P&L International, Inc. – ZipPhaser l (Stealthray 1000 by Raysat) first generation Phaser Array Antenna system for the maritime industry. The benefits, low profile, high performance, light weight, all are state of the art. The first generation antennas were made in Sofia, Bulgaria. The product is sound and has great potential in the marine communications. The satellite networks approving the antenna were, Intelsat, SES Americom and Loral Systems. The challenges were adjacent satellite interference of 2 degrees between satellites which is controlled by the FCC. Below is original documentation on the legal findings and why P&L International, Inc. has re-developed their product line strategy around ZipPhaser ll to correct the problems associated with the original design.
Before the
FEDERAL COMMUNICATIONS COMMISSION – RaySat Antenna Systems Stealthray 1000 – ZipPhaser 1
Washington, DC 20554
MODIFICATION APPLICATION
Raysat Antenna Systems, LLC (“RAS”) hereby submits this application to modify the
earth station authorizations granted to it in the above-captioned licensing proceedings.1
Specifically, consistent with the increased power available in the latest generation of the
StealthRayTM antenna, RAS seeks to add new emission designators to the StealthRayTM Licenses
to provide higher data rate communications services to U.S. government, military and other
customers.2 In addition RAS seeks to alter the satellite points of communication associated with
the StealthRayTM Licenses. Finally, RAS requests that the hub earth station associated with
1 Application of Raysat Antenna System, LLC for Authority to Operate 400 Land Mobile-Satellite
Service (“LMSS”) Earth Stations in the 14.0-14.5 GHz and 11.7-12.2 GHz Frequency Bands, File Nos.
SES-LIC-20060629-01083, et seq., Order and Authorization, DA 08-401 (Int’l Bureau and OET, Feb. 15,
2008) (“Order”) See also Call Signs E060101, E060447, E060448, E060449, E060450 and E060451 (the
“StealthRayTM Licenses”). In this modification application, the FCC Forms 312B that RAS files
for each license will contain only that technical information that is added or modified.
2 The StealthRayTM Licenses are composed of six separate network authorizations. Because RAS
requests the same general modifications to each license (with the exception of hub earth station changes)
and in the interest of administrative convenience, RAS has prepared a single narrative to accompany all
six modification applications.
Application of Raysat Antenna Systems,
LLC for Authority to Operate 400 Land
Mobile-Satellite Service (“LMSS”) Earth
Stations in the 14.0-14.5 GHz and 11.7-12.2
GHz Frequency Bands
File Nos. SES-LIC-20060629-01083
SES-LIC-20060629-02248
SES-LIC-20060629-02249
SES-LIC-20060629-02250
SES-LIC-20060629-02251
SES-LIC-20060629-02252
certain network call signs be modified due to changes in its operational requirements and
business plans.
No other license modifications are proposed and RAS does not seek to alter the license
conditions imposed by the Commission in the Order granting the StealthRayTM Licenses. As
discussed herein, grant of this modification application will serve the public interest.
I. DISCUSSION
RAS files this modification application to make three principal changes to the authority
granted by the Commission in the StealthRayTM Licenses. First, because the next generation of
the StealthRayTM antenna employs a higher-power block up-converter (“BUC”), RAS seeks to
add new emission designators to provide higher data rate communications services to U.S.
government, military and other customers. Second, RAS seeks to add the Horizons-2 and
Galaxy-16 satellites and to remove SBS-6 as authorized satellite points of communication.
Third, RAS requests that the hub earth station associated with certain authorized networks be
modified. As described more fully herein, grant of this modification application will strongly
serve the public interest by improving service to RAS’s customers.
A. Authority for Wider Bandwidth, Higher Data Rate Communications
1. New Emissions Designators
To enhance the operating characteristics of the StealthRayTM antenna, RAS has
developed a version with a higher-power BUC.3 The new BUC allows the antenna to operate
with up to 41.2 dBW EIRP, permitting the use of wider bandwidth emissions and significantly
3 The original StealthRayTM design includes a BUC located within the antenna housing, while the new
design locates the BUC outside the housing, improving thermal characteristics of the StealthRayTM
terminal and enhancing link performance. No other aspect of the StealthRayTM antenna design will
change. Thus, antenna gain characteristics, pointing rates and accuracies, network and antenna control
functionality and other factors remain identical to the authorized StealthRayTM antenna. A Radiation
Hazard Analysis is included as Attachment 1.
enhancing throughput and link performance. This, in turn, results in higher data rates and more
robust service to U.S. government, military and other customers. The use of wider bandwidth
emissions does not change the adjacent satellite interference characteristics and the signal
remains within the off-axis EIRP limits mandated by the Order.
The increased power associated with use of the larger BUC will permit RAS to utilize the
following emissions with the StealthRayTM antenna: 2M07G7W, 9M47G7W and 10M7G7W.
RAS respectfully requests that the StealthRayTM Licenses be modified to reflect the higher power
BUC and new emission designators as more fully described in the attached link budgets and in
the FCC Form 312.4
Accounting for transmission losses through the antenna, the maximum uplink EIRP per
carrier is increased from 30.5 dBW (for the 518 kHz emission) to 35.7 dBW (for the new 2 MHz
emission) and 41.2 dBW (for the new 9 and 10 MHz emissions), respectively. However, given
the wider bandwidths, the maximum EIRP spectral density remains within the limits of the
original filing as coordinated and authorized. Thus, the use of these wider bandwidth emissions
improves the adjacent satellite protection characteristics of the StealthRayTM terminal. A
summary of some key link budget parameters is given in Table 1.
Emission
Designator
FEC Rate Necessary Bandwidth
(MHz)
Flange PSD
(dBW/4kHz)
2M07G7W 0.3125 2.07 -18.1
9M47G7W 0.431 9.47 -19.2
10M7G7W 0.2 10.67 -19.7
Table 1: Link Budget Summary
4 The link budgets are included as Attachment 2.
2. Other Operational Conditions Remain Unchanged
RAS hereby confirms that it will continue to operate the StealthRayTM antenna in full
conformance with the express conditions contained in Order and the StealthRayTM Licenses. In
particular, RAS will operate such that off-axis EIRP spectral density levels are no greater than
that permitted for routinely licensed VSATs, and on a secondary basis only (immediately ceasing
transmissions in the event of harmful interference to primary and U.S. government operations).
RAS further confirms that the requested modifications will have no adverse impact on other
authorized users of the Ku-band. The StealthRayTM antenna will continue to meet the stated
levels necessary to protect NASA TDRSS operations and Radio Astronomy stations forth in the
applicable agreements referenced in paragraph 50 of the Order.
The proposed license modification will not affect the control and monitoring functions
included in RAS’s licensed networks to ensure that the StealthRayTM antenna operations do not
cause harmful interference to other users of the spectrum. Thus, there is no increased potential
for interference from the modified StealthRayTM operations.
B. Satellite Points of Communication
RAS requests that the FCC add satellites Horizons-2 at 74.05 degrees WL and Galaxy-16
at 99 degrees WL5 as authorized satellite points of communications. The coordination letters
associated with the addition of these satellites are included in this modification application as
Attachment 3. RAS also seeks to remove the SBS-6 satellite as an authorized satellite point of
communication.
5 Galaxy-16 launched on June 18, 2006 and replaced Galaxy 4R. Only Galaxy 4R is available in the list of satellites
on the FCC Form 312B.
These satellite changes will help optimize RAS’s use of available capacity and better
support the needs of RAS’s commercial, government and military customers. Accordingly, grant
of the requested modification will further the public interest.
C. Modification of Hub Earth Stations
Due to changes in its operational requirements and business objectives, RAS requests that
the hub earth stations associated with certain networks be modified. Specifically, the G2
(KA416), Stratos (E950149), SES-Americom (E920698), and SDN Global (E050007) hubs are
to be replaced with Intelsat Riverside (E020126), HNS (E000166 and E940460), and the New
Skies Mediaport (E000102). Also, an additional earth station (E070139) is to be added at the
Intelsat teleport in Hagerstown, MD. A summary list of the desired hub earth stations is included
in Table 2.
Raysat Auth.
IBFS File No.
Raysat
Call Sign
Associated Hub Earth
Station (Original)
Associated Hub Earth
Station (New)
SES-LIC-
20060629-
01083
E060101 Spacenet, McLean, VA
(Call Sign E860326)
SAME
SES-LIC-
20060629-
02248
E060447 Intelsat, Hagerstown,
MD (Call Signs
E040140, E040141,
E040414, E040475)
SAME but add E070139
SES-LIC-
20060629-
02249
E060448 G2, Silver Spring, MD
(Call Sign KA416)
HNS, Germantown, MD (Call
Sign E000166)
SES-LIC-
20060629-
02250
E060449 Stratos, Englewood, CO
(Call Sign E950149)
Intelsat, Riverside, CA (Call
Sign E020126)
SES-LIC-
20060629-
02251
E060450 SES Americom,
Woodbine, MD (Call
Sign E920698)
SES New Skies, Manassas, VA
(Call Sign E000102)
SES-LIC-
20060629-
02252
E060451 Charlotte, NC (Call Sign
E050007)
HNS, North Las Vegas, NV
(Call Sign E940460)
The new hub earth stations will better satisfy RAS’s business objectives and its
customers’ service needs. Accordingly, grant of the requested hub earth station modifications is
fully consistent with the public interest.
II. SECTION 304 WAIVER
In accordance with Section 304 of the Communications Act of 1934, 47 U.S.C. § 304
RAS hereby waives any claim to the use of any particular frequency or of the electromagnetic
spectrum because of previous use of the same, whether by license or otherwise.
III. CONCLUSION
For all of the foregoing reasons, RAS respectfully requests that the StealthRayTM
Licenses be modified to include the new emission designators and related operational
information, satellite points of communication and hub earth stations set forth in the instant
application.
Respectfully submitted,
s/ Carlos M. Nalda
__________________________
Carlos M. Nalda
Joshua T. Guyan
Squire Sanders & Dempsey L.L.P.
1201 Pennsylvania Avenue, NW
Suite 500
Washington, DC 20004
(202) 626-6659
Counsel for Raysat Antenna Systems, LLC
August 18, 2008
CERTIFICATION OF PERSON RESPONSIBLE
FOR PREPARING ENGINEERING INFORMATION
I hereby certify that I am familiar with Part 25 of the Commission’s Rules, that I have
either prepared or reviewed the engineering information submitted in this Modification
Application, and that it is complete and accurate to the best of my knowledge and belief.
Richard J. Barnett, PhD, BSc
Telecomm Strategies Inc.
6404 Highland Drive
Chevy Chase, Maryland 20815
(301) 656-8969
Dated: August 13, 2008
ATTACHMENT 1
RADIATION HAZARD ANALYSIS
1
Radiation Hazard Analysis
RaySat
This analysis predicts the radiation levels around a proposed earth station complex, comprised of
one (reflector) type antennas. 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 employees 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.
Earth Station Technical Parameter Table
Antenna Actual Diameter 0.245 meters
Antenna Surface Area 0.047 sq. meters
Antenna Isotropic Gain 26.8 dBi
Number of Identical Adjacent Antennas 1
Nominal Antenna Efficiency (ε) 35%
Nominal Frequency 14.25 GHz
Nominal Wavelength (λ) 0.0211 meters
Maximum Transmit Power / Carrier 20.0 Watts
Number of Carriers 1
Total Transmit Power 20.0 Watts
W/G Loss from Transmitter to Feed 0.5 dB
Total Feed Input Power 17.83 Watts
Near Field Limit Rnf = D²/4λ =0.71 meters
Far Field Limit Rff = 0.6 D²/λ = 1.71 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 reflector surface can be calculated from the expression:
PDrefl = 4P/A = 151.102 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 should receive training specifying this area as a high exposure
2
area. Procedures must be 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) = 53.423 mW/cm² (2)
from 0 to 0.71 meters
Evaluation
Uncontrolled Environment: Does Not Meet Controlled Limits
Controlled Environment: Does Not Meet Uncontrolled 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: 0.71 < R Rff = 1.7 meters
PDff = 22.885 mW/cm² at Rff
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 FarField 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. Usually this will correspond to the antenna gain pattern envelope defined by
the FCC or the ITU, which takes the form of:
Goff = 32 – 25log(Θ)
for Θ from 1 to 48 degrees; -10 dBi from 48 to 180 degrees
(Applicable for commonly used satellite transmit antennas)
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 two (2) degrees off axis At the far-field limit, we can calculate the power density
as:
Goff = 32 – 25log(2) = 32 – 7.52 dBi = 280.2 numeric
PD2 deg off-axis = PDffx 280.2/G = 13.55 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 D meters away from the center line of the dish, 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 = 0.53423 mW/cm² at D off axis (6)
See Section 8 for the calculation of the distance vs. elevation angle required to achieve this rule
for a given object height.
4
7.0 Region Between the Feed Horn and Sub-reflector
Transmissions from the feed horn are directed toward the subreflector surface, and are confined
within a conical shape defined by the feed horn. The energy between the feed horn and
subreflector is conceded to be in excess of any limits for maximum permissible exposure. This
area will not be accessible to the general public. Operators and technicians should receive training
specifying this area as a high exposure area. Procedures must be established that will assure that
all transmitters are rerouted or turned off before access by maintenance personnel to this area is
possible.
8.0 Evaluation of Safe Occupancy Area in Front of Antenna
The distance (S) from a vertical axis passing through the dish center to a safe off axis location in
front of the antenna can be determined based on the dish diameter rule (Item 6.0). Assuming a flat
terrain in front of the antenna, the relationship is:
S = (D/ sin α) + (2h – D – 2)/(2 tan α) (7)
Where: α = minimum elevation angle of antenna
D = dish 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 all but the most powerful stations (> 4 kilowatts RF at the feed).
For D = 0.245 meters
h = 2.0 meters, delta between antenna and object >1 m
Then:
α S
10 0.7 meters
15 0.5meters
20 0.4 meters
25 0.3 meters
30 0.3 meters
5
9.0 Summary of Results
The earth station site will be protected from uncontrolled access by virtue of the fact that it will
be mounted on the roof of a vehicle. 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 table below summarizes all of the above calculations.
6
RaySat
Parameter Abbr. Units Formula
Dish # Hub
Antenna Diameter Df 0.245 meters
Antenna Centerline h 2.0 meters
Antenna Surface Area Sa 0.047 meters2 (π * Df2 )/ 4
Antenna Ground Elevation GE 0.0 meters
Frequency of Operation f 14.25 GHz
Wavelength λ 0.0211 meters c / f
HPA Output Power PHPA 20.0 watts
HPA to Antenna Loss Ltx 0.5 dB
Transmit Power at Flange P 12.51 dBW 10 * Log(PHPA) – Ltx
17.83 watts
Antenna Gain Ges 26.8 dBi
473.2 n/a
PI π 3.1415927 n/a
Antenna Aperture Efficiency η 35% n/a Ges / (PI * Df /λ)2
1. Reflector Surface Region Calculations
Reflector Surface Power Density PDas 1511.02 W/m2 (16 * P)/(π * D2)
151.102 mW/cm2 Does Not Meet Controlled Limits
Does Not Meet Uncontrolled Limits
2. On-Axis Near Field Calculations
Extent of Near Field Rn 0.71 meters D2 / (4 *λ)
2.34 feet
Near Field Power Density PDnf 534.23 W/m2 (16 * η * P )/ (π *D2)
53.423 mW/cm2 Does Not Meet Controlled Limits
Does Not Meet Uncontrolled Limits
3. On-Axis Transition Region Calculations
Extent of Transition Region (min) Rtr 0.71 meters D2 / (4 *λ)
Extent of Transition Region (min) 2.34 feet
Extent of Transition Region (max) Rtr 1.71 meters (0.6 * D2) /λ
Extent of Transition Region (max) 5.62 feet
Worst Case Transition Region Power Density PDtr 534.23 W/m2 (16 *η * P)/ (π * D2)
53.423 mW/cm2 Does Not Meet Controlled Limits
Does Not Meet Uncontrolled Limits
Uncontrolled Environment Safe Operating Distance Rsu 38.1 m =(PDnf)*(Rnf)/Rsu
Controlled Environment Safe Operating Distance Rsc 7.6 m =(PDnf)*(Rnf)/Rsc
4. On-Axis Far Field Calculations
Distance to the Far Field Region Rf 1.7 meters (0.6 * D2) /λ
5.62 feet
On-Axis Power Density in the Far Field PDff 228.85 W/m2 (Ges * P) / (4 * π * Rf2)
22.885 mW/cm2 Does Not Meet Controlled Limits
Does Not Meet Uncontrolled Limits
5. Off-Axis Levels at the Far Field Limit and Beyond
Reflector Surface Power Density PDs 135.503 W/m2 (Ges * P) / (4 * π * Rf2)*(Goa/Ges)
Goa/Ges at example angle θ 2 degree 0.592 Goa = 32 – 25*log(θ)
13.5503 mW/cm2 Does Not Meet Uncontrolled Limits
PDs 5.3423 W/m2 ((16 * η * P )/ (π *D2))/100
0.53423 mW/cm2 Meets Uncontrolled Limits
S = (D/ sin α) + (2h – D – 2)/(2 tan α)
α = minimum elevation angle of antenna 10 deg
h = maximum height of object to be cleared, meters 2.0 m
GD = Ground Elevation Delta antenna-obstacle 1.0 m
elevation angle 10 0.7 m
15 0.5 m
20 0.4 m
25 0.3 m
30 0.3 m
2.4 feet
Note: Maximum FCC power density limits for 6 GHz is 1 mW/cm2 for general population/uncontrolled exposure as per
7. Off-Axis Safe Distances from Earth Station
FCC OE&T Bulletin No. 65, Edition 97-01 August 1997, Appendix A page 67.
Summary of All RadHaz Parameters
6. Off-axis Power Density in the Near Field and Transitional Regions Calculations
Power density 1/100 of Wn for one diameter
removed
ATTACHMENT 2
LINK BUDGETS
2M07G7W
Data Rate 480.0 kbps Sat Name TestSat
FEC 5/16 Turbo Sat Long. 79 deg
Modulation bpsk BPSK / QPSK Sat Rx, G/T 4.5 dB/K
Threshold Eb/No 2.00 dB Sat Tx, EIRP 48 dBW
Occ BW 1.35 SFD -90 dBW/m^2
Spread Spectrum n (Y / N) IP / OP ratio 5 dB
Chip Rate 1.54 Mchips/s U/L Freq 14.25 GHz
Total # of spread Links 1 D/L Freq. 11.95 GHz
Beta Factor 1.00
Rx Site Name Hub Tx Site Name Remote
Rx Lat 39 deg Tx Lat 39 deg
Rx Long 77 deg Tx Long 77 deg
Rx G/T 33 dB/K Tx Ant Gain 27.5 dBi
Ant Gain 55 dBi Tx Loss 2.5 dB
System Temp 150 K Radome loss 0.5 dB
Pointing Loss 0.35 dB
Tx HPA 14.28 W
ASI U/L EIRP in our direction -3.9 dBW/4KHz
DL interferemce, dBW/4KHz -30.6 dBW/4KHz DownLink Fade 5.5 dB
Threshold C/N -3.05 dB
C/Io Uplink WRT Saturation 38.1 dB/Hz
C/Io Downlink WRT Saturation 114.6 dB/Hz
Tx Slant Range 37536418.2 m Rx Slant Range 37536418.2 m
Tx FSL 207.0 dB Rx FSL 205.5 dB
Uplink EIRP 35.7 dBW OPBO 32.5 dB
Uplink C/No 61.1 dB-HZ D/L EIRP 15.5 dBW
U/L C/N -0.8 dB D/L C/No 71.1 dB/Hz
G(1m^2) Tx 44.5 dBi D/L C/N 9.3 dB
U/L flux density @ satellite -127.5 dBW/m^2
IPBO 37.5 dB
C/I up 13.7 dB
C/I dn 20.3 dB
Clear Sky C/(N + I) -1.35 dB
CS Eb/No 3.70 dB
Clear Sky (CS)Margin 1.70 dB
D/L Faded C/(N+I) -3.05 dB
D/L faded Eb/No 2.00 dB
D/L Faded Margin 0.00 dB
PSD @ ant Flange -18.1 dBW / 4KHz
Occupied BW 2073.6 KHz
D/L PSD/4KHz -11.6 dBW/4KHz
Tx Site Rx Site
Az Angle 183.18 183.18 deg
El Angle 44.80 44.80 deg
Pol Angle 2.47 2.47 deg
Interference Parameters
Data Parameters Satellite Parameters
Rx Site Parameters Tx Site Parameters
9M47G7W
Data Rate 756.1 kbps Sat Name TestSat
FEC 0.431 Turbo Sat Long. 79 deg
Modulation bpsk BPSK / QPSK Sat Rx, G/T 4.5 dB/K
Threshold Eb/No 4.70 dB Sat Tx, EIRP 48 dBW
Occ BW 1.35 SFD -90 dBW/m^2
Spread Spectrum y (Y / N) IP / OP ratio 5 dB
Chip Rate 7.02 Mchips/s U/L Freq 14.25 GHz
Total # of spread Links 1 D/L Freq. 11.95 GHz
Beta Factor 1.00
Rx Site Name Hub Tx Site Name Remote
Rx Lat 39 deg Tx Lat 39 deg
Rx Long 77 deg Tx Long 77 deg
Rx G/T 33 dB/K Tx Ant Gain 27.5 dBi
Ant Gain 55 dBi Tx Loss 1.5 dB
System Temp 150 K Radome loss 0.5 dB
Pointing Loss 0.35 dB
Tx HPA 40.00 W
ASI U/L EIRP in our direction -3.9 dBW/4KHz
DL interferemce, dBW/4KHz -30.6 dBW/4KHz DownLink Fade 7.1 dB
Threshold C/N -4.98 dB
C/Io Uplink WRT Saturation 49.1 dB/Hz
C/Io Downlink WRT Saturation 114.6 dB/Hz
Tx Slant Range 37536418.2 m Rx Slant Range 37536418.2 m
Tx FSL 207.0 dB Rx FSL 205.5 dB
Uplink EIRP 41.2 dBW OPBO 27.0 dB
Uplink C/No 66.6 dB-HZ D/L EIRP 21.0 dBW
U/L C/N -1.9 dB D/L C/No 76.6 dB/Hz
G(1m^2) Tx 44.5 dBi D/L C/N 8.1 dB
U/L flux density @ satellite -122.0 dBW/m^2
IPBO 32.0 dB
C/I up 12.6 dB
C/I dn 19.1 dB
Clear SkyC/(N+I) with 1 carrier -2.48 dB
CS Eb/No with 1 carriers 7.20 dB
CS Margin with 1 carriers 2.50 dB
D/L Faded C/(N+I) -4.98 dB
D/L Faded Eb/No with 1 carrie 4.70 dB
D/L Faded Margin 0.00 dB
Aggregate PSD @ ant Flange -19.2 dBW / 4KHz
Occupied BW 9473.5 KHz
D/L PSD/4KHz -12.8 dBW/4KHz
Tx Site Rx Site
Az Angle 183.18 183.18 deg
El Angle 44.80 44.80 deg
Pol Angle 2.47 2.47 deg
Interference Parameters
Data Parameters Satellite Parameters
Rx Site Parameters Tx Site Parameters
10M7G7W
Data Rate 1580.0 kbps Sat Name TestSat
FEC 0.200 Turbo Sat Long. 79 deg
Modulation bpsk BPSK / QPSK Sat Rx, G/T 4.5 dB/K
Threshold Eb/No 1.50 dB Sat Tx, EIRP 48 dBW
Occ BW 1.35 SFD -90 dBW/m^2
Spread Spectrum n (Y / N) IP / OP ratio 5 dB
Chip Rate 7.90 Mchips/s U/L Freq 14.25 GHz
Total # of spread Links 1 D/L Freq. 11.95 GHz
Beta Factor 1.00
Rx Site Name Hub Tx Site Name Remote
Rx Lat 39 deg Tx Lat 39 deg
Rx Long 77 deg Tx Long 77 deg
Rx G/T 33 dB/K Tx Ant Gain 27.5 dBi
Ant Gain 55 dBi Tx Loss 1.5 dB
System Temp 150 K Radome loss 0.5 dB
Pointing Loss 0.35 dB
Tx HPA 40.00 W
ASI U/L EIRP in our direction -3.9 dBW/4KHz
DL interferemce, dBW/4KHz -30.6 dBW/4KHz DownLink Fade 7.1 dB
Threshold C/N -5.49 dB
C/Io Uplink WRT Saturation 49.1 dB/Hz
C/Io Downlink WRT Saturation 114.6 dB/Hz
Tx Slant Range 37536418.2 m Rx Slant Range 37536418.2 m
Tx FSL 207.0 dB Rx FSL 205.5 dB
Uplink EIRP 41.2 dBW OPBO 27.0 dB
Uplink C/No 66.6 dB-HZ D/L EIRP 21.0 dBW
U/L C/N -2.4 dB D/L C/No 76.6 dB/Hz
G(1m^2) Tx 44.5 dBi D/L C/N 7.6 dB
U/L flux density @ satellite -122.0 dBW/m^2
IPBO 32.0 dB
C/I up 12.1 dB
C/I dn 18.6 dB
Clear Sky C/(N + I) -2.99 dB
CS Eb/No 4.00 dB
Clear Sky (CS)Margin 2.50 dB
D/L Faded C/(N+I) -5.49 dB
D/L faded Eb/No 1.50 dB
D/L Faded Margin 0.00 dB
PSD @ ant Flange -19.7 dBW / 4KHz
Occupied BW 10665.0 KHz
D/L PSD/4KHz -13.3 dBW/4KHz
Tx Site Rx Site
Az Angle 183.18 183.18 deg
El Angle 44.80 44.80 deg
Pol Angle 2.47 2.47 deg
Interference Parameters
Data Parameters Satellite Parameters
Rx Site Parameters Tx Site Parameters
Data Rate 1580.0 kbps Sat Name TestSat
FEC 0.200 Turbo Sat Long. 79 deg
Modulation bpsk BPSK / QPSK Sat Rx, G/T 4.5 dB/K
Threshold Eb/No 1.50 dB Sat Tx, EIRP 48 dBW
Occ BW 1.35 SFD -90 dBW/m^2
Spread Spectrum n (Y / N) IP / OP ratio 5 dB
Chip Rate 7.90 Mchips/s U/L Freq 14.25 GHz
Total # of spread Links 1 D/L Freq. 11.95 GHz
Beta Factor 1.00
Rx Site Name Hub Tx Site Name Remote
Rx Lat 39 deg Tx Lat 39 deg
Rx Long 77 deg Tx Long 77 deg
Rx G/T 33 dB/K Tx Ant Gain 27.5 dBi
Ant Gain 55 dBi Tx Loss 1.5 dB
System Temp 150 K Radome loss 0.5 dB
Pointing Loss 0.35 dB
Tx HPA 40.00 W
ASI U/L EIRP in our direction -3.9 dBW/4KHz
DL interferemce, dBW/4KHz -30.6 dBW/4KHz DownLink Fade 7.1 dB
Threshold C/N -5.49 dB
C/Io Uplink WRT Saturation 49.1 dB/Hz
C/Io Downlink WRT Saturation 114.6 dB/Hz
Tx Slant Range 37536418.2 m Rx Slant Range 37536418.2 m
Tx FSL 207.0 dB Rx FSL 205.5 dB
Uplink EIRP 41.2 dBW OPBO 27.0 dB
Uplink C/No 66.6 dB-HZ D/L EIRP 21.0 dBW
U/L C/N -2.4 dB D/L C/No 76.6 dB/Hz
G(1m^2) Tx 44.5 dBi D/L C/N 7.6 dB
U/L flux density @ satellite -122.0 dBW/m^2
IPBO 32.0 dB
C/I up 12.1 dB
C/I dn 18.6 dB
Clear Sky C/(N + I) -2.99 dB
CS Eb/No 4.00 dB
Clear Sky (CS)Margin 2.50 dB
D/L Faded C/(N+I) -5.49 dB
D/L faded Eb/No 1.50 dB
D/L Faded Margin 0.00 dB
PSD @ ant Flange -19.7 dBW / 4KHz
Occupied BW 10665.0 KHz
D/L PSD/4KHz -13.3 dBW/4KHz
Tx Site Rx Site
Az Angle 183.18 183.18 deg
El Angle 44.80 44.80 deg
Pol Angle 2.47 2.47 deg
Interference Parameters
Data Parameters Satellite Parameters
Rx Site Parameters Tx Site Parameters
ATTACHMENT 3
COORDINATION LETTERS
Federal Communications Commission DA 08-401
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
RAYSAT ANTENNA SYSTEMS, LLC
Application for Authority to Operate 400
Land Mobile-Satellite Service (“LMSS”)
Earth Stations in the 14.0-14.5 GHz
and 11.7-12.2 GHz Frequency Bands
))))))))))))))))
IBFS File Nos. SES-LIC-20060629-01083;
SES-LIC-20060629-02248;
SES-LIC-20060629-02249;
SES-LIC-20060629-02250;
SES-LIC-20060629-02251;
SES-LIC-20060629-02252;
SES-AMD-20070620-00839
Call Signs: E060101; E060447;
E060448; E060449;
E060450; E060451
ORDER AND AUTHORIZATION
Adopted: February 15, 2008 Released: February 15, 2008
By the Chief, International Bureau, and the Chief, Office of Engineering and Technology:
I. INTRODUCTION
1. By this Order, we grant Raysat Antenna Systems, LLC (Raysat) authority to operate up to
four hundred technically identical mobile earth terminals (METs) that will be mounted on vehicles and
used while in motion throughout the continental United States.1 These METs will provide Land Mobile-
Satellite Service (LMSS), using the standard Ku-band frequency ranges of 14.0-14.5 GHz (Earth-tospace)
and 11.7-12.2 GHz (space-to-Earth), and will communicate with Fixed-Satellite Service (FSS)
satellites in geostationary satellite orbit (GSO).2 The Raysat METs will provide data communications to
end users in vehicles, including emergency responder and military vehicles, trucks, cars, trains, and other
in-motion platforms. Grant of this authorization will enhance competition in an important sector of the
mobile telecommunications market in the United States.
1 As discussed below in Part III.C.1, we are licensing the earth stations as six separate earth station call signs due to
the manner in which Raysat has proposed to operate its network.
2 The FSS is a radiocommunication service between earth stations at given positions, when one or more satellites are
used; the given position may be a specified fixed point or any fixed point within specific areas; in some cases this
service includes satellite-to-satellite links, which may also be operated in the inter-satellite service; the FSS also may
include feeder links for other space radio-communication services. See 47 C.F.R. § 2.1.
Federal Communications Commission DA 08-401
2
II. BACKGROUND
A. Application and Amendment
2. Raysat’s application originally sought authority to operate a Ku-band mobile satellite network
consisting of up to four thousand in-motion METs to be mounted on vehicles operating throughout the
United States.3 Raysat subsequently amended this application on June 20, 2007, to reduce the requested
number of remote METs from 4000 to 400 and to provide additional information with respect to certain
operational characteristics of its proposed network.4
3. Description of System. Raysat’s proposed network will offer two-way communication data
capabilities to moving vehicles, including high-speed Internet access, Voice over Internet Protocol
(VoIP), access to government and corporate intranets, virtual private networks, streaming video and
audio, file sharing, and other services.5 Raysat anticipates that the greatest demand for its proposed
network will come from local, state, and federal government agencies.6 Raysat also expects demand from
commercial enterprise customers.7
4. The space segment of Raysat’s network will use FSS space stations and associated hub earth
station facilities that the Commission has already authorized to provide FSS in the United States.8 In
order to permit both transmission and reception while the METs are in motion, the proposed network
utilizes a phased array antenna developed by Raysat that is mounted on the tops of vehicles.9 Each MET
consists of an outdoor antenna unit, an indoor controller, and a satellite communication modem.10
5. According to Raysat, its system employs antenna pointing systems to ensure that antennas
will transmit only when correctly pointed towards the intended satellite. Raysat has designed its METs to
use Global Positioning System (GPS) signals to determine each MET’s location and calculate the
pointing direction to the target satellite.11 The METs are designed to employ a three-axis gyroscope as
3 Raysat, Inc., Application for Authority to Operate 4,000 In-Motion Mobile Satellite Antennas in the 14.0-14.5
GHz and 11.7-12.2 GHz Frequency Bands, IBFS File No. SES-LIC-20060629-01083 (Application). The Raysat
application was originally filed on June 29, 2006, by an affiliated company, Raysat, Inc. Raysat, Inc. is a developer
and manufacturer of phased array antennas for use in satellite communications and is one of four members of the
Raysat limited liability corporation. Id. at 3.
4 Raysat Antenna Systems, LLC, Application for Authority to Operate 400 Land Mobile-Satellite Service (“LMSS”)
Earth Stations in the 14.0-14.5 GHz and 11.7-12.2 GHz Frequency Bands, IBFS File No. SES-AMD-20070620-
00839 (Amendment).
5 Application at 4. Raysat estimates that the forward channel of its proposed service will offer speeds of 1 to 14
megabits per second (Mbps), with a return channel of 128 to 512 kilobits per second (kbps). Id.
6 Application at 4-5.
7 Application at 5. Because of the size and cost of the antenna and the cost of the service, Raysat does not view this
service as a consumer product. Id. at 3.
8 Application at 2. The proposed FSS space stations are as follows: Intelsat-Americas 7 at 129° W.L.; Intelsat-
Americas 8 at 89° W.L.; AMC-4 at 101° W.L.; AMC-5 at 79° W.L.; AMC-6 at 72° W.L.; SBS-6 at 74° W.L.; and
Horizons-1 at 127° W.L. Id. The proposed earth station hubs are in the following locations: (1) McLean, VA (Call
Sign E860326); (2) Hagerstown, MD (Call Signs E040140, E040141, E040414, E040475); (3) Silver Spring, MD
(Call Sign KA416); (4) Englewood, CO (Call Sign E950149); (5) Woodbine, MD (Call Sign E920698); and (6)
Charlotte, NC (Call Sign E050007). Id.
9 Application at 2.
10 Application at 6.
11 Application at 6.
Federal Communications Commission DA 08-401
3
well as receive power measurements to maintain the antenna pointing to within close tolerances.12 Raysat
also indicates that each MET automatically searches for and acquires the target satellite and maintains
pointing accuracy by means of automatic control of the azimuth, elevation, and polarization angles while
the antenna is in motion.13 According to Raysat, the received signal from the target satellite is constantly
sampled, and if the received power exceeds a specific level, the MET will track that satellite signal.14
Raysat indicates that the MET will transmit only if there is a signal lock, i.e., the MET verifies the
radiofrequency characteristics of the received signal, network identification, and other parameters. When
signal lock is lost, the MET stops transmitting and searches for a new downlink signal, and, according to
Raysat, until the MET finds the correct downlink signal and is properly pointed, it is not permitted to
transmit.15
6. The Raysat system also incorporates automatic muting capabilities designed to protect
adjacent satellites from interference in case of pointing errors. Specifically, in the event a MET
mechanically mispoints by more than 0.5 degrees, it will mute the transmit carrier.16 Such muting will
occur in less than 100 milliseconds (ms).17 In addition, if the downlink signal from the satellite is lost for
any reason, the MET will sense this loss of signal and will mute transmissions.18 Once muted, the MET
may not re-commence transmissions until the pointing error is corrected, or the intended satellite receive
signal is re-acquired.19 Raysat has been testing its system since August 2005 under an experimental
license pursuant to Part 5 of the Commission’s rules.20
7. Procedural History. Raysat’s application was placed on public notice on July 5, 2006.21
Parsons Transportation Group Inc. filed comments in support of the application.22 ViaSat, Inc. (ViaSat)
filed comments requesting that the Commission not grant Raysat’s application unless Raysat corrects
alleged technical deficiencies in its application and resolves potential interference issues identified by
ViaSat.23 Raysat’s amendment was subsequently placed on public notice on June 27, 2007. No
comments were filed in response.24
B. VMES Rule Making
8. On May 15, 2007, the Commission released a Notice of Proposed Rule Making inviting
comment on proposed rules for the licensing and operation of Vehicle-Mounted Earth Stations (VMES)
12 Application at 6.
13 The initial acquisition time is less than 60 seconds, and the antenna is capable of tracking through the horizontal
plane at tracking speed of 60 degrees per second. Application at 5-6.
14 Amendment at 7.
15 Amendment at 7.
16 Application at 6.
17 Amendment at 8.
18 Amendment at 8. This muting will be accomplished in less than 100 milliseconds. Id.
19 Amendment at 8.
20 File Number 0135-EX-ML-2005, Call Sign WD2XTB (granted Jan. 23, 2006).
21 Report No. SES-00834, Satellite Radio Applications Accepted for Filing (July 5, 2006).
22 Comments of Parsons Transportation Group Inc. (filed Aug. 4, 2006) (Parsons Comments).
23 Comments of ViaSat, Inc. (filed Aug. 4, 2006) (ViaSat Comments). Raysat replied to ViaSat’s comments. See
Reply of Raysat, Inc. (filed Aug. 17, 2006) (Raysat Reply). ViaSat responded to Raysat’s reply comments. See
Response of ViaSat, Inc. (filed Aug. 29, 2006) (ViaSat Response).
24 Report No. SES-00939, Satellite Radio Applications Accepted for Filing (June 27, 2007).
Federal Communications Commission DA 08-401
4
as an application of the FSS in the conventional and extended Ku-band frequencies (VMES Notice).25
Specifically, the Commission sought comment on a proposal to allocate spectrum for use with VMES in
the FSS in the Ku-band at 14.0-14.5 GHz (Earth-to-space) on a co-primary basis and at 11.7-12.2 GHz
(space-to-Earth). The Commission also proposed to adopt Ku-band VMES licensing and service rules
modeled on the Commission’s rules for Ku-band Earth Stations on Vessels (ESVs).26 Raysat’s proposed
operations are similar to the VMES operations that are the subject of the VMES Notice, although, unlike
the operations under discussion in the VMES proceeding, Raysat does not seek to operate on a primary
basis in either the 11.7-12.2 GHz or 14.0-14.5 GHz bands. Thus, Raysat’s operations are addressed in
this Order under existing regulatory requirements and precedent. In the event Raysat seeks to operate
pursuant to the modified regulatory framework under consideration in the VMES proceeding, it would
need to apply for a license modification following any adoption of new or modified rules in that
proceeding.
III. DISCUSSION
9. Raysat proposes to operate its system as a Mobile-Satellite Service (MSS) using an existing
secondary MSS allocation in the 14.0-14.5 GHz frequency band and as a non-conforming use in the 11.7-
12.2 GHz band. As explained below, we grant Raysat’s application under the Commission’s existing
rules.
A. Space-to-Earth (11.7-12.2 GHz)
10. Raysat proposes to receive communications in the 11.7-12.2 GHz band from GSO FSS space
stations to METs. The 11.7-12.2 GHz band is allocated to the FSS for downlink operations on a primary
basis.27 It is also allocated on secondary basis for operation of grandfathered terrestrial radio stations.28
As Raysat recognizes, this band contains no allocation – either domestically or internationally – for
MSS.29 Thus, Raysat requests a waiver of U.S. Table of Frequency Allocations (Table of Allocations) to
permit the use of the 11.7-12.2 GHz frequency band for downlinks to its mobile-satellite network.30
11. The use of the radiocommunication frequencies in the United States must accord with the
Table of Allocations contained in Section 2.106 of the Commission’s rules.31 The Commission will grant
a waiver of the Table of Allocations for non-conforming uses “when there is little potential interference
into any service authorized under the Table of Allocations and when the non-conforming operator accepts
any interference from authorized services.”32 In particular, the Commission has permitted METs to
25 See Amendment of Parts 2 and 25 of the Commission’s Rules to Allocate Spectrum and Adopt Service Rules and
Procedures to Govern the Use of Vehicle-Mounted Earth Stations in Certain Frequency Bands Allocated to the
Fixed-Satellite Service, IB Docket No. 07-101, Notice of Proposed Rule Making, 22 FCC Rcd 9649 (2007) (VMES
Notice).
26 See id. at ¶ 2. Service rules for ESVs were adopted by the Commission in 2005 and are codified at 47 C.F.R.
§ 25.222. See Procedures to Govern the Use of Satellite Earth Stations on Vessels in the 5925-6425 MHz/3700-
4200 MHz Bands and 14.0-14.5 GHz/11.7-12.2 GHz Bands, Report and Order, 20 FCC Rcd 674 (2005) (ESV
Report and Order).
27 47 C.F.R. § 2.106.
28 47 C.F.R. § 2.106, Footnote NG184.
29 Application at 15.
30 Application at 15.
31 See 47 C.F.R. §2.102(a).
32 Application at 15, citing Fugro-Chance, Inc., Order and Authorization, 10 FCC Rcd 2860 (Int’l Bur. 1995)
(authorizing operations of receive-only mobile earth terminals in the 11.7-12.2 GHz band on a non-interference
basis).
Federal Communications Commission DA 08-401
5
receive in spectrum assigned to FSS downlinks “when a downlink transmission from a fixed-satellite
appears identical regardless of whether it is being received by fixed or mobile terminals.”33
12. We find that circumstances justify a waiver of the Table of Allocations in this instance.
Because Raysat’s METs will communicate with existing FSS space stations and will not alter either the
footprint or the power of downlink transmissions from these satellites, Raysat’s proposed operations will
not cause interference to other licensed users of the band. In similar circumstances, the Commission has
previously permitted METs to receive communications in Ku-band spectrum assigned for FSS space-to-
Earth communications.34 Accordingly, we conclude that a waiver of Section 2.106 of the Table of
Allocations serves the public interest. Raysat is permitted to receive FSS, however, in the 11.7-12.2 GHz
band on a non-conforming basis with respect to the Table of Allocations, solely on a non-interference
basis to all primary and secondary services allocated to use the band. Raysat must also accept
interference from any of these services. Raysat states in its application that it would accept such
conditions.35
B. Earth-to-Space (14.0-14.5 GHz)
13. Raysat’s METs will transmit in the 14.0-14.5 GHz frequency band. This band is allocated on
a primary basis for non-Federal FSS Earth-to-space communications.36 It also contains an allocation for
MSS Earth-to-space communications on a secondary basis for non-Federal government use.37 Because
Raysat proposes to operate its METs on a secondary basis in the 14.0-14.5 GHz band, we conclude that
such use is consistent with the Table of Allocations and grant authority for such operations, subject to the
conditions set forth in the paragraphs below.
14. Raysat must operate its MSS Earth-to-space communications on a secondary basis in the
14.0-14.5 GHz band and must protect other services with allocations on a primary basis in this band and
must coordinate with other services operating on a secondary basis. Other services in the band include (1)
FSS networks – both in the GSO and non-geostationary satellite orbit (NGSO) – operating on a primary
basis in the 14.0-14.5 GHz band, (2) space research services operating in the 14.0-14.5 GHz band on a
secondary basis,38 (3) Federal government terrestrial fixed and mobile stations operating on a secondary
basis in the 14.4-14.5 GHz segment, (4) the radio astronomy service operating on a secondary basis in the
14.47-14.5 GHz band, and (5) grandfathered Non-Federal land mobile stations licensed on a secondary
basis in the 14.2 – 14.4 GHz segment. We discuss each of these services below.
33 Id.
34 See, e.g., Qualcomm, Inc., Memorandum Opinion, Order, and Authorization, 4 FCC Rcd 1543, 1544 (1989)
(Qualcomm) (authorizing space-to-Earth transmissions to up to 12,400 land mobile earth terminals in the 11.7-12.2
GHz frequency band on a non-interference basis).
35 Application at 15.
36 47 C.F.R. § 2.106.
37 Id. Systems operating under a secondary allocation must not interfere with, and must accept interference from,
systems operating with primary status. Secondary services can, however, claim protection from harmful
interference from stations of the same or other secondary service(s) to which frequencies may be assigned at a later
date. 47 C.F.R. §§ 2.104(d); 2.105(c).
38 The secondary space research allocation is limited in the U.S. Table of Allocations to the 14.0-14.2. 47 C.F.R. §
2.106. However, the Table of Frequency Allocations in Article 5 of the International Telecommunication Union
Regulations includes a secondary space research allocation in the 14.2-14.3 GHz frequency band, and in the 14.4-
14.47 (uplink) frequency band.
Federal Communications Commission DA 08-401
6
1. Protection of FSS in the 14.0-14.5 GHz Band
a. GSO FSS
15. Non-routine Licensing. Raysat’s proposed system does not meet the Commission’s
technical requirements for routine licensing. The Commission routinely licenses Ku-band earth station
facilities that meet its two-degree orbital spacing technical requirements set forth in Part 25 of the
Commission’s rules.39 These technical requirements ensure that the earth stations’ operations do not
cause harmful interference to adjacent satellite systems.40 In part, these technical rules consist of a
minimum antenna diameter41 and maximum power level limits, which are set forth in Sections 25.209 and
25.212 of the Commission’s rules.42 Raysat acknowledges that, under the worst-case operating
conditions, its METs do not comply with the off-axis gain limits of Section 25.209.43 Specifically, Raysat
states that the antenna pattern of its METs does not comply with the limits of Section 25.209 between
1.25 and 3.0 degrees, between 5 and 6 degrees, at 9 degrees, and at 15 degrees.44 The worst case
difference is 2.4 decibels (dB) at 2.25 degrees.45
16. Although Raysat’s proposed system is not eligible for routine licensing, it may still be
authorized under the provisions of Section 25.220 of the Commission’s rules, which govern the licensing
of non-routine transmit/receive earth station operations that do not conform to Sections 25.209 and
25.212.46 Pursuant to Section 25.220, an applicant can seek authorization for non-routine transmit/receive
earth stations under one of two procedural options to demonstrate that it will not cause interference to
39 In 1983, the Commission established a two-degree orbital spacing policy to maximize the number of in-orbit
satellites serving the United States in either the C-band or the Ku-band. See Licensing of Space Stations in the
Domestic Fixed-Satellite Service and Related Revisions of Part 25 of the Rules and Regulations, Report and Order,
FCC 83-184, 54 Rad. Reg. 2d (P & F) 577 (1983) (Two-Degree Spacing Order); summary printed in Licensing
Space Stations in the Domestic Fixed-Satellite Service, 48 Fed. Reg. 40233 (Sept. 6, 1983), on recon., Licensing of
Space Stations in the Domestic Fixed-Satellite Service and Related Revisions of Part 25 of the Rules and
Regulations, Memorandum Opinion and Order, 99 FCC 2d 737 (1985). At that time, the Commission began
assigning adjacent in-orbit satellites to orbital locations two degrees apart in longitude, rather than the three to four
degrees longitude previously used.
40 See generally Two-Degree Spacing Order, 54 Rad Reg. 2d (P&F) 577 (adopting two degree orbital spacing policy
to maximize the number of in-orbit satellites operating in the Ku- and C-bands).
41 The antenna diameter is important because it affects the antenna gain. Decreasing the antenna diameter produces
wider main beams and higher side lobes. As a result, the allowable antenna gain pattern envelope effectively creates
a minimum earth station antenna diameter because at some point the main beam will become wide enough to cause
unacceptable interference to adjacent satellites. See VMES Notice, 22 FCC Rcd at 9669 ¶ 42 and n.88.
42 47 C.F.R. §§ 25.209 and 25.212.
43 See Application at 13. Many antennas are shaped like parabolas, or large curved bowls. The “axis,” or boresight,
is the line running through the center of the bowl and perpendicular to the plane of the edge of the bowl. The
majority of the energy is transmitted along the boresight in what is called the main beam of the antenna. The “offaxis”
angle is the angle formed by the axis and any other line running through the center of the bowl. The energy
transmitted from an antenna forms “ripples,” alternately increasing and decreasing in magnitude as the off-axis
angle increases. These ripples are called “side lobes.” See VMES Notice, 22 FCC Rcd at 9669 n.88.
44 Application at 13.
45 Application at 13.
46 47 C.F.R. § 25.220. The provisions of Section 25.220 were adopted in 2005 as part of the Commission’s space
station reform proceeding. See 2000 Biennial Regulatory Review – Streamlining and Other Revisions of Part 25 of
the Commission’s Rules Governing the Licensing of, and Spectrum Usage by, Satellite Network Earth Stations and
Space Stations, Fifth Report and Order in IB Docket No. 00-248, and Third Report and Order in CC Docket 86-496,
20 FCC Rcd 5666 (2005) (Fifth Report and Order).
Federal Communications Commission DA 08-401
7
satellites adjacent to the target satellites.47 Section 25.220(c)(1) provides that a non-routine earth station
may be authorized if the applicant proposes to limit the maximum power density of the signal input into
the earth station’s antenna to a certain level. This level is determined by reducing the maximum
permissible input power density for a routinely-licensed station by the number of decibels that the noncompliant
antenna exceeds the applicable gain limits in Section 25.209. Alternatively, Section
25.220(c)(2) provides that a non-routine Ku-band earth station that does not meet the input-power limit
prescribed in Section 25.220(c)(1) may be authorized if the applicant files a statement from the operator
of the target satellite certifying that it has coordinated the proposed operation of the non-routine earth
station with the operators of all adjacent GSO satellites within six degrees of separation.
17. We find that Raysat has satisfied the procedural options of both Section 25.220(c)(1) and
(c)(2). First, Raysat confirms that it has reduced the power density of its system pursuant to Section
25.220(c)(1) so that it appears to be a routine earth station from the perspective of adjacent satellites.48
Second, as part of its application Raysat submitted letters from the target satellite operators, as set forth
by Section 25.220(c)(2), which certify that the operators have coordinated Raysat’s proposed operations
with the operators of satellites within six degrees of the intended satellite.49 We find that these factors are
sufficient to protect currently-deployed GSO FSS space stations from interference from Raysat’s
proposed operations.
18. In the event, however, that another lawfully operating co-frequency FSS satellite commences
operation at a location within six degrees of the target satellites in the future, Raysat must reduce
aggregate off-axis radiation from its METs to levels one dB below the routine-processing envelope,
pending demonstration of coordination with the operator of the new satellite. Such a reduction in power
is reasonable during any period of time when Raysat’s operations have not been coordinated and will
minimize the possibility of unacceptable interference to new FSS satellites.
19. Pointing Accuracy, Operational Characteristics, and Link Margins. ViaSat questions
whether the pointing accuracy of Raysat’s METs is sufficient to prevent interference to adjacent satellites,
because Raysat proposes to operate its system using a single channel per carrier (SCPC) modem that
transmits at relatively narrow bandwidths at high power densities compared to a spread-spectrum
modem.50 Thus, ViaSat contends, minor shifts in antenna pointing would emit high power densities in the
direction of victim satellites. Although Raysat designed its system to mute transmissions when a MET
mispoints by more than 0.5 degrees,51 ViaSat observes that Raysat’s METs have a pointing error standard
deviation of 0.35 degrees, which ViaSat claims will not support viable service in real-world conditions
because such deviation would result in the MET not being operational 15 percent of the time.52 We are
satisfied that the pointing accuracy of Raysat’s system, in conjunction with the other protections for GSO
FSS operators described in this Order and Authorization, is sufficient to protect adjacent GSO FSS
satellites from interference. Although ViaSat is correct that SCPC systems have higher power density per
bandwidth than spread spectrum systems, Raysat has reduced the power density of its system under
47 See Fifth Report and Order at 5669 ¶ 3; 47 C.F.R.§ 25.202(a)(2).
48 Application at 13 (stating that the RF flange power density of the Raysat system will be -18.1 dBW/4 kHz, which
is more than 4 dB below the input power-density limit of -14 dBW/4kHz specified in Section 25.212(c)). The
minimum margin at any off-axis angle is 1.64 dB. See Application at 17.
49 See Application at Exhibit 1.
50 ViaSat Comments at 4.
51 See supra, para. 6.
52 ViaSat Comments at 5. Raysat also presents calculations to counter ViaSat’s assertion that its METs will not be
operational 15 percent of the time. Raysat Reply Comments at 8. Under Raysat’s calculations, the outage will be
less than 0.4 percent of the time. Id.
Federal Communications Commission DA 08-401
8
Section 25.220(c)(1), so that a Raysat MET appears to be a routine earth station from the perspective of
adjacent satellites.53 As long as an applicant demonstrates successfully that its MET meets the
Commission’s two-degree spacing requirements, we will not dictate whether a system uses SCPC or
spread spectrum technology, nor decline to authorize the system based upon claimed performance
deficiencies.54
20. In addition, ViaSat claims that Raysat fails to demonstrate that its METs can achieve a
positive link margin from the MET to the hub earth station using the power density level at which Raysat
proposes to operate, even under ideal circumstances.55 Raysat submitted an analysis disputing ViaSat’s
claim.56 We have reviewed the link budget information supplied by Raysat and are satisfied that a
positive link margin can be achieved for one of the two emissions requested, the 518KG7W emission.57
21. Raysat’s application, however, also seeks to operate a higher data rate emission (2M07G7W)
at an equivalent isotropically radiated power (EIRP) density of 6 dB less than its 518KG7W emission.
Raysat did not supply a link budget analysis for this emission, and we share ViaSat’s concern that Raysat
may not be able to achieve either a positive link margin or the required bit error rate without increasing
the EIRP at the MET.58 Without further information we cannot evaluate Raysat’s proposed use of this
emission designator. Accordingly, we dismiss, without prejudice, Raysat’s proposed use of the
2M07G7W emission designator.
22. Central Network Management. ViaSat also expresses concern that Raysat’s proposed use of
an unspread signal will increase the risk of interference to GSO FSS systems without central network
53 See supra, para. 17. We also note that Raysat has obtained certification from adjacent satellite operators stating
that they do not oppose its proposed operations. Id.
54 We note that we have authorized Raysat’s network based on the information that it has provided for a non-spread
spectrum system. See Amendment at 10 (stating that “the [Raysat] network uses only FDMA and TDMA
transmission schemes”). Raysat acknowledges that it must obtain prior Commission approval, through a
modification application, before it can use spread spectrum multiple access schemes, such as code division multiple
access (CDMA). See Amendment at 5.
55 ViaSat Comments at 6.
56 Raysat Reply at 9-10. In its application, Raysat states its system will operate using 1/3 forward error correcting
codes (FEC), but its demonstration is based on a slightly lower rate of 5/16 FEC. We are not concerned about this
minor difference because Raysat has demonstrated that it can achieve the required positive link margin, and we
expect that the FEC technique and rate that Raysat chooses in its final system implementation will not affect the
emission designator that Raysat has submitted in its application.
57 Raysat has demonstrated that it can achieve a link margin of 1.7 dB using a power spectral density of -18.1
dBW/4 kHz at the antenna flange for its 518KG7W emission. Emission designators describe the emission,
modulation, and transmission characteristics of the signal employed and are codified in Section 2.201 of the
Commission’s rules. See 47 C.F.R. § 2.201. Emissions are designated according to their classification and
necessary bandwidth, and a minimum of three symbols are used to describe the characteristics of a signal: the first
symbol shows the type of modulation; the second, the nature of the signal(s) modulating the main carrier; the third,
the type of information to be transmitted. See id. Accordingly, an emission with the designator 518KG7W is phase
modulated (G) with two or more channels containing quantized or digital information (7) transmitting a combination
of different types of information (W). See id. The prefix “518K” indicates that the bandwidth of the emission is 518
kilohertz. See 47 C.F.R. § 2.202(b)(2).
58 In order to achieve a non-negative link margin for the 2M07G7W emission, using the same FEC technique and
rate that it uses for its 518KG7W emission, Raysat would need to use a power spectral density of at least -19.8
(= -18.1 – 1.7) dBW/4 kHz at the antenna flange, resulting in a higher EIRP out of the earth station antenna. Raysat,
however indicates it would use a power spectral density of -24.1 dBW/4 kHz, which is 4.3 dB too low to achieve a
non-negative link margin, assuming the same FEC characteristics are used for the two emission types Raysat states
it intends to use.
Federal Communications Commission DA 08-401
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management.59 ViaSat argues that lack of central network management allows each antenna user to
adjust the power and bandwidth usage of the antenna, which could lead to aggregate power levels in
excess of the off-axis EIRP density mask set defined by Sections 25.209 and 25.134 of the rules and
result in interference to adjacent GSO FSS satellites.60 We find that Raysat’s application, as amended,
adequately addresses this concern. In its amendment, Raysat explains that each MET will operate
through a single hub earth station manned by qualified personnel that, subject to Raysat’s direction, will
ensure that the MET operates in accordance with Raysat’s license.61 Raysat states that it will assign each
individual MET to a particular hub and satellite, and that METs are not able to switch from one hub
station or satellite to another on their own.62 For this reason, we have authorized Raysat’s system as six
separate earth station licenses. Thus, there will be central control over all METs associated with a
particular hub.63
23. In sum, we conclude that we can license Raysat’s METs under our existing rules for nonroutine
earth stations. Specifically, Raysat has obtained certifications from adjacent GSO FSS operators
that they do not object to Raysat’s proposed operations. In addition, Raysat’s reduction in transmitter
power, combined with the antenna accuracy and muting capabilities of its system, will help minimize the
risk of interference to adjacent GSO FSS networks. Should interference in fact result to GSO FSS
networks from Raysat’s operations, it is incumbent upon Raysat to immediately cease transmissions from
the interfering MET in order to terminate the interference.
b. NGSO FSS
24. In 2001, the Commission permitted NGSO FSS gateway and user terminal uplinks to operate
in the 14.0-14.5 GHz band as a primary service.64 Thus, Raysat’s MSS network – as a secondary service
in this band – has an obligation to protect NGSO FSS operations from interference. We observe,
however, that there are no authorized Ku-band NGSO FSS systems and no pending applications for such
systems.65
25. Raysat states that the antenna radiation pattern of its METs will not meet the off-axis EIRP
limitations of Section 25.209(a)(2) for regions not in the plane of the geostationary arc, i.e., the elevation
plane.66 Raysat has committed, however, to take all necessary steps to protect any future Ku-band NGSO
FSS systems licensed by the Commission, prior to the new system’s launch, to ensure that the Raysat
59 ViaSat Comments at 2-3.
60 ViaSat Comments at 3.
61 Amendment at 9.
62 Amendment at 10. For this reason, we have authorized Raysat’s system as six separate earth station licenses. See
infra paras. 33-34.
63 In addition, we observe that the tracking and acquisition safeguards discussed above provide real time, near
instantaneous shutoff protection to adjacent GSO FSS operators.
64 See Amendment of Parts 2 and 25 of the Commission’s Rules to Permit Operation of NGSO FSS Systems Co-
Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range, First Report and Order and
Further Notice of Proposed Rule Making, ET Docket No. 98-206, FCC 00-418, 16 FCC Rcd 4096 (2000).
65 The only authorized Ku-band NGSO FSS systems surrendered their authorizations. See Virtual Geosatellite LLC,
IBFS File No. SAT-LOA-19990108-00007, Public Notice, Policy Division Information, Actions Taken, Report No.
SAT-00420, DA 07-617 (Int’l Bur. Feb. 9, 2007); SkyBridge L.L.C., IBFS File No. SAT-LOA-19970228-0021,
Public Notice, Policy Division Information, Actions Taken, Report No. SAT-00314, DA 05-2327 (Int’l Bur. Aug.
19, 2005).
66 Application at 14.
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system does not cause harmful interference to the new system.67 These steps include Raysat operating its
system at reduced power levels sufficient to mitigate harmful interference into Ku-band NGSO FSS
systems that comply with the technical requirements of Part 25 of the Commission’s rules.68
26. We agree that such conditions are appropriate to protect future Ku-band NGSO FSS systems
from interference. Accordingly, if the Commission authorizes a Ku-band NGSO FSS system in the
future, Raysat must successfully coordinate its operations with that future licensee and obtain an affidavit
from the licensee that Raysat’s system proposed operations are acceptable. In the absence of such an
affidavit, Raysat’s system must cease service immediately upon launch and operation of the first satellite
of the Ku-band NGSO FSS system, or demonstrate that it will not cause harmful interference to the new
NGSO FSS system. Failure to make such a demonstration may subject Raysat’s METs to further
conditions by the Commission designed to address potential harmful interference.69
2. Protection of Space Research in the 14.0-14.2 GHz Band
27. The 14.0-14.2 GHz portion of the Ku-band is domestically allocated for secondary-status
Federal-government operation in the Space Research Service (SRS).70 The National Aeronautics and
Space Administration (NASA) currently operates SRS Tracking and Data Relay Satellite System
(TDRSS) stations in White Sands, New Mexico, and in Guam that receive signals from geostationary
satellites in the 14.0-14.05 GHz segment of the SRS band.71 NASA also plans to establish an additional
TRDSS receive facility at Blossom Point, MD, in the near future.72
28. As part of its application, Raysat included a copy of a coordination agreement with NASA to
protect the current and future TDRSS sites.73 Pursuant to this agreement, Raysat will protect TDRSS
operations at White Sands by means of exclusion zones within which Raysat’s METs will be prohibited
from operating.74 Above 14.2 GHz, an exclusion zone extends for 10 kilometers (km) north and south of
67 Application at 14-15.
68 Application at 15.
69 Raysat states that its application, as amended, extends only to those mobile earth stations that Raysat itself may
operate, and that other operators may purchase mobile earth stations from Raysat to include in their own networks.
Such operators will seek separate operating authority from the Commission. Amendment at 4. We anticipate that
any future authorizations will be subject to the same condition to protect future NGSO FSS systems from
interference.
70 47 C.F.R. § 2.106.
71 See VMES Notice, 22 FCC Rcd at 9665 (para. 31).
72 On August 17, 2007, the National Telecommunications and Information Administration (NTIA) informed the
Commission that a site in Blossom Point, MD has been selected for a new TDRSS earth station. The coordinates are
38o25’44″ N, 77o05’20″ W, and the site has a terrain height at approximately sea level. The new earth station is
expected to become operational within three years and to have similar technical characteristics to that of its White
Sands, NM, terminal except that this station will have improved RF filtering. See Public Notice, International
Bureau Announces New NASA TDRSS Earth Station Site, Report No. SPB-221, DA 07-4028 (rel. Sept. 25, 2007).
73 Application at 8. A copy of Raysat’s coordination agreement with NASA is attached as Exhibit 2 to Raysat’s
application. See “A Coordination Agreement Between the National Aeronautics and Space Administration
(hereinafter “NASA”) and Raysat, Incorporated for Operation of the Raysat LMSS Terminals in the 14.0-14.5 GHz-
Band” (NASA Coordination Agreement). Because Raysat’s application is only for operations within the Contiguous
United States (CONUS), the coordination agreement does not address protection of NASA’s TDRSS site in Guam.
If Raysat applies for future authorization to operate outside of CONUS, the coordination agreement with NASA
calls on Raysat and NASA to develop an addendum to accommodate Raysat’s protection of the Guam site. See
NASA Coordination Agreement at n1.
74 Application at 8.
Federal Communications Commission DA 08-401
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the White Sands for Raysat transmissions; below 14.2 GHz, the zone extends 46 km to the north and 73
km to the south.75 Raysat states that it will program the coordinates of these exclusion zones into its
METs, and that the stations will terminate transmissions within these zones by means of a GPS system
integrated into the antenna.76 Accordingly, we condition the authority granted in this Order upon Raysat’s
adherence to the terms of the coordination agreement with NASA. Raysat will also need to update its
coordination agreement with NASA to include the new TDRSS site at Blossom Point, MD. Raysat will
be required to cease operations within 125 km of the new Blossom Point facilities when those facilities
become operational, unless Raysat reaches an agreement with NASA permitting such operations.77
3. Protection of US Government Fixed and Mobile Stations in the 14.4-14.5
GHz Band
29. In addition to the non-Federal primary FSS and secondary MSS allocations in the 14.4-14.5
GHz segment, the Federal government has secondary fixed and mobile allocations in the band.78 Our
records indicate that there are several fixed point-to-point operations and a limited number of fixed
stations used by the Federal government for terrestrial telecommand.79 There also are several Federal
government aeronautical mobile stations, land-based aeronautical mobile stations, and land mobile
stations in the band. Furthermore, there are several Federal government surface telemetering mobile
stations in the band that are used to send telemetry information to other stations on the ground. The
14.4-14.5 GHz band appears to be used predominantly by fixed, mobile, and transportable telemetry
microwave systems. The band also is used to transmit air traffic control video links, closed circuit
television, and range test data (including airborne downlink data transmissions).80 Because the 14.4-14.5
GHz band is shared with the U.S. government, we have coordinated Raysat’s application with National
Telecommunications and Information Administration (NTIA) which administers authorizations for
federal stations. NTIA has concurred with Raysat’s proposed frequencies and operations.
4. Protection of Radio Astronomy in the 14.47-14.5 GHz Band
30. The National Science Foundation (NSF), an independent Federal agency created by
Congress, supports radio-astronomy observation in the 14.47-14.5 GHz band at National Radio
Astronomy Observatories in New Mexico and West Virginia. The use of the band for radio-astronomy
observation at those sites is recognized in Footnote US203 to the Table of Allocations, which requires
steps to be taken to minimize interference with such operation from terrestrial radio transmitters.81 The
NSF also supports radio-astronomy observation in the same band at various other sites in the continental
United States, Hawaii, Puerto Rico, and the U.S. Virgin Islands.
31. As part of its application, Raysat includes a coordination agreement reached with the NSF
75 See NASA Coordination Agreement at tables 3 & 4.
76 Application at 8.
77 We note that the Commission has proposed to prohibit VMES operators from operations in the 14.0-14.2 GHz
band within 125 km of TDRSS sites, absent successful coordination of such operations with NASA. See VMES
Notice, 22 FCC Rcd at 9665-66 (para. 32). This is the same approach that the Commission took for ESVs. See id.,
n.75.
78 VMES Notice, 22 FCC Rcd at 9667. See also 47 C.F.R. § 2.106.
79 VMES Notice, 22 FCC Rcd at 9667.
80 Id.
81 47 C.F.R. § 2.106, Footnote US203.
Federal Communications Commission DA 08-401
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regarding the measures that Raysat will undertake to protect radio astronomy service sites.82 Pursuant to
this agreement, Raysat will protect radio astronomy operations at ten sites by means of exclusion zones
within which Raysat’s METs will be prohibited from operating.83 These exclusion zones range from 160
km separation from the Green Bank, WV, and Socorro, NM, sites to 25 km separation from the Very
Long Baseline Array site at Hancock, NH.84 Raysat states that the coordinates of these exclusion zones
will be programmed into its METs, and that antenna transmissions within these zones will be terminated
by means of a GPS system integrated into the antenna.85 We condition the authority granted in this Order
on Raysat’s adherence to the terms of its coordination agreement with NSF.
5. Protection of Non-Federal Land Mobile Stations in the 14.2-14.4 GHz Band
32. Prior to March 2, 2005 the Table of Allocations contained an allocation for mobile services in
the 14.2 – 14.4 GHz band. These operations were authorized under Part 101, Subpart J of the
Commission’s Rules. Footnote 184 to the Table of Allocations provides that land mobile stations that
were authorized prior to March 1, 2005 are allowed to continue operating on a secondary basis until their
license expires. Our licensing records indicate that there are approximately twenty-five licenses that
authorize stations in the 14.2 – 14.4 GHz band. We also note, however, that these twenty-five licenses
authorize the stations to operate in other bands in addition to the 14.2 – 14.4 GHz band, giving them an
alternative to operating in the 14.2 – 14.4 GHz band. Given the transient nature of any such operations,
the limited number of such stations authorized in the band, and the fact that they are also authorized to
operate in alternate bands, we believe that Raysat’s operation is unlikely to interfere with these
grandfathered licenses.
C. Other Matters
1. Separate Call Signs
33. We find that it is appropriate to license Raysat’s METs under six separate authorizations,
each with a separate call sign, rather than under a single authorization and call sign.86 Although Raysat
sought authorization for its METs under a single license application, Raysat states that it relies on
separate hubs to manage its METs, and that individual METs can operate with only one hub station at any
given time.87 The six hub earth stations are geographically distinct, and there is no single point governing
the entire network of Raysat METs.88 Instead, personnel of each hub earth station will ensure that the
METs operate in accordance with Raysat’s license, pursuant to contractual arrangement.89 Thus, we
conclude that Raysat actually seeks to operate its METs as six separate networks, rather than as a single
network. As a condition to this Order and Authorization, Raysat must submit the application fees for five
additional earth station applications that would have been due when it filed its original application, a total
82 Application at 8. A copy of Raysat’s coordination agreement with NSF is attached as Exhibit 3 to RaySat’s
application. See “Technical Operational Coordination Agreement for the Joint Usage of the Band 14.0-14.5 GHz
Between the National Science Foundation and Land Mobile Satellite Service Earth Stations (LMSS) Operated by
RaySat, Inc.” (NSF Coordination Agreement).
83 Application at 8.
84 See NSF Coordination Agreement at 4.
85 Application at 8.
86 The six authorized earth station hubs are in the following locations: (1) McLean, VA; (2) Hagerstown, MD; (3)
Silver Spring, MD; (4) Englewood, CO; (5) Woodbine, MD; and (6) Charlotte, NC. See Application at 2.
87 Amendment at 10.
88 Raysat Reply at 4.
89 Amendment at 9.
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of $41,300, within 30 days of the release date of this Order and Authorization.90 Failure to due so will
render its authorizations null and void.
34. Accordingly, we shall issue six call signs to Raysat, and each of the call signs will be
associated with a particular hub earth station as set forth in Appendix A to this authorization. Raysat may
allocate METs among the six call signs, up to an aggregate of 400 mobile user earth stations. A MET can
operate under only one call sign at any given time, although Raysat may allocate METs dynamically
among call signs during the license terms, as Raysat deems necessary. Raysat must maintain an up-todate
roster of which METs operate pursuant to a particular call sign at any given time, and this roster must
be available to Commission staff upon demand.
2. Data Logging Requirements
35. As a condition of its authorization, Raysat must maintain logs on the operation of its METs,
as well as a point of contact for resolving any interference complaints, as set forth below. ViaSat argues
that data logging requirements should apply to Raysat’s proposed operations in order to identify and
correct interference issues, should they arise.91 Raysat proposed operations will be transitory in nature
and will take place in bands where regularly licensed spectrum operators have equal or superior rights.
We agree with ViaSat that maintaining logs on METs operations will help identify and resolve any
interference concerns raised by such operators. The Commission has imposed such data logging
requirements on LMSS operations in the Ku-band in the past,92 and data logging is part of the rules
governing analogous ESV operations.93 We also note that the Commission is considering similar data
logging requirements for VMES in the Ku-band.94
36. We will impose data logging and point of contact requirements on Raysat’s proposed
operations similar to those imposed on previous Ku-band LMSS and ESV licensees. Accordingly, Raysat
must maintain a point of contact within the United States with the authority and capability to mute the
METs if necessary. Raysat shall submit a letter to be included in its license file with the name and
telephone number of the contact prior to commencing operation. Raysat must also maintain records of
the locations of METs in longitude and latitude, and of the ownership of vehicles on which the METs
have been installed. The geo-location information must be recorded at time intervals of no greater than
every twenty minutes while the mobile earth station terminal is transmitting.95 Raysat must maintain the
information for a year and make it available to appropriate entities within twenty-four hours of request.
We also require Raysat to maintain logs of all alleged incidences of interference, the stations involved,
and the outcome of the incident.96
37. We disagree that data logging requirements are unnecessary and impractical, as Raysat
contends.97 Although Raysat contends that the similarly-situated mobile satellite-newsgathering and
ESVs have been able to operate in the Ku-band with minimal interference to FSS users, we agree that
90 See contactMEO Communications, LLC, Order and Authorization, 21 FCC Rcd 4035 (Int’l Bur. 2006).
91 ViaSat Comments at 4.
92 See Qualcomm, 4 FCC Rcd at 1545-46.
93 See 47 C.F.R. § 25.222(c); see also ESV Report and Order, 20 FCC Rcd at 695-96, ¶ 48.
94 See VMES Notice, 22 FCC Rcd at 9676-77 ¶¶ 61-64.
95 Accord with 47 C.F.R. § 25.222(c)(1).
96 Compare with Qualcomm, 4 FCC Rcd at 1456.
97 Raysat Reply at 7.
Federal Communications Commission DA 08-401
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such operations still have the potential to cause interference in some instances.98 Indeed, ESVs are
subject to data logging requirements for this very reason, as noted above. Furthermore, we are not
persuaded by Raysat’s assertion that data logging requirements are unnecessary because Raysat’s
operations under an experimental license have not yielded any examples of interference into other
systems.99 Limited operations under an experimental license do not rule out the possibility of interference
resulting from the operation of a larger number of METs under a commercial license. Finally, the
security concerns raised by Raysat regarding disclosure of the location of METs used by U.S.
Government and military users can be addressed while still maintaining data logging requirements. We
observe that the geo-location information that must be logged is required to be made available only to
other network operators or U.S. Government agencies, and need not be disclosed publicly. If, in
particular circumstances, national security or other concerns argue against even this limited disclosure,
Raysat is free to seek limited waiver of the disclosure requirement under existing Commission rules.100
3. Radiation Hazard Requirements
38. The Commission has observed that the mounting of earth stations on vehicles may pose the
possibility of human exposure to radiofrequency (RF) radiation.101 The Commission’s rules define the
maximum permissible exposure (MPE) to non-ionizing radiation for the general public in an uncontrolled
environment in the 14.0-14.5 GHz band to be 1.0 mW/cm2 averaged over any 30 minute time period.102
For individuals in a controlled occupational environment, the MPE is 5.0 mW/cm2 averaged over any 6
minute time period.103 Raysat has provided a radiation hazard analysis that states that the METs will
produce power densities that would result in exceeding these criteria for a person located at or around the
surface area of the MET antennas.104
39. We are conditioning the authorization to require that a label or labels be permanently placed
on the MET, warning about the radiation hazard and including a diagram showing the regions around the
earth station where the levels could exceed 1.0 mW/cm2. Individuals will need to be prevented from
straying within this region by means of signs, caution tape, verbal warnings, placement of the earth
station or other appropriate means so as to minimize access to the hazardous region.
IV. CONCLUSION
40. We conclude that we can grant Raysat’s application, as amended, under existing Commission
rules for the licensing non-routine earth stations. Accordingly, we grant Raysat authority to operate up to
four hundred technically identical in-motion METs to be mounted on vehicles throughout the continental
United States, subject to the conditions specified herein.
V. ORDERING CLAUSES
41. Accordingly, IT IS ORDERED that the applications of Raysat Antenna Systems, LLC (IBFS
File Nos. SES-LIC-20060629-01083, SES-LIC-20060629-02248, SES-LIC-20060629-02249, SES-LIC-
20060629-02250, SES-LIC-20060629-02251, SES-LIC-20060629-02252), as amended by IBFS File No.
98 ViaSat Response at 4.
99 Raysat Reply at 7.
100 See 47 C.F.R. § 1.3.
101 VMES Notice, 22 FCC Rcd at 9680.
102 47 C.F.R. § 1.1310.
103 Id.
104 Application, Radiation Hazard Analysis at 1.
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SES-AMD-20070620-00839, ARE GRANTED, to the extent indicated herein, and Raysat Antenna
Systems, LLC IS AUTHORIZED to operate up to four hundred technically identical in-motion METs to
be mounted on vehicles throughout the continental United States, according to the specifications of its
application and amendment, and in compliance with the Commission’s rules, subject to the conditions
specified herein.
42. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC’s METs are limited to
communications with the satellites set forth in its application, specifically Intelsat-Americas 7 at 129°
W.L., Intelsat-Americas 8 at 89° W.L., AMC-4 at 101° W.L., AMC-5 at 79° W.L., AMC-6 at 72° W.L.,
SBS-6 at 74° W.L., and Horizons-1 at 127° W.L. Raysat Antenna Systems, LLC must seek Commission
approval to modify its authorization in the event the satellites change orbital locations, or if Raysat
Antenna Systems, LLC desires to add satellites as points of communication.
43. IT IS FURTHER ORDERED that the Raysat Antenna Systems, LLC METs must accept
interference from lawful operation of any station in the 11.7-12.2 GHz band in accordance with the U.S.
Table of Frequency Allocations (47 C.F.R. § 2.106) and shall immediately terminate space-to-Earth
operations upon notification that such operations are causing harmful interference, not permitted under
the terms of a pertinent coordination agreement, with lawful operation of any radio system in the 11.7-
12.2 GHz band in conformance with the U.S. Table of Frequency Allocations.
44. IT IS FURTHER ORDERED that the operation of an Raysat Antenna Systems, LLC MET
shall immediately terminate upon notification that such operation is causing harmful interference, not
permitted under the terms of pertinent coordination agreements, with (1) lawful operation of any radio
system in the 14.0-14.5 GHz band authorized on a primary basis in conformance with the U.S. Table of
Frequency Allocations or authorized on a secondary basis prior to the effective date of this order, or (2)
operation of any TDRSS earth station in the band 14-14.2 GHz, or (3) radio astronomy observations in
the 14.47-14.5 GHz band.
45. IT IS FURTHER ORDERED that, if the Commission authorizes a Ku-band NGSO FSS
system in the future, Raysat Antenna Systems, LLC must successfully coordinate its operations with that
future licensee and obtain an affidavit from the licensee that Raysat Antenna Systems, LLC’s system
proposed operations are acceptable. In the absence of such an affidavit, Raysat Antenna Systems, LLC’s
system must cease service immediately upon launch and operation of the first satellite of the Ku-band
NGSO FSS system, or demonstrate that it will not cause harmful interference to the new NGSO FSS
system. Failure to make such a demonstration may subject Raysat Antenna Systems, LLC’s METs to
further conditions by the Commission designed to address potential harmful interference.
46. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC shall maintain a point of
contact for discussing interference concerns with other licensees and U.S. Government agencies and shall
submit a letter to be included in its license file with the name and telephone number of the contact prior to
commencing operation. Raysat Antenna Systems, LLC shall maintain records of the locations of mobile
earth station stations in longitude and latitude, and of the ownership of vehicles on which the mobile earth
station stations have been installed. The geo-location information shall be recorded at time intervals of no
greater than every twenty minutes while the mobile earth station terminal is transmitting. Raysat Antenna
Systems, LLC must maintain the information for a year and make it available to appropriate entities
within twenty-four hours of request. Raysat Antenna Systems, LLC must maintain logs of all alleged
incidences of interference, the stations involved, and the outcome of the incident.
47. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC METs must employ a
tracking algorithm that is resistant to capturing and tracking adjacent satellite signals, and each Raysat
Antenna Systems, LLC MET must be capable of inhibiting its own transmission in the event it detects
unintended satellite tracking.
Federal Communications Commission DA 08-401
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48. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC METs must be monitored
and controlled by a ground-based network control and monitoring center. Each Raysat Antenna Systems,
LLC must be able to receive “enable transmission” and disable transmission” commands from the
network control center and must cease transmission immediately after receiving any “parameter change”
command until it receives an “enable transmission” command from the network control center. The
network control center will monitor operation of each Raysat Antenna Systems, LLC METs to determine
if it is malfunctioning, and each Raysat Antenna Systems, LLC mobile earth station will self-monitor and
automatically cease transmission upon detecting an operational fault that could cause harmful interference
to the fixed satellite service network.
49. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC’s operation in the 11.7-12.2
and 14.0-14.5 GHz bands shall be in accordance with the space station authorization for the satellites with
which Raysat Antenna Systems, LLC’s METs communicate.
50. IT IS FURTHER ORDERED that operations pursuant to this authorization shall conform to
the requirements of Raysat Antenna Systems, LLC’s coordination agreements with NASA and NSF.
Raysat Antenna Systems, LLC will need to update its coordination agreement with NASA to include
operations within 125 km of the new TDRSS site at Blossom Point, MD. Raysat Antenna Systems, LLC
METs shall cease operations within 125 km of the new Blossom Point facilities when those facilities
become operational, unless Raysat Antenna Systems, LLC reaches an agreement with NASA permitting
such operations.
51. IT IS FURTHER ORDERED that, in the event that another co-frequency FSS satellite
commences operation at a location within six degrees of the target satellite, Raysat Antenna Systems,
LLC must reduce aggregate off-axis radiation from its METs to levels one dB below the routineprocessing
envelope, pending demonstration of coordination with the operator of the new satellite.
52. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC’s proposed use of the
2M07G7W emission designator IS DISMISSED without prejudice for the reasons stated herein.
53. IT IS FURTHER ORDERED that Section 2.102 of the Commission’s rules IS WAIVED with
respect to operation of the Raysat Antenna Systems, LLC METs in the 11.7-12.2 GHz downlink band
consistent with the terms of this authorization.
54. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC shall take all reasonable
and customary measures to ensure that the MET does not create a potential for harmful non-ionizing
radiation to persons who may be in the vicinity of the MET when it is in operation. At a minimum,
permanent warning label(s) shall be affixed to the MET warning of the radiation hazard and including a
diagram showing the regions around the MET where the radiation levels could exceed 1.0 mW/cm2. The
operator of the MET shall be responsible for assuring that individuals do not stray into the regions around
the MET where there is a potential for exceeding the maximum permissible exposure limits required by
Section 1.1310 of the Commission’s rules, 47 C.F.R. § 1.1310. This shall be accomplished by means of
signs, caution tape, verbal warnings, placement of the MET so as to minimize access to the hazardous
region and/or any other appropriate means.
55. IT IS FURTHER ORDERED that Raysat Antenna Systems, LLC must submit application
fees for its five additional earth station hubs in the amount of $41,300 within 30 days of the release of this
Order and Authorization. Failure to due so will render its authorizations null and void.
56. Raysat Antenna Systems, LLC may decline this authorization as conditioned within 30 days
from the date of release of this Order and Authorization. Failure to respond within that period will
constitute formal acceptance of the authorization as conditioned.
Federal Communications Commission DA 08-401
17
57. This Order and Authorization is issued on delegated authority pursuant to Sections 0.241 and
0.261 of the Commission’s rules, 47 C.F.R. §§ 0.241 and 0.261, and is effective upon release. Petitions
for reconsideration under Section 1.106 of the Commission’s rules, 47 C.F.R. § 1.106, may be filed within
thirty days of the date of this Order and Authorization.
FEDERAL COMMUNICATIONS COMMISION
Helen Domenici
Chief
International Bureau
Julius Knapp
Chief
Office of Engineering and Technology
Federal Communications Commission DA 08-401
18
Appendix: Hub Earth Station Association with Call Signs
Raysat Authorization IBFS File No. Raysat
Call Sign Associated Hub Earth Station
SES-LIC-20060629-01083 E060101 Spacenet, McLean, VA (Call Sign E860326)
SES-LIC-20060629-02248 E060447 Intelsat, Hagerstown, MD (Call Signs E040140, E040141, E040414, E040475)
SES-LIC-20060629-02249 E060448 G2, Silver Spring, MD (Call Sign KA416)
SES-LIC-20060629-02250 E060449 Stratos, Englewood, CO (Call Sign E950149)
SES-LIC-20060629-02251 E060450 SES Americom, Woodbine, MD (Call Sign E920698)
SES-LIC-20060629-02252 E060451 Charlotte, NC (Call Sign E050007)
