Attachment Exhibit A

This document pretains to SES-STA-20150716-00456 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015071600456_1096173

                                          Exhibit A

                           DESCRIPTION OF STA REQUEST

I.       DESCRIPTION OF STA REQUEST

         ISAT US, Inc. (“ISAT US”) hereby requests special temporary authority (“STA”) to
operate two earth station user terminal antenna types located in Lino Lakes, Minnesota, Palm
Bay, Florida, and Chantilly, Virginia, to facilitate over-the-air site acceptance testing (OSAT)
of the Inmarsat Global Xpress Ka band network components using the Inmarsat 5 F2 (I5 F2)
satellite located at 55W. The earth station antenna types are the Seatel GX60 and the
Skyware Atom65 (“Antennas”). Operations of the Antennas during this OSAT period would
be within the envelope of the technical parameters of the existing license applications for the
respective Antennas, with the exception of additional frequency bands discussed below.1 All
operations would be at fixed locations. The Inmarsat Global Xpress I5 F2 satellite and the
Lino Lakes Satellite Access Station have both been authorized for US market access from the
55W orbital location.2

        ISAT US will be responsible for the technical aspects of the user terminal support,
using the Ka-band portion of the satellite prior to its commercial operation. The user terminal
operations will be closely monitored by the Inmarsat Network Operations Center (NOC) and
various engineering teams associated with the OSAT campaign to ensure compliance with the
requested testing authority. It is expected that the Antennas will be used starting August 14,
2015 for up to 30 days.

II.      ISAT US SEEKS AUTHORITY TO TEST THE ANTENNAS ON
         ADDITIONAL FREQUENCY BANDS (29.4-29.5 GHz/19.6-19.7 GHz)

        In addition to the frequencies that ISAT US requested in the underlying pending user
terminal applications (i.e., 29.5-30 GHz/19.7-20.2 GHz), ISAT US seeks authority to test on
the following additional frequency bands: 29.4-29.5 GHz (uplink) and 19.6-19.7 GHz
(downlink). ISAT US requests this authority on a non-interference and non-protected basis.
ISAT US requests a waiver of the U.S. Table of Frequency Allocations,3 as necessary, to
allow the proposed FSS STA operations in the 19.6-19.7 GHz frequencies. Grant of a waiver
would serve the public interest because it would allow end-to-end network testing in
conjunction with the OSAT, facilitating the deployment of satellite broadband services to
commercial, government, military and consumer users. As discussed below, grant of the
requested waivers would not undermine the policy objective of the rule, as the primary
operators in these bands under the U.S. Table would be protected from harmful interference.


1
 See, ISAT US GX user terminal earth station applications, Seatel GX60, filed Feb. 24, 2014,
Public Notice Mar. 4, 2015 (Call Sign E140029; IBFS File No. SES-LIC-20140224-
00098)(no comments were filed on the application); Skyware Atom65, filed Jun. 25, 2015,
(Call Sign E150097; IBFS File No. SES-LIC-20150625-00383).
2
 See, Inmarsat Mobile Networks, Inc., Granted March 30, 2015, (Call Sign E120072; IBFS
File No. SES-LIC-20120426-00397) (“Lino Lakes Order”).
3
    47 C.F.R. § 2.106.
                                               1


       For clarity ISAT US provides the following technical parameters for the additional
frequencies requested:

EARTH-to-SPACE:
Transmit Frequencies: 29.4-29.5 GHz and 29.5-30 GHz
Transmit Polarisation: RHCP
Maximum EIRP: 50.4 dBW
RF Modulation: 8 APSK (max)
Minimum Elevation for Transmission: 10 degrees

SPACE-to-EARTH:
Receive Frequencies: 19.6-19.7 GHz and 19.7-20.2 GHz
Receive Polarisation: LHCP
Maximum Spacecraft EIRP: 54dBW
RF Modulation: 16 APSK
Azimuth Range: 360 degrees

Duration of Communications: approximately 30 days

Space Station Coordination

        The coordination of communications for the use of the additional frequencies (29.4-
29.5 GHz/19.6-19.7 GHz) with the Inmarsat-5 F2 spacecraft at the 55W orbital location with
existing spacecraft operators during OSAT is the responsibility of Inmarsat and ISAT US.
ISAT US has undertaken coordination of communications for the support of the OSAT
of Inmarsat-5 F2 with other spacecraft operators that may be potentially affected during
OSAT.

        All the preparatory activities and contacts for such coordination have been made and
all issues have been satisfactorily resolved. ISAT US 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 OSAT activities, to ensure that the OSAT will be
conducted on a non-interference basis. There are currently no MSS feeder link operations in
the 29.4-29.5 GHz and 19.6-19.7 GHz band segments, and grant of the proposed STA on a
non-interference, non-protected basis would not prejudice any future operations in this band.

        Moreover, the proposed STA operations in the 19.6-19.7 GHz frequencies are
unlikely to cause interference into fixed service operations that are co-primary in that band
segment. As the Commission acknowledged in granting market access for the Inmarsat-5 F2
spacecraft, the space-to-Earth transmissions comply with the pfd limits established under
Article 21 of the ITU Radio Regulations established to protect all fixed earth stations.4

                               *      *       *      *       *

       Grant of the requested STA will serve the public interest, convenience and necessity
because it will enable ISAT US to conduct essential network testing and the Inmarsat-5 F2

4
    Lino Lakes Order ¶ 27.
                                              2


spacecraft, within technical parameters consistent with the parameters described herein using
the identified Antennas, without creating any risk of harmful interference. ISAT US
respectfully requests that the Commission grant STA beginning August 14, 2015 for a period
of 30 days.




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Document Created: 2015-07-14 11:36:54
Document Modified: 2015-07-14 11:36:54

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