Attachment SES-STA-20190828-011

SES-STA-20190828-011

DECISION submitted by FCC

Grant

0000-00-00

This document pretains to SES-STA-20190828-01117 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2019082801117_1935249

                         SESSTA-2019092$OlU7      182019003117
           E930489
                                                    LLC
           Comcast Cable Communications Management,



                                                                                                                         Approved by 0MB
                                                                                                                                3060—0678

                                 APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
Special Temporary Authority for Expired Ku—band earth station E93 0489 Littleton, Co
    1. Applicant

              Name:          Comcast Cable Communications        Phone Number:                    215—286—7454
                             Management, LLC
              DBA Name:                                          Fax Number:                      215—286—1022
              Street:        One Comcast Center                  E—Mail:                          sheilasrnith@cabIe.comcast.com


                             1701 John F. Kennedy Boulevard
              City:          Philadelphia                        State:                           PA
              Country:       USA                                 Zipcode:                         19103       —2838
              Attention:     Sheila Smith



                                                                                          //


                                                                             #Sf5 47                      Of/y7
                                                                          Call Sign      rant
                                                                          (or other identifier)
                                                                                     T    Dates


                                                                          Aro

I


    2. Contact

                 Name:         Catherine fox                          Phone Number:                       215 286—8818
                 Company:      Comcast Cable Communications           Fax Number:
                               Management, LLC
                 Street:       One Comcast Center                     E—Mail:                             Catherinefox@Comcast.com
                               1701 John F. Kennedy Boulevard
                 City:         Philadelphia                           State:                               PA
                 Country:      USA                                    Zipcode:                            19103      —2838
                 Attention:                                           Relationship:


    (If your application is related to an application filed with the Commission, enter either the file number or the ID Submission ID of the related
    application. Please enter only one.)
     3. Reference File Number or Submission ID 1B20 19003 116
        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).
    •
    0    Governmental Entity      c, Noncommercial educational licensee
    o Other(please explain):
    4b. Fee Classification    CGX   —   Fixed Satellite Transmit/Receive Earth Station
    5. Type Request


         Use Prior to Grant                                  Change Station Location                         Other
    •


    6. Requested Use Prior Date
          09/06/2019




2


    7. CityLittleton                                                            8. Latitude
                                                                                (dd mm ss.s h)    39    30     50.0   N
    9. State   CO                                                               10. Longitude
                                                                                (dd mm ss.s h)    105    1     30.5   W
    1 1. Please supply any need attachments.
    Attachment 1: Radhaz                              Attachment 2: STA Narrative                            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.)
         Special Temporary Authority per attached for expired Call Sign E930489




    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
      Catherine Fox                                                               Deputy General Counsel
               WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 1$, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZAT[ON
                       (U.S. Code, Title 47, Section 3 12(a)(I)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




3


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The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing instructions,
searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you
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federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fcc.gov. PLEASE
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 sponsor this collection, unless it displays a currently valid 0MB control number or if we fail to provide you with this notice. This
collection has been assigned an 0MB 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.




4


Applicant: Comcast Cable Communications Management, LLC
Call Sign: E9304$9
File No.: SES-STA-20190828-0l 117
Special Temporary Authority (“STA”)

Comcast Cable Communications Management, LLC (“Comcast”) is granted Special Temporary
Authorization for 60 days to operate its licensed fixed Ku-band Transmit-Only satellite earth
station located at geographic coordinates 39° 30’ 50”N, 105° 01’ 30.5” W in Littleton, CO with
the listed satellites at their permanent orbital location in the frequency band 14000-14500 MHz
(Earth-to-space) under the following conditions:

   1. Operations shall comply with 47 C.F.R.    § 25.2 12.
   2. Operations with Ku-band satellites: AMC 6 (S2347), AMC 15(S2 180), AMC 21
      (S2676), Anik FiR (S2674), Anik F2 (S2646), Anik F3 ($2703), Arsat 2 (S2956),
      Eutelsat 113 West A ($2695), Eutelsat 115 West B ($2938), Eutelsat 117 West A
      ($2873), Eutelsat 117 West B (S2926), Galaxy 3C (S2381), Horizons 1 (S2475), Galaxy
      16 (52687), Galaxy 17 ($2715), Galaxy 18 (S2733), Galaxy 19 (S2647), Galaxy 28
      (S2160), Intelsat 16 (S2750), Intelsat 30 ($2887), Intelsat 31(S2924), SES-1 (S2807),
      SES- 2 (S2826), SES-3 (S2892), SES-lO ($2950), SES-15 (S2951), Star One C2
      (S2678), and Star One C3 (S2845) with only frequency 14000 MHz.

   3. All operations shall be on an unprotected and non-harmful interference basis, Comcast,
      shall not cause harmful interference to, and shall not claim protection from, interference
      caused to it by any other lawfully operating station and it shall cease transmission(s)
      immediately upon notice of such interference and must inform the Commission, in
      writing, immediately of such an event.

   4. The licensee shall take all necessary measures to ensure that the antenna does not create
      potential exposure of humans to radiofrequency radiation in excess of the FCC exposure
      limits defined in 47 CFR 1.1307(b) and 1.1310 wherever such exposures might occur.
      Measures must be taken to ensure compliance with limits for both occupational?
      controlled exposure and for general populationluncontrolled exposure, as defined in these
      rule sections. Compliance can be accomplished in most cases by appropriate restrictions,
      such as fencing. Requirements for restrictions can be determined by predictions based on
      calculations, modeling, or by field measurements. The FCCs OFT Bulletin 65 (available
      on-line at www.fcc.gov/oeUrfsafety) provides information on predicting exposure levels
      and on methods for ensuring compliance, including the use of warning and alerting signs
      and protective equipment for workers.

  5. Grant of this STA is without prejudice to any determination that the Commission may
     make regarding pending or future Comcast applications.

  6. Any action taken or expense incurred as a result of operations pursuant to this STA is
     solely at Comcast’s risk.


This action is issued pursuant to Section 0.26 1 of the Commission’s rules on delegated authority,
47 C.F.R. §0.261, and is effective upon release.



                                                                ,1_1


                                    File #5E5TAt 7OZB-?Ji/7

                                    Call Sign rant Date             ‘1
                                    (or other identifier)


                    REQUEST FOR SPECIAL TEMPORARY AUTHORITY

         Comcast Cable Communications Management, LLC (“Comcast”) requests Special
Temporary Authority (“STA”) to operate a previously licensed transmit Ku-band earth station
facility (E930489) for a period of sixty (60) days beginning September 13, 2019. The purpose of
this STA is to authorize interim operation of this facility pending action on a forthcoming license
application for permanent operating authority. As set forth below, FCC approval of this request
will serve the public interest, convenience and necessity.

        Section 25.120(b)(l) of the Commission’s rules provides that STA may be granted upon
a finding of “extraordinary circumstances requiring temporary operations in the public interest
and that a delay in the institution of service would seriously prejudice the public interest.”
Section 25. 120(b)(3) further provides that the Commission may grant STAs for a period of sixty
(60) days without placing the request on public notice where the applicant plans to file a request
for regulatory authority. Comcast submits that the instant request satisfies both rule sections.

        The subject earth station is located at Comcast’s national transmission center in Littleton,
Colorado. Comcast uses the Littleton complex to distribute video programming to its cable
television headends throughout the country, and to otherwise provide support to its various
media operations. Comcast holds many FCC authorizations for earth stations located at the
Littleton complex. In the past year, it has filed timely renewal applications for dozens of earth
station authorizations and also surrendered the authorizations for numerous earth stations. Due
to an accidental administrative error, however, the license for this station expired on December
10, 2018 without a renewal application being filed. This STA application is being filed promptly
after discovery of the inadvertent error.

       No party will be prejudiced by FCC grant of this STA request. The subject station
(which is not being operated) was previously licensed and the transmit frequencies remain
protected in the frequency coordinator’s database. Moreover, a new radiation hazard study has
been completed for this facility (see Attachment A).

        Favorable action on this request will also serve the public interest. As indicated, the
station is being used to distribute video programming to Comcast customers nationwide and will
be operated in accordance with the technical parameters set forth on the station’s most recent
license authorization. Grant of the requested STA will thus simply reinstate the operational
authority of an earth station that has been used by Comcast for many years without prejudice to
any party. Accordingly, Comcast submits that FCC approval of this request for STA is
warranted.




 47 C.f.R. § 25.120(b)(1).


                                 STA Application Amendment

       Comcast Communications Management, LLC (“Comcast”) is seeking a STA to allow it
to resume operations from a previously-licensed facility. The subject station is used to provide
transmission service, on a case-by-case basis (as circumstances require), to Ku-band satellites
included in the following list (each of which is on the approved space station list):

       AMC6
       AMC 15
       AMC 21
       Anik FIR
       AnikF2
       Anikf3
       Arsat 2
       Ciel 2
       EchoStar 9/Galaxy 23
       Eutelsat 113 West A
       Eutelsat 115 West B
       Eutelsat 117 West A
       Eutelsat 117 West B
       Galaxy 3C
       Galaxy 13/Horizons I
       Galaxy 16
       Galaxy 17
       Galaxy 18
       Galaxy 19
       Galaxy 2$
       Intelsat 16
       Intelsat 30
       Intelsat 31
       Nimiq 5
       QuetzSat I
       SES I
       SES 2
       SES 3
       SES 10
       SES 15
       Star One C2
       Star One C3


                                                                                      Exhibit
Radiation Hazard Report                                                               Page 1 of 5


      Analysis of Non-Ionizing Radiation for a 9.1-Meter Earth
                          Station System
This report analyzes the non-ionizing radiation levels for a 9.1-meter earth station system. The
analysis and calculations performed in this report comply with the methods described in the FCC
Office of Engineering and Technology Bulletin, No. 65 first published in 1985 and revised in 1997 in
Edition 97-01. The radiation safety limits used in the analysis are in conformance with the FCC R&D
96-326. Bulletin No. 65 and the FCC R&D specifies that there are two separate tiers of exposure
limits that are dependant on the situation in which the exposure takes place and/or the status of the
individuals who are subject to the exposure. The Maximum Permissible Exposure (MPE) limits for
persons in a General Population/Uncontrolled environment are shown in Table 1. The General
Population/Uncontrolled MPE is a function of transmit frequency and is for an exposure period of
thirty minutes or less. The MPE limits for persons in an Occupational/Controlled environment are
shown in Table 2. The Occupational MPE is a function of transmit frequency and is for an exposure
period of six minutes or less. The purpose of the analysis described in this report is to determine the
power flux density levels of the earth station in the far-field, near-field, transition region, between the
subreflector or feed and main reflector surface, at the main reflector surface, and between the
antenna edge and the ground and to compare these levels to the specified MPEs.

                Table 1. Limits for General Population/Uncontrolled Exposure (MPE)
                    Frequency Range (MHz)          Power Density (mWIcm2)
                            30-300                              0.2
                           300-1500                  Frequency (MHz)*(0.8/1 200)
                         1500-100,000                           1.0

                    Table 2. Limits for Occupational/Controlled Exposure (MPE)
                    Frequency Range (MHz)          Power Density (mW/cm2)
                            30-300                              1.0
                           300-1500                  Frequency (MHz)*(4.0/1200)
                         1500-100,000                           5.0

          Table 3. Formulas and Parameters Used for Determining Power Flux Densities
      Parameter                     Symbol            Formula                 Value          Units
      Antenna_Diameter                  D                Input                  9.1          m
      Antenna Surface Area           Asurface          it_D/_4                65.04          m2
      Subreflector_Diameter            Dsr               Input                121.9          cm
      Area of Subreflector             Asr            7t_Dsr2/4             11674.54         cm2
      Frequency                         F                Input                14250          MHz
      Wavelength                                       300_/_F             0.021053          m
      Transmit_Power                   P                 Input               1500.00         W
      Antenna_Gain_(dBi)              Ges                Input                 60.9          dBi
      Antenna Gain (factor)            G               l0cb0               1230268.8         n/a
      Pi                                              Constant             3.1415927         n/a
      Antenna Efficiency                                                       0.67          n/a


                                                                                    Exhibit
Radiation Hazard Report                                                             Page2 015



1. Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the following equation:

    Distance to the Far Field Region                        Rif = 0.60 D2 I 2                   (1)
                                                                =2360.1 m

The maximum main beam power density in the far field can be determined from the following
equation:

    On-Axis Power Density in the Far Field                  Sif = G P 1(4 t Rff2)               (2)
                                                                = 26.365 W/m2
                                                                = 2.636 mW/cm2

2. Near Field Calculation

Power flux density is considered to be at a maximum value throughout the entire length of the
defined Near Field region. The region is contained within a cylindrical volume having the same
diameter as the antenna. Past the boundary of the Near Field region, the power density from the
antenna decreases linearly with respect to increasing distance.

The distance to the end of the Near Field can be determined from the following equation:

   Extent of the Near Field                                 Rnf     D2 1(4 2.)                  (3)
                                                                  = 983.4 m

The maximum power density in the Near Field can be determined from the following equation:

   Near Field Power Density                                 Snf     16.0 i P / (7t D2)          (4)
                                                                  = 61.547W/m2
                                                                  = 6.155 mW/cm2

3. Transition Region Calculation

The Transition region is located between the Near and Far Field regions. The power density begins
to decrease linearly with increasing distance in the Transition region. While the power density
decreases inversely with distance in the Transition region, the power density decreases inversely
with the square of the distance in the Far Field region. The maximum power density in the Transition
region will not exceed that calculated for the Near Field region. The power density calculated in
Section us the highest power density the antenna can produce in any of the regions away from the
antenna. The power density at a distance R can be determined from the following equation:

   Transition Region Power Density                          St = Sg Rnf I R                     (5)
                                                               = 6.1 55 mW/cm2


                                                                                   Exhibit
Radiation Hazard Report                                                            Page3of5

4. Region between the Main Reflector and the Subreflector

Transmissions from the feed assembly are directed toward the subreflector surface, and are
reflected back toward the main reflector. The most common feed assemblies are waveguide flanges,
horns or subreflectors. The energy between the subreflector and the reflector surfaces can be
calculated by determining the power density at the subreflector surface. This can be determined
from the following equation:

   Power Density at the Subreflector                        S = 4000 P I Asr                   (6)
                                                              = 513.939 mW/cm2

5. Main Reflector Region

The power density in the main reflector is determined in the same manner as the power density at
the subreflector. The area is now the area of the main reflector aperture and can be determined from
the following equation:

   Power Density at the Main Reflector Surface          Ssurace = 4 P / Asurface               (7)
                                                                = 92.253 W/m2
                                                                = 9.225 mW/cm2


6. Region between the Main Reflector and the Ground

Assuming uniform illumination of the reflector surface, the power density between the antenna and
the ground can be determined from the following equation:

   Power Density between Reflector and Ground               Sg = P / Asurface                  (8)
                                                               = 23.063 W/m2
                                                               = 2.306 mW/cm2


                                                                                    Exhibit
Radiation Hazard Report                                                             Page4of5

7. Summary of Calculations

           Table 4. Summary of Expected Radiation levels for Uncontrolled Environment
                                            Calculated Maximum
                                          Radiation Power Density                Hazard
 Region                                         Level (mWicm2)                Assessment
 1. Far Field (Rif = 2360.1 m)                              2.636            Potential Hazard
 2. Near Field (Rnf = 983.4 m)                  Snf         6.155            Potential Hazard
 3. Transition Region (Rnf < R < Rif)           St          6.155            Potential Hazard
 4. Between Main Reflector and                  Ssr      513.939             Potential Hazard
     Subreflector
 5. Main Reflector                              Ssurtace    9.225            Potential Hazard
 6. Between Main Reflector and Ground           Sg          2.306            Potential Hazard

             Table 5. Summary of Expected Radiation levels for Controlled Environment
                                            Calculated Maximum
                                           Radiation Power Density
 Region                                        Level (mWIcm2)              Hazard Assessment
 1. Far Field (Rif = 2360.1 m)                   S          2.636           Satisfies FCC MPE
 2. Near Field (Rnf = 983.4 m)                              6.155            Potential Hazard
 3. Transition Region (Rnf < R < Ri)             St         6.155            Potential Hazard
 4. Between Main Reflector and                   S.       513.939            Potential Hazard
     Subreflector
 5. Main Reflector                               Ssurface   9.225            Potential Hazard
 6. Between Main Reflector and Ground            Sg         2.306           Satisfies FCC MPE

It is the applicant’s responsibility to ensure that the public and operational personnel are not exposed
to harmful levels of radiation.



8. Conclusions

Based on the above analysis it is concluded that the FCC MPE guidelines have been exceeded (or
met) in the regions of Table 4 and 5. The applicant proposes to comply with the MPE limits by one
or more of the following methods.

Radiation hazard signs will be posted while this earth station is in operation.

Due to the remote and secure location of the proposed earth station antenna at the Douglas
Teleport, the area of operation around the antenna will be limited to those that have knowledge of
the potential for radiation exposure. The applicant will ensure that no buildings or other obstacles
will be in the areas that exceed the MPE levels.


                                                                                      Exhibit
Radiation Hazard Report                                                               Page 5 015

Means of Compliance Controlled Areas

The earth station’s operational staff will not have access to the areas that exceed the MPE levels
while the earth station is in operation.

The transmitters will be turned off during antenna maintenance

The applicant agrees to abide by the conditions specified in Condition 5208 provided below:

       Condition 5208 The licensee shall take all necessary measures to ensure that the
                       -




       antenna does not create potential exposure ofhumans to radiofrequency radiation
       in excess ofthe FCC exposure limits defined in 47 CFR 1.1307(b) and 1.1310
       wherever such exposures might occur. Measures must be taken to ensure
       compliance with limits for both occupational/controlled exposure andfor general
       population/uncontrolled exposure, as defined in these rule sections. Compliance
       can be accomplished in most cases by appropriate restrictions such as fencing.
       Requirements for restrictions can be determined by predictions based on
       calculations, modeling or by field measurements. The FCC’s OET Bulletin 65
       (available on-line at www.fcc.gov/oet/rfsafety) provides information on predicting
       exposure levels and on methods for ensuring compliance, including the use of
       warning and alerting signs and protective equipmentfor worker.


I HEREBY CERTIFY THAT I AM THE TECHNICALLY QUALIFIED PERSON RESPONSIBLE FOR THE
PREPARATION OF THE RADIATION HAZARD REPORT, AND THAT IT IS COMPLETE AND CORRECT
TO THE BEST OF MY KNOWLEDGE AND BELIEF.




BY:

Gary K. Edwards
Senior Manager
COMSEARCH
19700 Janelia Farm Boulevard
Ashburn, VA 20147


DATED: August 27, 2019



Document Created: 2019-10-05 01:19:02
Document Modified: 2019-10-05 01:19:02

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