Attachment 20140421163506.pdf

20140421163506.pdf

DECISION submitted by IB/FCC

Grant

2014-04-15

This document pretains to SES-STA-20140205-00065 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014020500065_1043935

KA25 SES—STA—20140205—00065 Inmarsat Hawaii Inc. 1B2014000210 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—5158 DBA Name: Fax Number: 202—248—5186 Street: 1101 Connecticut Avenue NW E—Mail: chris.murphy@inmarsat.com Suite 1200 City: Washington State: DC Country: USA Zipcode: 20036 —= Attention: Chris Murphy | oo s§ Caornk{? ;’/‘: o {x> PS ******‘I Pileg rmtnnedepeienenenp SES—S /7/A—20/2/oans —Oad LS Call Sign KA 25 aramDem_ 2Z/LS]2RNU4 (or other identifier) International Bureau

Applicant: Inmarsat Hawaii Inc. Call Sign: KA25 File No.: SES—STA—20140205—00065 Special Temporary Authority (STA) Inmarsat Hawaii Inc. is granted, under the following conditions, STA for a 30—day period commencing on launch date, which is estimated on May 16, 2014, of the Express AMA4R satellite, to operate its 19— meter antenna earth station at Paumalu, Hawaii at geographical coordinates 21 deg 40° 14.6 " N.L. and 158 deg 02‘ 03.1" W.L. to provide C—band telemetry, tracking and control (TT&C) functions while the satellite is in transfer orbit on the way to its final geostationary orbital location 80 deg. E.L. 1. The operation of TT&C will be transmitted on 6535.0 MHz frequency (Earth—to—space) circular LH and RH and received on 4199.5 MHz frequency (space—to—Earth) using circular LH and RH and with 89 dBW maximum EIRP within coordinated emission and power limits. All operations shall be on an unprotected and non—harmful interference basis, Inmarsat Hawaii Inc., KA25, shall not cause harmful interference to, and shall not claim protection from, interference caused to it by any other lawfully operating station and it shall cease transmission(s) immediately upon notice of such interference. All operations under this grant of special temporary authority must be on an unprotected and non— harmful interference basis, i.e., Inmarsat Hawaii Inc. must not cause harmful interference to, and shall not claim protection from interference caused to it by, any other lawfully operating station. In the event of any harmful interference under this grant of special temporary authority, Inmarsat Hawaii Inc. must cease operations immediately upon notification of such interference, and must inform the Commission, in writing, immediately of such an event. Any action taken or expense incurred as a result of operations pursuant to this special temporary authority is solely at Inmarsat Hawaii Inc.‘s risk. 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. [ aif. Ceand P48 nnia mias * Pllo® LE TL 20. in pe PZZLL/2*4 Catl Sign K445 ommDare {or other identifier)

2. Contact Name: Chris Murphy Phone Number: 202—248—5158 Company: Inmarsat Fax Number: 202—248—5186 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? P @ 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 «4 Other(please explain): 4b. Fee Classification CGX — Fixed Satellite Transmit/Receive Earth Station 5. Type Request {34 Use Prior to Grant 3 Change Station Location @ Other 6. Requested Use Prior Date 04/06/2014 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: Exhibit A 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 ({narrative) . 13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is Yes £4 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 Chris Murphy 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).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fcc.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control numberorif we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. 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.

Exhibit A DESCRIPTION OF STA REQUEST AND PETITION FOR WAIVER OF SECTIONS 25.137 AND 25.114 1. DESCRIPTION OF STA REQUEST Inmarsat Hawaii Inc. ("Inmarsat Hawaii") 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 AM4R 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 AM4R is not currently a licensed pointof communication for the 19m Antenna. The Express AMA4R 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 April 7", 2014. 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 AM4R will be at or near 80.0° E.L. No on—station operations with Express AM4R 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 19m Antenna will be limited to the LEOP portion of the mission only. II. 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 AM4R spacecraft as the spacecraft is not listed as a point of communications on Inmarsat Hawaii‘s license for the antenna. * The Express AMA4R 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 AM4R 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 cireumstances 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 AM4R. 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 AM4R 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 AMA4R 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 CFR. §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 AMA4R satellite. Inmarsat Hawaii understands that Express AMA4R is licensed by RSCC (Russian Satellite Communications Company) of the Russian Federation. Express AMA4R 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 AMA4R 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 dB W 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.FR. §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 AM4R 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 AMA4R 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 AMA4R 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 April 6", 2014 for a period of 30 days.


Document Created: 2019-04-18 18:18:42
Document Modified: 2019-04-18 18:18:42
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