Final Narrative Statement

0158-EX-ST-2012 Text Documents

Intelsat License LLC

2012-03-07ELS_123757

Request for Experimental Special Temporary Authority Intelsat License LLC NARRATIVE DESCRIPTION AND PUBLIC INTEREST STATEMENT Ground Testing of KuStream Terminal File No. 0158-EX-ST-2012 Intelsat License LLC (“Intelsat”) seeks experimental special temporary authority (“STA”) for ground testing of a vehicle-mounted earth station (“VMES”) terminal to demonstrate the functionality of the terminal with the Intelsat network to a U.S. Government customer. Intelsat seeks to commence operations no later than March 15, 2012 for a period of 30 days. I. INTRODUCTION Intelsat, a leading satellite service provider, is demonstrating Ku-band mobile VSAT connectivity using its Fixed-Satellite Service (“FSS”) network. The demonstration involves temporary operation of a vehicle-mounted terminal in the 14.0-14.5 GHz band (transmit) and 11.7-12.2 GHz band (receive). The terminal – the TECOM KuStream 1500 – is designed for aeronautical applications but is being demonstrated in the land mobile context. Adjacent FSS satellites will be protected from harmful interference by limiting the off- axis EIRP spectral density along the GSO arc to no more than the levels permitted for routinely licensed Ku-band VSAT terminals and VMES terminals. Intelsat’s temporary operations, which are also limited in geographic scope, will not impact other users of the Ku-band (including U.S. Government radio astronomy and space services). There is ample precedent for granting Intelsat an experimental STA to perform this testing based on prior authority for experimental operations granted to Boeing (Call Sign WC2XVE), ARINC (Call Sign WC2XPE), Hughes Network Systems (Call Sign WE2XEW), -1-

Request for Experimental Special Temporary Authority Intelsat License LLC Panasonic Avionics (Call Sign WD9XQT) and others. In fact, the KuStream terminals manufactured by TECOM/Qest have been previously licensed to operate on both an experimental and commercial basis by the Commission. For more information on the KuStream terminal, see www.kustream.com. II. DESCRIPTION OF PROPOSED EXPERIMENTAL OPERATIONS Intelsat seeks to demonstrate the TECOM KuStream 1500 terminal on a stationary and in-motion vehicle. Intelsat seeks to conduct ground testing for a 30-day period commencing no later than March 15, 2012. The demonstration will be confined to a 50-mile radius around coordinates 35º 09’ 47” N, 79º 00’ 15” W near Fayetteville, North Carolina. Intelsat recognizes and accepts that any experimental STA will be conditioned upon non-interference and protection of co-frequency operations, including Ku-band FSS operations and U.S. Government radio astronomy and space services. The general objectives of the testing to be carried out under this experimental STA include: (i) integrating and testing of the KuStream 1500 terminal in the Intelsat network; (ii) demonstrating two-way data service using a mobile platform; (iii) validating the predicted performance of the system; and (iv) demonstrating that the system meets the established interference requirements for Ku-band mobile VSAT systems. This testing will be very limited in duration (several days of testing over the 30-day STA period). In all cases, the terminal will operate in selected test conditions in a dedicated manner under close control of Intelsat’s network control personnel. A. The KuStream 1500 Terminal The KuStream 1500 terminal, manufactured by TECOM/Qest, is a government version of the KuStream terminal that has been previously authorized by the Commission for both -2-

Request for Experimental Special Temporary Authority Intelsat License LLC experimental and commercial operations. For example, the TECOM terminal was authorized for aeronautical experimental operations by Row 44, Inc. in 2009 (File No. 0236-EX-PL-2009, Call Sign WF2XBY), and for commercial operations in 2010 (File No. SES-MOD-20091021-01342, Call Sign E080100). The material operating parameters of the KuStream antenna are well-known to the Commission, including: o 0.2º pointing accuracy; automatic muting within 100ms if pointing offset exceeds 0.5º and transmissions do not resume until pointing accuracy is within 0.2º; o Compliance with Section 25.209 antenna gain pattern through 35º skew angle (the terminal automatically mutes transmissions at skew angles greater than 35º); and o Compliance with Section 25.222 and 25.226 off-axis EIRP levels (i.e., VSAT routine licensing levels applicable to Ku-band ESV and VMES operations). Thus, the KuStream antenna complies fully with the Commission’s two-degree spacing policies and VMES rules designed to protect co-frequency operations from harmful interference. Charts are provided below showing the gain of the KuStream 1500. Section 25.209 gain patterns and off-axis EIRP levels are provided below and confirm applicable limits are met for co-polarization and cross-polarization for all operating scenarios. -3-

KuStream 1500 Gain Co—polarization, GEO Plane o Full Azimuth: +/— 180 Degrees —Stew=0 Dog. & —stew=35 bog. L ——FCC25.20% GEO Plane Gain Gain (aBi) w mt saso aso 420 90 so 30 0 30 so so 120 150 180 Asimuth Angle {degree}

KuStream 1500 Gain Co—polarization, GEO Plane Close in: +/— 15 Degrees Azimuth —Stew=0 ber. fN |Eerelomeeose —Stew=25 beg. 22) \ \ Gain (aBi) C S SA Y 4 0 3 6 9 12 15 Asimuth Angle {degree)

Request for Experimental Special Temporary Authority Intelsat License LLC The terminal will be configured to not transmit more than 44 dBW EIRP (This translates into a an ERP of 15,310 W and a transmit power of 17.35 W). This power limitation is implemented as part of the commissioning procedure of the terminal. The terminal includes an iDirect modem which will be set with an appropriate maximum Tx IF level to ensure that 44 dBW EIRP is not exceeded. In addition, the terminal and space segment will operate in single carrier mode (i.e., there will be a single hub-to-terminal carrier and a single terminal-to-hub carrier) . Below are charts showing the off-axis power spectral density of the carrier transmitted from the KuStream 1500 terminal. -6-

KuStream 1500 Power Spectral Density Co—polarization, GEO Plane 44 dBW Tx EIRP over 4.992 MHz Full Azimuth:+/— 180 Degrees ® |___L _ 10 —Stew=0 Deg. a —Stew=35 Deg. 0 —rcc25225 Geo Plane Power Spectral Density {dBW/Aktt2) &s wl w & [— wfi _ (JW\{ HT z.1 2 } saso aso 420 90 30 0 30 so 120 150 180 Asimuth Angle {degree}

KuStream1500 Power Spectral Density Co—polarization, GEO Plane 44 dBW Tx EIRP over 4.992 MHz Close in: +/— 15 DegreesAzimuth 20 10 m t ——i—{a/ lW Power Spectral Density {dBW/Aktt2) Wik L /\/A”( ~ I 3 s 12 is Asimuth Angle {degree)

Request for Experimental Special Temporary Authority Intelsat License LLC Intelsat has included a Radiation Hazard study as Attachment A. B. Satellite Points of Communications Intelsat will utilize commercial FSS satellite capacity to conduct its experimental operations. Specifically, the antenna will communicate with Intelsat’s Galaxy 25 satellite at 93.1ºW.L. and Intelsat’s Galaxy 19 satellite at 97.0º W.L.. The operations proposed herein will be in compliance with the off-axis EIRP limits set forth in the Commission’s VMES rules. Example link budget analyses are below. -9-

Request for Experimental Special Temporary Authority Intelsat License LLC Galaxy 25 – Forward and Return Carriers Customer Support Engineering & Capacity Management Satellite and Role: G-25 @ 93.10°W Total lease resource [MHz]: 27.0 Link Budget Report for: TECOM Demo Transponder: KH07/KV07 (NAKH/NAKV) Total D/L EIRP Avail. at be/bp [dBW]: 36.1 / 47.1 Platform bias: -0.52°E; 0.00°N Total D/L EIRP Used at be/bp [dBW]: 34.4 / 45.4 Opportunity-ID / SSR-ID Sat. TWT Power [Watts]: 100.0 Total BW Used [MHz]: 23.5 Done by: bauerf Date: 21 Jan 2012 Sat. D/L EIRP at be/bp [dBW]: 39.9 / 50.9 Xp Operational Mode: Multi-Carrier OBO= -3.8 dB SFD at be/bp [dBW/m2]: -80.5 / -87.4 Application: STRIP7 v3.9 Operational Band Up/Dw [MHz]: (14154 - 14181) / (11854 - 11881) Polarization Up/Dw: H/V Diameter Gtx G/T Latitude Longitude Xpol TOTAL HPA Antennas Location (Nearest City and Country) Notes [m] [dBi] [dB/K] [°N] [°E] [dB] Power [W] MTN-K11 11.0 62.0 38.7 39.70 282.27 30.0 MTN-K11 - United States 1.8 TECOM 0.44 33.0 11.8 35.16 280.75 26.0 Fayetteville - UNITED STATES 16.3 Per Carrier Link Parameters and Results Noise Space Alloc. b.e. D/L C/N Clear Sky Eb/No Clear Sky Link U/L HPA HPA Gx Tx E/S Rx E/S Carrier Type PEB WGL UPC BW Factor BW EIRP thresh. C/N thresh. Eb/No Availab. EIRP size OBO apprvl #, Type, [I.R, OH, FEC, RS, modulation] [MHz] (Roll-off) [MHz] [MHz] [dBW] [dB] [dB] [dB] [dB] [%/yr] [dBW] (Watt) [dB] [dB] [dB] MTN-K11 TECOM DIG (6.221 Mbps, OH=0.0%, 0.3059 FEC, QPSK) 10.168 1.20 12.203 18.075 34.4 0.2 6.3 2.3 8.4 99.93 64.6 1.8 0.0 0.0 0.0 n/a TECOM MTN-K11 Spread (1.040 Mbps, OH=0.0%, 1/2 FEC, BPSK) 4.160 1.20 4.992 0.136 13.1 -3.2 -0.6 2.8 5.4 99.95 44.0 12.6 0.0 0.0 0.0 No TOTAL: 2 Carriers 17.195 18.211 34.4 ISCO comments: Antenna pattern comments: Clear Sky C/N includes 1.5 dB additional margin for terrestrial interference, antenna mis-pointing Notes: Eb/No includes 0.4 dB IF-RF degradation. * Analysis results based on today's operational levels of interference. Results are not guaranteed due to possible fluctuations in operational interferences over time. - 10 -

Request for Experimental Special Temporary Authority Intelsat License LLC - 11 -

Request for Experimental Special Temporary Authority Intelsat License LLC - 12 -

Request for Experimental Special Temporary Authority Intelsat License LLC III. PROTECTION OF OTHER USERS IN THE 14.0–14.5 GHZ BAND Protection of Fixed-Satellite Service. Intelsat will comply with the Commission’s VMES rules set forth in 47 C.F.R. § 25.226. Thus, the terminal will operate in such a manner that the off-axis EIRP levels are no greater than the levels produced by a routinely licensed VSAT earth station. To the extent that any adjacent satellite operator experiences unacceptable interference from Intelsat’s experimental operations, Intelsat will cease terminal transmissions immediately. Protection of Potential NGSO FSS Systems. Intelsat acknowledges that non- geostationary orbit (“NGSO”) systems are also permitted to operate in the Ku-band. However, no such systems are currently authorized or plan to operate within the period contemplated for the proposed experimental operations. Protection of Terrestrial Radio Services. Intelsat has examined current spectrum use in the 14.0-14.5 GHz band and has determined that there are no active FCC-licensed terrestrial services in this band in North America with which its proposed operations could conflict. Protection of the Radio Astronomy Service. Given the time and geographic limitations on the proposed operations, there is no potential for interference into US Government radio astronomy sites. However, Intelsat nonetheless agrees to comply with exclusion zones designed to protect such radio astronomy sites set forth in Section 25.226(d). Protection of Space Research Service. Intelsat recognizes the utilization of the frequency band from 14.0-14.05 GHz and the possible use of the band from 14.05-14.2 GHz allocated to the National Aeronautics and Space Administration (“NASA”) Tracking and Data Relay Satellite System (“TDRSS”) for space research conducted at White Sands, New Mexico and Blossom - 13 -

Request for Experimental Special Temporary Authority Intelsat License LLC Point, Maryland. For purposes of this experimental STA application and consistent with Section 25.226(c), Intelsat will avoid AES operation within line-of-sight vicinity of these earth stations. IV. SUPERVISION AND CONTROL For purposes of these experiments, the Intelsat terminal will be operated under Intelsat’s full supervision and control. The point of contact for the planned experimental operations is: Christopher M. Hudson (cell) +1-202-352-1272 chris.hudson@intelsatgeneral.com ISOC – Intelsat Secure Operating Center +1 (404) 381-2727 ISOC@intelsatgeneral.com This contact will have access to all network functions, and will have the ability and authority to cease all transmissions from the terminals wherever they are located. VIII. CONCLUSION Grant of this experimental STA will allow Intelsat to further develop and demonstrate the mobile VSAT technologies for US government customers. The subject terminal has been designed to protect other uses in the Ku-band from interference and will comply with FCC rules and policies to protect co-frequency users of the Ku-band. Because there is ample precedent for granting this experimental STA and it is plainly in the public interest to do so, Intelsat respectfully requests grant at the earliest practicable time. - 14 -


Document Created: 2012-03-07 11:56:33
Document Modified: 2012-03-07 11:56:33
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