Attachment Narrative SES-STA-20170613-00643

Attachment Narrative

This document pretains to SES-STA-20170613-00643 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017061300643_1237185

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of

Application of RBC Signals LLC for a )
60-Day Special Temporary Authorization ) Call Sign:
(“STA”) To Operate an Earth Station To )
Provide Tracking, Telemetry & Command ) File No.:
(“TT&C”) to Foreign-Licensed Satellites )

REQUEST FOR SPECIAL TEMPORARY AUTHORITY

RBC Signals LLC (“RBC Signals”), pursuant to Section 25.120 of the Commission’s

Rules, 47 C.F.R. § 25.120, respectfully seeks a 60-day special temporary authorization (“STA”)

to operate a M2 Antenna Systems 3.5m earth station (the “M2 3.5m”) at a facility in Deadhorse,

Alaska to communicate with certain foreign-licensed low-Earth orbit (“LEO”) mobile-satellite

service (“MSS”) cubesats to perform tracking, telemetry and command (“TT&C”) for

housekeeping, orientation and subsystem control following the satellites’ launch. RBC Signals

seeks to perform these short-term TT&C operations in the 399.926-399.950 MHz band (Earth-to-

space) and 401.05-401.25 MHz band (space-to-Earth). RBC Signals seeks this 60-day STA to

ensure the timely initiation of TT&C operations and plans to file an application for regular earth

station operating authority.

I. BACKGROUND

RBC Signals is a Seattle, Washington-based satellite services company that provides earth

station services around the world. RBC Signals partners with other earth station operators or

operates its own earth stations to efficiently support various satellite service applications.

RBC Signals seeks short-term authority to conduct TT&C operations for three U.K.-licensed

3U cubesats – Red Diamond, Green Diamond and Blue Diamond (the “3 Diamonds”) – that will

operate at an altitude of approximately 500 km in MSS spectrum at 2170-2200 MHz (space-to-

II. DISCUSSION

RBC Signals seeks to operate the M2 3.5m – a variant of an earth station that has been

previously licensed by the Commission for similar TT&C operations 3 – with the 3 Diamonds

satellites in the 399.926-399.950 MHz band (uplink) and 401.05-401.25 MHz band (downlink).

RBC Signals is not requesting U.S. market access for the 3 Diamonds satellites to operate or

demonstrate service links in the United States and therefore is not providing the full technical

information required by Sections 25.114 and 25.137 of the Commission’s rules, 47 C.F.R. §§ 25.114

and 25.137. To the extent necessary, RBC Signals respectfully seeks a waiver of Section 25.114

and 25.137 of the Commission’s rules to permit the limited TT&C operations proposed herein.

Nonetheless, RBC Signals provides information herein, the companion Technical

Appendix, Attachments and draft FCC Form 312 Schedule B, which contain relevant information

relating to the proposed TT&C operations, including earth station operational characteristics,

satellite technical and orbital parameters, TT&C link budgets and an orbital debris mitigation

statement for the 3 Diamonds satellites.4 Grant of this STA request is in the public interest

because it will facilitate the safe operation of the 3 Diamonds satellites during testing and

demonstration and ensure the timely initiation of TT&C for these novel and important cubesat

operations.

A. TT&C Uplink Operations

The United States Table of Frequency Allocations (“Table of Allocations”), Section 2.106

3
See Spire Global, Inc., File No. SES-LIC-20160317-00249, Call Sign E160035.

4 The 3 Diamonds satellites will operate under the SSG-CSL and SSG-3D ITU NGSO system
filings submitted by the United Kingdom late last year. RBC Signals understands that
coordination is ongoing and that certain adjustments to the initial ITU filings for the demonstration
satellites may be forthcoming. RBC Signals also has attached the UK licenses for the Red
Diamond, Green Diamond and Blue Diamond satellite as Attachment 2.

3

of the Commission’s rules, 47 C.F.R. § 2.106 provides that the 399.9-400.05 MHz band is shared

on a co-primary basis between MSS and federal radionavigation-satellite services. RBC Signals

seeks to perform limited TT&C uplink operations in frequencies from 399.926-399.950 MHz

consistent with the co-primary MSS allocation in this band.

As discussed above, the 3 Diamonds satellites will be launched as demonstration satellites

for SSG’s MSS constellation and will provide data, voice and messaging services directly to fixed

and mobile terminals. These terminals include land, maritime and aeronautical mobile terminals, as

well as fixed terminals that may serve as base stations for “bring your own” mobile devices.

Additional information regarding the 3 Diamonds mission and SSG’s long-term constellation can be

found on the SSG web site.5

RBC Signals will operate the M2 3.5m earth station at a site in Deadhorse, Alaska and

provide TT&C uplink operations for SSG’s MSS system consistent with the MSS allocation in the

band.6 Given the altitude and spacing of the 3 Diamonds satellites (with overlapping beams), 7 the

proposed TT&C earth station will transmit approximately 5% of the time to communicate with the

satellites. The limited transmission window, as well as the remote location of the facility (in the

North Slope of Alaska), limit the potential for interference from the proposed operations.

5 See https://www.skyandspace.global/operations-overview/.
6 The limited, data-only TT&C operations for the 3 Diamonds MSS demonstration satellites are
consistent with the Commission’s limitation on use of the band for non-voice communications of
NGSO satellites. See 47 C.F.R. §25.103 (“Definitions…. Non-Voice, Non-Geostationary (NVNG)
Mobile-Satellite Service. A Mobile-Satellite Service reserved for use by non-geostationary
satellites in the provision of non-voice communications which may include satellite links between
land earth stations at fixed locations.”) See also Section II.D, infra, requesting, out of an
abundance of caution, a waiver to permit TT&C uplink operation in this MSS band.
7
The rising order of satellites above the horizon is Blue, then Green, then Red. Initial relative
orbit phasing between Blue and Green is 0.31735 degrees, and between Blue and Red is 2.53879
degrees. After phasing end (end of July) the relative phasing between Blue and Green will be 4.44
degrees and between Blue and Red will be 8.88 degrees.

4

RBC Signals understands that there is limited U.S. government use of the band, 8 but

acknowledges that there is a pending FCC rulemaking addressing further use of this band,9 as well

as a proceeding developing U.S. preliminary views on a related WRC-19 agenda item.10 RBC

Signals acknowledges that any grant of earth station operating authority would be subject to the

outcome of these proceedings. In addition, as noted previously, RBC Signals is consulting with

NTIA and NOAA staff to ensure that the interests of the United States are fully accommodated and

that the proposed TT&C services will not cause interference to current or future U.S. government

operations.

In view of the foregoing, RBC Signals anticipates that its operations will be compatible with

spectrum users and will present no potential for interference in the 399.926-399.950 MHz uplink

band. RBC Signals will conduct its TT&C operations on a non-harmful interference basis and, if

RBC Signals learns that its operations are causing harmful interference to other operations, it will

modify or suspend operations to immediately resolve such interference.

B. TT&C Downlink Operations

The Table of Allocations provides that the 401-402 MHz band is shared on a co-primary

basis between meteorological aids and space operations services. RBC Signals seeks to perform

TT&C downlink operations in frequencies from 401.05-401.25 MHz consistent with the co-primary

8
See https://www.ntia.doc.gov/files/ntia/publications/compendium/0399.90-
0400.05_01DEC15.pdf.
9See generally Amendment of Part 2 of the Commission’s Rules for Federal Earth Stations
Communicating with Non-Federal Fixed Satellite Service Space Stations; Federal Space Station
Use of the 399.9-400.05 MHz Band; and Allocation of Spectrum for Non-Federal Space Launch
Operations, ET Docket No. 13-115, RM-11341; see also https://www.fcc.gov/items-on-circulation.
10See International Bureau Seeks Comment on Recommendations Approved by World
Radiocommunication Conference Advisory Committee, Public Notice, IB Docket No. 16-185, DA
17-365 (rel. Apr. 24, 2017).

5

space operations allocation in this band. 11

RBC Signals understands that there is no U.S. government use of the 400.05-400.15 MHz

sub-band,12 but there are certain meteorological aids and space research operations conducted in the

400.15-400.25 MHz sub-band.13 Based on our research and consultations to date, RBC Signals

believes the proposed TT&C downlink (earth station receive) operations in this band will not present

a potential for interference into other users of this band.14 However, if RBC Signals learns that its

operations are causing harmful interference to other operations, it will suspend or modify its

operations to immediately resolve such interference.

C. The 3 Diamonds Satellites

SSG is developing technology that will permit cubesats to deliver narrowband connectivity

services to otherwise unconnected users in remote locations on an extremely cost-effective basis.

When fully launched, the SSG constellation will support user voice calls and messaging, machine-

to-machine (“M2M”) and Internet of Things (“IoT”) services, and data storage and forwarding in

both fixed and mobile applications in MSS spectrum at 2170-2200 MHz (space-to-Earth) and 1980-

2010 MHz (Earth-to-space), subject to coordination with incumbent operations. The 3 Diamonds

satellites’ TT&C spectrum assignments were approved by the UK Ministry of Defence, representing

11See 47 C.F.R. § 2.1 (defining “space operations” as “a radiocommunication service concerned
exclusively with the operation of spacecraft, in particular space tracking, space telemetry, and
space telecommand.”).
12See https://www.ntia.doc.gov/files/ntia/publications/compendium/0400.05-
0400.15_01DEC15.pdf.
13See https://www.ntia.doc.gov/files/ntia/publications/compendium/0400.15-
0401.00_01DEC15.pdf.
14
RBC Signals would also note that the downlink PFD of the 3 Diamonds satellites in the 400.15-
400.25 MHz sub-band is -134 dBW/(m2 · 4 kHz), 9 dB lower than the -125 dBW/(m2 · 4 kHz) limit
set forth in Annex 1 of App. 5 of the ITU Radio Regulations. See RR 5.264 and 47 C.F.R. § 2.106.

6

a substantial validation of SSG’s narrow-band satellite communications platform. 15

SSG was recently awarded Frost & Sullivan’s 2016 Global Narrow-Band Nano-Satellite

Connectivity Services Technology Innovation Award for its proposed satellite communications

constellation concept. 16 Additionally, SSG recently signed an agreement with the U.S. Department

of Defense (“DOD”) for space situational awareness services to help ensure the safe operations of

the 3 Diamonds satellites.17

Through its partnership with the Indian Space Research Organization (“ISRO”), SSG will

launch its three UK-licensed cubesats on or about June 23, 2017. The requested STA is intended to

support initial TT&C operations for SSG’s demonstration and proof-of-concept satellites and RBC

Signals will file an underlying application for longer-term TT&C earth station operating authority.

D. Waiver Requests

The Commission may waive its rules for “good cause shown.” 18 As discussed below, good

cause exists to waive certain rules in this case if necessary to permit RBC Signals to perform critical

TT&C functions for the 3 Diamonds demonstration mission, such waivers would not undermine

the purpose of the rules, and such waivers are consistent with Commission policies and precedent.

1. Waiver of Sections 25.114 and 25.137

RBC Signals respectfully seeks a waiver of Sections 25.114 and 25.137 of the

Commission’s rules, 47 C.F.R. §§ 25.114 and 25.137, to the extent necessary to perform TT&C for

the 3 Diamonds without making the full technical showings required for non-U.S. licensed space

15 See http://www.asx.com.au/asxpdf/20160927/pdf/43bhb4pwhkhym8.pdf.
16See https://www.slideshare.net/FrostandSullivan/2016-global-narrowband-nanosatellite-
connectivity-services-technology-innovation-award.
17 See https://www.skyandspace.global/sky-space-signs-agreement-us-department-defence/.
18 See 47 C.F.R. § 1.3. WAIT Radio v. FCC, 418 F.2d 1153, 1157 (D.C. Cir. 1969).
7

stations to access the U.S. market.

As noted, RBC Signals is not requesting U.S. market access nor any other authorization to

test and demonstrate the 3 Diamonds satellites service functionality in the United States.

Accordingly, RBC Signals is not providing the full technical information contemplated by Sections

25.114 and 25.137 of the Commission’s rules for such authority. In the attached Technical

Appendix, however, RBC Signals provides technical information necessary to assess earth station

and satellite operational characteristics, including link budgets, emissions information and an

orbital debris mitigation statement for the 3 Diamonds satellites.

Section 25.137 of the Commission’s rules requires that an applicant proposing to use a U.S.-

licensed earth station to communicate with foreign-licensed spacecraft demonstrate that the

Commission’s policies for U.S. market access are satisfied, including the obligation to file detailed

satellite technical information as specified in Section 25.114. Because the M2 3.5m earth station

will be used solely for TT&C operations and no SSG satellite services will be conducted in the

United States, and because sufficient information to assess the satellites’ operation in the relevant

bands has been submitted, grant of a waiver will not undermine the purpose of these requirements.

The 3 Diamonds satellites are licensed by the United Kingdom, a WTO-member country.

To the extent relevant, there is a presumption in favor of entry for these satellites. 19 In addition, the

United Kingdom has stringent satellite licensing requirements, including for orbital debris

mitigation purposes, that are well-recognized by the Commission. 20 Thus, the Commission can be

assured that operation of the 3 Diamonds satellites will be fully consistent with international

19
See 47 C.F.R. § 25.137(a)(2).
20See generally Inmarsat plc, Petition for Declaratory Ruling, File Nos. SAT-PPL-20081219-
00235 and SAT-APL-20090609-00068, Call Sign S2780.

8

standards and requirements.

Moreover, strictly requiring a full satellite application technical demonstration is

unnecessary and unduly burdensome in this limited context. RBC Signals is proposing to operate

a single earth station in a remote area of Alaska for the limited purpose of performing TT&C during

the 3 Diamonds demonstration mission. It has provided relevant satellite and earth station technical

characteristics in the attached Technical Appendix and draft FCC Form 312 Schedule B, and the

proposed TT&C operations will be consistent with industry practice and conducted on a non-

harmful interference basis.

The Commission has previously granted similar waivers in the context of proposed TT&C

operations with foreign-licensed satellites.21 Accordingly, grant of the requested waiver is

consistent with Commission precedent and would permit RBC Signals to timely commence TT&C

operations to support the 3 Diamonds demonstration mission.

2. Waiver of Section 25.202(g)(1)

Section 25.202(g)(1) provides that “telemetry, tracking, and command signals may be

transmitted in frequencies within the assigned bands that are not at a band edge only if the

transmissions cause no greater interference and require no greater protection from harmful

interference than the communications traffic on the satellite network or have been coordinated with

21 See, e.g., SES Americom, Inc., File No. SES-MFS-20160624-00607, Call Sign E050287
(granting authority for an earth station to provide TT&C services to the foreign-licensed ASTRA
3A operating at 86.85° W.L.); Hawaii Pacific Teleport, L.P., File No. SES-MFS-20131030-00913,
Call Sign E030115 (granting authority for an earth station to provide TT&C services to ASTRA
3A operating at 176.85° W.L.); SES Americom, Inc., File No. SES-STA-20161110-00884, Call
Sign E050287 (granting authority for an earth station to provide TT&C services to ASTRA 3A
during drift from 86.85° W.L. to 47.0° W.L.); Hawaii Pacific Teleport, L.P., File No. SES-STA-
20131030-00914, Call Sign E030115 (granting authority for earth station to provide TT&C services
to ASTRA 3A operating at 176.85° W.L).; PanAmSat Licensee Corp., File No. SES-STA-
20090922-01212, Call Sign E040125 (granting authority for an earth station to communicate with
the foreign-licensed NSS-12 satellite for purposes of providing launch and early operations
services).

9

operators of authorized co-frequency space stations ….”22 It is not clear that this rule applies in

the context of the dedicated 3 Diamonds’ TT&C frequencies approved by the United Kingdom and

assigned to SSG, but RBC Signals requests a waiver of the rule out of an abundance of caution.

The general purpose of the rule is to simplify the coordination process for satellite systems,

to provide an incentive for the operator to maximize the efficiency of its system’s TT&C

operations, and to minimize the constraints placed on other satellite operations; 23 and Section

25.202(g)(1) includes language stating the interference potential and protection required for TT&C

operations shall be no greater than those of other co-frequency communications traffic on the

satellite. Because SSG has been assigned a dedicated TT&C band, there is no basis to compare its

TT&C transmissions with other traffic in a separate frequency band. Similarly, because the TT&C

frequencies have been assigned to SSG, there is no question of whether the frequencies are or are

not at the band edge.

But there may be a question as to whether the assigned TT&C frequencies would be

considered in the satellites’ service band and band edge under Section 25.202(g). The Commission

has permitted TT&C operations outside of a satellite’s assigned service band where it has found

the operations will not cause interference to other licensed operations and will otherwise serve the

public interest.24 The Commission also has permitted mid-band TT&C operations consistent with

22
See 47 C.F.R. § 25.202(g)(1). The operational characteristics of the 3 Diamonds’ TT&C have
been selected to minimize interference into other satellite networks. See 47 C.F.R. § 25. 202(g)(2).
23See, e.g., Amendment of the Commission’s Rules with regard to the 3650-3700 MHz
Government Transfer Band; The 4.9 GHz Band Transferred from Federal Government Use, First
Report and Order and Second Notice of Proposed Rulemaking, 15 FCC Rcd 20488, 20538-39,
para. 129 (2000).
24See, e.g., EchoStar Satellite Operating Corp., File No. SAT-LOA-20070105-00003, Call Sign
2725 (March 18, 2009).

10

Section 25.202(g)’s requirements. 25 For the same reasons and to the extent necessary in this STA

request, grant of a waiver would not undermine the purpose of the rule, would be consistent with

Commission precedent and would serve the public interest.

E. Public Interest Considerations

RBC Signals respectfully requests this 60-day STA pursuant to Section 25.120 of the

Commission’s Rules, 47 C.F.R. § 25.120. Section 25.120(a) provides that STA requests should be

filed at least three working days prior to the date of commencement of the proposed operations.

Here, RBC Signals is proposing to commence operations on or about June 23, 2017. Additionally,

the Commission may grant a 60-day STA if the STA request has not been placed on public notice

and the applicant plans to file a request for regular authority for the operations. RBC Signals plans

to file an application for longer-term authority as soon as possible, based on further consultations

with the FCC staff and other U.S. government agencies, to permit continuing TT&C operations for

the 3 Diamonds demonstration mission.

Expeditious processing of this STA request will ensure that RBC Signals is able to

commence TT&C in time for the launch of the 3 Diamonds satellites and assist SSG in demonstrating

the significant benefits of its novel satellite communications system. For its part, the 3 Diamonds

demonstration mission will help the satellite industry delivery affordable satellite-based connectivity

services to remote locations, reaching diverse regions and customers. RBC Signals acknowledges

that any action on the requested STA will not affect the Commission’s ultimate determination with

respect to the application for longer-term TT&C earth station operating authority.

25See, e.g., Iridium Constellation LLC, ORDER AND AUTHORIZATION, File Nos. SAT-MOD-
20131227-00148 and SAT-AMD-20151022-00074, Call Sign S2110 (Aug. 1, 2016).
11

III. CONCLUSION

In view of the foregoing, including the unique and limited scope of this request, the public

interest would be served by a grant of a 60-day STA to allow RBC Signals to perform TT&C for the

U.K.-licensed 3 Diamonds satellites commencing on or about June 23, 2017.

12

Document Created: 2017-06-13 17:52:49
Document Modified: 2017-06-13 17:52:49

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC