Federal Communications Commission
Washington, D.C. 20554
June 28, 2013
Mr. Zuhair Muakkit
Antenna Technology Communications, Inc.
450 North McKemy Avenue
Chandler, AZ 85226-2606
Call Sign: E010255
File No.: SES-MOD-20130117-00082
Dear Mr. Muakkit:
On January 17, 2013, Antenna Technology Communications, Inc. (Antenna Technology) filed the above-
captioned application to modify its current fixed earth station authorization to replace a 7.6- meter
antenna with a 2.4-meter antenna, as well as to add operations in the 5850-5925 MHz (Earth-to-space)
frequency band to communicate with "ALSAT" as the point of communication. For the reasons
discussed below, we dismiss the application as defective, without prejudice to re-filing.1
Section 25.112 of the Commission's rules,2 requires the Commission to return, as unacceptable for filing,
any earth station application that is not substantially complete, that contains internal inconsistencies, or
that does not substantially comply with the Commission's rules. The deficiencies and inconsistencies in
Antenna Technology's application are as follows:
In item E18 of Schedule B of Form 312, Antenna Technology states that a frequency coordination
report is not required for the emission designator 5G00G1F, which will operate in the 5850-6425 MHz
frequency band. Antenna Technology's statement is incorrect. Section 25.130(b) of the Commission's
rules requires a frequency coordination analysis to be provided as part of applications for earth stations
transmitting in frequency bands shared with equal rights between terrestrial and space services.3 Because
the 5840-6425 MHz frequency band is shared with equal rights with terrestrial services, the failure to
provide a frequency coordination analysis renders Antenna Technology's application incomplete.
In item E21 of Schedule B to Form 312, Antenna Technology incorrectly lists "ALSAT" as the
sole point of communication in the 5850-5925 MHz frequency band. An application for an earth station
to communicate with ALSAT may be granted only in cases where the earth station is eligible for "routine
processing." The criteria for routine processing of an earth station communicating in C-band frequencies
are specified in Section 25.212(d) of the Commission's rules, 47 C.F.R. 25.212(d). Notably,
frequencies outside the 5925-6425 MHz (Earth-to-space) and 3700-4200 MHz (space-to-Earth) frequency
bands are not authorized for routine licensing. Because only earth stations that meet routine licensing
If Antenna Technology re-files an application in which the deficiencies identified in this letter have been
corrected but otherwise identical to the one dismissed, it need not pay an application fee. See
47 C.F.R. 1.1111(d).
47 C.F.R. 25.112.
47 C.F.R. 25.130(b).
Federal Communications Commission DA 13-1461
criteria may be granted ALSAT as a point of communication, Antenna Technology's application is
internally inconsistent and does not substantially comply with the Commission's rules.
In item E49 of Schedule B to Form 312, Antenna Technology indicates that the Maximum EIRP
Density per Carrier will be 25.80 dBW/4 kHz for emission carrier 5G00G1F. That value, however, is
inconsistent with the value of -4.2 dBW/4 kHz, which is computed using the values Antenna Technology
provides in response to items E48 (Maximum EIRP per Carrier (dBW)), E47 (Emission Designator), E38
(Total Input Power at antenna flange (Watts)), and E42 (Transmit Antenna Gain (dBi)).
In item E59 of Schedule B to Form 312, Antenna Technology indicates that the western limit of
the antenna elevation angle will be 42.8 degrees. This elevation angle is inconsistent with an antenna
elevation angle of 41.6 degrees, which is calculated from the latitude and longitude that Antenna
Technology provides in items E11 and E12.
Finally, pursuant to Section 25.132(a)(1) of the Commission's rules,4 we request that Antenna
Technology demonstrate compliance with the antenna performance standards of Sections 25.209(a) and
(b) of the Commission's rules.5 Although Antenna Technology indicates in item E15 that the 2.4-meter
Prodelin GD Satcom model 1251 antenna complies with the antenna gain patterns that are specified in
Section 25.209(a) and (b) of the Commission's rules, we request a demonstration of compliance in light
of the inconsistencies in the technical information noted above and the small diameter of the requested
antenna. If Antenna Technology cannot demonstrate compliance with Section 25.209(a) and (b), then
Antenna Technology must either submit the certifications contained in Section 25.220(d)(1)(i-iv),6 or cite
the particular application file number and call sign of a license in which that type of non-routine antenna
has been previously approved.7 Please note that the Commission maintains a list of approved non-routine
antenna at https://transition.fcc.gov/ib/sd/nresa/
Accordingly, pursuant to Section 25.112(a) (1) of the Commission's rules, 47 C.F.R. 25.112(a)(1), and
Section 0.261 of the Commission's rules on delegations of authority, 47 C.F.R. 0.261, we dismiss
Antenna Technology's application without prejudice to re-filing.
Paul E. Blais
Chief, Systems Analysis Branch
47 C.F.R. 25.132(a)(1).
47 C.F.R. 25.209(a) and (b).
47 C.F.R. 25.220(d)(1)(i-iv).
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
Report and Order, 20 FCC Rcd 5666, 5690-91 para. 59 (2005).