Attachment Narr and Annexes

This document pretains to SES-STA-20140821-00668 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2014082100668_1058802

                                                                                  Exhibit A
                                                                                Page 1 of 8

                 REQUEST FOR SPECIAL TEMPORARY AUTHORITY

              By this application, SES Government Solutions, Inc., formerly known as
Americom Government Services, Inc. (“SES-GS”) respectfully requests special
temporary authority (“STA”) for a period of 30 days to operate an earth station at
MacDill Air Force Base in Tampa, FL, that will communicate with the O3b Ka-band non-
geostationary orbit fixed-satellite service (“NGSO FSS”) satellite fleet. As discussed
below, grant of the requested authority is in the public interest as it will allow SES-GS to
test and evaluate O3b services that may be of interest to U.S. government customers.
SES-GS does not seek to provide commercial services to end users. In order to
accommodate the schedule for testing, SES-GS requests action on this STA by no later
than October 15.
              Background: SES-GS provides reliable and secure commercial satellite
services to U.S. Government, Intelligence and Civilian agencies. SES-GS believes that
adding access to the O3b network may be an attractive option for such customers.
Because of its lower NGSO orbit, the O3b fleet can offer service with reduced latency at
affordable rates. In order to introduce prospective customers to the capabilities of the
O3b network, SES-GS has procured a set of antennas that can communicate with the
O3b constellation and can be used to evaluate and demonstrate the O3b services.
SES-GS initially sought and was granted Commission authority to locate these
antennas at a site in Bristow, VA, 1 but now proposes to relocate the antennas to
Tampa. Under the requested STA, SES-GS seeks to operate the antennas only for
testing and providing demonstrations and will not be offering service to customers for a
fee.
              Protection of Authorized Stations: SES-GS seeks authority herein to
communicate with O3b in a subset of the Ka-band spectrum that O3b has been licensed




1
  See SES Government Solutions, Inc., File Nos. SES-STA-20131022-00888 (grant-
stamped Jan. 6, 2104); SES-STA-20131022-00887 (grant-stamped Jan. 31, 2014); &
SES-STA-20140612-00517 (grant-stamped July 29, 2014).


                                                                                  Exhibit A
                                                                                Page 2 of 8

to use for its existing U.S. earth stations. 2 Specifically, SES-GS requests authority for
the following O3b beams:
       Beam 3: 28.172-28.388 GHz uplink and 18.372-18.588 GHz downlink
       Beam 4: 28.601-28.817 GHz uplink and 18.801-19.017 GHz downlink
       Beam 5: 28.855-29.071 GHz uplink and 19.055-19.271 GHz downlink
              NGSO FSS has a primary allocation in the beam 4 and 5 spectrum, but
does not have a primary U.S. allocation in the band 3 spectrum. However, SES-GS
demonstrates herein that its proposed communications with the O3b network in the
beam 3 frequencies will not cause interference to primary operations, and SES-GS will
not claim interference protection from such operations.
              LMDS in the 28.172-28.350 GHz Band: In most of the O3b uplink
spectrum for beam 3, terrestrial local multipoint distribution service (“LMDS”) systems
are primary, and FSS has a secondary allocation. In order to ensure that its proposed
secondary operations would not cause interference to LMDS operations, SES-GS
asked Comsearch to identify all existing and proposed terrestrial networks in the vicinity
of the Tampa site. Comsearch notified each of these operators of the technical
parameters of the planned SES-GS transmissions. In the attached report, Comsearch
confirms that it did not receive any objections to the proposed operations from any of
the potentially affected terrestrial systems.
              The Commission has previously indicated that secondary FSS operations
in the 27.6-28.35 GHz band are “for the purpose of providing limited gateway-type
service.” 3 SES-GS believes that the focus of these Commission’s statements has been
on ensuring that FSS operations are compatible with LMDS by limiting the number and

2
 See O3b Limited, Call Sign E130021, File No. SES-LIC-20130124-00089 (“O3b Texas
Application”), granted June 20, 2013 (“O3b Texas License”), Section C (authorizing
operations in the 17.8-18.6 GHz, 18.8-19.3 GHz, 27.6-28.4 GHz, and 28.6-29.1 GHz
bands); O3b Limited, Call Sign E100088, File No. SES-LIC-20100723-00952 (“O3b
Hawaii Application”), granted Sept. 25, 2012 (“O3b Hawaii License”), Section C (same).
3
 Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission’s Rules to
Redesignate the 27.5-29.5 GHz Frequency Band, to Reallocate the 29.5-30.0 GHz
Frequency Band, to Establish Rules and Policies for Local Multipoint Distribution
Service and for Fixed Satellite Services, First Report and Order and Fourth Notice of
Proposed Rulemaking, 11 FCC Rcd 19005, 19025, ¶ 45 (1996).


                                                                                   Exhibit A
                                                                                 Page 3 of 8

ubiquity of FSS terminals permitted to use the spectrum. The proposal by SES-GS to
operate at a single site in Tampa is clearly consistent with this underlying rationale.
Furthermore, as noted above, LMDS systems in the vicinity of the site have been
notified of the proposed SES-GS operations and have not objected. Accordingly, grant
of the requested SES-GS STA will not undermine the primary spectrum rights of LMDS
systems.
                GSO FSS in the 28.350-28.388 GHz and 18.372-18.588 GHz Bands: In
the remaining segment of the beam 3 uplink frequencies, the spectrum is allocated to
GSO FSS uplinks on a primary basis, with a secondary allocation for NGSO FSS
uplinks. GSO FSS downlinks are primary throughout the beam 3 downlink spectrum,
and there is no NGSO FSS allocation in this segment.
                Uplink transmissions from the proposed SES-GS earth station will not
cause harmful interference to primary GSO FSS networks. In support of its Hawaii
application, O3b demonstrated that its proposed operations at that site would comply
with ITU uplink EPFD limits applicable to the 28.35-28.4 GHz band. 4 This showing was
based on the power levels of the earth station and the angular separation between the
O3b and geostationary orbits as viewed from the Earth. In its later Texas application,
O3b cross-referenced the O3b Hawaii Application and demonstrated that because the
Texas site is further north than the Hawaii location, the angular separation is greater,
providing a greater margin of compliance. 5 The SES-GS proposed Tampa site is also
further north than O3b’s Hawaii location, and the SES-GS antennas will operate at
lower power levels than the O3b Hawaii or Texas antennas. 6 Accordingly, for the
reasons set forth in the O3b Hawaii and Texas Applications, the proposed SES-GS
operations will comply with the applicable ITU EPFDup limits. As a result, grant of STA

4
    O3b Hawaii Application, Narrative at 14-15 & Technical Appendix at 26-28.
5
    O3b Texas Application, Narrative at 6.
6
  Specifically, the maximum earth station EIRP density transmitted by the proposed
SES-GS 1.8 meter Tampa earth station for a 216 MHz signal is 21.5 dBW/4kHz, which
is equivalent to 31.5 dBW/40kHz. This results in an input power spectral density of
-31.5 dBW/4kHz. Assuming a 32 - 25 log(Ɵ) gain mask, the off-axis gain of the
transmitting earth station for an off-axis angle of 7.4° is 2.8 dBi, resulting in a worst-case
off-axis EIRP density towards the GSO of -28.7 dBW/4kHz or -18.7 dBW/40kHz.


                                                                                 Exhibit A
                                                                               Page 4 of 8

for use of the 28.35-28.4 GHz band on a secondary basis to communicate with the O3b
constellation is consistent with Commission precedent. 7
               SES-GS proposes to use the 18.372-18.588 GHz band on a non-
conforming basis. SES-GS acknowledges that it is not entitled to protection from
interference caused by primary GSO FSS operations in this spectrum. Furthermore,
O3b has demonstrated that transmissions from its space stations will comply with the
limits developed by the ITU to protect GSO FSS networks from unacceptable
interference. 8 O3b’s compliance demonstration is based on the angular separation
between the O3b and GSO orbits when viewed from the earth, which increases for
latitudes further from the equator. 9 SES-GS seeks authority here for operations in
Tampa that are at a higher latitude than the O3b authorized site in Hawaii, and
accordingly the analysis provided in the O3b Hawaii Application supports grant of
authority here.
               Earth Station Technical Parameters: SES-GS is attaching the following
documents to provide the technical details of the operations proposed under the
requested STA:
               1. Schedule B. Although SES-GS is not seeking a permanent license for
                  the Tampa demonstration site, SES-GS is providing as Annex 1 hereto
                  a Schedule B with the applicable technical parameters for the
                  Commission’s convenience.

               2. Comsearch report. As discussed above, Comsearch identified and
                  notified the 28 GHz terrestrial networks in the vicinity of the Tampa
                  site. Attached as Annex 2 is the report confirming that no terrestrial
                  licensee objected to the proposed operations of SES-GS.


7
  See, e.g., O3b Texas License, Provisions 90086 and 90087 (specifying that
transmissions from the earth station are secondary in the 27.6-28.4 GHz band and must
comply with ITU EPFD requirements); O3b Hawaii License, Provisions 90039 and
90040 (same); Northrop Grumman Space & Missions Systems Corp., 24 FCC Rcd
2330, 2354 at ¶¶ 72-73 (Int'l Bur. 2009) (authorizing NGSO uplink operations on a
secondary basis in primary GSO spectrum conditioned on compliance with ITU EPFD
limits); contactMEO Communications, LLC, 21 FCC Rcd 4035, 4043-44 at ¶¶ 23-24,
(Int'l Bur. 2006) (same).
8
    See O3b Hawaii Application, Narrative at 12-14 & Technical Appendix at 22-26.
9
    See id.


                                                                               Exhibit A
                                                                             Page 5 of 8

             3. Link budgets. Representative link budgets for the Tampa earth station
                are provided in Annex 3.

             In addition, SES-GS incorporates by reference herein technical materials it
previously provided:
             1. Antenna patterns. The Tampa site will use the same 1.8 meter
                antennas, manufactured by General Dynamics SATCOM
                Technologies, that were used at the SES-GS Bristow site. The
                antenna patterns were submitted as Annex 3 in File No. SES-STA-
                20131022-00887.

             2. Radiation hazard study. SES-GS has performed an analysis of the
                maximum radiofrequency levels emitted from the satellite
                communications antenna, and it was submitted as Annex 5 in File
                No SES-STA-20131022-00887.

             Finally, SES-GS incorporates by reference herein technical materials
provided by O3b:
             1. Schedule S and beam contour description. In October 2013, O3b
                provided supplemental information regarding its constellation in
                connection with O3b’s application for a blanket license for Earth
                Stations on Vessels. This set of data included a revised Schedule S
                and responses to specific FCC questions. See O3b Limited, Call Sign
                E130098, File No. SES-AMD-20131025-01138, filed Oct. 25, 2013,
                Completed Schedule S and O3b Reply. The operational
                characteristics of the proposed SES-GS Tampa terminal are within all
                aspects of the envelope defined for user terminals in O3b’s
                Schedule S. Furthermore, the beam contours for the proposed
                operations can be derived from the formulas O3b supplied on page 10
                of its Reply.

             2. Service area definition. The SES-GS Tampa location falls within the
                “U” service area identified in the O3b revised Schedule S, which
                includes all locations on Earth with elevation angles to the operational
                O3b satellites greater than 3 degrees.

             3. U.S. government coordination. As explained in the O3b Hawaii
                Application, coordination of the O3b NGSO satellite system has been
                completed, and the coordination agreement has been provided
                confidentially to the Commission. See O3b Hawaii Application,
                Attachment A at 33, Section A.12. O3b has advised SES-GS that the
                agreement contemplates the operation of U.S. earth stations.

             4. Compliance with PFD limits. O3b has shown that the power flux
                density (“PFD”) of the O3b system complies with all applicable FCC


                                                                                  Exhibit A
                                                                                Page 6 of 8

                   limits. See O3b Limited, Call Sign E130107, File No. SES-LIC-
                   20130618-00516, Technical Supplement filed July 24, 2013 at 6-8.
                   This showing is based on a worst-case methodology to calculate the
                   maximum EIRP density produced by the O3b downlinks. The
                   proposed SES-GS Tampa earth station will be operated with O3b
                   downlink signals that are below this maximum EIRP density level.

                5. Notification of satellite operational flexibility. O3b has advised SES-GS
                   that O3b has filed new information with the Commission concerning an
                   expansion of the possible configurations in which O3b positions its
                   NGSO satellites. See, e.g., O3b Limited, Call Sign E130107, File
                   No. SES-AMD-20140814-00653, Exhibit. SES-GS has reviewed the
                   O3b document and incorporates it by reference herein.

                U.S. Market Access: The O3b Hawaii Application included a showing that
allowing U.S. earth stations to communicate with the foreign-licensed O3b NGSO
constellation is consistent with U.S. market access policies, 10 as those policies are set
forth in the DISCO II framework 11 and codified in Section 25.137. 12 The Commission
granted the application, thereby authorizing communication between the Hawaii earth
station and the O3b satellite fleet. 13 Subsequent to that grant, no change has occurred
in the O3b satellite network’s operating parameters or the services that the network will
be used to provide. Under these circumstances, no additional showing is needed to
allow SES-GS to use its proposed Tampa antennas to communicate with the O3b
satellite constellation. 14
                In any event, the SES-GS Tampa antennas will be used for evaluation and
demonstration purposes only, and not for commercial services. As a result, grant of the
requested authority to communicate with the O3b constellation will have no effect on
competition within the U.S.


10
     See O3b Hawaii Application, Legal Narrative at 10-24.
11
  See Amendment of the Commission’s Policies to Allow Non-U.S. Licensed Space
Stations providing Domestic and International Service in the United States, Report &
Order, 12 FCC Rcd 24094 (1997) (“DISCO II”).
12
     47 C.F.R. § 25.137.
13
   See O3b Hawaii License, Section D (authorizing communications with the U.K.-
licensed O3b NGSO satellite system).
14
     See DISCO II, 12 FCC Rcd at 24176, ¶ 192.


                                                                                 Exhibit A
                                                                               Page 7 of 8

                  Waiver Requests: SES-GS requests grant of any necessary waiver of the
Commission’s rules in connection with the instant STA request. Such waiver is
consistent with Commission policy:
                        The Commission may waive a rule for good
                        cause shown. Waiver is appropriate if special
                        circumstances warrant a deviation from the
                        general rule and such deviation would better
                        serve the public interest than would strict
                        adherence to the general rule. Generally, the
                        Commission may grant a waiver of its rules in a
                        particular case if the relief requested would not
                        undermine the policy objective of the rule in
                        question and would otherwise serve the public
                        interest. 15

                  Section 25.145(c): Section 25.145(c) of the Commission's rules requires
Ka-band NGSO systems to meet global and U.S. service coverage requirements. 16
O3b has explained that its network, which was designed with a focus on providing
service to emerging markets and areas without significant terrestrial broadband
infrastructure, cannot meet these requirements. 17 O3b argued that granting a waiver of
the coverage requirements to allow access to the O3b network would further, not
undermine, achievement of the rule’s purpose – fostering seamless global
communications. 18 The Commission granted a waiver of the rule for both the O3b
Hawaii and Texas gateway and TT&C earth stations, but stated that the grant was
without prejudice to action on any waiver request to provide additional U.S. services. 19
                  SES-GS seeks grant of any necessary waiver of Section 25.145(c) in
connection with the instant STA request. As with the O3b Hawaii and Texas stations,
the proposed SES-GS Tampa antennas will not provide commercial services to end


15
  PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes
omitted).
16
     47 C.F.R. § 25.145(c).
17
  See O3b Limited, Call Sign E100088, File No. SES-LIC-20100723-00952 (“O3b
Hawaii Application”), Legal Narrative at 21-22.
18
     Id. at 22.
19
     See O3b Hawaii License, Provision 90044; O3b Texas License, Provision 90044.


                                                                                   Exhibit A
                                                                                 Page 8 of 8

users. Instead, the antennas will be operated only for purposes of evaluating the
capabilities of the O3b network and demonstrating those capabilities to prospective
customers interested in using O3b capacity for their communications needs, whether
outside or inside the U.S. No fees will be charged to customers for these
demonstrations, and accordingly the proposed operations will have no effect on
competition in the U.S. In these circumstances, preventing SES-GS from
communicating with the operational O3b global satellite network because that network
does not comply with Commission coverage requirements would serve no conceivable
public interest objective.
                Section 25.210(i)(1): O3b has also explained that its satellite constellation
does not comply with the minimum cross-polarization isolation requirement for FSS
systems in Section 25.210(i)(1). 20 The Commission granted a waiver of this rule in the
O3b Hawaii and Texas Licenses. 21 For the same reasons, SES-GS requests that the
Commission grant any necessary waiver of Section 25.210(i)(1) in connection with the
instant STA request.

                Conclusion: The requested STA will allow SES-GS to evaluate and
demonstrate the O3b network’s operational capabilities and will not result in harmful
interference to other authorized spectrum users. Thus, grant of the STA will serve the
public interest.




20
     See O3b Hawaii Application, Legal Narrative at 22-23.
21
     See O3b Hawaii License, Provision 90041; O3b Texas License, Provision 90041.


                                                                                                 Annex 1       Page 1 of 8




      Approved by OMB
             3060-0678

 Date & Time Filed:
 File Number: ---
 Callsign/Satellite ID:
   APPLICATION FOR EARTH STATION AUTHORIZATIONS
                                                                                         FCC Use Only
                              FCC 312 MAIN FORM
                            FOR OFFICIAL USE ONLY
 APPLICANT INFORMATION
 Enter a description of this application to identify it on the main menu:
 STA Attachment for MacDill AFB,Tampa FL O3b Ka Demo
 1-8. Legal Name of Applicant
 Name:       SES Government Solutions, Inc.                     Phone Number:       703-610-0906
  DBA
  Name:
                                                                Fax Number:         703-610-1030
  Street:      2010 Corporate Ridge, Suite 550                  E-Mail:             joe.oloughlin@ses-gs.com
  City:        McLean                                           State:              VA
  Country:     USA                                              Zipcode:            22102 -
  Attention: Mr Joseph A O'Loughlin
 9-16. Name of Contact Representative
 Name:      Karis Hastings                           Phone Number:             202-599-0975
  Company: SatCom Law LLC                            Fax Number:
  Street:      1317 F Street, N.W.                   E-Mail:                   karis@satcomlaw.com
               Suite 400
  City:        Washington                            State:                    DC
  Country:     USA                                   Zipcode:                  20004-
  Attention:                                         Relationship:             Legal Counsel
                                            CLASSIFICATION OF FILING
 17. Choose the button next to the     b.
 classification that applies to this       b1. Application for License of New Station
 filing for both questions a. and b.
                                           b2. Application for Registration of New Domestic Receive-Only Station
 Choose only one for 17a and only
                                       (N/A) b3. Amendment to a Pending Application
 one for 17b.
                                       (N/A) b4. Modification of License or Registration
                                       (N/A) b5. Assignment of License or Registration
 a.
                                       (N/A) b6. Transfer of Control of License or Registration
    a1. Earth Station                  (N/A) b7. Notification of Minor Modification
 (N/A) a2. Space Station               (N/A) b8. Application for License of New Receive-Only Station Using Non-U.S.
                                       Licensed Satellite
                                       (N/A) b9. Letter of Intent to Use Non-U.S. Licensed Satellite to Provide Service in
                                       the United States
                                           b10. Other (Please specify)
                                           b11. Application for Earth Station to Access a Non-U.S.satellite Not Currently




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                                          Authorized to Provide the Proposed Service in the Proposed Frequencies in the
                                          United States.
 17c. Is a fee submitted with this application?
    If Yes, complete and attach FCC Form 159.

 If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
     Governmental Entity       Noncommercial educational licensee
     Other(please explain):
 17d.
 Fee Classification BAX - Fixed Satellite Transmit/Receive Earth Station
  18. If this filing is in reference to   19. If this filing is an amendment to a pending application enter:
  an existing station, enter:             (a) Date pending application was filed: (b) File number of pending application:
  (a) Call sign of station:
  Not Applicable                          Not Applicable                            Not Applicable
                                                    TYPE OF SERVICE
 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s):
 Select all that apply:

     a. Fixed Satellite
     b. Mobile Satellite
     c. Radiodetermination Satellite
     d. Earth Exploration Satellite
     e. Direct to Home Fixed Satellite
     f. Digital Audio Radio Service
     g. Other (please specify)
 21. STATUS: Choose the button next to the applicable            22. If earth station applicant, check all that apply.
 status. Choose only one.                                            Using U.S. licensed satellites
     Common Carrier       Non-Common Carrier                         Using Non-U.S. licensed satellites
 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214
 filings. Choose one. Are these facilities:
      Connected to a Public Switched Network Not connected to a Public Switched Network N/A
 24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s).
     a. C-Band (4/6 GHz)      b. Ku-Band (12/14 GHz)
     c.Other (Please specify upper and lower frequencies in MHz.)
 Frequency Lower: 18372 Frequency Upper: 29071
                                                    TYPE OF STATION
 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
     a. Fixed Earth Station
     b. Temporary-Fixed Earth Station
     c. 12/14 GHz VSAT Network
     d. Mobile Earth Station
  (N/A) e. Geostationary Space Station
  (N/A) f. Non-Geostationary Space Station
     g. Other (please specify)
 26. TYPE OF EARTH STATION FACILITY: Choose only one.
     Transmit/Receive Transmit-Only Receive-Only   N/A
                                             PURPOSE OF MODIFICATION



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  27. The purpose of this proposed modification is to: (Place an 'X' in the box(es) next to all that apply.)
  Not Applicable
                                              ENVIRONMENTAL POLICY
  28. Would a Commission grant of any proposal in this application or amendment have a
  significant environmental impact as defined by 47 CFR 1.1307? If YES, submit the statement
                                                                                                         Yes   No
  as required by Sections 1.1308 and 1.1311 of the Commission's rules, 47 C.F.R. §§ 1.1308 and
  1.1311, as an exhibit to this application.A Radiation Hazard Study must accompany all
  applications for new transmitting facilities, major modifications, or major amendments.
  ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier,
  aeronautical en route or aeronautical fixed radio station services are not required to respond to Items
                                                  30-34.
  29. Is the applicant a foreign government or the representative of any foreign government?             Yes   No

  30. Is the applicant an alien or the representative of an alien?                                       Yes   No   N/A

  31. Is the applicant a corporation organized under the laws of any foreign government?                 Yes   No   N/A
  32. Is the applicant a corporation of which more than one-fifth of the capital stock is owned of
  record or voted by aliens or their representatives or by a foreign government or representative        Yes   No   N/A
  thereof or by any corporation organized under the laws of a foreign country?
  33. Is the applicant a corporation directly or indirectly controlled by any other corporation of
  which more than one-fourth of the capital stock is owned of record or voted by aliens, their
  representatives, or by a foreign government or representative thereof or by any corporation            Yes   No   N/A
  organized under the laws of a foreign country?
  34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an
  identification of the aliens or foreign entities, their nationality, their relationship to the
  applicant, and the percentage of stock they own or vote.
                                                BASIC QUALIFICATIONS
  35. Does the Applicant request any waivers or exemptions from any of the Commission's
  Rules?                                                                                                 Yes   No
  If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting
  documents.
  36. Has the applicant or any party to this application or amendment had any FCC station
  authorization or license revoked or had any application for an initial, modification or renewal        Yes   No
  of FCC station authorization, license, or construction permit denied by the Commission? If
  Yes, attach as an exhibit, an explination of circumstances.
  37. Has the applicant, or any party to this application or amendment, or any party directly or
                                                                                                         Yes   No
  indirectly controlling the applicant ever been convicted of a felony by any state or federal
  court? If Yes, attach as an exhibit, an explination of circumstances.
  38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling
  the applicant, guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio
                                                                                                         Yes   No
  communication, directly or indirectly, through control of manufacture or sale of radio
  apparatus, exclusive traffic arrangement or any other means or unfair methods of competition?
  If Yes, attach as an exhibit, an explanation of circumstances
  39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a
                                                                                                         Yes   No
  party in any pending matter referred to in the preceding two items? If yes, attach as an exhinit,
  an explanation of the circumstances.
  40. If the applicant is a corporation and is applying for a space station license, attach as an
  exhibit the names, address, and citizenship of those stockholders owning a record and/or voting




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  10 percent or more of the Filer's voting stock and the percentages so held. In the case of
  fiduciary control, indicate the beneficiary(ies) or class of beneficiaries. Also list the names and
  addresses of the officers and directors of the Filer.
  41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the
  application is 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           Yes     No
  possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of
  "party to the application" for these purposes.
  42a. Does the applicant intend to use a non-U.S. licensed satellite to provide service in the
                                                                                                          Yes     No
  United States? If Yes, answer 42b and attach an exhibit providing the information specified in
  47 C.F.R. 25.137, as appropriate. If No, proceed to question 43.
  42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued,
  what administration has coordinated or is in the process of coordinating the space station?United Kingdom

 43. Description. (Summarize the nature of the application and the services to be provided). SES Government
 Solutions seeks FCC authority to operate an earth station at MacDill AFB in Tampa, Florida, with
 the O3b U.K.-licensed non-geostationary Ka-band satellite system for testing and demonstration
 purposes only.
  43a. Geographic Service Rule Certification
  By selecting A, the undersigned certifies that the applicant is not subject to the geographic           A
  service or geographic coverage requirements specified in 47 C.F.R. Part 25.

  By selecting B, the undersigned certifies that the applicant is subject to the geographic service
  or geographic coverage requirements specified in 47 C.F.R. Part 25 and will comply with such            B
  requirements.

  By selecting C, the undersigned certifies that the applicant is subject to the geographic service
  or geographic coverage requirements specified in 47 C.F.R. Part 25 and will not comply with
  such requirements because it is not feasible as a technical matter to do so, or that, while             C
  technically feasible, such services would require so many compromises in satellite design and
  operation as to make it economically unreasonable. A narrative description and technical
  analysis demonstrating this claim are attached.

                                                    CERTIFICATION
 The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the
 regulatory power of the United States because of the previous use of the same, whether by license or otherwise, and
 requests an authorization in accordance with this application. The applicant certifies that grant of this application would
 not cause the applicant to be in violation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in
 exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned,
 individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits
 are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.
 44. Applicant is a (an): (Choose the button next to applicable response.)

      Individual
      Unincorporated Association
      Partnership
      Corporation
      Governmental Entity
      Other (please specify)

  45. Name of Person Signing                                     46. Title of Person Signing
  Joseph O'Loughlin                                              CTO




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                                                                                                           Page 5 of 8



 47. Please supply any need attachments.
  Attachment 1:                          Attachment 2:                            Attachment 3:

      WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR
                                                  IMPRISONMENT
      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
        (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).

               SATELLITE EARTH STATION AUTHORIZATIONS
          FCC Form 312 - Schedule B:(Technical and Operational Description)



                                          FOR OFFICIAL USE ONLY


 Location of Earth Station Site
 E1: Site Identifier:     MacDill AFB 1.8m Ka                  E5. Call Sign:
  E2: Contact Name          Tim Kavanaugh                      E6. Phone Number:         703-350-8665
  E3. Street:               8532 Marina Bay Drive              E7. City:                 Tampa
                                                               E8. County:               Hillsborough
  E4. State                 FL                                 E9. Zip Code              33621
  E10. Area of Operation:                                      Fixed
  E11. Latitude:            27 ° 50 ' 34.73 " N
  E12. Longitude:           82 ° 28 ' 59.43 " W
  E13. Lat/Lon Coordinates are:                                   NAD-27                    NAD-83           N/A
  E14. Site Elevation (AMSL):                                  0.97 meters
 E15. If the proposed antenna(s) operate in the Fixed Satellite Service (FSS) with geostationary
 satellites, do(es) the proposed antenna(s) comply with the antenna gain patterns specified in
 Section 25.209(a) and (b) as demonstrated by the manufacturer's qualification measurement? If     Yes     No N/A
 NO, provide asa technical analysis showing compliance with two-degree spacing policy.
 E16. If the proposed antenna(s) do not operate in the Fixed Satellite Service (FSS), or if they
 operate in the Fixed Satellite Service (FSS) with non-geostationary satellites, do(es) the
 proposed antenna(s) comply with the antenna gain patterns specified in Section 25.209(a2) and     Yes     No N/A
 (b) as demonstrated by the manufacturer's qualification measurements?
 E17. Is the facility operated by remote control? If YES, provide the location and telephone
 number of the control point.                                                                        Yes     No
 E18. Is frequency coordination required? If YES, attach a frequency
                                                                                                     Yes     No
 coordination report as
 E19. Is coordination with another country required? If YES, attach the name of
                                                                                                     Yes     No
 the country(ies) and plot of coordination contours as
 E20. FAA Notification - (See 47 CFR Part 17 and 47 CFR part 25.113(c))
 Where FAA notification is required, have you attached a copy of a
 completed FCC Form 854 and or the FAA's study regarding the potential
                                                                                                     Yes     No
 hazard of the structure to aviation?
 FAILURE TO COMPLY WITH 47 CFR PARTS 17 AND 25 WILL
 RESULT IN THE RETURN OF THIS APPLICATION.
 POINTS OF COMMUNICATION




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                                                                                         Page 6 of 8



 Satellite Name:OTHER | OTHER | If you selected OTHER, please enter the following:
 E21. Common Name: O3B-A                        E22. ITU Name: O3B-A
 E23. Orbit Location: Eq. NGSO                  E24. Country: United Kingdom
 POINTS OF COMMUNICATION (Destination Points)
 E25. Site Identifier: MacDill AFB 1.8m Ka
 E26. Common Name:                                                    E27. Country:USA
 ANTENNA
                                                                 E41/42. Antenna
               E28.                                     E32.
                       E29.       E30.                         GainTransmint and/or
   Site ID    Antenna                       E31. Model Antenna
                      Quantity Manufacturer                     Recieve(____dBi at
                Id                                      Size
                                                                    _____GHz)
 MacDill
 AFB 1.8m Ant 1-2      2           GD/Prodelin   GDST-1.8M 1.8           49.1 dBi at 18.562
 Ka
                                                                         52.8 dBi at 28.362
                                                     E37.                   E39.
                                                            E38. Total                E40.
                               E35.     E36.       Building              Maximum
           E33/34.                                             Input                  Total
  E28.                        Above    Above        Height                Antenna
          Diameter                                           Power at              EIRP for
 Antenna                     Ground     Sea         Above                  Height
         Minor/Major                                         antenna                   al
   Id                         Level    Level       Ground                  Above
          (meters)                                            flange                carriers
                             (meters) (meters)       Level                Rooftop
                                                             (Watts)                 (dBW)
                                                   (meters)               (meters)
 Ant 1-2     0.0/0.0         2.4       3.37      0.0        40.0       0.0         68.8
 FREQUENCY
                                                                    E48.     E49. Maximum
   E28.     E43/44.  E45. E46. Antenna                E47.
                                                                 Maximum ERIP Density per
  Antenna Frequency  T/R  Polarization              Emission
                                                                  EIRP per      Carrier
    Id    Bands(MHz) Mode  (H,V,L,R)               Designator
                                                                Carrier(dBW) (dBW/4kHz)
                                 Left Hand
 Ant 1-2     18372 18588 R                        1M00G7D       0.0            0.0
                                 Circular
 E50. Modulation and Services Digital Data
                                 Left Hand
 Ant 1-2 18372 18588 R                            216MG7D       0.0            0.0
                                 Circular
 E50. Modulation and Services Digital Data
                                 Left Hand
 Ant 1-2 18801 19017 R                            1M00G7D       0.0            0.0
                                 Circular
 E50. Modulation and Services Digital Data
                                 Left Hand
 Ant 1-2 18801 19017 R                            216MG7D       0.0            0.0
                                 Circular
 E50. Modulation and Services Digital Data
                                 Left Hand
 Ant 1-2 19055 19271 R                            1M00G7D       0.0            0.0
                                 Circular
 E50. Modulation and Services Digital Data
 Ant 1-2 19055 19271 R                            216MG7D       0.0            0.0




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                                                                                                           Page 7 of 8



                                 Left Hand
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28172 28388 T                                          1M00G7D             48.6           24.6
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28172 28388 T                                          216MG7D             68.8           21.5
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28601 28817 T                                          1M00G7D             48.6           24.6
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28601 28817 T                                          216MG7D             68.8           21.5
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28855 29071 T                                          1M00G7D             48.6           24.6
                                 Circular
 E50. Modulation and Services Digital Data
                                 Right Hand
 Ant 1-2 28855 29071 T                                          216MG7D             68.8           21.5
                                 Circular
 E50. Modulation and Services Digital Data
 FREQUENCY COORDINATION
                                  E54/55. E56.                  E58.                  E60.
                                                      E57.               E59.
                                   Range Earth                 Earth              Maximum
                         E52/53.                    Antenna            Antenna
  E28.                               of     Station            Station               EIRP
         E51. Satellite Frequency                   Elevation          Elevation
 Antenna                          Satellite Azimuth           Azimuth               Density
          Orbit Type      Limits                      Angle              Angle
    Id                              Arc      Angle             Angle              toward the
                          (MHz)                      Eastern           Western
                                    E/W Eastern               Western              Horizon
                                                      Limit              Limit
                                   Limit Limit                  Limit            (dBW/4kHz)
         Non-           18300
 Ant 1-2                          0.0/ 0.0 144.0    29.0      227.0    44.0      0.0
         Geostationary 18600
         Non-           18800
                                  0.0/ 0.0 144.0    29.0      227.0    44.0      0.0
         Geostationary 19300
         Non-           28100
                                  0.0/ 0.0 144.0    29.0      227.0    44.0      21.5
         Geostationary 28400
         Non-           28600
                                  0.0/ 0.0 144.0    29.0      227.0    44.0      21.5
         Geostationary 29100
 REMOTE CONTROL POINT LOCATION
 REMOTE CONTROL POINT LOCATION
 E61. Call Sign                                                                        E65. Phone Number

 NOTE: Please enter the callsign of the controlling station, not the callsign for
 which this application is being filed.
 E62. Street Address




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                                                                                             Page 8 of 8



 E63. City                                 E67. County                     E64/68.           E66. Zip
                                                                           State/Country     Code
                                                                           /
 FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

 The public reporting for this collection of information is estimated to average 0.25 - 24 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 have any comments on this burden estimate, or how we can improve the collection and reduce
 the burden it causes you, please write to the 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 OMB control number or if we fail to provide you with this notice. This collection has
 been assigned an OMB 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.




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                                     Annex 2



Ka-Band Earth Station – MacDill AFB, Fla.
     Frequency Coordination Report
                        28 GHz




  Prepared on Behalf of
    SES Government
     Solutions, Inc.
      August 14, 2014


                                                   SES Government Solutions, Inc.
                                           Ka-Band Earth Station – MacDill AFB, Fla.
                                                    Frequency Coordination Report



Table of Contents



1.    Summary of Results                                                       -1-

2.    28 GHz Common Carrier and LTTS Coordination                              -1-

3.    28 GHz LMDS Coordination                                                 -2-

4.    Earth Station Coordination Data                                          -3-

5.    Contact Information                                                      -7-




Comsearch Proprietary


                                                                    SES Government Solutions, Inc.
                                                            Ka-Band Earth Station – MacDill AFB, Fla.
                                                                     Frequency Coordination Report



    1. Summary of Results
On behalf of SES Government Solutions, Comsearch performed a coordination notice for all
existing and proposed terrestrial licenses within the coordination contour of their proposed Ka-
Band earth station at MacDill AFB, Fla., transmitting at 28 GHz1. Prior notification letters were
sent to the licensees and a copy of the notification data is provided in section four of this report.
The earth station coordination was finalized on August 11, 2014.

No objections were received from any of the incumbent 28 GHz licensees. Our notification to
the LMDS incumbents was performed under the assumption that the earth stations would be
operating on a secondary basis to LMDS Block A operations and a contact at SES Government
Solutions has been provided in case any concerns may arise in the future.


    2. 28 GHz Common Carrier and LTTS Coordination
In accordance with FCC Rules and Regulations, the Ka-Band earth station at MacDill AFB, Fla.
prior-coordinated by Comsearch. A notification letter and datasheet for this earth station were
sent to the following 28 GHz common carrier fixed microwave licensee on August 4, 2014. This
licensee is authorized to operate temporary fixed operations from 27.5 – 29.5 GHz on a
nationwide basis.


       Licensee                                               Authorized Geographic Area

       Verizon Wireless                                       Continental US


A notification letter and datasheet for the Ka-Band earth station at MacDill AFB, Fla. were also
sent to the following 28 GHz local television transmission licensee on August 4, 2014. This
licensee is authorized to operate temporary fixed operations from 27.5 – 29.5 GHz on a
nationwide basis.


       Licensee                                                Authorized Geographic Area

       Information Super Station, LLC                          Continental US


No objections were received from the common carrier or local television transmission service
incumbents.



1
 The proposed earth station will operate in the 27.6 – 28.4 GHz and 28.6 – 29.1 GHz portions of the Ka-
Band.


Comsearch Proprietary


                                                                          SES Government Solutions, Inc.
                                                                  Ka-Band Earth Station – MacDill AFB, Fla.
                                                                           Frequency Coordination Report



    3. 28 GHz LMDS Coordination
A Notification letter was sent to the following 28 GHz LMDS licensees on August 4, 2014. The
proposed earth station will operate on frequencies that overlap Block A of the LMDS service.
The total frequency allocation for Block A of the LMDS spectrum appears below.

Block A:            27.500-28.350 GHz
                    29.100-29.250 GHz
                    31.075-31.225 GHz


       Licensee                                    Market       Market Name

       Wireless Distribution Services             BTA239        Lakeland-Winter Haven, FL
       Straight Path Spectrum                     BTA336        Orlando, FL
       Nextlink/XO                                BTA4402       Tampa-St. Petersburg-Clearwater, FL



No objections were received from the LMDS incumbents.




2
    The proposed earth station will be located inside BTA440.


Comsearch Proprietary


                                                              SES Government Solutions, Inc.
                                                      Ka-Band Earth Station – MacDill AFB, Fla.
                                                               Frequency Coordination Report



 4. Earth Station Coordination Data
This section presents the data pertinent to the proposed Ka-Band earth station at MacDill AFB,
Fla. This data was circulated to all incumbent licensees in the shared 28 GHz frequency
ranges.




Comsearch Proprietary


                                                                                  SES Government Solutions, Inc.
                                                                          Ka-Band Earth Station – MacDill AFB, Fla.
                                                                                   Frequency Coordination Report


Date:   08/12/2014
Job Number:                                 140801COMSGE05
Administrative Information
Status                                      ENGINEER PROPOSAL
Call Sign                                   MACDILL
Licensee Code                               AMGOSE
Licensee Name                               SES Government Solutions, Inc.
Site Information                            MACDILL AFB, FL
Venue Name
Latitude (NAD 83)                           27° 50' 34.7" N
Longitude (NAD 83)                          82° 28' 59.4" W
Climate Zone                                B
Rain Zone                                   1
Ground Elevation (AMSL)                     0.97 m / 3.2 ft

Link Information
Satellite Type                              Low Earth Orbit
Mode                                        TR - Transmit-Receive
Modulation                                  Digital
Minimum Elevation Angle                     25.0°
Azimuth Range                               0.0° to 360°
Antenna Centerline (AGL)                    2.74 m / 9.0 ft

Antenna Information                                Receive - FCC32                         Transmit - FCC32
Manufacturer                                       GD Prodelin                             GD Prodelin
Model                                              GDST-1.8m                               GDST-1.8m
Gain / Diameter                                    49.1 dBi / 1.8 m                        52.8 dBi / 1.8 m
3-dB / 15-dB Beamwidth                             0.23° / 0.60°                           0.14° / 0.32°

Max Available RF Power           (dBW/4 kHz)                                               -31.3
                                 (dBW/MHz)                                                 -7.3

Maximum EIRP                     (dBW/4 kHz)                                               21.5
                                 (dBW/MHz)                                                 45.5

Interference Objectives:       Long Term           -156.0 dBW/MHz            20%           -151.0 dBW/4 kHz
                               20%
                               Short Term          -146.0 dBW/MHz            0.01%         -128.0 dBW/4 kHz
                               0.0025%
Frequency Information                              Receive 18.0 GHz                        Transmit 28.0 GHz
Emission / Frequency Range (MHz)                   216MG7D / 17852.0 - 18068.0             216MG7D / 27652.0 - 27868.0
                                                   216MG7D / 18112.0 - 18328.0             216MG7D / 27912.0 - 28128.0
                                                   216MG7D / 18372.0 - 18588.0             216MG7D / 28172.0 - 28388.0
                                                   216MG7D / 18801.0 - 19017.0             216MG7D / 28601.0 - 28817.0
                                                   216MG7D / 19055.0 - 19271.0             216MG7D / 28855.0 - 29071.0


Max Great Circle Coordination Distance             171.0 km / 106.2 mi                     100.0 km / 62.1 mi
Precipitation Scatter Contour Radius               100.0 km / 62.1 mi                      100.0 km / 62.1 mi




Comsearch Proprietary


                                                                               SES Government Solutions, Inc.
                                                                       Ka-Band Earth Station – MacDill AFB, Fla.
                                                                                Frequency Coordination Report




Coordination Values                       MACDILL AFB, FL
Licensee Name                             SES Government Solutions, Inc.
Latitude (NAD 83)                         27° 50' 34.7" N
Longitude (NAD 83)                        82° 28' 59.4" W
Ground Elevation (AMSL)                   0.97 m / 3.2 ft
Antenna Centerline (AGL)                  2.74 m / 9.0 ft
Antenna Model                             GD/Prodelin 1.8 Meter
Antenna Mode                                      Receive 18.0 GHz                           Transmit 28.0 GHz
Interference Objectives: Long Term                -156.0 dBW/MHz         20%                 -151.0 dBW/4 kHz 20%
                             Short Term           -146.0 dBW/MHz         0.01%               -128.0 dBW/4 kHz
                             0.0025%
 Max Available RF Power                                                 -31.3 (dBW/4 kHz)

                                                                          Receive 18.0 GHz
                  Transmit 28.0 GHz
                  Horizon                  Antenna                  Horizon        Coordination          Horizon      Coordination
Azimuth (°)       Elevation (°)            Discrimination (°)       Gain (dBi)     Distance (km)         Gain (dBi)   Distance (km)
  0                0.00                     93.53                   -10.00         151.60                -10.00       100.00
  5                0.00                     88.53                   -10.00         151.60                -10.00       100.00
 10                0.00                     83.53                   -10.00         151.60                -10.00       100.00
 15                0.00                     78.54                   -10.00         151.60                -10.00       100.00
 20                0.00                     73.54                   -10.00         151.60                -10.00       100.00
 25                0.00                     68.54                   -10.00         151.60                -10.00       100.00
 30                0.00                     63.55                   -10.00         151.60                -10.00       100.00
 35                0.00                     58.55                   -10.00         151.60                -10.00       100.00
 40                0.00                     53.56                   -10.00         151.60                -10.00       100.00
 45                0.00                     48.56                   -10.00         151.60                -10.00       100.00
 50                0.00                     43.57                   -10.00         151.60                -10.00       100.00
 55                0.00                     38.57                   -10.00         151.60                -10.00       100.00
 60                0.00                     33.58                   -10.00         151.60                -10.00       100.00
 65                0.00                     28.60                   -10.00         151.60                -10.00       100.00
 70                0.00                     23.61                   -10.00         151.60                -10.00       100.00
 75                0.00                     18.64                    -9.72         152.60                 -9.72       100.00
 80                0.00                     13.68                    -8.84         155.70                 -8.84       100.00
 85                0.00                      8.77                    -7.95         158.90                 -7.95       100.00
 90                0.00                      4.08                    -7.08         162.10                 -7.08       100.00
 95                0.00                      2.52                    -6.25         165.10                 -6.25       100.00
100                0.00                      6.79                    -5.53         167.70                 -5.53       100.00
105                0.00                     11.65                    -4.98         169.70                 -4.98       100.00
110                0.00                     16.59                    -4.66         170.80                 -4.66       100.00
115                0.00                     21.56                    -4.62         170.90                 -4.62       100.00
120                0.00                     26.54                    -4.86         170.10                 -4.86       100.00
125                0.00                     31.53                    -5.36         168.30                 -5.36       100.00
130                0.00                     36.52                    -6.04         165.80                 -6.04       100.00
135                0.00                     41.51                    -6.84         162.90                 -6.84       100.00
140                0.00                     46.51                    -7.71         159.80                 -7.71       100.00
145                0.00                     51.50                    -8.60         156.60                 -8.60       100.00
150                0.00                     56.50                    -9.46         153.50                 -9.46       100.00
155                0.00                     61.49                   -10.00         151.60                -10.00       100.00
160                0.00                     66.49                   -10.00         151.60                -10.00       100.00
165                0.00                     71.48                   -10.00         151.60                -10.00       100.00
170                0.00                     76.48                   -10.00         151.60                -10.00       100.00
175                0.00                     81.48                   -10.00         151.60                -10.00       100.00
180                0.00                     86.47                   -10.00         151.60                -10.00       100.00
185                0.00                     91.47                   -10.00         151.60                -10.00       100.00




Comsearch Proprietary


                                                                               SES Government Solutions, Inc.
                                                                       Ka-Band Earth Station – MacDill AFB, Fla.
                                                                                Frequency Coordination Report




Coordination Values                       MACDILL AFB, FL
Licensee Name                             SES Government Solutions, Inc.
Latitude (NAD 83)                         27° 50' 34.7" N
Longitude (NAD 83)                        82° 28' 59.4" W
Ground Elevation (AMSL)                   0.97 m / 3.2 ft
Antenna Centerline (AGL)                  2.74 m / 9.0 ft
Antenna Model                             GD/Prodelin 1.8 Meter
Antenna Mode                                      Receive 18.0 GHz                           Transmit 28.0 GHz
Interference Objectives: Long Term                -156.0 dBW/MHz         20%                 -151.0 dBW/4 kHz 20%
                             Short Term           -146.0 dBW/MHz         0.01%               -128.0 dBW/4 kHz
                             0.0025%
 Max Available RF Power                                                 -31.3 (dBW/4 kHz)

                                                                          Receive 18.0 GHz
                  Transmit 28.0 GHz
                  Horizon                  Antenna                  Horizon        Coordination          Horizon      Coordination
Azimuth (°)       Elevation (°)            Discrimination (°)       Gain (dBi)     Distance (km)         Gain (dBi)   Distance (km)
190                0.00                     96.47                   -10.00         151.60                -10.00       100.00
195                0.00                    101.46                   -10.00         151.60                -10.00       100.00
200                0.00                    106.46                   -10.00         151.60                -10.00       100.00
205                0.00                    111.46                   -10.00         151.60                -10.00       100.00
210                0.00                    116.45                    -9.46         153.50                 -9.46       100.00
215                0.00                    121.45                    -8.60         156.60                 -8.60       100.00
220                0.00                    126.44                    -7.71         159.80                 -7.71       100.00
225                0.00                    131.44                    -6.84         162.90                 -6.84       100.00
230                0.00                    136.43                    -6.04         165.80                 -6.04       100.00
235                0.00                    141.43                    -5.35         168.30                 -5.35       100.00
240                0.00                    146.42                    -4.86         170.10                 -4.86       100.00
245                0.00                    151.40                    -4.61         171.00                 -4.61       100.00
250                0.00                    156.39                    -4.65         170.80                 -4.65       100.00
255                0.00                    161.36                    -4.96         169.70                 -4.96       100.00
260                0.00                    166.32                    -5.52         167.70                 -5.52       100.00
265                0.00                    171.23                    -6.24         165.10                 -6.24       100.00
270                0.00                    175.92                    -7.07         162.10                 -7.07       100.00
275                0.00                    177.48                    -7.94         159.00                 -7.94       100.00
280                0.00                    173.21                    -8.83         155.80                 -8.83       100.00
285                0.00                    168.35                    -9.71         152.60                 -9.71       100.00
290                0.00                    163.41                   -10.00         151.60                -10.00       100.00
295                0.00                    158.44                   -10.00         151.60                -10.00       100.00
300                0.00                    153.46                   -10.00         151.60                -10.00       100.00
305                0.00                    148.47                   -10.00         151.60                -10.00       100.00
310                0.00                    143.48                   -10.00         151.60                -10.00       100.00
315                0.00                    138.49                   -10.00         151.60                -10.00       100.00
320                0.00                    133.49                   -10.00         151.60                -10.00       100.00
325                0.00                    128.50                   -10.00         151.60                -10.00       100.00
330                0.00                    123.50                   -10.00         151.60                -10.00       100.00
335                0.00                    118.51                   -10.00         151.60                -10.00       100.00
340                0.00                    113.51                   -10.00         151.60                -10.00       100.00
345                0.00                    108.52                   -10.00         151.60                -10.00       100.00
350                0.00                    103.52                   -10.00         151.60                -10.00       100.00
355                0.00                     98.52                   -10.00         151.60                -10.00       100.00




Comsearch Proprietary


                                                              SES Government Solutions, Inc.
                                                      Ka-Band Earth Station – MacDill AFB, Fla.
                                                               Frequency Coordination Report



 5. Contact Information
For questions or information regarding the 28 GHz Frequency Coordination Report,
please contact:



Contact person:         Joanna Lynch
Title:                  Manager, Spectrum & Data Solutions
Company:                Comsearch
Address:                19700 Janelia Farm Blvd., Ashburn, VA 20147
Telephone:              703-726-5711
Fax:                    703-726-5599
Email:                  jlynch@comsearch.com
Web site:               www.comsearch.com




Comsearch Proprietary


                                            COMSEARCH
                                       Earth Station Data Sheet
                               19700 Janelia Farm Boulevard, Ashburn, VA 20147
                                (703)726-5500 http://www.comsearch.com




 5. CERTIFICATION

I HEREBY CERTIFY THAT I AM THE TECHNICALLY QUALIFIED PERSON RESPONSIBLE FOR THE
PREPARATION OF THE FREQUENCY COORDINATION DATA CONTAINED IN THIS APPLICATION,
THAT I AM FAMILIAR WITH PARTS 101 AND 25 OF THE FCC RULES AND REGULATIONS, THAT I
HAVE EITHER PREPARED OR REVIEWED THE FREQUENCY COORDINATION DATA SUBMITTED
WITH THIS APPLICATION, 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 13, 2014




                                          -Comsearch Proprietary


Link Budget Creator— Rev 3.2.9: August 18, 2014                          Tier 2                     Tier 2
Ground Parameter                                                       Teleport                     Telco
  Location                                                     Vemon (LHCP), United States   Tampa, United States
  Latitude                                        ()                      34.2                      27.8
  Longitude (East)                                (°)                    260.7                      277.5
  E/S Range to SV                                 (km)                  10138.9                    92021
  E/S Elevation to SV                             (°)                     30.2                      43.5
  E/S Altitude                                    (Km)                     0.3                       0.0
  SV Beam Identifier                              (#)
  Minutes Into Pass (Sample #55)                  (Min)
  Telco Spot Beam Off—Angle                       (°)
  Telco Spot Beam Diameter                        (km)
  Maximum Roundtrip Latency                       (msec)
Modulation Parameters                                                   Forward
  Enter Receiver                                  Type                  DVB—S2
  Modem Overhead                                  (%)                     3.3%
  Number of Carriers per Channel                  (#)                       1
  Available Bandwidth                             (Hz)                216,000,000
  Channel Symbol Rate                             (sps)                180,000,000
  Channel Modulation Type                                                32APSK
  Channel FEC Rate                                                        0.83
  Channel Spectral Efficiency                     (bits/Sym)              447
  Channel Throughput (100% / 100% of Full Rate)   (bps)               725,506,073
Uplink                                                                  Forward
  E/S Tx Channels per HPA                         (#)                       5
  E/S Tx Carrier Frequency                        (MHz)                  28,020
  E/S Tx HPA Power Level                          (W)                     500
  E/S Tx OBO                                      (d8)                    —8.00
  E/S Tx Post—HPA Losses                          (dB)                    224
  E/S Tx Antenna Gain (7.3 m / 2.4 m)             (dB)                   64.82
  E/S Tx EIRP Per Channel                         (dBw)                   74.58
  E/S Tx Pointing Loss                            (dB)                    —0.50
  E/S Tx RF Link Availabllity                     (%)                    75.000
  E/S Tx Atmospheric Losses                       (dB)                    ~1.27
  E/S Tx Spreading Loss                           (dB)                   —151.11
Satellite                                                               Forward
  SV Number of Channels per HPA                   (#)                       1
  SV Rx GT                                        (dB/K)                   5.41
  SV Rx Power Per Tier                            (dBw)                  ~123.31
  SV Rx Flux Density Per Tier                     (dBW/mZ)               —78.31
  SV Tx OBO (ALC / ALC)                           (d8)                    —3.80
  SV Tx Post—TWTA Losses                          (dB)                    ~1.50
  SV Tx Antenna Gain                              (dBi)                  31.81
  SV Tx EIRP Per Channel/Carrier                  (dBw)                  44.64
  SV Tx Pointing Loss                             (dB)                    0.00
Downlink                                                                Forward
  E/S Rx Carrier Frequency                        (MHz)                  18,220
  E/S Rx Wavelength                               (m)                   o.016454
  E/S Rx RF Link Availability                     (%)                      50
  E/S Rx Atmospheric Losses                       (d8)                    —0.51
  E/S Rx Pointing Loss                            (d8)                    —0.50
  E/S Rx Antenna Gain (2.4 m / 7.3 m)             (dBi)                   51.1
  E/S Rx Effective GT                             (dB/K)                  27.6
  E/S Rx Power Per Channel                        (dBw)                  ~102.3
  E/S Rx Flux Density Per Channel                 (dBW/mZ)               —106.7
TotalLink                                                               Forward
  Carrier / Noise Bandwidth                       (dB)                   82.55
  Carrier / Noise Uplink                          (d8)                   22.74
  Carrier / Noise Downlink                        (dB)                   20.25
  Carrier / Intermodulation Im (C/im)             (dB)                   29.35
  (C/N) — Total Actual                            (d8)                    17.19
  (C/N) — Total Required                          (d8)                    16.60
  (E,/N,) — Total Actual                          (d8)                    11.00
  (E,/N,) — Total Required                        (d8)                    10.40
  Excess Margin                                   (dB)                    0.59
  Fade Margin                                     (dB)                    19.39


                                                                                                                          Annex 3



                    O3b Network Link Analysis - Tier 2 Service For Tampa, United States
Link Budget Creator - Rev 3.2.9: August 18, 2014                           Tier 2                             Tier 2
Ground Parameter                                                         Teleport                              Telco
  Location                                                      Vernon (LHCP), United States            Tampa, United States
  Latitude                                         (°)                      34.2                               27.8
  Longitude (East)                                 (°)                     260.7                               277.5
  E/S Range to SV                                  (km)                   10138.9                             9292.1
  E/S Elevation to SV                              (°)                      30.2                               43.5
  E/S Altitude                                     (km)                     0.3                                 0.0
  SV Beam Identifier                               (#)                                           12
  Minutes Into Pass (Sample #55)                   (Min)                                        26:8
  Telco Spot Beam Off-Angle                        (°)                                          0.20
  Telco Spot Beam Diameter                         (km)                                        64.90
  Maximum Roundtrip Latency                        (msec)                                      129.63
Modulation Parameters                                                    Forward                              Return
  Enter Receiver                                   Type                  DVB-S2                               DVB-S2
  Modem Overhead                                   (%)                      3.3%                                3.2%
  Number of Carriers per Channel                   (#)                        1                                   1
  Available Bandwidth                              (Hz)                216,000,000                          216,000,000
  Channel Symbol Rate                              (sps)               180,000,000                          180,000,000
  Channel Modulation Type                                                32APSK                                 8PSK
  Channel FEC Rate                                                          0.83                                0.75
  Channel Spectral Efficiency                      (bits/Sym)               4.17                                2.25
  Channel Throughput (100% / 100% of Full Rate)    (bps)              725,506,072.87                        391,954,582
Uplink                                                                   Forward                              Return
  E/S Tx Channels per HPA                          (#)                        5                                   1
  E/S Tx Carrier Frequency                         (MHz)                  28,020                              28,020
  E/S Tx HPA Power Level                           (W)                       500                                 40
  E/S Tx OBO                                       (dB)                     -8.00                               -3.00
  E/S Tx Post-HPA Losses                           (dB)                     -2.24                               -0.77
  E/S Tx Antenna Gain (7.3 m / 2.4 m)              (dB)                     64.82                               55.0
  E/S Tx EIRP Per Channel                          (dBW)                    74.58                               67.27
  E/S Tx Pointing Loss                             (dB)                     -0.50                               -0.50
  E/S Tx RF Link Availability                      (%)                    75.000                              50.000
  E/S Tx Atmospheric Losses                        (dB)                     -1.27                               -0.96
  E/S Tx Spreading Loss                            (dB)                   -151.11                             -150.35
Satellite                                                                Forward                              Return
  SV Number of Channels per HPA                    (#)                        1                                   5
  SV Rx G/T                                        (dB/K)                   5.41                                4.66
  SV Rx Power Per Tier                             (dBW)                  -123.31                             -130.29
  SV Rx Flux Density Per Tier                      (dBW/m2)                -78.31                              -84.54
  SV Tx OBO (ALC / ALC)                            (dB)                     -3.80                              -15.00
  SV Tx Post-TWTA Losses                           (dB)                     -1.50                               -1.50
  SV Tx Antenna Gain                               (dBi)                    31.81                               31.90
  SV Tx EIRP Per Channel/Carrier                   (dBW)                    44.64                               26.54
  SV Tx Pointing Loss                              (dB)                     0.00                                0.00
Downlink                                                                 Forward                              Return
  E/S Rx Carrier Frequency                         (MHz)                  18,220                              18,220
  E/S Rx Spreading Loss                            (dB)                   -150.35                             -151.11
  E/S Rx RF Link Availability                      (%)                    50.000                              75.000
  E/S Rx Atmospheric Losses                        (dB)                     -0.51                               -0.69
  E/S Rx Pointing Loss                             (dB)                     -0.50                               -0.50
  E/S Rx Antenna Gain (2.4 m / 7.3 m)              (dBi)                    51.08                               61.91
  E/S Rx Effective G/T                             (dB/K)                   27.59                               38.84
  E/S Rx Power Per Channel                         (dBW)                 -102.32                              -110.51
 E/S Rx Flux Density Per Channel                   (dBW/m2)              -106.72                              -125.76
Total Link                                                               Forward                              Return
  Carrier / Noise Bandwidth                        (dB)                   82.55                                82.55
  Carrier / Noise Uplink                           (dB)                   22.74                                15.76
  Carrier / Noise Downlink                         (dB)                   20.25                                12.46
  Carrier / Intermodulation Im (C/Im)              (dB)                   29.35                                25.81
  (C/N) - Total Actual                             (dB)                   17.19                                10.50
  (C/N) - Total Required                           (dB)                   16.60                                 9.50
  (Eb/No) - Total Actual                           (dB)                   11.00                                 6.98
  (Eb/No) - Total Required                         (dB)                    10.40                               5.98
  Excess Margin                                    (dB)                    0.59                                1.00
  Fade Margin                                      (dB)                    19.39                               12.70



Document Created: 2014-08-21 11:06:28
Document Modified: 2014-08-21 11:06:28

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