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Common Defects in Earth Station Application Filings

This resource page provides information on the most common defects found in earth station application filings and guidance for filers on ways to prevent them. The list below is based on known defects at this time and should not be considered complete. For more detailed guidance, applicants should consult the applicable statutes, Commission Orders, Rules, and Public Notices concerning earth station applications.

List of Common Defects:

  1. Defect: The earth station application identified All U.S. Licensed Satellites (ALSAT) or the "Permitted List" as a point of communication in frequency bands other than the conventional C-band or the conventional Ku-band.
  2. Defect: The earth station applicant fails to include a Radiation Hazard Analysis as an exhibit to its application.
  3. Defect: Failure to complete FCC 312 Main Form and Schedule B when filing an application for authorization to operate a new or modified Very Small Aperture Terminals (VSAT) network.
  4. Defect: Earth station application contains an inconsistency between the technical parameters provided. For example, on the FCC Form 312, Schedule B, the maximum EIRP density per carrier (question E49) is less than the average EIRP density per carrier as computed by using the Maximum EIRP per carrier (question E48) and the necessary bandwidth in the Emission Designator (question E47).
  5. Defect: Applications with inconsistencies regarding Total EIRP for all carriers.
  6. Defect: Failure to provide technical information regarding a non-U.S. licensed space station not previously authorized or not having technical details on file with the Commission.
  7. Defect: An FSS earth station application proposing to communicate in frequency bands that are shared coequally with terrestrial radiocommunications services fails to include a Frequency Coordination and Interference Analysis Report and/or the FSS earth station application includes a Frequency Coordination and Interference Analysis Report that was completed more than six months prior to the date the earth station application was filed with the Commission.
  8. Defect: Failure to file the application electronically through International Bureau's Electronic Filing System (IBFS).
  9. Defect: A transmit Ka-band GSO FSS earth station application failed to include antenna radiation patterns as an exhibit to the application.
  10. Defect: The earth station application lists frequency bands that are not available on the space station identified as a point of communication.
  11. Defect: The application does not substantially comply with the Commission's rules and the applicant fails to include a waiver request and/or merely includes a request to "waive all rules necessary."

1. Defect: The earth station application identified All U.S. Licensed Satellites (ALSAT) or the "Permitted List" as a point of communication in frequency bands other than the conventional C-band or the conventional Ku-band.

Solution

ALSAT and the Permitted List can only be used as a point of communication if the applicant's FSS earth station meets the two-degree technical standards and the application proposes to use the conventional C-band or the conventional Ku-band.  In bands other than the conventional C-band or conventional Ku-bands (or for earth stations that do not comply with the two-degree technical standards), the applicant must identify the specific space station with which it seeks to communicate and cannot use the ALSAT or Permitted List as a point of communication

We also note that ESVs can only designate the Permitted List or ALSAT as a point of communication in the Ku-band.  In the C-band, ESVs must designate specific space stations.

2. Defect: The earth station applicant fails to include a Radiation Hazard Analysis as an exhibit to its application.

 Solution

Generally, a Radiation Hazard Analysis is required as an exhibit for all fixed or temporary fixed transmitting earth station antennas.  There are limited exceptions to this rule.  Specifically, a Radiation Hazard Analysis is not required for the following types of fixed or temporary fixed transmitting earth station applications:

  1. Renewals, or
  2. Requests for minor modifications that do not involve:
    1. an increase in EIRP or EIRP density;
    2. an increase in transmitter power;
    3. any change in coordinates for stations operating in the C-band;
    4. a change in coordinates of 10 seconds or greater for stations operating in the Ku-band;
    5. or any change or addition to antenna facilities.

See International Bureau Eliminates Redundant Filing of Radiation Hazard Studies, Public Notice, Report No. DS-1492, DA 95-96, 10 FCC Rcd 2256 (rel. February 6, 1995)

For information regarding how the Radiation Hazard Analysis is evaluated on the merits by the Commission, please review "Evaluating Compliance with FCC Guidelines for Human Exposure to Radiofrequency Electromagnetic Fields,"OET BulletinNo. 65 (August 1997).

3. Defect Failure to complete FCC 312 Main Form and Schedule B when filing an application for authorization to operate a new or modified Very Small Aperture Terminals (VSAT) network.

Solution

An application for a new or modified transmitting earth station facility must be complete and submitted on FCC Form 312, Main Form and Schedule B, accompanied by any required exhibits.  For VSAT Networks that include both a hub earth station and remote terminals, the application must include not only a completed Schedule B for the hub earth station, but also a Schedule B for the remote terminals.  If there is more than one type of remote terminal, a Schedule B must be completed for each type of remote terminal.  For example, if more than one size of remote terminal is proposed, a Schedule B must be provided for each size of remote terminal.  The geographic coordinates are required for the hub earth station on Schedule B; geographic coordinates are not required for the remote terminals on Schedule B.

4. Defect: Earth station application contains an inconsistency between the technical parameters provided.

For example, on the FCC Form 312, Schedule B, the maximum EIRP density per carrier (question E49) is less than the average EIRP density per carrier as computed by using the Maximum EIRP per carrier (question E48) and the necessary bandwidth in the Emission Designator (question E47).

Solution

The maximum EIRP Density provided in the earth station application must agree with that derived from other information in the application, otherwise, the Commission cannot determine the actual emission power proposed in the application.  Specifically, the maximum EIRP density per carrier (question E49) must be greater than or equal to the computed average EIRP density per carrier generated from Maximum EIRP per carrier (question E48) and the necessary bandwidth in the Emission Designator (question E47).  Please note that the Schedule B indicates that the maximum EIRP density per carrier should be expressed in dBW per 4 kilohertz.

5. Defect: Applications with inconsistencies regarding Total EIRP for all carriers.

Solution

The Total EIRP for all carriers (question E40) must be consistent with the Total Input Power at the Antenna Flange (question E38) and the Antenna Transmit Gain (question E41/42).  The Total EIRP for all carriers must be greater than or equal to that of any individual carrier.

6. Defect: Failure to provide technical information regarding a non-U.S. licensed space station not previously authorized or not having technical details on file with the Commission.

Solution

Section 25.137(b) of the Commission's rules states that applications for earth stations seeking to access a non-U.S. licensed space station must include the same information for the non-U.S. licensed space station as required in Section 25.114 for a space station applicant seeking a U.S. license.  Therefore, all earth station applications seeking authority to communicate with a non-U.S. licensed space station must either include, or reference an application by IBFS File number that includes, the following:

  1. All the exhibits specified in Section 25.114(d) of the Commission's rules.  This includes, but is not limited to, link budgets or a two-degree spacing interference analysis for the non-U.S. licensed space station
  2. An FCC Form 312, Schedule S, as required by Section 25.114(a) of the Commission's rules

7. Defect: An FSS earth station application proposing to communicate in frequency bands that are shared coequally with terrestrial radiocommunications services fails to include a Frequency Coordination and Interference Analysis Report and/or the FSS earth station application includes a Frequency Coordination and Interference Analysis Report that was completed more than six months prior to the date the earth station application was filed with the Commission.

Solution

In frequency bands that are shared coequally with terrestrial radiocommunications services, the FSS earth station applicant must include a Frequency Coordination and Interference Analysis Report that is not older than six months.  See 47 C.F.R. §§ 25.115(c)(2)(iii) and 25.203.  Accordingly, prior to filing an application, an FSS earth station applicant should review Sections 25.202(a)(1) and 2.106 (Table of Allocations) of the Commission's rules to determine if the frequency bands sought are shared coequally with terrestrial radiocommunication services.

ESV applications should review the discussion in the answer to Question No. 15 above.

8. Defect: Failure to file the application electronically through International Bureau's Electronic Filing System (IBFS).

 Solution

Effective November 2004, all applications must be filed electronically through the IBFS.  Applications not filed through IBFS will be dismissed.  See Amendment of the Commission's Space Station Licensing Rules and Policies, 2000 Biennial Regulatory Review—Streamlining and the Revisions of Part 25 of the Commission's Rules Governing the Licensing of, and Spectrum Usage of Satellite Network Earth Stations and Space Stations, Fourth Report and Order, IB Docket Nos. 02-34 and 00-248, 19 FCC Rcd 7419 (2004)

9. Defect: A transmit Ka-band GSO FSS earth station application failed to include antenna radiation patterns as an exhibit to the application.

Solution

For Ka-band (18.3-18.8, 19.7-20.2, 28.35-28.6, and 29.25-30 GHz) transmit or transmit and receive GSO FSS earth station applications to be acceptable for filing, the application must contain antenna radiation patterns.  See Sections 25.115(e) and 25.138(d).

10. Defect: The earth station application lists frequency bands that are not available on the space station identified as a point of communication.

Solution

The earth station applicant should consult with the space station operator to ensure that the earth station application includes only frequency bands authorized on the particular space station to provide service in the United States.  In the past, earth station applicants have made the mistake of indicating all the bands in which the earth station is capable of operating without regard to the relevant space station's capabilities and the particular bands in which the space station has been authorized to provide service in the United States.  Futhermore, please note that where the earth station application is the procedural vehicle to obtain authorization for a non-U.S.-licensed space station to access the U.S. market, as noted above, the earth station application must comply with Sections 25.137 and 25.114 for the non-U.S. licensed space stations.

11. Defect: The application does not substantially comply with the Commission's rules and the applicant fails to include a waiver request and/or merely includes a request to "waive all rules necessary."

Solution

If an application does not substantially comply with the Commission's rules, the applicant must include a waiver request as an exhibit to the application that explains the waiver request sought and the basis for grant of the waiver request.  Please seeFAQ Question and Answer 3for a discussion of waivers and the pleading requirements.

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