Attachment SESSTA2017042000444.

SESSTA2017042000444.

DECISION submitted by FCC

GRANT

0000-00-00

This document pretains to SES-STA-20170420-00444 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017042000444_1219269

                    KA25            SES—STA—20170420—00444       182017001103
                    Inmarsat Inc.




                                                                                                                                  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:
Inmarsat 30—day STA for C—band TT&C during LEOP for Inmarsat—5 F4
 1. Appficant


          Name:            Inmarsat Inc.                            Phone Number:                         202—248—5150
          DBA Name:                                                 Fax Number:
          Street:          1101 Connecticut Avenue, NW              E—Mail:                               giselle.creeser@inmarsat.com
                           Suite 1200
          City:            Washington                        |      State:                                 DC
          Country:          USA                                     Zipcode:                              20036        —
          Attention:       Giselle Creeser




                                                                                           CallB%F\B\S . Grant
                                                                                           (or other identifier)


                                                                      GRANTED
                                                                    International Bureau


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                                                                 (or other identifier)
Applicant: Inmarsat Inc.                                                         Term Dates
Call Sign: KA25                                                  From:
File No.:   SES—STA—20170420—00444          GRANTED
                                          International Bureau   Approved:
Special Temporary Authority (STA)


Inmarsat Inc.("Inmarsat") is granted STA for 30 days to use its fixed earth station, Call Sign
KA25, in Paumalu, Hawaii to provide launch and early orbit phase (LEOP) services and provide
in—orbit testing (IOT) phase at near orbital location 83.5 degrees E.L. for the Inmarsat—5 F4
satellite. The final destination will be at orbital location 117.5 degrees E.L. The Inmarsat 5 F4
is expected to be launched on May 15, 2017. The following conditions are:


1.     Inmarsat—5 F4 at LEOP operations will be performed on 5926.5 MHz and 6422.5 MHz
uplink frequencies (Earth—to—space) (LH and CRH) and at 4199.0 MHz and 4199.5 MHz
downlink frequencies (space—to—Earth) (LV and CLH).

2.     The maximum uplink EIRP transmitted during the LEOP operations will be 89.0 dBW.

£3     The minimum elevation angle for transmission will be at 10 degrees.

4.     The LEOP operations must be coordinated with all operators of satellites that use the
same frequency bands and are in the LEOP path. All operators of satellites in that path will be
provided with an emergency phone number where the licensee can be reached in the event that
harmful interference occurs. Currently the 24x7 contact information for the Inmarsat—5 F4 LEOP
operations is as follows: Satellite Control Centre in London, Tel. +44 20 7728 1182.

8.       All operations shall be on an unprotected and non—harmful interference basis, i.¢.,
Intelsat shall not cause harmful interference to, and shall not claim protection from interference
caused to it by, any other lawfully operating radiocommunication station and it shall cease
transmission(s) immediately upon notice of such interference.

6.      This grant does not constitute grant of U.S. market access to Inmarsat—5 F4 at any
location.

7.    Grant of this authorization is without prejudice to any determination that the Commission
may make regarding any future pending applications.

8.      Any action taken or expense incurred as a result of operations pursuant to this STA is
solely at Inmarsat‘s own 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.


2. Contact


             Name:          Inmarsat Inc.                       Phone Number:         .               202—248—5150

             Company:                                           Fax Number:
             Street:        1101 Connecticut Avenue, NW         E—Mail:                               giselle.creeser@inmarsat.com
                            Suite 1200
             City:          Washington                          State:                                DC
             Country:       USA                                 Zipcode:                              20036          —
             Attention:                            oo           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?
@ 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         g4 Noncommercial educational licensee
g4 Other(please explain):

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

5. Type Request


      Use Prior to Grant                                Change Station Location                            Other
234                                                C3                                                 @

6. Requested Use Prior Date
       05/12/2017
7. CityPaumalu                                                             8. Latitude
                                                                           (dd mmss.s h)    21   40       14.6   N


9. State   HI                                                               10. Longitude
                                                                            (dd mmss.s h)     158   2     3.1   E
11. Please supply any need attachments.
Attachment 1: Narrative                           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.)
     Inmarsat Inc.        requests STA for 30 days to use its 19—meter earth station antenna to allow
     C—band TT&C with the Inmarsat—5 F4 spacecraft during LEOP.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is               Yes            {:}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
   Giselle Creeser                                                             Director, Regulatory
           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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Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
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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.


                                     Before the
                      FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554

Application of

Inmarsat Inc.                                    Call Sign: KA25

For Special Temporary Authority                  File No. SAT—STA—2017




                APPLICATION FOR SPECIAL TEMPORARY AUTHORITY

       Inmarsat Inc. ("Inmarsat") hereby requests special temporary authority ("STA") for thirty

(30) days, beginning May 12, 2017, to use its 19—meter earth station antenna located in Paumalu,

Hawaii and operated under Call Sign KA25 (the "19m Antenna") to permit C—band telemetry,

tracking, and control ("TT&C") communications with the Inmarsat—5 F4 spacecraft during its

Launch and Early Orbit Phases ("LEOP").! 19m Antenna operations during this LEOP period

would be within the envelope of the KA25 license technical parameters and would require only

the addition of Inmarsat—5 F4 as a point of communication. Inmarsat and its affiliates will

provide a network of ground stations around the globe that will provide communicafion with the

spacecraft during the LEOP. The Inmarsat facility at Paumalu, Hawaii will form part of the

Inmarsat ground station network for this launch support using the 19m Antenna.

       The Inmarsat—5 F4 satellite is scheduled for launch on May 15, 2017. Inmarsat will be

responsible for the technical aspects of the launch support, using the C—band portion of the

satellite prior to its commercial operation. The mission control center will be located in Los

Angeles, and all the mission operations will be conducted by Boeing under the direction of

Inmarsat Global. It is expected that the 19m Antenna will be used intermittently during the first


1      See 47 C.F.R. § 25.120(b)(4).


few days of support (typically 8—12 days) for limited periods when the spacecraft is visible from

the Paumalu station.

       Following the LEOP phase and before entering commercial service, Inmarsat—5 F4 will

undergo an electrical propulsion orbit raising phase for 5—9 weeks followed by a one month in—

orbit testing ("IOT") phase both at or close to the geostationary location of §3.5E. At the end of

IOT, the satellite will commence operational service at 117.5E. Once Inmarsat—5 F4 enters

operational service, nominal on—station TT&C operations will be conducted in Ka—band from

Perth and Merredin, Australia.

       To be clear, Inmarsat Hawaii‘s support to Inmarsat Global Ltd. using the Paumalu station

and 19m Antenna will be limited to the LEOP portion of the mission only. Given the lack of

visibility to the relevant orbital locations, no operations with Inmarsat—5 F4 will be possible from

the Paumalu ground station when the satellite is undergoing electrical propulsion orbit raising,

IO0T, or once it becomes operational.

       1.       TO THE EXTENT APPLICABLE, GOOD CAUSE EXISTS FOR WAIVER
                OF CERTAIN PORTIONS OF SECTIONS 25.137 AND 25.114

       Inmarsat provides the necessary legal and technical information to support this STA

request and also requests certain waivers to permit communicate from the 19m Antenna to the

Inmarsat—5 F4 spacecraft. Under FCC Rule 25.137, earth station applicants "requesting authority

to communicate with a non—U.S. licensed space station" must submit the same technical

information required by FCC Rule 25.114 for U.S.—licensed space stations and certain legal

information."




2      47 C.F.R. § 25.137.


        Inmarsat seeks authority to support the needed TT&C during the LEOP of the Inmarsat—5

F4 spacecraft from shortly after launch to low—earth orbit. Inmarsat does not request authority to

provide commercial service to the United States, and thus believes that Section 25.137 does not

apply. However, to the extent the Commission determines that Inmarsat‘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 respectfully requests a waiver of Sections 25.137 and 25.114 of

the Commission‘s rules, to the extent it has not provided the information required herein.

        The Commission may grant a waiver for good cause shown and is appropriate if special

circumstances warrant a deviation from the general rule and such a deviation will serve the

public interest." Here, good cause exists for waiver of portions of Section 25.114 requiring legal

and technical information not relevant to the LEOP, such as antenna patterns, energy and

propulsion and orbital debris. To the extent the information requirements of Rule 25.114 are

relevant to the LEOP service, Inmarsat provides such information herein.

        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 simply is providing

TT&C 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 earth station applicants requesting authority to operate with



3       See 47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert.
denied, 409 U.S. 1027 (1972); Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166
(D.C. Cir. 1990).

4      See 47 C.F.R. § 25.137.


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 — to prevent warehousing of orbital locations by

operators seeking to serve the United States — is not a concern here.

           Inmarsat seeks authority only to conduct LEOP support for Inmarsat—5 F4, which is

licensed by the UK Space Agency and is a commercial communications satellite primarily

supporting broadband data services to mobile users in the Indian Ocean region. As Inmarsat‘s

    19m Antenna license demonstrates, Inmarsat has the requisite authority to perform the LEOP of

the Inmarsat—5 F4 satellite, except for the point of communication. Moreover, Inmarsat will

conduct the operations on an unprotected, non—interference basis.

           Finally, Inmarsat notes that it expects to communicate with the Inmarsat—5 F4 satellite

using the 19m Antenna pursuant to this STA for a maximum period of 12 days under nominal

launch conditions. Requiring Inmarsat to provide technical and legal information, where there is

no risk of interference and the operation is expected to cease within 12 days, is unnecessary and

would pose undue hardship without serving underlying policy objectives. Given these particular

facts, Inmarsat believes that the waiver sought herein is appropriate.

          IL.     INFORMATION RELEVANT TO LEOP SUPPORT

          Inmarsat provides the following technical parameters for informational purposes only.

The operations contemplated in this request fall within the existing license parameters for the

19m Antenna.




s         See 47 C.F.R. § 25.137(d).


        Earth Station Information

        EARTH—to—SPACE:
        Transmit Frequencies: 5926.5 MHz and 6422.5 MHz
        Transmit Polarization: Linear Horizontal and Circular RH
        Maximum EIRP: 89 dBW
        RF Modulation: FM
        Minimum Elevation for Transmission: 10 degrees

        SPACE—to—EARTH:
        Receive Frequencies: 4199.0 MHz and 4199.5 MHz
      — Receive Polarization: Linear Vertical and Circular LH
        Maximum Spacecraft EIRP : 6 dBW within +/— 70 degrees
        RF Modulation: PM
        Azimuth Range: 360 degrees
        Duration of Communications: three months from launch.

        Space Station Coordination

        Inmarsat maintains responsibility for the coordination of communications supporting the

launch of the Inmarsat—5F4 spacecraft with existing spacecraft operators during LEOP and other

operations. Inmarsat has undertaken coordination of communications for the support of the

launch of Inmarsat—5 F4 with other spacecraft operators that may be potentially affected during

LEOP.

        If necessary, Inmarsat will 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.


       III.      CONCLUSION

       For the foregoing reasons, Inmarsat respectfully requests STA for 30 days, beginning

May 12, 2017, to use its 19m Antenna to permit C—band TT&C communications with the

Inmarsat—5 F4 spacecraft during its LEOP phases. Grant of the requested STA serves the public

interest by enabling Inmarsat to provide essential TT&C functions to the Inmarsat—5 F4

spacecraft consistent with the technical parameters of the 19m Antenna license and without

creating any risk of harmful interference.

                                                   Respectfully submitted,

                                                   Inmarsat Inc.
                                                   By: Giselle Creeser
                                                   Giselle Creeser
                                                   Director, Regulatory
                                                   1101 Connecticut Ave. NW
                                                   Suite 1200
                                                   Washington, DC 20036
April 20, 2017



Document Created: 2017-05-10 16:08:59
Document Modified: 2017-05-10 16:08:59

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