- 7. Temporary Orbit Location
- NGSO
- 8. City
- Jacksonville
- 9. State
- NM
- 10. Requested Duration (not to exceed 180 days)
- 30
- 11. Latitude (dd mm ss.s h)
- 35 8 19.0 N
- 12. Longitude (dd mm ss.s h)
- 106 35 39.60 W
- 13. Description
- EX PARTE NARRATIVE IN SUPPORT OF APPLICATION FOR SPECIAL TEMPORARY AUTHORITY Applicant: Parsons Corporation Location: Albuquerque, NM (Site-ID: PAFR) Antenna: Raven Defense 6-meter parabolic, Transmit/Receive S-band Term: 30 days (May 6 – June 5, 2026) Companion: SES-STA-20250825-00592 (SES-STA-20250825-00592 did not show up to select when filling out this form as related STA) (STPSat-7 / Site-ID ROOST / Call Sign E230134) I. Overview Parsons Corporation hereby requests a 30-day Special Temporary Authority (STA) under 47 C.F.R. § 25.120 to operate a second, physically identical 6-meter Raven Defense earth station antenna (designated PAFR) at its Albuquerque, New Mexico facility. The PAFR antenna is co-located with the currently-authorized ROOST antenna — the subject of SES-STA-20250825-00592 (Call Sign E230134) — and is situated less than 100 meters (well under one arc-second of latitude/longitude) from ROOST. PAFR will operate with RF parameters identical to those authorized for ROOST under the parent STA, including the grant-as-issued bandwidth conditions established following NTIA coordination. II. Commission Staff Guidance Prior to filing, Parsons sought and received written guidance from the FCC Space Bureau concerning the proper filing construct. Staff advised on 23 April 2026 (J. Gallinate) that (1) no vehicle exists to modify an existing STA; a new, separate STA is required for the additional antenna; (2) reuse of the existing §25.203 coordination study and OET-65 RADHAZ analysis is appropriate given the identical antenna and identical parameters; and (3) the ROOST and PAFR STAs may be consolidated into a single authorization at the time either is renewed. Staff further clarified on 24 April 2026 that 30-day STAs do not require placement on Public Notice under §25.120, and that each 30-day STA must be renewed as a fresh filing rather than extended. Parsons intends to file this and four additional 30-day STAs on a rolling basis through October 3, 2026, at which point Parsons will file a consolidated 180-day STA combining both ROOST and PAFR under a single authorization. III. Public Interest Justification PAFR is required to support mission-continuity operations for the active STPSat-7 mission, a U.S. Government experimental satellite under the DoD Space Test Program. Operational redundancy between ROOST and PAFR provides resilience against single-antenna unavailability due to maintenance, weather, or equipment fault, preserving continuity of command, control, and telemetry services for on-orbit assets. While convenience to the applicant alone would not support an STA under §25.120(b)(1), the mission-continuity benefit to ongoing U.S. Government satellite operations constitutes the public-interest basis required by the rule. Extraordinary circumstances include the compressed operational timeline of the supported mission and the need to stand up redundant ground segment capability without interrupting ongoing operations. IV. Technical Identity with ROOST PAFR is physically and electrically identical to ROOST: • Same manufacturer and model: Raven Defense 6-meter parabolic reflector • Same antenna gain: 36.3 dBi at 2109.75 MHz uplink; 40.4 dBi at 2277.9 MHz downlink • Same centerline above ground level: 3.66 m • Same mount configuration: X-Y full-motion, 6°/sec maximum slew, autotrack • Same uplink RF envelope: 2109.75 MHz center, 72K0G1D emission (72 kHz bandwidth), 7.2 dBW/4 kHz max RF power, 57.3 dBW on-axis EIRP, BPSK, RHCP • Same downlink RF envelope: 2277.9 MHz center, 1.5 MHz received bandwidth (per grant Condition 6), OQPSK, RHCP, Convolutional 1/2 + Reed-Solomon (255, 223) FEC • Same point of communication: STPSat-7 (Call Sign E230134, 500 km / 60° inclination LEO) • Same minimum elevation mask: 5° per STA condition PAFR is located less than 100 meters from ROOST — below the one arc-second of latitude/longitude threshold (~101 feet) used by the frequency coordinator to determine coordination reuse eligibility. V. Coordination and RADHAZ Reuse Comsearch (Gary Edwards, Satellite Manager), the frequency coordinator that conducted the §25.203 coordination study for ROOST (Job Number 250919COMSGE02) and issued the March 2026 extension (Job Number 260327COMSGE13), confirmed in writing on 21 April 2026 that Parsons may rely on the existing coordination study and the existing OET-65 radiation hazard (RADHAZ) analysis for PAFR operations. The reuse basis is that (1) PAFR operates with identical parameters to ROOST, and (2) PAFR is within one second of latitude/longitude of ROOST (approximately 101 feet / 31 meters). The existing §25.203 coordination established a 215-kilometer coordination distance contour around Albuquerque with interference objectives of -154.0 dBW/4 kHz (long term, 20%) and -131.0 dBW/4 kHz (short term, 0.0025%). These contours and interference objectives apply identically to PAFR. The existing OET-65 RADHAZ analysis — computing a far-field start of 151.8 meters, a near-field extent of 63.3 meters, and a transition-region maximum power density of 7.368 mW/cm² — remains valid for PAFR. The Comsearch confirmation email is attached. VI. No Aggregate Interference Increase Grant of this STA will not increase the aggregate interference environment around Albuquerque beyond what the Commission already authorized under SES-STA-20250825-00592. PAFR and ROOST will not operate simultaneously on the STPSat-7 uplink with overlapping transmissions such that combined EIRP would exceed the authorized envelope; operational scheduling ensures only one antenna transmits per pass. Aggregate power flux density at the Commission's coordination contour boundary, therefore, remains bounded by the limits already coordinated. Parsons will continue to comply with all conditions of the parent STA, including the 5° elevation TX inhibit, SBE coordination requirement for the 2025-2110 MHz uplink band, and the 1.5 MHz received downlink bandwidth cap established through NTIA coordination. VII. Term, Renewal, and Consolidation Intent Parsons requests a term of 30 days for this STA pursuant to Commission staff guidance that 30-day STAs are not placed on Public Notice under §25.120. Parsons intends to file consecutive 30-day renewal STAs monthly through October 3, 2026, at which point Parsons will file a consolidated 180-day STA combining both ROOST (currently SES-STA-20250825-00592) and PAFR under a single authorization. If the supported mission concludes before any term expires, Parsons will promptly notify the Commission and surrender the STA. Parsons is not seeking permanent Part 25 authorization for this facility at this time. VIII. Attachments • Comsearch coordination reuse confirmation (Gary Edwards, 21 April 2026) • Existing §25.203 frequency coordination study — Albuquerque_Extension_ClientLetter_STPsat7 (Comsearch Job 250919COMSGE02 + extension 260327COMSGE13) • Existing OET-65 RADHAZ analysis — Parsons Frequency Coordination & RADHAZ Summary (Albuquerque, NM) • Parent STA file: SES-STA-20250825-00592 (accessible to Space Bureau staff via ICFS) IX. 24/7 Point of Contact for Interference Cessation • Joseph Miller, Strategic Space & Ground Communications Lead — +1 619.788.4967 / Joseph.Miller@Parsons.us • Joshua Morrison, Operations Lead — +1 808.256.3064 / Joshua.Morrison@Parsons.us X. Conclusion and Request for Expedited Processing For the reasons stated above, and in reliance on Commission staff guidance of 23-24 April 2026, Parsons respectfully requests that the Commission grant this 30-day Special Temporary Authority for PAFR operations at Albuquerque, NM. Parsons requests expedited processing, given the mission-continuity basis for the filing and the reuse of fully-developed coordination and RADHAZ records already on file with the Commission. Respectfully submitted, Joseph Miller Strategic Space & Ground Communications Lead Parsons Corporation Joseph.Miller@Parsons.us | +1 619.788.4967
- 14. Is the Applicant filing an optional Schedule B with this application?
- No