Attachment Narrative Statement SES-STA-20160224-00170

Attachment Narrative Statement

This document pretains to SES-STA-20160224-00170 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016022400170_1127968

requested STA and associated waivers to permit Ka-band maritime operations is
consistent with Commission precedent and would strongly serve the public interest.
Harris CapRock seeks an STA for a period of up to 60 days commencing on Monday,
February 29, 2016, or as soon as practicable thereafter.
I. BACKGROUND
As the Commission is aware, Harris CapRock has been engaged in extensive
development and testing of its ST5000-2.4 terminal,2 an innovative maritime earth station
terminal designed to communicate in C-band, Ku-band and Ka-band FSS frequencies.
Harris CapRock has filed a commercial modification application to authorize the
ST5000-2.4 terminal to operate in C-band and Ku-band frequencies,3 the pendency of
which effectively precludes the filing of another modification application to add Ka-band
operational authority and necessitates this request to enable the ST5000-2.4 terminal to
communicate O3b’s Ka-band NGSO FSS system. Harris CapRock intends to file a
license modification application to authorize long-term Ka-band operations of the
ST5000-2.4 terminal at the earliest practicable time.
The Technical Appendix and draft FCC Form 312 and Schedule B contain
relevant information relating to the technical parameters, antenna performance
information, radiation hazard analysis and general antenna specifications for the ST5000-
2.4 terminal. Harris CapRock requests a waiver of certain rules necessary to facilitate
ST5000-2.4 Ka-band operations in the maritime context as proposed herein. Furthermore,
Harris CapRock’s operations of the ST5000-2.4 terminal will be consistent with the terms
and conditions imposed on ESV terminal operations with the O3b system.
A. O3b’s NGSO FSS System
In 2015, the Commission granted O3b’s Petition for Declaratory Ruling seeking
market access to serve the United States.4 In that application, O3b submitted a Schedule

2
See, e.g., Harris CapRock, File No. 0734-EX-ST-2015 (authorization expired Jan. 22,
2016); File No. 0454-EX-ST-2015 (authorization expired Nov. 12, 2015).
3
See Harris CapRock, File Nos. SES-MOD-20150915-00599 & SES-AMD-20151205-
00907 (Call Sign E060157) (“Pending Modification Application”).
4
See O3b Limited, File No. SAT-LOI-20141029-00118, Call Sign S2935 (granted Jan.
22, 2015).

2

S describing the technical characteristics of its satellite system. Harris CapRock will
operate the ST5000-2.4 terminals consistent with the technical parameters outlined in the
O3b Schedule S.
The Commission has granted Ka-band ESV operating authority to O3b for
maritime operations nearly identical to those proposed herein. In May 2014, the
Commission granted O3b a blanket ESV license and a related waiver to operate one
hundred ESV terminals on U.S. and non-U.S.-registered vessels in NGSO primary Ka-
band spectrum, 28.6-29.1 GHz (Earth-to-space) band and 18.8-19.3 GHz (space-to-Earth)
band.5 In September 2014, the Commission granted authority to O3b to operate ESV
terminals on three non-U.S.-registered vessels in GSO primary Ka-band spectrum, 28.35-
28.4 GHz (Earth-to-space) band and 18.3-18.6 GHz (space-to-Earth).6 In May 2015, the
Commission granted O3b maritime operating authority to operate terminals on six non-
U.S.-registered maritime vessels in the local multipoint distribution service (“LMDS”)
primary uplink band, the 27.6-28.35 GHz (Earth-to-space), and the fixed service (“FS”)
primary downlink band, 17.8-18.3 GHz (space-to-Earth).7 Most recently, in January
2016, the Commission granted O3b a waiver to operate on up to thirty foreign-flagged
vessels in the in the 27.6-28.4 GHz, 17.8-18.6 GHz and 18.8-19.3 GHz bands.8
The foregoing constitutes extensive precedent for Commission licensing of Ka-
band maritime terminals to communicate with O3b’s NGSO FSS system. The proposed

5
See O3b Limited, File No. SES-LIC-20130528-00455 (Call Sign E130098); Letter from
Jose Albuquerque, Chief, Satellite Division and Mark Settle, Chief, Policy and Rules
Division, to Joslyn Read, O3b Limited, DA 14-637 (rel. May 13, 2014).
6
See File No. SES-MSC-20140318-00150, Letter from Jose Albuquerque, Chief,
Satellite Division and Mark Settle, Chief, Policy and Rules Division, to Suzanne Malloy,
O3b Limited, DA 14-1369 (rel. September 22, 2014).
7
See SES-MSC-20150206-00066, Letter from Jose Albuquerque, Chief, Satellite
Division and Mark Settle, Chief, Policy and Rules Division, to Suzanne Malloy, O3b
Limited, DA 15-601 (rel. May 20, 2015).
8
See File No. SES-MSC-20151021-00760, Letter from Jose Albuquerque, Chief,
Satellite Division and Mark Settle, Chief, Policy and Rules Division, to Suzanne Malloy,
O3b Limited, DA 16-99 (rel. January 29, 2016).

3

operations of the ST5000-2.4 terminal are virtually identical to those authorized in the
Commission decisions noted above, and thus can be authorized on the same basis as the
prior grants to O3b. Grant of the requested STA will enhance competition and enable
more efficient provision of critical communications services to government users and
commercial customers in the maritime, oil and gas, and other industries.
Harris CapRock notes that O3b has previously completed all necessary
coordination with U.S. government satellite networks operating in the Ka-band, including
GSO and NGSO networks. O3b has also completed coordination with the U.S.
government under footnote US334 of the United States Table of Frequency Allocations
(“Table of Allocations”). Harris CapRock’s proposed operations will be in accordance
with all existing and future coordination agreements between O3b and other authorized
Ka-band spectrum users. Finally, Harris CapRock will operate pursuant to the terms of
O3b’s U.S. market access grant and, to the extent relevant, will fully satisfy any
conditions of the grant to communicate with O3b’s NGSO system.9
II. SPECTRUM USE
The Table of Allocations and the Commission’s Ka-band Plan (“Ka-band Plan”)
identify various spectrum allocations for NGSO FSS operations but no rules have been
adopted for mobile earth stations or ESV operations in these bands. In the absence of
such rules, Harris CapRock intends to operate the ST5000-2.4 terminal on a non-
conforming (unprotected and non-interference) basis at all times when the terminals are
in motion. When the ESVs are stationary, Harris CapRock will operate the ST5000-2.4
in accordance with the Table of Allocations and Ka-band Plan or, to the extent necessary,
seek a limited waiver of the Commission’s Rules to operate the terminal on a non-
conforming basis. Because the Commission has not adopted technical rules governing
Ka-band ESV maritime operations, Harris CapRock will comply with the Commission’s
general rules and policies governing Ku-band ESV operations.10
Harris CapRock seeks to communicate with O3b’s Ka-band NGSO FSS system in

9
See O3b Limited, File No.SAT-LOI-20141029-00118 (Call Sign S2935) (granted Jan.
22, 2015).
10
See 47 C.F.R. 25.222; Technical Appendix, IV & V (Tracking Report).

4

the following bands: 27.6-28.4 GHz (Earth-to-space), 28.6-29.1 GHz (Earth-to-space),
17.8-18.6 GHz (space-to-Earth) and 18.8-19.3 GHz (space-to-Earth). Issues associated
with Ka-band maritime terminal operations in these band segments are discussed below.
A. Uplink Frequencies and Ka-band Designation
a. Primary NGSO FSS Uplink
The Table of Allocations and Ka-band Plan provide that the 28.6-29.1 GHz
(Earth-to-space) band may be used by NGSO FSS systems on a primary basis and by
GSO FSS systems on a secondary basis.11 Accordingly, when the ESVs are stationary,
Harris CapRock will operate the ESVs on a primary basis in the 28.6-29.1 GHz band.
When the ESVs are in motion, however, Harris CapRock intends to operate the ST5000-
2.4 terminal on a non-conforming (unprotected and non-interference) basis.
As discussed in Section III, below, Harris CapRock respectfully requests a waiver
of the Table of Allocations, 47 C.F.R. §2.106, and Ka-band Plan to the extent necessary
to permit its non-conforming use of the 28.6-29.1 GHz band. 12 Harris CapRock
demonstrates that it can operate the ST5000-2.4 terminal without causing harmful
interference to authorized spectrum users and agrees to accept any harmful interference
from other services while operating on a non-conforming, unprotected basis. In addition,
Harris CapRock will not claim protection from conforming uses of the 28.6-29.1 GHz
band while the ESVs are in motion.
b. Secondary NGSO FSS Uplink
The Commission’s Table of Allocations and Ka-band Plan provide that LMDS
systems operate on a primary basis and FSS systems on a secondary basis in the 27.5-

11
In the Matter of Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's Rules
to Redesignate the 27.5-29.5 GHz Frequency Band, to Reallocate the 29.5-30.0 GHz
Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution
Service and for Fixed Satellite Services, 11 FCC Rcd. 19005, ¶¶ 57-58 and 78 (1996)
(“Ka-band Plan R&O”). See also In the Matter of Redesignation of the 17.7-19.7 GHz
Frequency Band, Blanket Licensing of Satellite Earth Stations in the 17.7-20.2 GHz and
27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-
17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite-Service Use, 15
FCC Rcd 13430, ¶¶ 28 and 34 (2000) (“Redesignation of Ka-band Plan R&O”).
12
See United States Table of Frequency Allocations, 47 C.F.R. §2.106.

5

28.35 GHz (Earth-to-space) band.13 In addition, GSO FSS systems operate on a primary
basis and NGSO FSS systems operate on a secondary basis in the 28.35-28.4 GHz (Earth-
to-space) band.14
Accordingly, when the ESVs are stationary, Harris CapRock will operate the
ST5000-2.4 terminal on a secondary, non-harmful interference basis to LMDS in the
27.6-28.35 GHz band and to GSO FSS systems in the 28.35-28.4 GHz band. When the
terminal is in motion, however, Harris CapRock will operate the ST5000-2.4 on a non-
conforming (unprotected and non-interference) basis.
Harris CapRock notes that its proposed operations in the 27.6-28.35 GHz band are
consistent with the Commission’s view on the type of FSS operations that would not
cause harmful interference to primary LMDS stations in the band. The Commission has
previously stated that FSS operations in this band are limited to “gateway-type”
operations. 15 The Commission’s main concern is ubiquitous terminals that could
interfere with LMDS operations.16 Although the rules limit operations in some bands to
gateway earth stations only, the 27.5-28.35 GHz band is not among them and there is no
requirement that earth stations actually serve as gateways.
Harris CapRock’s proposed stationary ESV operations at a small number of port
and offshore locations will be limited in scope and consistent with the Commission’s
views on high data-rate, gateway-type operations. The Commission has previously

13
See Ka-band Plan R&O ¶¶ 59-62; see also Redesignation of Ka-band R&O ¶ 28.
14
Ka-band Plan R&O ¶ 42; see also Redesignation of Ka-band Plan R&O ¶ 28.
15
The Commission’s references to “gateway-type” service in the 27.5-28.35 GHz band
are not intended as a requirement that all earth stations in the band serve as gateway earth
stations. Rather, the mention of “gateway-type” service in the 27.5-28.35 GHz band
serves as an example of what the Commission’s envisions as the type of service that FSS
operators would be able to provide on a secondary basis without causing interference to
primary LMDS stations in the band.
16
In the Matter of Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's Rules
to Redesignate the 27.5- 29.5 GHz Frequency Band, to Reallocate the 29.5-30.0 GHz
Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution
Service and for Fixed Satellite Services, Third Report and Order, 12 FCC Rcd 22310,
22327, ¶ 42 (1997).

6

recognized that Ka-band maritime earth station operations are consistent with its view of
“gateway-type” operations.17 Accordingly, Harris CapRock can be permitted to operate
on a secondary basis to LMDS in the 27.6-28.35 GHz band.
As a secondary user, Harris CapRock’s proposed NGSO FSS operations in the
27.6-28.35 GHz band must not cause interference to primary LMDS stations. The
attached Comsearch coordination reports demonstrate that Harris CapRock may operate
the ST5000-2.4 terminal without causing harmful interference to LMDS licensees.
Harris CapRock has completed coordination of its proposed Ka-band ESV operations in
the 27.6-28.35 GHz band with existing terrestrial licenses in the port areas where
equipped vessels will be docked. 18 No objections were received from incumbent
licensees. Furthermore, Harris CapRock agrees not to cause harmful interference to
future primary LMDS operations in the band and will accommodate any future LMDS
licensees to the extent necessary to avoid harmful interference.
As a secondary user in the 28.35-28.4 GHz band, Harris CapRock must operate
the ST5000-2.4 terminal on a secondary basis to GSO FSS system and not cause harmful
interference to U.S.-licensed GSO FSS operations. Harris CapRock will operate the
terminal consistent with the off-axis EIRP limits specified in Section 25.138 of the
Commission’s Rules to ensure no interference with GSO FSS Ka-band satellite
operations.19 Furthermore, as discussed, the ST5000-2.4 terminal is designed to meet
certain FCC ESV operational requirements for Ku-band ESVs, including the pointing
accuracy, automatic cessation and recording requirements. 20 Finally, O3b has
demonstrated that operations of its Ka-band NGSO system comply with relevant

17
See O3b Limited, File No. SES-MSC-20150206-00066.
18
Frequency coordination reports have been completed for port locations in Fort
Lauderdale, Florida, Miami, Florida, Port Canaveral, Florida and San Juan, Puerto Rico.
See Technical Appendix, VII.
19
See 47 C.F.R. § 25.138; Technical Appendix, I.
20
See Technical Appendix, V.

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Equivalent Power Flux Density (“EPFD”) uplink limits,21 thus providing the required
level of protection to GSO FSS systems.
When the ST5000-2.4 is in motion, Harris CapRock intends to operate the
terminal on a non-conforming (unprotected and non-interference) basis in the 27.6-28.4
GHz band. As discussed in Section III, below, Harris CapRock respectfully requests a
waiver of the Table of Allocations, 47 C.F.R. §2.106, and Ka-band Plan to the extent
necessary to permit its non-conforming use of the 27.6-28.4 GHz band. 22 Harris
CapRock demonstrates that it can operate the ST5000-2.4 terminal without causing
harmful interference to authorized spectrum users and agrees to accept any harmful
interference from other services while operating on a non-conforming, unprotected basis.
In addition, Harris CapRock will not claim protection from conforming uses of the 27.6-
28.4 GHz band while the ESVs are in motion.
B. Downlink Frequencies and Ka-band Designation
a. Primary NGSO FSS Downlink
The Table of Allocations and the Commission’s Ka-band Plan provide that the
18.8-19.3 GHz (space-to-Earth) band may be used by NGSO FSS operations on a
primary basis. 23 Accordingly, when the ESVs are stationary, Harris CapRock will
operate the ESVs on a primary basis in the 18.8-19.3 GHz band. Because the
Commission has not adopted rules governing Ka-band terminal operations onboard
maritime vessels, Harris CapRock intends to operate the ESVs on a non-conforming basis
when the vessels are in motion.

21
See O3b Limited, File No. SES-MSC-20150206-00066, Technical Appendix A.7;
contactMEO Communications, LLC, 21 FCC Rcd 4035, 4043-4044 (IB 2006) (where the
Commission held that compliance with the ITU’s EPFD limits provides a sufficient basis
for an NGSO FSS system to operate on a non-interference basis in a band in which GSO
FSS systems are primary).
22
See United States Table of Frequency Allocations, 47 C.F.R. §2.106.
23
See Ka-band Plan R&O ¶¶ 59-62; see also Redesignation of Ka-band R&O ¶ 28. Note
that low power point-to-multipoint terrestrial fixed systems may continue to be licensed
and operate on a co-primary basis with NGSO/FSS in the 18.82-18.87 GHz and 19.16-
19.21 GHz bands.

8

As discussed in Section III, below, Harris CapRock respectfully requests a waiver
of the Table of Allocations, 47 C.F.R. §2.106, and Ka-band Plan to the extent necessary
to permit its non-conforming use of the 18.8-19.3 GHz band. 24 Harris CapRock
demonstrates that it can operate the ST5000-2.4 terminal without causing harmful
interference to authorized spectrum users and agrees to accept any harmful interference
from other services while operating on a non-conforming, unprotected basis. In addition,
Harris CapRock will not claim protection from conforming uses of the 18.8-19.3 GHz
band while the ESVs are in motion.
b. Downlink with No NGSO FSS Allocation
The Table of Allocations and the Commission’s Ka-band Plan provide that the
17.8-18.3 GHz band may be used by FS systems on a primary basis and NGSO FSS
systems are non-conforming.25 Similarly, the Table of Allocations and Ka-band Plan
provide that in the 18.3-18.6 GHz band, FSS services are limited to GSO FSS
operations.26 Accordingly, Harris CapRock will operate its ESVs on a non-conforming
basis while stationary or in motion in the 17.8-18.6 GHz band.
As discussed in Section III, below, Harris CapRock respectfully requests a waiver
of the Table of Allocations, 47 C.F.R. §2.106, and Ka-band Plan to the extent necessary
to permit its non-conforming use of the 17.8-18.6 GHz band. 27 Harris CapRock
demonstrates that it can operate the ST5000-2.4 terminal without causing harmful
interference to authorized spectrum users and agrees to accept any harmful interference
from other services while operating on a non-conforming, unprotected basis. In addition,
Harris CapRock will not claim protection from conforming uses of the 17.8-18.6 GHz
band while the ESVs are in motion.
III. WAIVER REQUESTS

24
See United States Table of Frequency Allocations, 47 C.F.R. §2.106.
25
See Redesignation of Ka-band Plan R&O ¶¶ 28 and 34.
26
Id.; see United States Table of Frequency Allocations, footnote NG164.
27
See United States Table of Frequency Allocations, 47 C.F.R. §2.106.

9

Harris CapRock is seeking a waiver of the U.S. Table of Frequency Allocations,
47 C.F.R. § 2.106, and the Commission’s Ka-band plan to the extent necessary to permit
non-conforming operation of the ST5000-2.4 terminal. In considering requests for non-
conforming uses, the Commission has indicated it would grant such waivers when there
is little potential for interference into any service authorized under the Table of
Allocations and when the non-conforming operator accepts any interference from
authorized services.28 In the following sections, Harris CapRock demonstrates it can
operate the ST5000-2.4 terminal on a non-conforming basis consistent with Commission
policies and precedent.
A. 28.6-29.1 GHz Uplink Band
When the ESVs are in motion, Harris CapRock proposes to operate the ST5000-
2.4 terminal on a non-conforming basis in the 28.6-29.1 GHz band. Harris CapRock will
not claim protection from conforming uses of the spectrum while the ESVs are in motion
and agrees to accept any harmful interference from other services. In addition, Harris
CapRock will immediately terminate its ESV operations upon notification that such
operations are not permitted under the terms of a coordination agreement with, or are
causing harmful interference to, any lawfully operating radio system in the 28.6-29.1
GHz band in conformance with the Table of Allocations. Harris CapRock’s operations
will be in accordance with any coordination agreement that has been or will be reached
between O3b and other lawfully operating spectrum users.
There is little to no potential for interference to existing secondary GSO FSS
systems in these bands.29 While there are no rules for mobile maritime operations in the
Ka-band, Harris CapRock will operate the proposed terminals within the off-axis EIRP
limits specified in Section 25.138 of the Commission’s Rules and will otherwise comply

28
See Letter from Jose Albuquerque, Chief, Satellite Division and Mark Settle, Chief,
Policy and Rules Division, to Suzanne Malloy, O3b Limited, DA 14-1369 (rel.
September 22, 2014); Contactmeo Communications, LLC, Order and Authorization, 21
FCC Rcd 4035, 4044 (IB 2006); ViaSat AMSS Order, File No. SES-MFS-20090624-
00789; see also 47 C.F.R. § 1.3.
29
There is no potential for interference into other NGSO FSS systems because O3b’s
system is currently the only authorized NGSO FSS system in the United States.

10

with the Commission’s two-degree spacing policy. 30 As discussed in the attached
Technical Appendix, the ST5000-2.4 terminal is designed to meet the FCC’s
requirements for Ku-band ESV operations, including: (i) pointing accuracy of 0.2° or
better; (ii) automatic cessation of emissions within 100 ms if pointing offset exceeds 0.5°;
and (iii) transmissions will not resume until pointing accuracy is within 0.2°.31 Harris
CapRock has also designed a system to record a vessel’s location, transmit frequency,
channel bandwidth and satellite used, which can be made available to a FSS operator
within 24 hours of a request.
Article 22 of the ITU Radio Regulations sets forth standards for interference
protection of GSO satellite networks from NGSO satellite systems. As previously
demonstrated by O3b, operations of the subject Ka-band NGSO system comply with the
relevant EPFD uplink limits in the 28.6-29.1 GHz band.32 Harris CapRock will operate
the ST5000-2.4 consistent with the EPFD limits of O3b’s system to provide the required
level of protection from GSO FSS systems operating in the 28.6-29.1 GHz band.
B. 27.6-28.4 GHz Uplink Band
When the ESVs are in motion, Harris CapRock proposes to operate the ST5000-
2.4 terminal on a non-conforming basis in the 27.6-28.4 GHz band. Harris CapRock will
not claim protection from conforming uses of the spectrum while the ESVs are in motion
and agrees to accept any harmful interference from other services while operating on a
non-conforming, unprotected basis. In addition, Harris CapRock will immediately
terminate its ESV operations upon notification that such operations are not permitted
under the terms of a coordination agreement with, or are causing harmful interference to,
any lawfully operating radio system in the 27.6-28.4 GHz band in conformance with the
Table of Allocations. Harris CapRock’s operations will be in accordance with any

30
See 47 C.F.R. § 25.138; Technical Appendix, Section III.
31
See Technical Appendix, IV. & V.
32
See O3b Limited, File No. See File No. SES-LIC-20130528-00455, Technical
Appendix, A.7; contactMEO Communications, LLC, 21 FCC Rcd 4035, 4043-4044 (IB
2006) (where the Commission held that compliance with the ITU’s EPFD limits provides
a sufficient basis for an NGSO FSS system to operate on a non-interference basis in a
band in which GSO FSS systems are primary).

11

coordination agreement that has been or will be reached between O3b and other lawfully
operating spectrum users.
There is little to no potential for interference to LMDS or GSO FSS operations
from Harris CapRock’s proposed ESV operations in the 27.6-28.4 GHz band. Not only
has Harris CapRock coordinated the relevant port areas, but while the ESVs are in motion
the subject vessels will be sufficient distance from the U.S. coastline to prevent harmful
interference to potentially affected terrestrial licensees. In addition operations of the
ST5000-2.4 will be consistent with the EPFD uplink limits in the 27.6-28.4 GHz band to
protect authorized spectrum users pursuant to Article 22 of the ITU Radio Regulations.33
Furthermore, Harris CapRock will operate the proposed terminals within the off-axis
EIRP limits specified in Section 25.138 of the Commission’s Rules and observe the
Commission’s Ku-band ESV requirements for pointing accuracy, recording and
automatic cessation. Thus, while the ESVs are in motion, Harris CapRock can operate on
a non-conforming basis without causing harmful interference to authorized GSO FSS or
LMDS operations in the 27.6-28.4 GHz band.
C. 18.8-19.3 GHz Downlink Band
When the ESVs are in motion, Harris CapRock proposes to operate the ST5000-
2.4 terminal on a non-conforming basis in the 18.8-19.3 GHz band. Harris CapRock will
not claim protection from conforming uses of the spectrum while the ESVs are in motion
and agrees to accept any harmful interference from other services while operating on an
unprotected, non-conforming basis. In addition, Harris CapRock will immediately
terminate its ESV operations upon notification that such operations are not permitted
under the terms of a coordination agreement with, or are causing harmful interference to,
any lawfully operating radio system in the 18.8-19.3 GHz band in conformance with the
Table of Allocations. Harris CapRock’s operations will also be in accordance with any

33
See O3b Limited, File No. SES-MSC-20150206-00066, Technical Appendix A.7;
contactMEO Communications, LLC, 21 FCC Rcd 4035, 4043-4044 (IB 2006) (where the
Commission held that compliance with the ITU’s EPFD limits provides a sufficient basis
for an NGSO FSS system to operate on a non-interference basis in a band in which GSO
FSS systems are primary).

12

coordination agreement that has been or will be reached between O3b and other lawfully
operating spectrum users.
Because there are no other Ka-band NGSO FSS systems authorized in the United
States, Harris CapRock’s proposed operations will not cause harmful interference to other
NGSO FSS systems. Furthermore, as previously demonstrated by O3b, operations of the
subject Ka-band NGSO system comply with the relevant Power Flux Density (“PFD”)
downlink limits for the 18.8-19.3 GHz band designed to protect terrestrial FS services.34
Harris CapRock’s proposed ESV operations are consistent with the PFD limits of O3b’s
system and will provide the required level of protection from terrestrial FS systems
operating in the 18.8-19.3 GHz band when the ESVs are in motion. Furthermore, the
ESVs will operate within the off-axis EIRP limits specified in Section 25.138 of the
Commission’s Rules and observe the Commission’s Ku-band ESV requirements for
pointing accuracy, recording and automatic cessation to ensure no harmful interference to
authorized FS operations.
D. 17.8-18.6 GHz Downlink Band
When the ESVs are stationary or in motion, Harris CapRock proposes to operate
the ST5000-2.4 terminal on a non-conforming basis in the 17.8-18.6 GHz band. Harris
CapRock will not claim protection from conforming uses of the spectrum while the ESVs
are in motion and agrees to accept any harmful interference from other services while
operating on an unprotected, non-conforming basis. In addition, Harris CapRock will
immediately terminate its ESV operations upon notification that such operations are not
permitted under the terms of a coordination agreement with, or are causing harmful
interference to, any lawfully operating radio system in the 17.8-18.6 GHz band in
conformance with the Table of Allocations. Harris CapRock’s operations will be in
accordance with any coordination agreement that has been or will be reached between
O3b and other lawfully operating spectrum users.
There is no potential for the proposed operations to cause interference to other
spectrum users because they are receive operations and would be the victim of

34
See O3b Limited, File No. SES-LIC-20130528-00455, Technical Appendix, A.5-A.7.
Fixed Service stations in the United States operating in the 18.8-19.3 GHz band are no
longer co-primary with FSS users in this band. (See 47 C.F.R. § 101.85(b)(2).)

13

interference from terrestrial transmit operations. As previously demonstrated by O3b,
operations of its Ka-band NGSO system comply with the relevant PFD downlink limits
for the 17.8-18.6 GHz band designed to protect terrestrial FS services.35 Operations of
the O3b system also comply with EPFD downlink limits in the 18.3-18.6 GHz band,36
therefore providing the required level of protection from GSO FSS systems operating in
the band. Furthermore, the ESVs will operate within the off-axis EIRP limits specified in
Section 25.138 and observe the Commission’s Ku-band ESV pointing accuracy,
recording and automatic cessation requirements to ensure that there is no harmful
interference to GSO FSS systems in this band.
E. Waiver Precedent
There is strong Commission precedent for granting the waivers requested herein.
The Commission has granted virtually identical waivers to O3b for its non-conforming
use of the Ka-band for maritime operations. 37 Harris CapRock’s proposed ESV
operations are fundamentally the same as O3b’s authorized operations. The Commission
also has granted similar waivers to enable Ka-band aeronautical operations in the absence
of rules governing Ka-band earth stations aboard aircraft (“ESAAs”).38
Harris CapRock has demonstrated that it can operate the ST5000-2.4 terminal in
the maritime context on a non-conforming basis in each band without causing harmful
interference to authorized users and agrees to accept any harmful interference from other
authorized systems. Accordingly, grant of the requested waivers is consistent with
Commission precedent and will not undermine other uses of the subject bands.
IV. EXPEDITED CONSIDERATION
Harris CapRock respectfully requests expedited processing of this STA request
under Section 25.120. Section 25.120(a) provides that STA requests should be filed at

35
See O3b Limited, File No. SES-MSC-20150206-00066, Technical Appendix A.5
36
Id. A.7
37
See File No. SES-LIC-20130528-00455 (Call Sign E130098); File No. SES-MSC-
20140318-00150; File No. SES-MSC-20150206-00066; File No. SES-MSC-20151021-
00760; Section I.A.
38
See ViaSat Authorization, File No. SES-LIC-20120427-00404, Call Sign E120075.

14

least three working days prior to the date of commencement of the proposed operations.
Here, Harris CapRock is proposing to commence operations on Monday, February 29,
2016.
As the Commission is aware, the pendency of a separate modification application to
add the ST5000-2.4 in the C-band and Ku-band to Harris CapRock’s ESV license
effectively precludes filing a new modification to add Ka-band operating authority to the
license.39 Harris CapRock has consulted with Commission staff and concluded, as a
result of processing limitations within the International Bureau Filing System (IBFS), it is
necessary to file requests for STA authority to support initial ST5000-2.4 Ka-band
operations. Harris CapRock requests this 60-day STA to permit operation of the ST5000-
2.4 during the pendency of its concurrently filed 180-day STA application, which will
afford the Commission time to place the application on public notice for comment by
interested parties.
Expeditious processing of this STA request will ensure that the substantial public
benefits of ST5000-2.4 terminal operations can be realized until such time as Harris
CapRock is able to file its contemplated modification application for long-term operating
authority. Harris CapRock acknowledges that any action on the requested STA will not
affect the Commission’s ultimate determination with respect to the forthcoming
modification application. Accordingly, Harris CapRock respectfully submits that the
public interest will be served by grant of the requested STA commencing February 29,
2016.
V. PUBLIC INTEREST
Grant of the requested 60-day STA will strongly serve the public interest.
Authorizing operation of the ST5000-2.4 terminal will allow Harris CapRock to provide
more robust broadband satellite communications services to a wide array of users,
including vessels in motion, marine barges and remote oil platforms that may be unable
to obtain communications services through alternative facilities. The ST5000-2.4 multi-
band terminal also will enhance operational flexibility and available satellite capacity by
utilizing Ka-band spectrum, in addition to other commercial FSS bands, to meet maritime
39
See Pending Modification Application.

15

customer needs. Users will be able to utilize high-speed Internet access, corporate VPN,
e-mail, voice and other services, including emergency communications to support
employees in remote locations, throughout international and U.S. waterways.
Near-term deployment of this terminal will also ensure that Harris CapRock (a
U.S. equipment manufacturer and service provider) and other U.S. interests can
participate more fully in the development of these important new services and improve
competition among maritime service providers. Moreover, Harris CapRock has
expended considerable effort in preparing equipment and personnel to facilitate near-term
introduction of the ST5000-2.4 terminal and grant of the requested authority will allow
commercial and government customers to benefit from the expansion of maritime
satellite communications services.
C. CONCLUSION
In view of the foregoing, the public interest would be served by a grant of the
requested 60-day STA to allow Harris CapRock to operate the ST5000-2.4 terminal in the
Ka-band with the O3b system as described herein by February 29, 2016 or at the earliest
practicable time thereafter.

16

Document Created: 1190-04-22 00:00:00
Document Modified: 1190-04-22 00:00:00

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