Narrative

0607-EX-ST-2018 Text Documents

Thales Avionics, Inc.

2018-04-05ELS_207554

                        Thales Avionics, Inc.
              Request for Special Temporary Authority
                                 for
    Thales Advanced Connectivity Terminal, Ka-band (ACT-A) ESAA

Applicant Description
Thales Avionics, Inc. with its InFlyt Experience operations in Melbourne and Orlando, FL and
Irvine, CA is a global leader in providing leading-edge, connected inflight entertainment systems
and services, including high-speed Internet connectivity, to commercial airlines worldwide.
Thales is currently developing and will be testing a new Advanced Connectivity Terminal, Ka-
band (ACT-A) that is a key component of Thales’s end-to-end inflight connectivity (IFC) service
offerings to commercial airlines. Thales’s IFC service using the ACT-A will enable airlines to meet
the increasing demands of passengers’ inflight connectivity needs and provide access to critical,
real-time inflight data to improve airline operational efficiencies.

Thales Avionics has an active blanket license authorization1 to operate ESAA called Modular
Connectivity Terminals, Ka-band (MCT-A) with four FCC-authorized GSO satellites whose Ka-
band spot beam coverage areas include CONUS, most of Canada, and portions of Mexico and
the Caribbean region. The four points of communication are: AMC-15 (S2180) at 105.0° W.L.,
AMC-16 (S2181) at 85.0° W.L., EchostarXVII (S2753) at 107.1° W.L., and Jupiter 2 (S2834) at
97.1° W.L.

Thales is currently preparing, and will submit shortly to the FCC, an application seeking
modification to its blanket authorization to add the ACT-A terminal.

STA Request
While Thales’s license modification application, filing, and processing are ongoing, Thales seeks
STA to allow developmental and performance testing of up to four (4) ACT-A terminals. The ACT-
A ESAA will communicate in the conventional Ka-band with the aforementioned points of
communication, using the spectrum shown in the following table2:

Point of Communication        Satellite     GSO Orbital         Transmit Spectrum          Receive Spectrum
       (Call Sign)            Operator     Location (W.L.)           (MHz)                      (MHz)
Echostar XVII (Jupiter-1)                                                                   18300 – 19300
                               Hughes           107.1°             29300 – 30000
         (S2753)                                                                            19700 – 20200
                                                                                            18300 – 19300
     Jupiter-2 (S2968)         Hughes            97.1°             29300 – 30000
                                                                                            19700 – 20200
                                                                   28438 – 28563            18638 – 18763
      AMC-15 (S2180)              SES           105.0°
                                                                   29500 – 30000            19700 – 20200
                                                                   28438 – 28563            18638 – 18763
      AMC-16 (S2181)              SES            85.0°
                                                                   29500 – 30000            19700 – 20200

1
 See Call Sign E170068, File No. SES-LIC-20170217-00183, granted July 7, 2017.
2
 The points of communication and spectrum in this STA request are identical to those authorized in
Thales’s active ESAA blanket license referenced in Footnote 1.


Thales expects ACT-A testing to commence on or about May 1, 2018 and continue for a period
of 180 days. Grant of the requested STA will allow Thales to improve and expand its overall IFC
service offerings to its airline customers by improving end-user experience with higher
throughput rates, and allowing Thales to offer services to airlines with trans-equatorial flight
routes, where high skew angle conditions prevent two-axis, flat panel ESAA operations.

Description of Testing
Mobile testing will be performed throughout CONUS with the ACT-A terminal installed on a
leased test aircraft and Thales mobile test van. This will allow Thales to verify and optimize
terminal performance while it is operating in a wide range of skew angles, elevation angles, and
link conditions.

A high-level diagram Thales’s IFC network architecture to be used for testing the ACT-A terminal
is shown below:




Thales intends to test the ACT-A in CONUS and its territorial waters only; no testing will be
conducted in Canada, Mexico, the Caribbean, or over any international waters. The area of
testing is shown below, within the red line.


The ACT-A will transmit return channel carriers to the satellites using OQPSK modulation. Return
channel symbol rates will range from 1.024 Msps to 8.192 Msps, using code rates between ½
and 9/10. Spectral spreading may also be used at rates of 2x and 4x. During all testing the ACT-A
will remain compliant with the EIRP spectral density limits defined in §25.138, as detailed later
in this request.

Forward channel performance and information rates transmitted to and received by the ACT-A
will be characterized and optimized during testing. The forward channels use the DVB-S2
standard, have a symbol rate of 47 Msps, and use QPSK and 8PSK modulation with code rates
between ¼ and 9/10.

Flight Testing
Flight test will be conducted with the ACT-A installed on a test aircraft (expected to be a
Gulfstream G3 as of the time of this request). The test aircraft will fly several flight routes
throughout CONUS that will enable the ACT-A to make intrasatellite beam-to-beam handovers,
as well as intersatellite beam handovers.


The expected flight routes as of the time of this request are as follows:




                                   Buffalo, NY to Melbourne, FL


Regional Florida


Seattle, WA to Buffalo, NY


A block diagram of the ACT-A architecture onboard the test aircraft is shown below:




Mobile Van Testing
Thales will conduct ground mobile testing throughout CONUS utilizing the ACT-A installed on the
roof of Thales’s ESAA test van.


A block diagram of the ACT-A architecture installed on the test van is shown below:




System Description
The Thales ACT-A terminal consists of:

    -   ThinKom Ka2517 Antenna
    -   RF/IF Unit (KRFU)
    -   Antenna Control Unit (KANDU)
    -   Thales Modem Manager (TMM)

The ThinKom Ka2517 antenna is an array of 2 flat circular apertures, one for transmitting Ka-
band signals and one for receiving, as shown in the pictures below:


Each aperture is made up of concentric, motorized rotating plates that steer the beams, and the
apertures transmit and receive circularly polarized signals (switchable). A low-noise block
converter (LNB) is located in the antenna unit, directly below the receive aperture.

The KRFU unit houses an IF-to-RF upconverter and a 50-watt solid-state power amplifier (SSPA).

The KANDU is the antenna control unit. It processes information it receives from the aircraft
inertial navigation system (INS) and manages the exchange of the OpenAMIP discrete messages
used for antenna pointing and tracking, transmit power control, and transmit muting/unmuting.

The TMM hosts the Hughes Jupiter aeronautical modem and terminal management functions of
the ACT-A. In the forward channel direction (ground-to-aircraft), the modman demodulates the
received IF signal it receives from the KANDU, and forwards IP packets via Ethernet to the on-
board IFC system. In the return channel direction (aircraft-to-ground), user IP data from test PCs
is encapsulated by software and proprietary firmware, then coded and modulated on an IF
carrier, which is passed to the KRFU.

Antenna Pointing System Description
The ACT-A employs both closed-loop and open-loop pointing control to maintain a pointing
accuracy of ≤ 0.2°.

The closed-loop pointing system uses INS information, data from gyroscopes located on the
antenna, and sensor data from a received signal strength detector. A receive beam conical scan
algorithm removes gyro drift to maintain antenna line-of-sight (LOS) stabilization, to keep the
apertures peaked on the target satellite. The transmit antenna LOS, which is tightly calibrated to
the receive antenna, is locked to the nominal center of the receive antenna conscan.


The electronics and software that monitor and control sensors and actuators update at a rate
that allows detection and action to mute the transmitter within 100 milliseconds when required.
This system also contains a frequency-tracking beacon receiver and can utilize Eb/N0 feedback
from the modem to optimize operation in a high adjacent satellite interference (ASI)
environment.

Protection of Other Services

Off-Axis Emissions

The ACT-A AES testing will operate at EIRP spectral densities which comply with FCC
§25.138(a)(1). Operations within CONUS and its territorial waters will require elevation and
skew angles which provide off-axis emissions below the mask. The worst emissions, PSDs, and
maximum EIRPs are summarized below:

                                 Gain       EIRP
                                  at      Spectral      RF
              Emission EIRP      EIRP      Density    Power      ERP   ERP
             (Msym/s) (dBW) (dBi) (dBW/MHz) (Watts) (dBW) (kW)
               8.190    49.5     36.5      40.327     19.77     47.31 53.83
               6.144    48.2     36.5      40.325     14.83     46.06 40.36
                     Summary of Test Emissions and Power Requirements

The following charts show that the operation of the ACT-A terminal will comply with §25.138(a)
EIRP spectral density masks.




 ACT-A AES terminal RHCP co-polarized 29.5 GHz off-axis emissions, +/- 50°. Worst case ESD is
 40.3 dBW/MHz. All sidelobes fall under §25.138(a)(1) mask. The above example considers an
                      8.19 MSym/s carrier with an EIRP of 49.46 dBW.


  ACT-A AES terminal RHCP co-polarized 29.5 GHz emissions, +/- 10 degrees. All sidelobes fall
                              under the §25.138(a)(1) mask.

Radiation Hazard Study
Included as Attachment A is a radiation hazard study. Thales will ensure that all testing will
protect the general public and all trained personnel working on or around the terminal.

Points of Contact
In case of any inadvertent reported interference, Thales will cease ACT-A transmissions as soon
as possible upon notification to Thales’s 24/7 points of contact:

    1) Martin Matura
       phone: 321-292-0878
       email: martin.matura@us.thalesgroup.com

    2) Thales Network Operations Center (NOC)
       phone: 949-754-6985


Attachment A – Radiation Hazard Study


                                    Radiation Hazard Analysis

                                       Thales Avionics, Inc

                                      ThinKom AES Antenna



This analysis predicts the radiation levels around a proposed earth station terminal, comprised
of one array type antenna. This report is developed in accordance with the prediction methods
contained in OET Bulletin No. 65, Evaluating Compliance with FCC Guidelines for Human
Exposure to Radio Frequency Electromagnetic Fields, Edition 97-01, pp 26-30. The maximum
level of non-ionizing radiation to which personnel may be exposed is limited to a power density
level of 5 milliwatts per square centimeter (5 mW/cm2) averaged over any 6 minute period in a
controlled environment and the maximum level of non-ionizing radiation to which the general
public is exposed is limited to a power density level of 1 milliwatt per square centimeter (1
mW/cm2) averaged over any 30 minute period in a uncontrolled environment. Note that the
worse-case radiation hazards exist along the beam axis. Under normal circumstances, it is highly
unlikely that the antenna axis will be aligned with any occupied area since that would represent
a blockage to the desired signals, thus rendering the link unusable and disabling the transmitter.

The Thales ThinKom AES system will typically operate above 15 degrees elevation. The main
beam gain of the antenna will vary with elevation as shown in Table 1 below. The system is
equipped with a 50-watt amplifier, and has 3 dB of output back-off and 1 dB of output circuit
losses. The worst-case scenario, in terms of worst power density levels, involves the high
elevation angle and has been presented here.

                         Table 1 - Earth Station Technical Parameter Table

Antenna Aperture major axis              0.444 meters

Antenna Surface Area                     0.1873 sq. meters

Antenna Isotropic Gain                   36.5 dBi @ 45° elevation angle

Number of Identical Adj. Antennas        1

Nominal Frequency                        29.5 GHz

Nominal Wavelength (λ)                   0.0102 meters

Maximum Transmit EIRP / Carrier          49.5 dBW

Number of Carriers                       1

Total HPA Power                          50.00 Watts

SSPA Output Backoff                      3 dB

W/G Loss from Transmitter to Feed        1 dB


Total Feed Input Power                   19.91 Watts

AES Terminal EIRP                        49.5 dBW @ 45° elevation angle

Near Field Limit                         Rnf = D²/4λ = 4.600 meters

Far Field Limit                          Rff = 0.6 D²/λ = 11.0 meters

Transition Region                        Rnf to Rff

In the following sections, the power density in the above regions, as well as other critically
important areas will be calculated and evaluated. The calculations are done in the order
discussed in OET Bulletin 65.

1.0 At the Antenna Surface

The power density at the antenna radiating surface can be calculated from the expression:

 PDrefl = 4P/A = 42.519 mW/cm² (1)

 Where: P = total power at feed, milliwatts

         A = Total area of reflector, sq. cm

In the normal range of transmit powers for satellite antennas, the power densities at or around
the reflector surface is expected to exceed safe levels. This area will not be accessible to the
general public. Operators and technicians shall receive training specifying this area as a high
exposure area. Procedures have been established that will assure that all transmitters are
rerouted or turned off before access by maintenance personnel to this area is possible.

2.0 On-Axis Near Field Region

The geometrical limits of the radiated power in the near field approximate a cylindrical volume
with a diameter equal to that of the antenna. In the near field, the power density is neither
uniform nor does its value vary uniformly with distance from the antenna. For the purpose of
considering radiation hazard it is assumed that the on-axis flux density is at its maximum value
throughout the length of this region. The length of this region, i.e., the distance from the
antenna to the end of the near field, is computed as Rnf above.

The maximum power density in the near field is given by:

 PDnf = (16ε P)/(π D²) =     8.345 mW/cm² (2) @45° Elevation

                                 from 0 to 4.600 meters

Evaluation

 Uncontrolled Environment:       Does Not Meet Uncontrolled Limits

 Controlled Environment:         Does not Meet Controlled Limits


3.0 On-Axis Transition Region

The transition region is located between the near and far field regions. As stated in Bulletin 65,
the power density begins to vary inversely with distance in the transition region. The maximum
power density in the transition region will not exceed that calculated for the near field region,
and the transition region begins at that value. The maximum value for a given distance within
the transition region may be computed for the point of interest according to:

 PDt =       (PDnf)(Rnf)/R = dependent on R (3)

 where:      PDnf = near field power density

             Rnf = near field distance

             R = distance to point of interest

 For:        4.60 < R < 11.04 meters

We use Eq (3) to determine the safe on-axis distances required for the two occupancy
conditions:

Evaluation

 Uncontrolled Environment Safe Operating Distance,(meters), Rsafeu:        38.4m @45° elevation



 Controlled Environment Safe Operating Distance,(meters), Rsafec:          7.7m @45° elevation




4.0 On-Axis Far-Field Region

The on- axis power density in the far field region (PDff) varies inversely with the square of the
distance as follows:

 PDff = PG/(4πR²) = dependent on R (4)

 where: P = total power at feed

         G = Numeric Antenna gain in the direction of interest relative to isotropic radiator

         R = distance to the point of interest

 For:    R > Rff = 11.0 meters

         PDff = 4.611 mW/cm² at Rff @45° ,

                 4.61138 mW/cm² at Rff @45°


We use Eq (4) to determine the safe on-axis distances required for the two occupancy
conditions:

Evaluation

 Uncontrolled Environment Safe Operating Distance,(meters), Rsafeu :       See Section 3

 Controlled Environment Safe Operating Distance,(meters), Rsafec :         See Section 3

5.0 Off-Axis Levels at the Far Field Limit and Beyond

In the far field region, the power is distributed in a pattern of maxima and minima (sidelobes) as
a function of the off-axis angle between the antenna center line and the point of interest. Off-
axis power density in the far field can be estimated using the antenna radiation patterns
prescribed for the antenna in use. This will correspond to the antenna gain pattern for an off-
axis angle. For the Thales AES antenna at 1.5 degrees off axis the antenna gain is:

 Goff = 26.50 dBi at 1.5 degree @45°

Considering that satellite antenna beams are aimed skyward, power density in the far field will
usually not be a problem except at low look angles. In these cases, the off-axis gain reduction
may be used to further reduce the power density levels.

For example: At 1.5 degree off axis at the far-field limit, we can calculate the power density as:

Goff =   26.50 dBi = 3981.07 numeric @45° elevation



 PD1.5 deg off-axis = PDffx 446.68/G = 0.6514 mW/cm² (5)



6.0 Off-Axis power density in the Near Field and Transitional Regions

According to Bulletin 65, off-axis calculations in the near field may be performed as follows:
assuming that the point of interest is at least one antenna diameter removed from the center of
the main beam, the power density at that point is at least a factor of 100 (20 dB) less than the
value calculated for the equivalent on-axis power density in the main beam. Therefore, for
regions at least Deff meters away from the center line of the antenna, whether behind, below,
or in front under of the antenna's main beam, the power density exposure is at least 20 dB
below the main beam level as follows:

 PDnf(off-axis) = PDnf /100 =     0.08345 mW/cm² at D off axis (6) @45°

                                  0.08345 mW/cm² at D off axis (6) @45°

See Section 7 for the calculation of the distance vs. elevation angle required to achieve this rule
for a given object height.


7.0 Evaluation of Safe Occupancy Area in Front of Antenna

The distance (S) from a vertical axis passing through the antenna center to a safe off axis
location in front of the antenna can be determined based on the effective antenna diameter
rule (Item 6.0). Assuming a flat area in front of the antenna, the relationship is:

 S = (Deff/ sin α) + (2(h-GDeff) - Deff - 2)/(2 tan α) (7)

 Where: α = minimum elevation angle of antenna

           D = effective antenna diameter in meters

           h = maximum height of object to be cleared, meters

For distances equal or greater than determined by equation (7), the radiation hazard will be
below safe levels.

   For          D=            0.49 meters

                h=            2.0 meters

                GD =          1 meters - elevated height of earth station above ground (min)

   Then:

                α             S

                15            0.9 meters

                25            0.6 meters

                35            0.4 meters

                45            0.4 meters

This is fuselage mounted antenna, and all persons working on or near the antenna will be
properly trained regarding radiation hazard. The antenna transmitter will be disabled any time
work inside the radome is in progress.



8.0 Summary

The earth station site will be protected from uncontrolled access. The terminal is mounted,
under a radome, on the top of the aircraft fuselage and it is pointed upward. The terminal may
also be mounted on top of a test van. Access to the terminal will be limited to trained
operations personnel. There will also be proper emission warning signs placed and all operating
personnel will be aware of the human exposure levels at and around the earth station. 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 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 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 equipment for worker.



The following table summarizes all of the above calculations:


Table - Summary of All RadHaz Parameters                                ThinKom AES Antenna

Parameter                                    Abbr.             Units    Formula

Antenna Elevation Angle Operation Scenario           @45°

Antenna Dimensions                           Dma     0.433    meters    major axis (azimuth)

Effective Aperture Diameter                  Deff     0.49    meters

Antenna Centerline                           ACL      3.0     meters    Mount on test van ~9’

Antenna Surface Area                         Sa      0.1873   meters2   (π * Deff2 )/ 4

Frequency of Operation                       f        29.5     GHz

Wavelength                                   λ       0.0102   meters    c/f

HPA Output Power                             PHPA    50.00     watts

HPA to Antenna Loss                          Ltx      4.0       dB      3 dB OBO + 1 dB OCL

Transmit Power at Flange                     P       12.99     dBW      10 * Log(PHPA) - Ltx

Antenna Gain                                 Ges     36.50     dBi      Varies with elevation

                                                     4466.8     n/a

PI                                           π       3.1416     n/a

Antenna Aperture Efficiency                  η       19.63%     n/a     Ges / (PI * Df /λ)2

Maximum EIRP                                 EIRP     49.5     dBi      Varies with elevation

1. Reflector Surface Region Calculations             @45°

Reflector Surface Power Density              PDas    425.19    W/m2     (16 * P)/(π * Deff2)

Reflector Surface Power Density              PDas    42.519   mW/cm2    Does Not Meet Uncontrolled Limits

                                                                        Does not Meet Controlled Limits

2. On-Axis Near Field Calculations                   @45°

Extent of Near Field                         Rnf     4.600    meters    Dma2 / (4 *λ)

Extent of Near Field                         Rnf     15.09     feet

Near Field Power Density                     PDnf    83.45     W/m2     (16 * η * P )/ (π *Deff2)

Near Field Power Density                     PDnf    8.345    mW/cm2    Does Not Meet Uncontrolled Limits

                                                                        Does not Meet Controlled Limits

3. On-Axis Transition Region Calculations            @45°

Extent of Transition Region (min)            Rtr      4.60    meters    Dma2 / (4 *λ)

Extent of Transition Region (min)                    15.09     feet

Extent of Transition Region (max)            Rtr     11.04    meters    (0.6 * Dma2) /λ

Extent of Transition Region (max)                    36.21     feet

Worst Case Transition Region Power Density   PDtr    83.45     W/m2     (16 *η * P)/ (π * Deff2)

Worst Case Transition Region Power Density   PDtr    8.345    mW/cm2    Does Not Meet Uncontrolled Limits

                                                     @45°               Does not Meet Controlled Limits


Uncontrolled Environment Safe Operating Distance          Rsu         38.4            m          =(PDnf)*(Rnf)/Rsu

Controlled Environment Safe Operating Distance            Rsc          7.7            m          =(PDnf)*(Rnf)/Rsc

4. On-Axis Far Field Calculations                                     @45°

Distance to the Far Field Region                          Rff         11.0          meters       (0.6 * Dma2) /λ

                                                                      36.21          feet

On-Axis Power Density in the Far Field                    PDff        46.11          W/m2        (Ges * P) / (4 * π * Rf2)

On-Axis Power Density in the Far Field                    PDff        4.611         mW/cm2       Does Not Meet Uncontrolled Limits

                                                                                                 Meets Controlled Limits

5. Off-Axis Levels at the Far Field Limit and Beyond                  @45°

Reflector Surface Power Density                           PDs         6.514          W/m2        (Ges * P) / (4 * π * Rf2)*(Goa/Ges)

Goa/Ges at example angle θ 1.5 degree                                 0.141                      GoA approx 8.5 dB down at 1.5 deg
                                                                                             2
Off-Axis Power Density                                               0.6514         mW/cm        Meets Uncontrolled Limits

6. Off-axis Power Density in the Near Field and Transitional Regions Calculations


6. Off-axis Power Density in the Near Field and                       @45°
Transitional Regions Calculations
Power density 1/100 of Wn for one diameter removed        PDs        0.8345          W/m2        ((16 * η * P )/ (π *Deff2))/100

                                                                     0.08345        mW/cm2       Meets Uncontrolled Limits

7. Off-Axis Safe Distances from Earth Station                                                    S = (Deff/ sin α) + 2(h - GD - 2)/(2 tan α)

α = minimum elevation angle of antenna                                               deg

h = maximum height of object to be cleared, meters                     2.0            m

GD = Ground Elevation Delta antenna-obstacle                           1.0            m

                                                                        S

                            15                                         0.9            m

                            25                                         0.6            m

                            35                                         0.4            m

                            45                                         0.4            m

Note: Maximum FCC power density limits for 14 GHz is 1 mW/cm2 for general population/uncontrolled exposure as per FCC OE&T Bulletin
No. 65, Edition 97-01 August 1997, Appendix A page 67.



Document Created: 2018-04-05 11:32:14
Document Modified: 2018-04-05 11:32:14

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