Attachment SESSTA2012022200189.

SESSTA2012022200189.

DECISION submitted by EDUCATIONAL COMMUNICATIONS OF COLORADO SPRINGS INC.`

STA GRANT

0000-00-00

This document pretains to SES-STA-20120222-00189 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012022200189_941132

                                             1B2012000627
     E120034     SES—STA—20120222—00189
                                 of Colorado prings Inc
                                            S
     Educational Communications


                                                                                                     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 request for Briargate Boulevard uplink
 1. Applicant


           Name:          Educational Communications of     Phone Number:           202—293—0569
                          Colorado Springs Inc
           DBA Name:                                        Fax Number:             202—293—0810
           Street:        1850 M Street NW #240             E—Mail:                 lee@s—plaw.com


           City:          Washington                        State:                  DC
           Country:       USA                               Zipcode:                20036       —
           Attention:     Lee J Peltzman


2. Contact


             Name:         Dane Ericksen, P.E.                  Phone Number:                         707—996—5200
             Company:      Hammett & Edison, Inc.               Fax Number:                           707—996—5280
             Street:       470 Third Street West                E—Mail:                               dericksen@h—e.com


             City:         Sonoma                               State:                                 CA
             Country:      USA                                  Zipcode:                              95476       —
             Attention:                                         Relationship:                          Engineer


(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 1B2012000580

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

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

5. Type Request


@ Use Prior to Grant                               C Change Station Location                          {3 Other



6. Requested Use Prior Date
      02/16/2012
7. CityColorado Springs                                                    8. Latitude
                                                                           (dd mm ss.s h)   38   56    394    N


9. State   CO                                                               10. Longitude
                                                                            (dd mm ss.s h)    104    47   48.0   W

11. Please supply any need attachments.
Attachment 1: STA Justification                    Attachment 2: RF safety exhibit                    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.)
     STA justification           (attachment 1)           RF safety exhibit            (attachment 2)




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
   Ronald Johnson                                                              Chairman, Board of Directors

           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.


                    Educational Communications of Colorado Springs, Inc.
                             Ku—Band Satellite Uplink STA Request

                Statement of Hammett & Edison, Inc., Consulting Engineers

The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by the Educational
Communications of Colorado Springs, Inc. (ECCS), licensee of Noncommercial Educational FM
Station KTLF, Channel 213CO, 90.5 MHz, Colorado Springs, Colorado, to prepare the technical
portions of an application for Special Temporary Authority (STA) for a new Ku—band satellite uplink
station at the KTLF studios, 1665 Briargate Boulevard, Colorado Springs, Colorado.

                                           Reason for STA

ECCS operates an extensive network of FM Translator stations, fed by satellite. This uplink, formerly
E930054, was inadvertently allowed to expire in 2003.          Also, circa 2007, the uplink had been
relocated by 1.9 km, from the previously licensed location of 1802 Chapel Hills Drive, Colorado
Springs, to the current KTLF studios at 1665 Briargate Boulevard, Colorado Springs. The expired
license and location discrepancy were only recently discovered by new KTLF staff. In order to avoid
disruption of the FM translator network, ECCS is requesting STA for the continued operation of the
uplink until its application for a new satellite uplink license is granted. As is documented in a just—
filed Ku—band uplink license application, Application Submission ID 1B2012000580, the uplink is in
compliance with FCC guidelines for human exposure to radio frequency energy. A copy of the RF
safety exhibit is also included as an attachment to this STA application.

                                              Summary
An application for a new uplink license, at the current location, has been filed. Grant of STA will
allow the continued operation of the ECCS FM Translator network without interruption, and is
respectfully requested.




February 17, 2012




HAMMETT & EDISON, INC.                                                                           120208B
CONSULTING ENCINEERS                                                                       h:
SAN FRANCISCO                                                                     STA Exhibit, Page 1 of 1


                         Educational Communications of Colorado Springs, Inc.
                    Ku—Band Satellite Uplink Application « Colorado Springs, Colorado

                         Statement of Hammett & Edison, Inc., Consulting Engineers

   The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by the Educational
   Communications of Colorado Springs, Inc., licensee of Noncommercial Educational FM Station
   KTLF, Channel 213C0O, 90.5 MHz, Colorado Springs, Colorado, to prepare the technical portions of an
   application for a new Ku—band satellite uplink station from the KTLF studios at 1665 Briargate
   Boulevard, Colorado Springs, Colorado.

                                        Prevailing Exposure Standards
   The U.S. Congress requires that the Federal Communications Commission ("FCC") evaluate its
   actions for possible significant impact on the environment. In Docket 93—62, effective October 15,
   1997, the FCC adopted the human exposure limits for field strength and power density recommended
   in Report No. 86, "Biological Effects and Exposure Criteria for Radiofrequency Electromagnetic
   Fields," published in 1986 by the Congressionally chartered National Council on Radiation Protection
   and Measurements ("NCRP"). Separate limits apply for occupational and public exposure conditions,
   with the latter limits generally five times more restrictive. The more recent standard, developed by the
   Institute of Electrical and Electronics Engineers and approved as American National Standard
   ANSI/IEEE C95.1—2006, "Safety Levels with Respect to Human Exposure to Radio Frequency
   Electromagnetic Fields, 3 kHz to 300 GHz," includes similar exposure limits. These limits apply for
   continuous exposures and are intended to provide a prudent margin of safety for all persons, regardless
   of age, gender, size, or health.

   For 14.0—14.5 GHz Ku—Band satellite transmitting antennas, the prevailing standard for occupational
   exposures of unlimited duration is 5 mW/cm, and 1 mW/cm2 for public exposures of unlimited
   duration.


                                          Proposed Uplink Facilities
   It is proposed to use a Prodelin Model 1184 1.8—meter diameter satellite earth station Ku—Band
   transmitting antenna, and the 2—watt version of the Raydyne ComSearch Model DT8000 transmitter.
   The antenna would be pole—mounted on the ground, in a fenced area at the rear of the KTLF studios
   parking lot, as shown by the attached Figure 1.

   The     eastern—most      geostationary communication satellite    that the proposed       antenna would
   communicate with would be at 69°W longitude, and the western—most satellite would be at
   125°W longitude.         The antenna orientation to the eastern—most satellite would be 131.1°T with an
   elevation angle of 31.7°, the antenna orientation to a satellite at the middle of the domestic satellite arc
   would be 167.7°T with an elevation angle of 44.2°, and the antenna orientation to the western—most

  HAMMETT & EDISON, INC.                                                                                   120208
  CONsSULTT CGINEERS                                                                              s
P san 1?R.AN::{§§)EN ‘                                                              RF Safety Exhibit, Page 1 of 3


                       Educational Communications of Colorado Springs, Inc.
                Ku—Band Satellite Uplink Application » Colorado Springs, Colorado

satellite would be 210.3°T with an elevation angle of 40.3°. The greatest elevation angle would occur
when communicating with a satellite at 105°W, where an elevation angle of 44.9° would be needed.
Thus, communication with the eastern—most satellite represents the antenna orientation with the lowest
elevation angle.

                                             NIST Nomograph

The highest power density was determined using a method developed by the staff of the National
Bureau of Standards (NBS, now the National Institute for Standards and Technology, "NIST"), "An
Efficient and Accurate Method for Calculating and Representing Power Density in the Near—Field
Zone of Microwave Antennas.""* Figure 2 from Page 6 of that report is applicable to the proposed
installation, and it is reproduced here in Figure 2. According to the NIST paper, this nomograph is
applicable to all aperture antennas with diameter—to—wavelength ratios of 30 or greater.                 Since a
1.8—meter diameter antenna at 14.25 GHz has a diameter—to—wavelength ratio of approximately 85.5 to
1, the nomograph is applicable.

Figure 2 characterizes the power density variation in the near—field.           The extent of the near—field
covered by this nomograph extends to a D#/A ratio of unity, where D is the antenna diameter and A is
the wavelength, expressed in compatible units (F.e., either both in meters or both in centimeters). For
Ku—Band uplinks the mid—band wavelength is 0.021 m (2.1 em), so for the proposed 1.8—m antenna,
D®/A equals approximately 154 meters. Thus, the distance over which this nomograph is applicable
includes substantial distances from the uplink site.

At Page 3 of the NIST paper, the formula S = 38.6 — 20l0ogiqD is given for calculating the maximum
power density for watt of antenna input power, where S is the power density in dBm/cm? and
D is the antenna diameter in centimeters. For higher input powers a 10logio(P) factor must be applied,
where P is the antenna input power in watts.             Thus for the maximum antenna input power of
2.0 watts the main beam the power density would be 38.6 — 20logi,(180) + 10logi,(2.0), or
—3.5 dBm/cm2.       This is 3.5 dB lower than the 1.0 mW/cm(0 dBm/cm?) the FCC guideline for
uncontrolled (public) exposures. Thus, because of the relatively low transmitter power, there are no
areas where the public limit would be exceeded, even for a person elevated above ground and in the
main beam of the uplink antenna.

Because there is no portion of the uplink signal predicted to exceed even the public limit, the normally
pertinent locations of the closest nearby structures in the satellite arc look angle become moot. The
uplink antenna is therefore inherently compliant with respect to public exposures, and, of course, also


*   Publication number NBSIR—85/8036, December 1985. This paper was written by Richard L. Lewis and Allen C.
    Newell, and was sponsored by the U.S. Environmental Protection Agency (EPA).
HAMMETT & EDISON, INC.                                                                                     120208
CONSULTING ENGINEERS                                                                               e
SAN FRANCISCO                                                                        RF Safety Exhibit, Page 2 of 3


                        Educational Communications of Colorado Springs, Inc.
               Ku—Band Satellite Uplink Application » Colorado Springs, Colorado

occupational exposures. Nevertheless, the applicant will keep the fence around the uplink antenna
locked, to prevent unauthorized access, and in the event maintenance or repairs are needed on the
feedhorn—side of the parabolic antenna, the uplink transmitter will first be shut off.

                                                    Summary
Operation of the proposed uplink will comply with the public exposure guidelines, since there are no
portions even in the main beam of the uplink where the predicted power density will exceed the public
limit.

                                               List of Figures

In carrying out these engineering studies, the following attached figures were prepared under my
direct supervision:
1.       Satellite views of the KTLF studio site.
2.       NIST nomograph




February 9, 2012




HAMMETT & EDISON, INC.                                                                                 120208
CONSULTING ENCGINEERS                                                                          w
SANFPRANCICO    _                                                                RF Safety Exhibit, Page 3 of 3


                     Educational Communications of Colorado Springs, Inc.
                Ku—Band Satellite Uplink Application « Colorado Springs, Colorado

                                           Uplink Site
                                                  Satellite   _Hybrid




A = Satellite uplink location. Source: ACME Mapper




HAMMETT & EDISON, INC.
CONSULTING ENCGINEERS                                                                      120208A
SAN FRANCISCO                                                           RF Safety Exhibit, Figure 1A


                       Educational Communications of Colorado Springs, Inc.
                Ku—Band Satellite Uplink Application » Colorado Springs, Colorado

                                           Uplink Site
                                              Map   Satellite      Hybrid       Terrain      Topo    DoOQ




                                                         m
                                                        [N 38 5639.4"       W 104    48.0°
                                                        nome                 zisce


A = Satellite uplink location. Source is again ACME Mapper.




HAMMETT & EDISON, INC.
CONSULTING ENGINEERS                                                                                               120208A
SAN FRANCISCO                                                                                   RF Safety Exhibit, Figure 1B


                                        Educational Communications of Colorado Springs, Inc.
                                   Ku—Band Satellite Uplink Application » Colorado Springs, Colorado

Y—axis distance divided by D          Relative Power Density Contours in the Y—Z Plane for D >30)1




        0.67

      0.50

      0.33
                                                                               ~2.S@@

                               0                   0.25                        0.5                        75                          1.0
                                                                  Z—axis distance divided by D /A


                                                          Nomograph from NTIS #NBSIR85—3036, page 6.
                                       Additional notations by Hammett & Edison, Inc., Consulting Engineers, San Francisco




HAMMETT & EDISON, INC.
CONSULTING ENGINEERS                                                                                                             120208A
SAN FRANCISCO                                                                                                  RF Safety Exhibit, Figure 2



Document Created: 2012-02-29 17:30:12
Document Modified: 2012-02-29 17:30:12

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