Attachment STA Request

This document pretains to SES-STA-20120731-00706 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012073100706_961258

                               Request for Special Temporary Authority


            SATCOM Digital Networks, LLC (“SATCOM”) requests special temporary authority

(“STA”) for 60 days beginning August 10, 2012 to conduct on-site testing in the extended Ku-

Band (13.75- 13.77 GHz and 13.78-14.00 GHZ) in preparation of operation using Amazonas-1

commencing September 1, 2012. The FCC may grant an STA for a period not to exceed 60 days

where the STA request has not been placed on public notice and the applicant plans to file a

request for regular authority for the service. An application for license for this operation has

been filed with the Commission, (File Number SES-LIC-20120724-00688, filed July 24, 2012

and assigned call sign E120144).



            SATCOM seeks use of AMAZONAS-1 in the extended Ku-Band to provide domestic

service in the U.S. because it has the only available 36 MHz channel capacity. Details of the

proposed operation are attached.



            This system will provide U.S. domestic video services to institutional facilities, such as

retirement housing and prisons. The requested STA serves the public interest by allowing

SATCOM to perform necessary testing and to resolve any issues in preparation for operation.

SATCOM’s service will meet niche market needs currently underserved or unserved in the

marketplace.




{00421683-1 }


                                           Exhibit For
                                    SATCOM Digital Networks
                                Cranberry Township, Pennsylvania
                                RSI Satcom 6.4 Meter Earth Station


     Compliance with FCC Report & Order (FCC96-377) for the 13.75 - 14.0 GHz Band
                              Analysis and Calculations

1.       Background

This Exhibit is presented to demonstrate the extent to which the proposed SATCOM Digital
Network’s satellite earth station, to be located in Cranberry Township, Pennsylvania, is in
compliance with FCC REPORT & ORDER 96-377. The potential interference from the earth
station to US Navy shipboard radiolocation operations (RADAR) and the NASA space research
activities in the 13.75 - 14.0 GHz Band is addressed in this exhibit. The parameters for the earth
station are:

                          Table 1. Earth Station Characteristics

     •   Coordinates (NAD83):                     40° 42’ 25.0” N, 80° 05’ 44.0” W

     •   Satellite Location for Earth Station:     Amazonas 1 and 2 at 61.0° WL

     •   Frequency Band:                           13.75-14.0 GHz for uplink

     •   Polarizations:                            Circular and Linear

     •   Emissions:                                23M0G7W

     •   Modulation:                               Digital

     •   Maximum Aggregate Uplink EIRP:            80.92 dBW for all Carriers

     •   Transmit Antenna Characteristics
            Antenna Size:                          6.4 meters in Diameter
            Antenna Type/Model:                    RSI Satcom
            Gain:                                  57.4 dBi

     •   RF power into Antenna Flange:             23.52 dBW or 9.9 dBW/ MHz
                                                   or -14.1 dBW/4 kHz (Maximum)

     •   Minimum Elevation Angle:
            Cranberry Twp, Pa.                    39.0° @ 152.0° Az. (Amazonas 1 & 2) at 61.0° W


     •   Side Lobe Antenna Gain:                   32 - 25*log(θ)

Because the above uplink spectrum is shared with the Federal Government, coordination in this
band requires resolution data pertaining to potential interference between the earth station and
both Navy Department and NASA systems. Potential interference from the earth station could
impact with the Navy and/or NASA systems in two areas. These areas are noted in FCC Report
and Order 96-377 dated September 1996, and consist of (1) Radiolocation and radio navigation,
(2) Data Relay Satellites.

Summary of Coordination Issues:

1) Potential Impact to Government Radiolocation (Shipboard Radar)
2) Potential Impact to NASA Data Relay Satellite Systems (TDRSS)


2.       Potential Impact to Government Radiolocation (Shipboard Radar)

Radiolocation operations (RADAR) may occur anywhere in the 13.4 - 14 GHz frequency band
aboard ocean going United States Navy ships. The Federal Communication Commission (FCC)
order 96-377 allocates the top 250 MHz of this 600 MHz band to the Fixed Satellite Service
(FSS) on a co-primary basis with the radiolocation operations and provides for an interference
protection level of -167 dBW/m2/4 kHz.

The closest distance to the shoreline from the Cranberry Township earth station is approximately
341 km Southeast toward the Chesapeake Bay. The calculation of the power spectral density at
this distance is given by:

         1.   Clear Sky EIRP:                 80.92 dBW
         2.   Carrier Bandwidth:              23.0 MHz
         3.   PD at antenna input:            -14.1 dBW/4 kHz
         4.   Transmit Antenna Gain:          57.4 dBi
         5.   Antenna Gain Horizon:           FCC Reference Pattern
         6.   Antenna Elevation Angle:        39.0°

The proposed earth station will radiate interference toward the Chesapeake Bay according to its
off-axis side-lobe performance. A conservative analysis, using FCC standard reference pattern,
results in off-axis antenna gains of -9.9 dBi towards the Chesapeake Bay.

The signal density at the shoreline, through free space is:

PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = -14.1 dBw/4 kHz + (-9.9 dBi) – 10*log[4Π*(341000m)2]
      = -145.6 dBW/m2/4 kHz + Additional Path Losses (~85.0 dB)
      = -230.6 dBW/m2/4 kHz


Our calculations indicate additional path loss of approximately 85.0 dB including absorption loss
and earth diffraction loss for the actual path profiles from the proposed earth station to the
nearest shoreline.

The calculated PFD including additional path losses to the closest shoreline location is –230.6
dBW/m2/4 kHz. This is 63.6 dB below the –167 dBW/m2/4 kHz interference criteria of R&O
96-377. Therefore, there should be no interference to the US Navy RADAR from the Cranberry
Township earth station due to the distance and the terrain blockage between the site and the
shore.



3.     Potential Impact to NASA’s Data Relay Satellite System (TDRSS)

The geographic location of the SATCOM Digital Networks’ earth station in Cranberry
Township, Pennsylvania is outside the 390 km radius coordination contour surrounding NASA’s
White Sands, New Mexico ground station complex. Therefore, the TDRSS space-to-earth link
will not be impacted by the SATCOM Digital Networks earth station in Cranberry Township.

The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if
an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 6.4 meter earth
station antenna will have an EIRP greater than 71 dBW/6 MHz in this band. The total EIRP for
all carriers is 80.92 dBW, and the equivalent EIRP per 6 MHz segment will be 77.09 dBW/6
MHz. Therefore, there could be interference to the TDRSS space-to-space link (Table 1).

In order to meet the 71 dBW/6 MHz interference criteria, the earth station would have to be
limited to an RF power density 6.1 dB lower than the maximum of -14.1 dBW/4kHz or -20.2
dBW/4kHz for an EIRP of 74.82 dBW. If this operational condition cannot be met, then the
Cranberry Township, Pennsylvania earth station may not be tuned to operate at the frequencies
in the 13.770 to 13.780 GHz Band.



4.   Coordination Issue Result Summary and Conclusions

The results of the analysis and calculations performed in this exhibit indicate that compatible
operation between the earth station at the Cranberry Township facility and the US Navy and
NASA systems space-to-earth link are possible. This analysis has been based on the assumption
of 23 MHz bandwidth carriers.

Operations in NASA systems space-to-space link (13770.0 to 13780.0 MHz) will not be
permitted.


                                            Table 1

         Excluded Frequency Range for SATCOM Digital Networks Earth Station

              System                        Frequency Restriction
              TDRSS                         13.770-13.780 GHz (see Note 1)


Note 1: In order to meet the 71 dBW/6 MHz interference criteria, the earth station would have to
be limited to a maximum total EIRP of 74.82 dBW.

No interference to US Navy RADAR operations from the Cranberry Township, Pennsylvania
earth station will occur.



Document Created: 2012-07-30 11:36:09
Document Modified: 2012-07-30 11:36:09

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