Attachment Proba-V STA

This document pretains to SES-STA-20140618-00532 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014061800532_1050763

                                          .        SES—STA—201 30820—
                                                                       00751
                                       Universal Space Network,
                                                                Inc.               rzorsoors4e


                                                                                                                        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:
PROBA—V 180 Day STA
 1. Applicant

           Name:        Universal Space Network, Inc.       Phone Number:                        215—328—9130
           DBA Name:                                        Fax Number:                          215—328—9132
           Street:      417 Caredean Drive                  E—Mail:                              jgreet@uspacenet.com
                        Suite A                                         .
           City:        Horsham                             State:                               PA
           Country:     USA                                 Zipcode:                             19044       —
           Attention:   Joanne Greet

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Applicant: Universal Space Network Corporation
Call Sign: None
File No.: SES—STA—20130820—00751


Universal Space Network Corporation (USN) is granted Special Temporary Authority
(STA) for 180 days, from 10/1/2013 thru March 31, 2014, to operate a fixed earth
stations in North Pole, AK to assist the European Space Agency (ESA) and Swedish
Space Corporation (SSC) with the in orbit payload validation and commissioning testing
of the science instrument on the PROBA—V satellite. Operations with t the PROBA—V
satellite is limited to the center frequency 8090.0 MHz (space—to—Earth) underthe
following conditions:


   1) This STA is being approved to assist the European Space Agency (ESA) and Swedish
      Space Corporation (SSC) with the in orbit payload validation and commissioning testing
      ofthe science instrument on the PROBA—V spacecraft.

   2) Operations under this STA 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.

   3) Any action taken or expense incurred as a result of operations pursuant to this
      STA is solely at USN‘s risk.

   4) 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.


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                                            Exhibit C
            PETITION FOR WAIVER OF SECTION 25.137 AND 25.114 AND OF
                  THE U.S. TABLE OF FREQUENCY ALLOCATIONS

L.      TO THE EXTENT THEY APPLY, GOOD CAUSE EXISTS FOR A WAIVER OF
        CERTAIN PORTIONS OF SECTIONS 25.137 AND 25.114

       Universal Space Network, Inc. (USN) is provided limited legal and technicalinformation
for the PROBA—V Satellite.‘ Pursuant to Section 25.137 of the Federal Communications
Commission‘s ("Commission" or "FCC") rules, the same technicalinformation required by
Section 25.114 for U.S.—licensed space station, 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.. .‘ USN seeks authority to support the in orbit science instrument
validation and commissioning campaign of PROBA—V beginning in October, 2013, not
commercial service to the United States, and thus believes that Section 25.137 does not apply.

PROBA—V is a small satellite carrying a vegetation instrument. The primary mission is to
deliverto the international vegetation science community daily land mass images of vegetation.
Section II. of this document describes the mission from ESA and more information can be found
on the European Space Agency‘s website.

        To the extent the Commission determines, however, that USN‘s request for authority to
provide this service on a special temporary basis is a request to serve the United States with a
non—U.S—licensed satellite, USN respectfully requests a waiver of Sections 25.137 and 25.114 of
the Commission‘s rules, to the extent that USN has not herein provided the information required
by these rules. * The Commission may grant a waiver for good cause shown." A waiveris
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. USN seeks
authority to conduct receive only payload telemetry to assist in the validation and commissioning
of the PROBA—V science instrument already in orbit. Thus, any information sought by Section
25.114 that is not relevant to the support — e.g., antenna patterns, energy and propulsion and
orbital debris — USN does not have. In addition, USN would not easily be able to obtain such
information because USN is not the operator of the PROBA—V satellite, nor is USN in
contractual privity with that operator. Rather, USN has contracted with Swedish Space
Corporation, Solona Sweden (SSC) to support the PROBA—V satellite.

       USN is seeking receive only authorization and as such no coordination has been
conducted by Comsearch,. Moreover, as with any STA, USN will conduct the support on an
unprotected, non—interference basis to government operations.


 FCC Form 312 Section B

‘47 C.B.R. § 25.137(a)

‘47 C.F.R. §§25.137 and 25.114

*47 C.F.R. §1.3


Because it is not relevant to the service for which USN seeks authorization, and because
obtaining the information would be a hardship, USN seeks a waiverof all the technical and legal
information required by Section 25.114, to the extent it is not provided herein. As noted above,
USN has provided the required information to the extent that it is relevant to the service for
which USN 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 commercial service being provided by the satellite; USN is
providing validationtesting of a science instrument in earth orbit. The instrument is a vegetation
mapper and is not a commercial payload. Thus, the purpose of the information required by
Section 25.137 is not implicated here. For example, Section 25.137(d) requires 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 USN to post a bond in orderto conduct the 180 days of support ofthe
PROBA—V satellite.

        It is USN‘s understanding that PROBA—V is licensed by ESA (Buropean Space Agency).
PROBA—V is the forth in the series spacecraft meant to conduct earth science in the EU. 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 service the United States — will not be undermined by grant of this waiver request.

        Finally, USN notes that it expects to communicate with the PROBA—V satellite using its
U.S. earthstation for a period of 180 days. Requiring USN to obtain technical and legal
information froman unrelated party, where there is no risk of interference and the operation will
cease within 180 days would pose undue hardship without serving underlying policy objectives.
Given these particular facts, the waiver sought herein is appropriate.




547 C.F.R. §25.137(d)(4)

647 C.F.R. §2.106

" Previously approved STA‘s for Universal Space Network SES—STA—20020725—01174; SES—STA—20021112—
02008; SES—STA—200403 1 5—00475


2. Contact


             Name:         Universal Space Network, Inc.       Phone Number:                         215—328—9130
             Company:                                          Fax Number:                           215—328—9132
             Street:       417 Caredean Drive                  E—Mail:                               jgreet@uspacenet.com
                           Suite A
             City:         Horsham                             State:                                PA
             Country:      USA                                 Zipcode:                              19044          —
             Attention:    Joanne Greet                        Relationship:                         Same


(If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID ofthe 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).
«3 Governmental Entity       4 Noncommercial educational licensee
&3 Other(please explain}:

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

5. Type Request


 @   Use Prior to Grant                            O   Change Station Location                       O    Other



6. Requested Use Prior Date
      09/25/2013
7. CityNorth Pole                                                         8. Latitude
                                                                          (dd mmss.sh)     64   48       15.3   N


9. State   AK                                                              10. Longitude
                                                                           (dd mm ss.sh)      147   30    0.8%   W
11. Please supply any need attachments.
Attachment 1: FCC 312                             Attachment 2: Waiver                               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.)
     Assist ESA with the in—orbit payload validation & commissioning testing of the science
     instrument on the spacecraft to start on October 1,                              2013 for 180 days.




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
   Joanne Greet                                                               Manager, Contracts & Compliance

           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: 2019-04-12 09:04:47
Document Modified: 2019-04-12 09:04:47

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