Attachment STA Justification

This document pretains to SES-STA-INTR2019-01173 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201901173_1663440

                                      COMSAT, Inc.

                    Request for Special Temporary Authority to
             Operate Santa Paula Teleport 12.8 Meter Hub Antenna to
         Communicate With Inmarsat 3F2 Satellite Using L-band Frequencies to
            Support Inmarsat Testing During Westward Drift of Satellite

                            File Number SES-MOD-20151009-00695
                                     Call Sign KB34

         COMSAT, Inc. (“COMSAT”) respectfully requests a grant of Special Temporary
Authority (“STA”) effective May 1, 2019 to allow COMSAT to operate its Santa Paula,
California Teleport 12.8 Meter Hub Antenna (SAPA 12.8M) to communicate with the
Inmarsat 3F2 Satellite (I3F2) using L-band Frequencies to support Inmarsat testing
during westward drift of I3F2. Prior to commencement of the drift that is being
accomplished by Inmarsat to reposition I3F2 it was located at 15.5 west longitude and
was authorized by the Commission for U.S. Market Access and was on the ISAT list.
Inmarsat is now in the process of drifting the satellite west and has contracted with
COMSAT to support testing of the satellite during part of the drift arc – that part being
from 60W to 170E Inmarsat has advised COMSAT that the final location of 3F2 has
not been decided at this time and that Inmarsat does not plan to seek U.S. Market Access
in relation to 3F2 at its new position. This STA is therefore only for limited testing
purposes during the drift.

     The STA that is needed for this purpose is to operate the SAPA12.8M antenna to
communicate with I3F2 during its drift utilizing the following Emissions-

#            Frequency Polarization Emission Tx/Rx Max      Max     Modulation
             (MHz)                                 EIRP EIRP
                                                   /Carrier Density
                                                   (dBW) (dBW/4kHz)

Pilot            1638.900     RHC         N0N         T       33          33            Pilot
Test Carrier 1   1639.180     RHC         10KG1E      T       42          38            PSK
Test Carrier 2   1639.220     RHC         10KG1E      T       42          38            PSK
Test Carrier 3   1537.290     RHC         05KG1E      R                                 PSK
Test Carrier 4   1537.295     RHC         05KG1E      R                                 PSK

          The SAPA 12.8M antenna is currently authorized per COMSAT’s KB34 license
to communicate in the L-band with ISAT list satellites and the power levels and other
particulars needed for the testing will be well within authorized levels. Grant of the STA
for the testing is in the public interest because Inmarsat services supported by I3 satellites
include maritime services used for Safety at Sea as well as services used by various U.S.
agencies. It is therefore respectfully requested that STA as described above be granted
for a period of 30 days, effective May 1, 2019.


       .

      Any questions with respect to this matter may be directed to James G. Lovelace at
571-599-3643.



Document Created: 2019-04-23 16:38:15
Document Modified: 2019-04-23 16:38:15

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