Attachment 20140918160426.pdf

20140918160426.pdf

DECISION submitted by IB-FCC

Grant

2014-09-16

This document pretains to SES-STA-20140731-00627 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014073100627_1061545

                                                          SES—STA—20140731—00627           182014001564
                                            O3b Limited




                                                                                                                                    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:
DTA STA to 30 days (Jul 2014)
 1. Applicant

           Name:        O3b Limited                           Phone Number:                            202—352—5985
           DBA Name:                                          Fax Number:                       »
           Street:      900 17th Street, NW, #300             E—Mail:                                  joslyn.read@o03bnetworks.com


           City:        Washington                            State:
           Country:     USA                                   Zipcode:                                        *
           Attention:   Ms Joslyn Read



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Applicant:         O3b Limited
No Call Sign
File No.:          SES—STA—20140731—00627


O3b Limited is granted special temporary authority (STA), for 30 days, to operate a fixed earth station
located at the Data Technology Solutions‘ Breaux Bridge, LA, facility at 30° 16‘ 54.12" N , 91° 54°
51.84" W, to communicate with the its NGSO FSS system licensed by the United Kingdom. Operations
pursuant to the STA are limited to testing and demonstration purposes only and are subject to the terms of
its application, the Commission‘s Rules, and the following conditions.

    1.   Operations are limited to the following frequency bands and emissions:

         Frequency Band           Emissions             Maximum E.LR.P.              Maximum E.LR.P. Density
         28.35—28.4 GHz           54AMGT7D               61.5 dBW                     21 dBW/4kHz
         18.3—18.6 GHz            54MGT7D

         Operations are on a secondary basis and O3b must not cause harmful interference to stations
         operating on a primary basis and must not claim protection from stations operating on a primary
         basis.

         Grant of this authorization is without prejudice to any determination that the Commission may
         make regarding any pending or future application to communicate with O3b‘s NGSO FSS
         system.

         Any action taken or expense incurred as a result of operations pursuant to this special temporary
         authority is solely at O3b‘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.

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                     GRANTED
                   International Bureau         Approved:


2. Contact


             Name:         Joseph A. Godles                     Phone Number:                        202—429—4900
             Company:      Goldberg Godles Wiener & Wright Fax Number:                               202—429—4912
                           LLP
             Street:        1229 19th Street, NW                E—Mail:                              jgodles@g2w2.com


             City:         Washington                           State:                                DC
             Country:      USA                                  Zipcode:                             20036      —2413
             Attention:                                         Relationship:                         Legal Counsel


(If your application is related to an application filed with the Comumission, 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).
(ol Governmental Entity      C Noncommercial educational licensee
C Other(please explain):

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

5. Type Request


g7y Use Prior to Grant                             {3 Change Station Location                       @ Other


6. Requested Use Prior Date
      09/15/2014


7. CityBreaux Bridge                                                        8. Latitude
                                                                            (dd mm ss.s h)    30   16     54.12   N
9. State   LA                                                               10. Longitude
                                                                            (dd mm ss.s h)    91   54     51.84    W
11. Please supply any need attachments.
Attachment 1: STA request                         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.)
    03b Limited hereby requests special temporary authority to operate an earth station to be
     located at the Data Technology Solutions facility in Breaux Bridge,                                          Louisiana that will
     communicate with the satellite system operated by O3b for non—commercial testing and
     demonstration purposes.




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
   Joslyn Read                                                                 Vice President, Regulatory Affairs
           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,
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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 sponsorthis collection, unless it displays a currently valid OMB control number orif 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.


                               REQUEST FOR SPECIAL TEMPORARY AUTHORITY

         03b Limited ("O3b"), pursuant to Section 25.120 of the Commission‘s rules, hereby respectfully
requests special temporary authority ("STA") to operate an earth station to be located at the Data
Technology Solutions ("DTS") facility in Breaux Bridge, Louisiana ("DTS Earth Station") that will
communicate with the satellite system operated by O3b. In this filing, O3b seeks a 30—day STA for the
period between September 15, 2014 and October 14, 2014.‘

         The DTS Earth Station will be used for non—commercial testing and demonstration purposes,
exhibiting O3b‘s system to the U.S. energy industry. The DTS Earth Station will simulate diverse data
applications on the O3b satellite system, including interactive video and audio teleconferencing, access
to Enterprise Cloud Services and very large file transfers. As discussed below, grant of the requested
authority is in the public interest as it will allow O3b to test and demonstrate O3b services that could
benefit the U.S. energy industry.

Test Details and Public Interest Showing

         The DTS Earth Station will communicate with O3b‘s Ka—band, Medium Earth Orbit, non—
geostationary orbit ("NGSO") satellite system* and O3b‘s gateway earth station in Vernon, TX.}

         The frequencies to be used by the DTS Earth Station are:

               e   28.35—28.4 GHz (uplink)
               e   18.3—18.6 GHz (downlink)

         The DTS Earth Station will consist of two (2) 1.2m antennas manufactured by Orbit, and will
operate with a ViaSat MEOLink modem. This Orbit 1.2m terminal is the same Orbit 1.2m terminal for
which 03b has previously been granted authority to operate at the CODA Lab location in San Diego,
California.*

         The DTS Earth Station antennas will be mounted on a fixed pedestal at the DTS facility.
Although the pointing angle of the antennas will change as O3b‘s in—orbit satellites are tracked, the
pedestal will remain stationary during the demonstration.



* 03b will be filing a second STA request, which it understands the International Bureau will put on Public Notice,
covering the 30—day period between October 15, 2014, and November 13, 2014.
* O3b‘s first four satellites were launched on June 25, 2013. O3b‘s next four satellites were launched on July 10,
2014.
3 See O3b Limited, Call Sign E130021, File No. SES—LIC—20130124—00089, granted June 20, 2013 ("O3b Texas
License").
4 See O3b Limited, File No. SES—STA—20131228—01209, filed December 23, 2013 ("O3b CODA STA Application"), and
which was placed on Public Notice on April 2, 2014 and granted on April 29, 2014.

                                                          1


         Grant of this application will serve the public interest, convenience, and necessity by allowing
03b to show how its system can effectively deliver low latency, high throughput service to and from
isolated resource extraction operations, such as offshore oil platforms." This capability will allow for
better connectivity and living conditions at these remote facilities while enhancing the safe and efficient
extraction of important energy resources. 03b will demonstrate the system‘s capabilities for providing a
variety of valuable communications, including voice and video conferencing and Enterprise Data
Applications.

Technical Parameters

         O3b is attaching the following documents with the technical details of the operations proposed
under the requested STA:

             e     Annex 1: FCC Form 312, Schedule B. O3b proposes to operate the DTS Earth Station
                   during this 30—day term in accordance with the parameters specified in the Schedule B."
             e     Annex 2: Link Budgets. Representative links for the DTS Earth Station are provided.
             e     Annex 3: Characteristics of the 1.2m Orbit Antenna are provided for the Commission‘s
                   convenience. O3b previously submitted this information to the Commission.‘
             e     Annex 4: Antenna Patterns. Measured 30 GHz band antenna performance data for the
                   1.2m antenna is provided for the Commission‘s convenience. O3b previously submitted
                   this data to the Commission.®

         Further, 03b incorporates by reference the following technical parameters previously provided
         by O3b:

                       e   Schedule S. In its application for a gateway earth station in Hawaii, 03b
                           submitted a Schedule S describing its satellite system‘s technical
                           characteristics.© The Schedule S correctly described the O3b satellite system for
                           that application, and numerically enveloped all of the necessary parameters for
                           future earth station applications. In order to assist the Commission in processing
                           present and future applications, however, 03b subsequently provided a



* The DTS Earth Station will not, for purposes of the STA, communicate with any offshore platforms or other offsite
facilities. The only points of communication will be O3b‘s space stations and O3b‘s gateway earth station in
Vernon, Texas.
® Although O3b is not currently seeking a regular license for the DTS Earth Station, O3b is providing a Schedule B
containing technical parameters for the Commission‘s convenience.
? See O3b maritime earth station application, File No. SES—LIC—20130528—00455, Technical Attachment at A.6.
® See O3b maritime earth station answers (Oct. 25, 2013) ("Maritime Earth Station Answers"), File No. SES—AMD—
20131025—01138, answer to Question 10.
° See O3b Limited, Call Sign E100088, File No. SES—LIC—20100723—00952, granted Sept. 25, 2012 ("O3b Hawaii
License").


                           modified Schedule S that incorporates additional information submitted to the
                           Commission since the Hawaii application was filed.*" O3b will operate its DTS
                           Earth Station within the parameters described in O3b‘s modified Schedule S.
                      e    U.S. Government Coordination. 03b has completed all necessary coordination
                           with US government satellite networks operating in Ka—band, including GSO and
                           non—GSO networks, as well as their associated specific earth stations filed under
                           9.7A and 9.7B of the ITU Radio Regulations through other administrations. O3b
                           has also completed coordination, according to US footnote 334 of the FCC table
                           of frequency allocations, with the US government, and this US334 coordination
                           agreement specifically provides for additional earth stations in US territory _
                           operating with O3b‘s satellites, such as the DTS Earth Station. As a result, O3b‘s
                           existing US334 coordination agreement covers the use of the DTS Earth Station
                           as requested in this application.

Proposed Spectrum Use

         O3b‘s proposed operations pose no risk of harmful interference to other lawfully authorized
stations. As demonstrated below, the DTS Earth Station will provide the requisite protection to
geostationary orbit ("GSO") FSS stations operating in the bands proposed by O3b. Transmissions by O3b
under the proposed STA will occur on a secondary, non—harmful interference basis, and O3b
acknowledges that it will not be entitled to interference protection.

UPLINK

28.35—28.4 GHz —Secondary uplink band shared with primary GSO FSS stations.

         In the 28.35—28.4 GHz band, there is a primary allocation for GSO FSS systems and a secondary
allocation for NGSO FSS systems. O3b‘s DTS Earth Station transmissions in this band will be consistent
with their secondary status vis—a—vis GSO FSS transmissions. The Commission has allowed similar
secondary use of frequencies in the Ka—band uplink allocated to GSO FSS on a primary basis where
applicants are prepared to accept interference from primary operations and can demonstrate that their
proposed operations are not likely to cause harmful interference to primary operations." O3b agrees to
both of these standards.

         As a secondary user of the 28.35—28.4 GHz band in the United States, O3b makes no claim of
protection from interference from U.S.—licensed GSO FSS networks in this band segment. Regarding
O3b‘s uplink operations in the 28.35—28.4 GHz band, the ITU has developed uplink equivalent power flux


9 See Maritime Earth Station Answers, Call Sign E130098, File No. SES—AMD—20131025—01138, answer to question
6.                                    .

*4 Northrop Grumman Space & Missions Systems Corporation, 24 FCC Red 2330, at 1« 72—73 {Int‘l Bur. 2009);
contactMEO Communications, LLC, 21 FCC Red 4035, at «) 23—24, (Int‘l Bur., 2006).

                                                       3


density limits ("EPFDu,p") limits to protect co—frequency GSO FSS operations from unacceptable
interference from NGSO FSS systems operating in the same frequencies. Specifically, in accordance with
Article 22 of the ITU Radio Regulations, if the applicable EPFDy,p limits are met, the NGSO FSS satellite
system is considered to have met its obligations to protect GSO FSS networks from unacceptable
interference. 03b demonstrated that its gateway located at Hawaii operating at the authorized power
levels will meet the applicable ITU EPFDy, limits in all frequency ranges where these limits apply, due to
the inherent angular separation between the O3b and geostationary orbits when viewed from the Earth
at latitudes away from the equator."

             The DTS Earth Station is located further north in latitude than the Hawaii gateway, * which
results in an even greater angular separation between the O3b and geostationary orbits as viewed from
the Earth and an even greater assurance that the applicable ITU EPFD ,, limits will be met by O3b‘s
proposed operations. The proposed DTS Earth Station operations, therefore, also will meet the
applicable ITU EPFDyp limits. In any event, O3b confirms that its operations will be on a secondary basis
relative to U.S.—licensed GSO FSS networks in the same band.

DOWNLINK

18.3—18.6 GHz — Non—conforming downlink band shared with primary GSO ESS stations.

             The 18.3—18.6 GHz band is allocated in the United States on a primary basis to GSO FSS. In the
18.3—18.6 GHz downlink band, the ITU has developed downlink equivalent power flux density
("EPFDaown") limits to protect GSO FSS networks from unacceptable interference from NGSO FSS systems
operating in the same frequencies. Specifically, in accordance with Article 22 of the ITU Radio
Regulations, if the applicable EPFDaown limits are met, the NGSO FSS satellite system is considered to
have met its obligations to protect GSO FSS networks from unacceptable interference. O3b confirms
that its system will meet the applicable ITU EPFDaown limits in all frequency ranges where these limits
apply."

             As an example of how these limits will be satisfied, O3b provided EPFDaown calculations for
transmissions to its Hawaii gateway earth station.*" 03b also showed how the EPFD4gown limits can be
satisfied at all latitudes.*" Compliance with the EPFDaown limits is more easily achieved in the case of
transmissions to O3b‘s DTS Earth Station than it is in the case of transmissions to O3b‘s Hawaii earth


* O3b Hawaii License Application, FCC File No. SES—LIC—20100723—00952, Technical Attachment at A.10.1.
* The O3b Hawaii gateway latitude is 21° 40‘ 17.8" N; the DTS Earth Station latitude is 30° 16‘ 54.3" N.
* See ITU Radio Regulations, Article 22. See also O3b Hawaii License Application, FCC File No. SES—LIC—20100723—
00952, Technical Attachment at A.10.1 for a discussion of O3b‘s compliance with the operational limits in Article 22
of the ITU Radio Regulations.                                  j
* O3b Hawaii License Application, FCC File No. SES—LIC—20100723—00952, Technical Attachment at
A.10.1.
‘8 See id.


station. 03b is able to satisfy the limits by taking advantage of the inherent angular separation of the
O3b and the GSO orbits when viewed from the surface of the Earth at latitudes away from the
equator, *‘ and O3b‘s DTS Earth Station will be located further from the equator than O3b‘s Hawaii earth
station. The DTS Earth Station location, therefore, presents an even stronger case for non—interference
to GSO FSS networks than the Hawaii gateway location.

Conclusion

            The requested STA will allow 03b to evaluate and demonstrate the O3b system‘s operational
capabilities and will not result in harmful interference to other authorized spectrum users. Accordingly,
and for good cause shown, O3b respectfully requests that its STA be granted in time for it to commence
testing under this 30—day STA request on September 15, 2014.




U See id.



Document Created: 2019-04-21 20:03:18
Document Modified: 2019-04-21 20:03:18

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