide essential TTAC functions to the Express
AM4 spacecraft, within technical parameters consistent with the licensed parameters of the
19m Antenna, without creating any risk of harmful interference. Inmarsat Hawaii
respectfully requests that the Commission grant STA beginning August 17, 2011 for a period
of 30 days.


2. Contact


             Name:          Chris Murphy                        Phone Number:                         202—248—5158
             Company:       Inmarsat Hawaii                     Fax Number:
             Street:         1101 Connecticut Ave, NW           E—Mail:                               chris_murphy@inmarsat.com
                            Suite 1200
             City:         Washington                           State:                                 DC
             Country:      USA                                  Zipcode:                              20036       —
             Attention:                                         Relationship:


(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).
£4 Governmental Entity        {£3 Noncommercial educational licensee
{34 Other(please explain):

4b. Fee Classification    CGX — Fixed Satellite Transmit/Receive Earth Station

5. Type Request

g7y Use Prior to Grant                            C Change Station Location                           ) Other


6. Requested Use Prior Date
      08/15/2011
7. CityHaleiwa                                                             8. Latitude
                                                                           (dd mm ss.s h)   21   40    14.6   N


9. State   HI                                                               10. Longitude
                                                                            (dd mm ss.s h)    158   2     3.1   W
11. Please supply any need attachments.
Attachment 1: Narrative                           Attachment 2:                                      Attachment 3:


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.)
    See Exhibit A.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is               Yes        «y 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
  Diane J Cornell                                                              Director
           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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Document Created: 2019-04-08 10:50:59
Document Modified: 2019-04-08 10:50:59

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