D. Throughout Its Quarter-Century History, Qualcomm Has Pioneered

Home , Antenna boresight

D. Throughout Its Quarter-Century History, Qualcomm Has Pioneered The Development OfMany Innovative Wireless Services, Technologies, And Applications, Including The Current Air-Ground Communications System

For more than a quarter century, Qualcomm has pioneered the development ofmany innovative wireless technologies. As the FCC knows, the company invented the Code Division

Multiple Access ("CDMA") -based cellular communications technology, which is used in the

U.S. and many other countries around the world for terrestrial wireless voice and broadband communications and countless mobile broadband products and services. The current Aircell air- ground system that operates in the 850 MHz band was designed by Qualcomm and uses the company's CDMA technology. Qualcomm also has developed Orthogonal Frequency Division

Multiple Access ("OFDMA") -based cellular technologies (e.g., LTE) that power the next- generation terrestrial mobile broadband networks operated by wireless carriers throughout the

U.S. and around the world.

Qualcomm is continuously innovating in the wireless space. Qualcomm has invested more than $16.0 billion in R&D ofwireless technologies since the company's founding in

1985. In fiscal 2010 alone, Qualcomm spent $2.55 billion, or 23% ofits revenues, on R&D ofa wide range ofadvanced wireless technologies. These enormous expenditures have enabled

Qualcomm to invent many ofthe technologies fueling the exponential growth in mobile broadband usage. And, through its Technology Licensing ("QTL") business unit, Qualcomm broadly licenses its technology to more than 180 handset and infrastructure manufacturers worldwide that make network equipment, handsets and other consumer devices, and develop mobile services and applications for cellular networks based on 3G and 4G technologies.

Qualcomm's chip division, Qualcomm CDMA Technologies ("QCT"), is the world's largest provider ofwireless chipset technology that is used in cell phones and consumer electronics devices. QCT's chipsets support all the major terrestrial mobile frequency bands, the

-22- full gamut ofstandardized, globally harmonized 3G and 4G wide area mobile broadband and cellular technologies, GPS-based and GLONASS-based location tools, Bluetooth, Wi-Fi, and

many operating systems, such as Android, Windows Mobile, Symbian, and Qualcomm's own

Brew Mobile Platform.

Furthermore, as noted above, Qualcomm currently operates its OmniTRACS service, a mobile satellite service within the band proposed herein for the Next-Gen AG system. For more than two decades, the highly successful OmniTRACS mobile communications and information service has allowed commercial trucking and construction companies to proactively manage their equipment fleets to improve productivity and security.47 As such, Qualcomm is fully

cognizant ofthe interference protection needs ofGSO satellite operations (like OmniTRACS)

and has meticulously designed the innovative Next-Gen AG communications service to fully

protect GSO satellite operations, and avoid causing harmful interference to radio astronomy and

TDRSS operations. The last thing Qualcomm would seek to do is to introduce a new

communications service that introduces any risk ofinterference to existing GSO operations,

especially Qualcomm's own OmniTRACS service.

-23- CONCLUSION

Qualcomm respectfully requests that the FCC seek comments on the attached Petition for

Rulemaking and thereafter move promptly to issue a Notice ofProposed Rulemaking to adopt the proposed rules and create a Next-Generation Air-Ground communications service at 14.0 to

14.5 GHz. Qualcomm looks forward to working with the Commission and all interested stakeholders to enable multi-gigabit-per-second air-ground broadband communications technology to support the exploding population ofmobile broadband devices and applications well into the future.

Respectfully submitted,

QUALCOMM INCORPORATED

Dean R. Brenner Vice President, Government Affairs John W. Kuzin Senior Director, Regulatory

1730 Pennsylvania Avenue, NW Suite 850 Washington, DC 20006 (202) 263-0020

Attorneysfor QUALCOMMIncorporated

Dated: July 7, 201]

-24- Appendix A

Interference Protection Analysis

A-I 1. Next-Gen AG System Description

The proposed Next-Gen AG system provides coverage to aircraft flying above the Continental United States ("CONUS") using about 150 Ground Stations ("GSs") located on the earth's surface. The proposed system would operate in the Ku band, at 14.0 to 14.5 GHz, and use a Time Division Duplex ("TDD") communications mode with an OFDMA-based air interface to support high-speed data connections between the GSs and in-flight aircraft.

The GSs would use beams that are narrow in azimuth (2° wide) and advanced antennas that operate with an isoflux pattern in elevation. The isoflux antenna pattern in elevation means that the GS antenna gain decreases in direct proportion to its distance from the aircraft; that is, as the aircraft flies closer to a GS and the antenna elevation angle needed to service the aircraft increases, the antenna gain ofthe serving GS decreases proportionately while maintaining an adequate Carrier-to-Noise (C/N) ratio. This advanced system design allows the Next-Gen AG system to avoid interference to satellite systems and other incumbent services while providing high-speed, low latency, broadband connectivity to aircraft. As shown below, the Next-Gen AG system will use this and other advanced techniques to provide full protection to the uplinks of Fixed Satellite Service ("FSS") Geo-Synchronous Orbit ("GSO") satellite operations, future Non Geo-Synchronous Orbit ("NGSO") satellite systems, and other incumbent users. NGSO satellite systems are in non-equatorial orbits and could be observed from any direction in the hemisphere above Next-Gen AG GSs (and aircraft). While NGSO satellite operations are not currently in the 14.0 to 14.5 GHz band, they may be authorized for operation in the future, and Qualcomm's system is designed to protect a typical NGSO system as set forth herein.

The Next-Gen AG system GSs use phased-array technology to form narrow beams so that several beams can be simultaneously active on the same frequencies without destructive mutual interference via space division re-use. These beams, ofcourse, will be sufficiently spatially separated to leave room for multiple, simultaneously active beams. TDD multiplexing is used to allow GSs to serve several aircraft via adjacent or overlapping beams. Frequency division multiplexing also is used to service aircraft whose GS beams would otherwise have harmful inter-beam interference. In the OFDMA-based air interface, for example, this is achieved by providing each aircraft with a disjoint subset ofthe tones in the full signal band.

A-2 Each Next-Gen AG system GS is designed to point its beam away from the GEO-arc and provide substantial roll-offtoward the GEO-arc to avoid any potential interference to the GSO satellites. As shown in Figure A.I, planes will be served by beams that cover an area in azimuth that generally is ± 60° from true north (that is, a 120° angle). Also, each GS will form one or more narrow (2°-wide) beams for communications with aircraft. By pointing away from the GEO-arc (which is directly above the equator ofthe earth) and by using narrow beams that sharply fall off outside the beam coverage region, any potential interference to GSO satellite operations is reduced to negligible levels, as explained in detail below.

The isoflux property ofthe GS antenna in elevation also is designed to protect potential future NGSO satellites. As the aircraft approaches a GS, and the elevation angle toward the plane from the GS increases, the transmit power for the GS-to-aircraft forward link ("FL") is reduced according to the diminished path loss, thereby protecting NGSO operations. As explained below, as an aircraft approaches a GS and the elevation angle between the plane and the GS increases above 10° (which occurs at a distance of60 kIn or less from the aircraft to the GS), the system begins the process ofhanding offcommunications to another GS. Another means of protecting NGSO satellites is to have the Next-Gen-AG system use the ephemeris information on the NGSO satellite locations and turn down its FL transmit power for that limited amount oftime that the GS, served aircraft, and NGSO satellite are all in alignment.

The aircraft antenna, which transmits RL communications, will be pointing downward from the aircraft (i.e., below the horizon) and thus have a high roll-offat angles toward the GEO-arc. The aircraft transceiver and antenna system is designed to be small, low-cost, and low-weight. In addition, the GS receive antenna will be a very high gain antenna to allow the aircraft to transmit with a very low EIRP. These two factors limit greatly the potential interference to GSO satellite operations.

The Next-Gen AG system or systems will operate in 500 MHz ofspectrum currently occupied in large measure by GSO satellite systems. As shown in Figure A.I below, the Next-Gen AG GS service areas are hexagonal regions that cover CONUS with each GS located in the southernmost

A-3 corner ofeach hexagon, radiating northward. The GSs will use a "point north" concept, similar in concept to what has been used for terrestrial systems in other bands and found acceptable.48

215 km, GS Row Spacing

GS Locations

248 km, GS Spacing [

Figure A.I. Next-Gen AG Ground Stations Configuration

From the southernmost corner ofeach GS service area, the angular coverage range is nominally ± 60° from true north, outside ofwhich the aircraft is handed offto another GS. There will be some overlap with neighboring service areas to ensure successful hand-offs between GSs. In the southernmost row ofGSs, aircraft flying at azimuth angles greater than ± 60° from the GS will be served by the nearest GS, but the EIRP ofthe serving beam will be reduced so as to meet the requirement ofnot interfering with the GEO-arc; in this case, the data rate to aircraft very close to the southern border may need to be reduced. However, by allocating greater transmission time to these planes, adequate throughput to the planes can be maintained. Thus, all GS transmit beams point away from the GEO-arc and roll-off in gain such that their power levels are substantially below the noise floor ofthe GSO satellite at those off-axis angles in excess of 120° from the boresight ofany GS beam.

48 See Amendment ofParts 2 and 25 ofthe Commission's Rules to Permit Operation ofNGSO FSS Systems Co-Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range; Amendment ofthe Commission's Rules to Authorize Subsidiary Terrestrial use ofthe 12.2-12.7 GHz Band by Direct Broadcast Satellite Licensees and Their Affiliates; and Applications of Broadwave USA, PDC Broadband Corporation, and Satellite Receivers, Ltd. To Provide a Fixed Service in the 12.2-12.7 GHz Band, Memorandum Opinion and Order and Second Report and Order, 17 FCC Red. 9614 (2002).

A-4 1.1 Next-Gen AG Link Budget, Data Rates, and Aggregate Throughput

The GS receiver has an antenna gain relative to system noise temperature in degrees Kelvin, i.e., "Gff", of ~ 8 dBIK, assuming a 4.5 dB noise figure, ambient noise temperature of290K, and antenna gain of37 dBi. The high gain GS receive antenna allows for the use ofvery low aircraft transmit power and fully protects satellite uplinks.

The baseline aircraft antenna used in the interference calculation is a blade antenna with 15 dB of peak gain, a horizontal 3 dB beamwidth ofapproximately 85° and a vertical beamwidth of approximately 12°, when taking into account fuselage ground plane effects, and boresight directed downward, centered at approximately _5° in elevation. The Gff ofthe plane terminal is assumed to be -13 dBIK.

The average antenna gain in the azimuth plane in 360° is - -7 dB relative to peak. The aircraft antenna gain averaged over ± 90° in azimuth (front ofantenna) relative to the antenna boresight is ~ -5 dB relative to peak, and the azimuthal antenna gain averaged over 90° to 270° (back of antenna) relative to the antenna boresight is - -15 dB. The baseline aircraft antenna roll-off in elevation is at least 10, 15, 20 dB at angles of 5°, 10°, and >20°, respectively, above the horizon. Vertical aperture ofthe baseline antenna aperture is about 4 inches, and its width is about 0.45 inches. Also, the boresight ofthe aircraft antenna points at 5° below horizon, and the antenna roll-offat the horizon is approximately 3 dB. These and other antenna specifications will ensure negligible impact upon satellite and other services in the 14.0 to 14.5 GHz band. In fact, the proposed rules in Appendix B to this petition specify the emission limits from the aircraft antenna into the GSO satellite on the GEO-arc. These performance-based rules for the Next-Gen AG service will protect satellite operations and give system developers/operators the necessary design flexibility.

Table A.l and Table A.2 below contain sample link budgets. They show GS and aircraft transceiver parameters for both the FL and RL ofthe Next-Gen AG system for an airplane located 300 km from the GS. At 60 km from the GS, the achieved e/N will be about the same as that ofTable A.I because ofthe GS antenna's isoflux property in elevation described above.

A-5 The atmospheric loss in Table A.I and Table A.2 are estimated from data by NASA.49 The 3 dB value accounts for the mean plus 3 standard deviations ofthe oxygen and water vapor losses in the atmosphere at very low elevation angles. As described below, rain fade also is accounted for in the margin in Table A.I and Table A.2. When rain fade exceeds the margins in Table A.I and Table A.2, power control may be used to allocate more power to the links impacted by rain and decrease the power from other links, while maintaining overall emissions into the GEO-arc well below the acceptable level. Specific rules relating to this power control feature are developed in this Appendix and provided in the Appendix B proposed rules. In addition to allocating more of the overall allowable power to links with severe rain fade, rate control will be used to temporarily reduce the data rate to/from affected planes. To compensate for the reduced data rate, the affected planes will be given more time for transmission to maintain their overall throughput while reducing the throughput ofother planes slightly.

GS EIRP in 50 MHz 39.5 dBW Atmospheric (Oxygen and Water Vapor) Loss at Ku Band 3.0 dB Plane Grr -13.0 dBIK llBW (BW = 50 MHz) -76.99 -dB-Hz IlBoltzmann 228.6 -dBIK-Hz Path Loss (300 km at 14 GHz) -164.9 dB C/N at Aircraft 10.21 dB Required CIN 4.00 dB Margin 6.21 dB

Table A.I. Forward Link ("FL") Budget for Next-Gen AG Service

Plane EIRP in 2 MHz 3.00 dBW Atmospheric (Oxygen and Water Vapor) Loss at Ku Band 3.00 dB GSGrr 8.00 dBIK IIBW (BW = 2 MHz) -63.01 -dB-Hz IlBoltzmann 228.60 -dBIK-Hz Path Loss (300 km at 14 GHz) -164.90 dB CIN at GS 8.69 dB Required CIN 4.00 dB Margin 4.69 dB

Table A.2. Reverse Link ("RL") Budget for Next-Gen AG Service

49 Louis J. Ippolito, "Propagation Effects Handbook for Satellite Systems Design: A Summary ofPropagation Impairments on 10 to 100 GHz Satellite Links with Techniques for System Design," NASA Document, 1989.

A-6 As seen in Table A.2, the RL EIRP requirement from the airplane is approximately 2 W (i.e., 3 dBW/2 MHz). This low EIRP requirement ofthe airplane transmitter limits greatly any potential interference into the satellite and TDRSS systems (which exist in the lower portion of the 14.0 to 14.5 GHz band), while enabling low-cost, small form factor, and easy-to-install aircraft equipment. A CIN ofapproximately 4 dB is needed to achieve I bpslHz for large packets using state ofthe art error correction codes. Thus, with the above parameters, the RL link budget leaves 4.69 dB ofmargin for potential degradations such as rain fade. 2 MHz is the minimum spectrum allocated in Table A.2 to an aircraft on the RL. However, the aircraft, depending on its RL data rate requirements, may be allocated additional multiples of2 MHz, perhaps as much as 10 MHz. Also, note that the RL bandwidth is dedicated to one aircraft, whereas the FL bandwidth is shared among a number ofplanes. Therefore, even with a 50 MHz FL carrier and a 2 MHz RL carrier, the throughput ratio on the FL and RL is not necessarily a factor of25 (based on 50 MHz on the FL versus 2 MHz on the RL) because ofthe sharing ofFL among multiple planes in a TDM fashion. Also, the bandwidth for FL and RL and their corresponding EIRP levels may be changed without impacting the interference calculations as long as the Power Spectral Density ("PSD") remains the same. Because PSD is the parameter that determines the interference level for operations in the 14.0 to 14.5 GHz band, the proposed rules in Appendix B to this Petition specify the allowable PSD limit from GSs and planes into the GEO-arc. FL and RL channel bandwidths and transmit power levels may be adjusted so long as the PSD limits specified in the proposed rules are not exceeded.

Table A.I shows that with 39.5 dBW ofGS EIRP per FL beam, there is - 6 dB ofmargin on the FL with a bandwidth efficiency of I bpslHz. However, there are three main sources ofpotential interference into Next-Gen AG-equipped aircraft: (i) VSAT terminals; (ii) NGSO terminals; and (iii) NGSO hubs. There also is the potential for rain fade, which will use the - 6 dB ofFL margin mentioned above and will be discussed later in this Appendix.

Calculations in later sections ofthis Appendix A will show that a ~T/T, hereafter referred to as Rise over Thermal ("RoT"), ofless than I % into GSO satellite uplinks can be achieved while each ofthe 150 Next-Gen AG GSs transmit up to 39.5 dBW on each of4 beams for a total of 45.5 dBW EIRP within a 50 MHz channel. Thus, the total permissible EIRP on the FL over the CONUS is 67.3 dBW. While there is about 6 dB ofmargin on the FL (see Table A.2) many

A-7 beams will not need to use the entire amount ofmargin to mitigate interference from satellite uplinks. Also, since the FL employs power control per beam, the total available 67.3 dBW EIRP power level may be shared among a maximum number of600 beams (based on 4 beams per GS) over the CONUS by allocating more power to beams that are undergoing rain fade while keeping the total ERIP over the CONUS :s 67.3 dBW. Furthermore, the system employs rate control and can lower a link's rate when there is excessive interference or rain fade, even though the probability ofsuch events is considered to be very small in the proposed system.

By allocating 39.5 dBW ofEiRP to each of4 co-frequency beams in each GS, it is possible to provide 1 bpslHz on each beam at the service area edge. With 150 GSs, 4 beams per GS, and - 500 MHz ofspectrum, the Next-Gen AG system can achieve - 300 Gb/s oftotal FL plus RL throughput supported via TOO communications. The specific division ofthe transmission time between FL and RL and channelization ofthe available bandwidth will be determined based on operational needs. As mentioned above, the interference calculations do not change with different FL and RL channel bandwidth as long as the EIRP for a given bandwidth is adjusted to maintain the PSO level set out in this Petition. See Appendix B.

2. Spectrum Considerations & Sharing Mean~

As described above, Qualcomm sought to design a Next-Gen AG system that would replicate, as closely as possible, a high-quality home/office broadband experience for the in-flight airline traveler. Qualcomm envisioned a system that would support much greater take-up penetration, for all the reasons set forth in Section I ofthis Petition. Thus, Qualcomm sought to operate in a frequency band with a substantial block ofspectrum, in the range of500 to 750 MHz, and one that presented a favorable sharing environment for an air-ground system.

These requirements forced Qualcomm to explore frequency bands above 5 GHz. Frequency bands above the high teens ofGHz, however, were deemed unsuitable both because ofhigher equipment costs and the substantial challenges that rain attenuation brings to providing a consistent, high-quality level ofair-ground mobile broadband service. Qualcomm sought a frequency band for its Next-Gen AG system that would support a coordinated collection of narrow, focused beams and allow substantial amount offrequency reuse within a GS service area and from service area to service area. A frequency band that is too low would render such use of

A-8 narrow beams unwieldy and quite costly to build GS antennas. Low frequencies also would make aircraft transceiver equipment too big and heavy - a major consideration for airplanes and airlines.

In addition, Qualcomm sought to avoid bands where there exists significant terrestrial point-to point or point-to-multipoint operation. While there are some successful examples ofsuch sharing, see, e.g., terrestrial sharing with satellite operations in the C-Band, sharing where terrestrial transmitters may point in any direction and with relatively low gain antennas compared to what prevails in C Band is quite challenging.

Also, the system could not operate in an unlicensed band because ofthe need to use higher transmit power than is permitted in any existing unlicensed band and the need for certainty as to the other users in the band to avoid receiving or causing interference.

In light ofthese considerations, Qualcomm proposes to deploy its Next-Gen AG system in the 14.0 to 14.50 GHz band. To the extent the FCC wants to enable competing systems, Qualcomm proposes that the 500 MHz band be divided into two sub-bands of 14.00 to 14.25 and 14.25 to 14.50 GHz and each sub-band be auctioned to support two licenses. Nonetheless, a single entity should be permitted to combine both licenses into a single system given business considerations associated with the Next-Gen AG service.

To enable an economically viable terrestrial-based mobile broadband service to aircraft, Qualcomm sought to design a system that operates with the smallest possible number ofGS cells. Thus, the range ofthe Next-Gen AG GSs is set at the maximum possible distance of 300 km consistent with the need to avoid signal blockage due to the curvature ofthe earth.

The fact that the proposed system will not interfere with services operating in accord with the current FCC and lTV Table ofFrequency Allocations is a necessary but not sufficient condition to enable a viable Next-Gen AG system. The Next-Gen AG system also must be able to reliably operate in the presence ofearth-to-space satellite operations within the 14.0 to 14.5 GHz band. For this reason, Qualcomm has examined potential interference from the full range ofsatellite earth stations in operation today - from the extremely large high power earth stations that satellite providers use in a small number ofkey cities to the hundreds ofthousands ofVSAT

A-9 terminals across the U.S. This includes the hundreds ofthousands ofQualcomm OmniTRACS units that successfully operate in this band. Obviously, Qualcomm would not propose a new service that would put at risk its highly successful OmniTRACS satellite communications and tracking service or the industries that rely upon the service.

The proposed Next-Gen AG system would operate in the Ku FSS uplink (earth-to-space) band at 14.0 to 14.5 GHz. Specifically, both the ground-to-airplane Forward Link and the airplane-to ground Reverse Link would use the 14.0 to 14.5 GHz band in a TOO fashion. The 14 GHz uplink band has well developed and internationally recognized criteria to limit interference into satellites. These criteria allow Qualcomm to calculate the worst case interference potential into GSO satellites and choose Rise over Thermal noise ("RoT") levels from the proposed Next-Gen AG into the uplink ofsatellites that, notably, are significantly less than the levels that adjacent satellites are allowed. so

Hence, Qualcomm determined that successful sharing between the Next-Gen AG system and the FSS uplink band was completely feasible. Such sharing ofa ground-based system with satellite operations is not unprecedented. For example, the FCC has allowed sharing in the downlink of the OBS Band for a different application. See n.48 supra. Here Qualcomm exploits what makes that sharing possible (coupled with several other innovative interference mitigation techniques). Specifically, all Next-Gen AG GSs transmit in a northerly direction and maintain very low emission levels into the GEO-arc. The GSs will use an isoflux antenna in elevation to keep the transmit power low enough at higher elevation angles to protect NGSO satellites and/or the GSs will use NGSO orbital ephemeris information to turn the FL power down when the NGSO satellite, airplane and GS align. Not only are the GSs transmitting to a location much closer to it than are satellite earth stations, but also the GS transmissions are in a very narrow beam and pointed away from the geostationary arc. This means ofoperation dramatically reduces any potential interference into GSO satellite operations.

so Qualcomm's sanguinity about sharing the Ku FSS uplink band does not extend to the matching downlink band. To Qualcomm's knowledge, the criteria governing interference into satellites are lacking for interference into earth stations. In addition, guaranteeing negligible interference impact from the Next-Gen AG system into, for example, VSAT terminals, was difficult from both airplane transmissions and even GS transmissions where VSATs are near the earth station. Thus, use ofthe downlink FSS band would introduce difficulties similar to sharing with terrestrial microwave operations.

A-10 The airplanes, in turn, transmit only to the GSs that are transmitting to them. Because ofthe very high gain ofthe GS receiving antennas, the airplanes are able to transmit with low effective power and at a very low angle ofelevation with respect to horizon. Furthermore, the Next-Gen AG aircraft antenna is located on the belly ofthe aircraft. The aircraft antenna's peak gain is angled at _5° from horizon because ofthe altitude ofthe aircraft and the fact that it needs to point its beam toward the GS on the ground. This results in high antenna pattern roll-offand blockage by aircraft body toward the higher elevation angles that would reach GSO satellites within the GEO-arc or NGSO satellites.

3. Ku-band Interference Mitigation and A ociated Requirements

3.1 Target y tern Parameters/Characteristics and Interference Thre hold Targets

3.1.1 Rise over Thermal ("RoT") Threshold into GEO and NGSO Uplinks

Table A.3 below shows the RoT targets used for the interference assessment into the uplink of GSO and NGSO satellites.

Airplanes GSs Transmit Transmit Target Target RoT RoT GEO Satellite UL Receive 1% 1%

NGSO Satellite UL 6% 6% Receive Table A.3. Rise over Thermal ("RoT") interference threshold for GSO and NGSO uplinks

The values given for the target RoT in Table A.3 above are thresholds for coordination given in Table 5.1 ofAppendix 5 ofthe Radio Regulations. For the purposes ofthis analysis, it is assumed that ifthe Next-Gen AG system gave rise to calculated signals into the satellite receiver that result in a RoT less than the values indicated in Table A.3 then the Next-Gen AG system will not interfere with the satellite operation.

A-II 3.1.2 TDRSS System Characteristics and Interference Thresholds51

The Next-Gen AG system is designed to meet the interference power density threshold to protect the NASA Tracking and Data Relay Satellite System ("TDRSS") system as demonstrated in a later section ofthis Appendix. TDRSS protection limits are summarized in Table A.4 for the White Sands, NM ("WSC"), Blossom Point, MD ("BP"), and Guam sites.

Interference Threshold Reference Percentage of Frequency Band Limit Measured at Time Antenna Output 13.4 - 14.0 GHz -176 dBW/kHz Never to be Exceeded

14.0 - 14.05 GHz -146 dBWIMHz Never to be Exceeded

-100 dBW (WSC, Guam), 14.05 - 14.4 GHz Never to be Exceeded -85 dBW (BP)

Table A.4. Interference limits into TDRSS

The TDRSS earth station sites and satellite locations are given in Table A.5.

TDRSS Satellite Long. Peak Antenna Earth Station Site LatlLong Degrees East Gain (dBi) N32 30' 18.686"/ -174, -171, -167.5, -150, White Sands (WSC) 66.4 WI06 36' 37.153" -79, -62, -49, -47,-41

N38 25' 44"/ -12, -41, -47, -49, Blossom Point (BP) 66.7 W77 OS' 02" -62, -79

N13 36' 0"/ 85,89, 133, -150, -167.5 Guam 61.9 W144 54' 0" -171,-174

Table A.5. Earth station and satellite locations

51 The protection criteria and associated information for the TDRSS are based upon the Coordination Agreement Between NASA and Panasonic for Operation ofthe eXConnect Ku-Band AMSS Terminals in the 14.0 14.5 GHz Band filed in association with the FCC Application ofPanasonic Avionics Corporation; File Nos. SES LlC-20100805-00992, SESAMD-20100914-01163 and SES-AMD-20101115-01432 (Call Sign EI00089). Qualcomm expects that the Next-Gen AG system operator would enter into a coordination agreement with NASA to protect the TDRSS similar in form to the NASA - Panasonic Coordination Agreement.

A-12 The TDRSS earth station antenna pattern is modeled by: 49 dBi for offaxis angles of

0.095 < e< 0.21; by the formula 32 - 25IoglO(e) for 0.21 ° < e< 48°; and -10 dBi for e> 48° as specified by the ITU.52

3.1.3 Interference Threshold for Radio Astronomy53

There are currently 13 Radio Astronomy sites in the United States that make measurements within the 14.47 to 14.50 GHz band. Interference limits into the Radio Astronomy sites is specified in terms ofpower flux density during their operational periods: -189 dBW/m2/Hz at ten ofthe sites, and -221 dBW/m2/Hz at the other three sites. As noted in the main body ofthe Petition, protection ofthe Radio Astronomy Service in the U.S. will be in accordance with US203 and US342 of47 C.F.R. § 2.106.

3.2 NGSO System Assumptions

Despite the fact that there are no NGSO operations at 14.0 to 14.5 GHz, Qualcomm has designed the Next-Gen AG system to protect a possible future NGSO system, as described below.

Qualcomm considers an NGSO system with satellites forming 50 beams and orbiting at an altitude of 1000 km above the earth's surface. The GIT ofthe satellite beams is approximately -7 dB/K, assuming system noise temperature of500 K and beamwidth of 17.34° for a beam diameter of300 km. The coverage area ofthe resulting beam is a circular area with a diameter of300 km. Thus, for the Next-Gen AG system with 150 GSs over the CONUS, there are at most 3 Next-Gen AG sites in the coverage area ofone NGSO spot beam. Also, it is assumed that the NGSO system implements a frequency reuse of3 in its spot beams. A frequency reuse of3 for the adjacent NGSO beams is a reasonable assumption ifthe NGSO system is to support high data rates.

52 "Radiation Patterns for Earth Station Antennas to Be Used When They Are Not Published," International Telecommunication Union Radio Regulations, Volume 2, Appendix 8, Annex 3 (2008). 53 The information relating to the Radio Astronomy sites is from "A Coordination Agreement Between the National Science Foundation ("NSF") and Row 44 Inc. ("Row 44") for Operation ofthe Row 44 AMSS and Radio Astronomy Sites Jointly Sharing the 14.0-14.5 GHz Band." Qualcomm expects that the Next-Gen AG system operator would enter into a coordination agreement with the NSF relating to protection ofradio astronomy services similar in form to the NSF - Row 44 Coordination Agreement.

A-13 The NGSO terminal and hub antenna are assumed to have the characteristics ofAntenna Type A described in Table A.7 below. A narrow beamwidth Type A antenna (l0) for NGSO terminals/hubs is used to: (i) provide the NGSO uplink higher EIRP while protecting the GEO are, and (ii) have a smaller exclusion zone around the GEO-arc.

The EIRP ofthe NGSO hub is assumed to be 58.5 dBW with a 100 MHz bandwidth. This EIRP achieves a CIN ofat least 15 dB at the satellite receiver as discussed below. The NGSO hub's antenna is assumed to serve the satellites at elevation angles ~ 15°. This is a reasonable assumption because operation at lower elevation angles is subject to blockage from trees and/or buildings and thus may limit service to some terminals. Assuming a satellite altitude of 1000 km, the distance between the satellite and the hub at elevation angle of 15° is - 2410 km. The CIN seen by the satellite beam at a 15° elevation angle is given by Table A.6.

Note that since the elevation angle in the NGSO system between the hub/terminals and the satellite is much higher than in the Next-Gen AG system, atmospheric losses (e.g., oxygen and water vapor) are very small, but rain fade is accounted for nonetheless. The NGSO system is assumed to have power control on the uplink and only uses the 4 dB rain fade margin shown in the link budget ofTable A.6 when there is rain fade. Thus, in clear sky conditions, the NGSO hub EIRP will be 58.5 dBW.

Hub EIRP 62.50 dBW Rain Fade -4.00 dB Satellite GfT -7.00 dBIK Beam Gain Roll-off at 15° Elevation Compared to Center ofBeam -2.00 dB llBW (BW = 100 MHz) -80.00 -dB-Hz llBoltzmann 228.60 -dBIK-Hz Path Loss (2410 km at 14 GHz) -183.00 dB CIN at Satellite 15.10 dB

Table A.6. CIN achieved at the NGSO hub satellite uplink

3.3 Details ofInterference Protection Calculations and Discussion

This section provides interference protection calculations for the Next-Gen AG system into current incumbent services (and future NGSO operations) as well as potential interference from those systems into the proposed Next-Gen AG system. Table A.7 shows two types ofantennas

A-14 that are used in the interference protection calculations. Antenna Type B is used to analyze the potential interference from VSAT terminals, whereas Antenna Type A is used to analyze potential interference from NGSO terminals and hubs. Antenna Type A is appropriate for future NGSO terminals and hubs because they too will have to protect the GEO-arc and are likely to opt for narrow beamwidth antennas to increase their coverage area.

Antenna Roll-off from Boresight (dB) Antenna 3dB Peak Antenna Type Beamwidth Gain (dBi) 5° to 10° to 15° to 20° to 30° to 100° to 140° to 10° 15° 20° 30° 100° 140° 180°

A 1.0 nJa 23 28 35 39 41 42 50

B 2.0 nJa 20 25 28 30 32 37 47

Table A.7. Antenna pattern assumed for VSAT and NGSO terminals and hubs

3.3.1 Next-Gen AG Potential Interference into GSO Satellites

In the two cases covered in the sections below - Next-Gen AG GS impact and aircraft impact on GSO satellites - the GSO satellite has a CONUS-wide footprint beam centered on the 48 states and slightly beyond into ocean areas offthe coastlines. The average GIT ofthe footprint is 2 dB/K.

3.3.1.1 Next-Gen-AG Ground Stations

First, a methodology is proposed for computing lIN from GSs into the CONUS beams ofGSO satellites. The results presented herein will hold for multi-beam satellites because the number of GSs seen by a spot beam is lower by almost the same proportion that G/T ofthe spot beam is higher than that ofthe CONUS beam. For example, iftwo beams cover the CONUS then each beam has 3 dB more GITthan the CONUS beam, but each beam sees halfthe number ofGSs. The reduced interference from the reduced number ofGSs compensates for the increased GIT of the spot beam resulting in approximately the same RoT as with the CONUS beam.

In the baseline system design, the GSs radiate 39.5 dBW EIRP within 50 MHz on a beam that is pointing straight north to cover an aircraft at the farthest distance from the GS (i.e., 300 km). For aircraft in other locations to the right or left ofthe north-south direction, the GS transmit EIRP is

A-15 reduced according to the smaller path loss. By way ofexample, an aircraft at one ofthe lower corners ofa hexagon that is at a 60° azimuth angle from the GS (a distance of 143 kIn from the GS, equal to the side ofthe hexagon in Figure A.l) will have a path loss that is - 6.4 dB less than at 300 kIn from the GS. Then, the required EIRP to service this aircraft is 39.5 - 6.4 = 33.1 dBW.

The beam antenna roll-offtoward the GEO-arc for the beam that points directly northward is designed to be 37 dB, resulting in an effective EIRP of2.5 dBW in 50 MHz toward the GEO-arc. For other locations, where the peak EIRP ofthe beam is less than 37 dBW, the roll-offtoward the GEO-arc will be less than 37, commensurate with the decrease in the peak EIRP ofthe beam. In the example described above, the beam roll-offtoward the GEO-arc needs to be 37-6.4 = 31.6 dB to ensure the effective EIRP toward GEO-arc, taking into account the GS antenna roll offtoward the GEO-arc, is less than 2.5 dBW/50 MHz.

In the baseline system design, there are 600 beams over CONUS because the system consists of 150 GSs and 4 co-frequency beams per site. lIN at the satellite receiver is given by Equation (I) below:

.!... = _L_~~oO PL.F. Gi (1) N BXl06 k Lot=l t t T' where: L is the path loss to GEO-arc; B is the Next-Gen-AG FL bandwidth in MHz (50 MHz in baseline design on FL); k is the Boltzmann constant; P is the EIRP ofthe beams that point directly north to cover the farthest distance northward, i.e., the peak EIRP; L; is the path loss ratio corresponding to the distance from GS to location ofa specific aircraft to the farthest distance from GS (300 km); F; is the i-th beam antenna roll-offtoward the GEO-arc relative to beam peak (i.e., beam peak to sidelback lobe toward GEO-arc); GIT is the satellite G/T at the i-th GS.

PL; is the power on the i-th beam needed to achieve the desired CIN to a given aircraft. It is lower than that needed by the aircraft at the farthest distance by the amount of lower path loss specified by L;. PL;F; is the power that is spilled into the GEO-arc from the i-th beam. As

A-16 described above, the GS beam is designed such that (PjLjF/BhB < 2.5 dBW/50 MHz. Then, lIN may be simplified as follows:

where GIT is the average ofG/T over the 600 beams and is for a typical CONUS beam 2 dB/K. Table A.8 computes the result ofEquation (2) ,which leads to an RoT of0.49%.

G Peak EIRP Per Beam 39.50 dBW G Antenna Front to Back Ratio -37.00 dB Number of Beams over CONUS (600, 150 GSs and 4 beams per site) 27.78 dB Atmospheric Loss at Ku Band 0.00 dB GEO Satellite Average Gff over CONUS 2.00 dB/K IIBW (BW = 50 MHz) -76.99 -dB-Hz IIB01tzmann 228.60 -dB/K-Hz Path Loss to Geo Arc (at 14 GHz) -207.00 dB Polarization Discrimination (GEO Satellite and BTS Linear) 0.00 dB

I at Satellite Receiver -23.11 dB

RT 0.49 0/0

Table A.8. RoT at GEO Satellite Uplink from Next-Gen AG GSs

Therefore, one means ofensuring that the RoT to satellite receivers in the GEO-arc is less than 0.5% is to require that

( PLiFi6 ) < -74.5 dBWIHZ fior a11')="I 2 3 ...,,600 (3) BX10 dB for all locations inside the coverage area. Equation (3) presupposes that there is no power sharing among different beams. It would, however, be desirable to be able to reduce EIRP of some beams and increase the EIRP ofbeams that may temporarily need more power such as when in rain fade. The rule for power sharing among all GS beams is given by:

PLiF~) ( < -68.5 dBWIHz for all i=I,2,3 ...,600. (4) BxlO dB

A-17 The second part ofEquation (4) ensures that the power ofno beam is increased more than 6 dB above a nominal value. This requirement will be included in the proposed service rules for the Next-Gen AG service in Appendix B to this Petition.

3.3.1.2 Next-Gen AG-Eguipped Aircraft into the GEO-arc

Each aircraft transmits at 3 dBW EIRP within a nominal 2 MHz bandwidth. Since each piece of spectrum may be used on a maximum of4 GS beams and there are a maximum of 150 GSs, the maximum number ofaircraft transmitting on the same piece ofspectrum over the CONUS is 600.

To compute the interference from all Next-Gen AG-equipped aircraft over the CONUS, the CONUS is divided into bins ofwidth of5° in longitude and 2.5° in latitude. This results in 89 bins over the CONUS. The contributions from aircraft in these bins are added together to compute the overall RoT into the GEO-arc. The lIN seen at the satellite from aircraft transmitters is given by Equation (5):

.!- = ~ ~~9 N.k E«(}.) G; (5) N 8Xl06k £'1=1 II IT' where: L is the path loss to GEO-arc; P is the aircraft transmit EIRP; k is the Boltzmann constant; B is the Next-Gen AG RL bandwidth in MHz (2 MHz in baseline design); N; is the number ofaircraft using the same piece ofspectrum in bin i, which on average is 600/89 for the baseline system; A; is the average roll-offin azimuth ofthe aircraft antenna relative to boresight in bin i; 0; is the elevation angle ofaircraft in bin i; E(OJ is the aircraft antenna roll-offat elevation angle B;; GIT is the satellite G/T at the i-th GS.

First, consider a satellite positioned at 100° longitude. Table A.9 shows the elevation angles in the longitude/latitude bins over the CONUS for longitudes of70° to 125° and latitudes of25° to 50°.

A-I8 125 120 1I5 110 105 100 95 90 85 80 75 70 50.0 27.95 29.60 30.93 31.90 32.49 32.69 32.49 47.5 30.25 32.04 33.49 34.55 35.20 35.42 35.20 34.55 33.49 28.14 45.0 32.53 34.48 36.06 37.22 37.93 38.17 37.93 37.22 36.06 32.53 30.25 42.5 34.79 36.91 38.62 39.89 40.68 40.94 40.68 39.89 38.62 36.91 34.79 32.34 40.0 37.03 39.32 41.19 42.58 43.43 43.72 43.43 42.58 41.19 39.32 37.03 37.5 41.72 43.75 45.27 46.21 46.53 46.21 45.27 43.75 41.72 39.25 35.0 44.10 46.30 47.96 48.99 49.34 48.99 47.96 46.30 44.10 32.5 48.84 50.66 51.79 52.18 51.79 50.66 48.84 46.44 30.0 54.60 55.03 54.60 53.34 51.35 48.74 27.5 57.89 57.41 51.00 25.0 60.76 53.19 Table A.9. Elevation angles over CONUS from a satellite at 100° longitude

Table A.9 shows that all bins have elevation angles greater than 25°. Then, the interference seen by the satellite in this example may be upper bounded by letting A; = 1 for all i, and approximating the E(B) for B; = 25°. Based on the baseline aircraft antenna characteristics described in Section 1.1, (E(BJ)dB < -20 dB for B; >20°, and assuming a uniform distribution of airplanes over the CONUS, i.e., N;=600/89, Equation (5) may be reduced to:

_L -2.0 G - 600 B x 106k 10 P T' (6) where GfT is the average ofGifT over the CONUS and is taken to be 2 dB/K. The lIN and RoT for the case ofa satellite at 100° longitude (based on Equation (6» may be calculated as shown in Table A.1 O.

A-19 Plane EIRP Per Beam 3.00 dBW Plane Antenna Average Roll-offToward GEO Arc -20.00 dB Number ofPlanes Using Same Spectrum Across CONUS (600, 150 GSs and 4 beams per site) 27.78 dB Atmospheric Loss at Ku Band 0.00 dB GEO Satellite Average Gff over CONUS 2.00 dB/K llBW (BW = 2 MHz) -63.01 -dB-Hz IlBoltzmann 228.60 -dB/K-Hz Path Loss to Geo Arc (at 14 GHz) -207.00 dB Polarization Discrimination (GEO Satellite and BTS Linear) 0.00 dB

lIN at Satellite Receiver -28.63 dB

RoT 0.14 °A,

Table A.tO. RoT at Uplink ofGEO Satellite at 100° Longitude from Next-Gen AG Aircraft

QuaIcomm recognizes that aircraft may roll ± 5° during normal flight. However, because the baseline aircraft antenna roll-off in elevation is at least 20 dB for angles 2:: 15° above horizon and the elevation angle to the satellite at 100° longitude over CONUS is 2:: 27.95° (see Table A.9), at all locations and worst case aircraft roll of5°, the aircraft antenna roll-offtoward the GEO-arc will be at least 20 dB and the RoT will be no greater than 0.14%, as computed in Table A.10 above.

Consider next a satellite at 140° longitude located at the far west ofthe CONUS and whose CONUS beam would see a lower elevation angle in the eastern longitude/latitude bins. Table A.11 shows the elevation angles for this satellite over the 89 bins. The azimuth angle from an aircraft to the satellite is defined as the angle between the line connecting the aircraft to the serving GS (i.e., the direction that the aircraft antenna points) and the line connecting the aircraft to the satellite. Table A.l2 shows azimuth angles for aircraft in the middle ofeach GS service area with the antenna pointing directly south relative to a satellite at 140° longitude. This angle is the median ofthe azimuth angle ofall possible aircraft locations within a GS service area.

A-20 125 120 115 110 105 100 95 90 85 80 75 70 50.0 30.93 29.60 27.95 26.01 23.82 21.40 18.80 47.5 33.49 32.04 30.25 28.14 25.77 23.17 20.38 17.44 14.37 4.69 45.0 36.06 34.48 32.53 30.25 27.70 24.91 21.93 18.80 15.55 8.79 5.33 42.5 38.62 36.91 34.79 32.34 29.59 26.62 23.44 20.12 16.69 13.16 9.58 5.95 40.0 41.19 39.32 37.03 34.39 31.45 28.28 24.91 21.40 17.78 14.08 10.33 37.5 41.72 39.25 36.41 33.27 29.89 26.33 22.64 18.84 14.97 11.05 35.0 44.10 41.42 38.38 35.03 31.45 27.70 23.82 19.84 15.81 32.5 43.56 40.29 36.74 32.95 29.01 24.95 20.80 16.61 30.0 38.38 34.39 30.25 26.01 21.71 17.36 27.5 35.75 31.43 18.06 25.0 37.03 18.71 Table A.H. Elevation angles over CONUS from a satellite at 140° longitude

125 120 115 110 105 100 95 90 85 80 75 70 50.0 19.28 25.41 31.33 37.00 42.43 47.61 52.55 47.5 19.97 26.27 32.31 38.06 43.52 48.70 53.60 58.26 62.70 74.98 45.0 20.75 27.24 33.40 39.23 44.72 49.88 54.74 59.32 63.66 71.75 75.57 42.5 21.63 28.31 34.61 40.52 46.03 51.16 55.96 60.45 64.68 68.69 72.51 76.19 40.0 22.63 29.52 35.96 41.93 47.45 52.55 57.27 61.66 65.77 69.64 73.31 37.5 30.87 37.45 43.48 49.00 54.04 58.67 62.94 66.91 70.64 74.15 35.0 32.40 39.11 45.19 50.68 55.64 60.16 64.30 68.12 71.68 32.5 40.95 47.06 52.50 57.37 61.75 65.73 69.38 72.77 30.0 54.47 59.21 63.43 67.24 70.70 73.90 27.5 61.18 65.21 75.07 25.0 63.27 76.29 Table A.12. Azimuth angles over CONUS from a satellite at 140° longitude

Since the baseline aircraft antenna discussed in Section 1.1 has a 3 dB azimuthal beamwidth of ±45, then the average azimuthal antenna roll-offfor all entries in Table A.12 that have elevation angles less than 15° is, as may be numerically computed, - -4 dB. Below, lIN ofEquation (5) is upper bounded by letting Ai = 1 for all bins with elevation angle > 15° and Ai = 10.04 for all bins with elevation angles < 15°; setting Ai = 1 for bins with elevation angles greater than 15° underestimates the roll-offtoward the GEO-arc and therefore upper bounds the interference.

In Table A.ll, the number ofbins with elevation angles e> 15°, 15° > e> 10°, and 10° > e> 4.7° is 78, 6, and 5, respectively. Then, assuming uniform distribution ofplanes over bins (Ni =600/89), Equation (5) is upper bounded by:

.!... :::; 600~6 ~ [(78E(8 > 15°) + 6AE(100 < 8 < 15°) + 5AE(5° < 8 < 10°))/89], (7) N BX10 k T

A-2l where, based on the aircraft antenna specification of Section 1.1, E(e > 15°), E(15° > e > 10°), E( 10° > e > 5°) are (when converted to dB) less than -20, -15, and -10 dB for the terms in Equation (7), and A (when converted to dB) is -4 dB. Then, the term in the square brackets in Equation (7) is reduced to - 0.012, i.e., -19.2 dB. Computing Equation (7) based on the parameters in Table A.l0 provides an RoT of0.17%.

Ifone were to account for the maximum ±5° roll ofthe plane during a normal flight, the RoT increases from 0.17% to ~ 0.21 %. Pursuant to Table A.ll, 66 ofthe 89 total bins covering the CONUS have elevation angles ofat least 20° toward satellite; for these 66 bins, the aircraft antenna discrimination toward the satellite is at least 20 dB, even at the worst case plane roll of 5°. Taking into account the reduced average antenna roll-off for the remaining 23 bins, the term in square brackets in Equation (7) is, as may be numerically computed, about -18.2 dB, which means that the RoT - taking into account the ± 5° flight plane roll- is about 0.21 %. Although approximations are made in arriving at Equation (7), such as using the average GfT over the CONUS, the methodology does accurately characterize the upper bound of interference.

The above calculations considered a maximum of600 aircraft communicating on a given piece ofspectrum (150 Ground Stations and 4 co-frequency beams per GS) within the CONUS. The aircraft are distributed uniformly across the CONUS and among the GSs, because for a given GS, there may be at most 4 planes communicating on the same piece ofspectrum. Iffor some reason most ofthe planes are concentrated on the east or west coast it may be necessary to increase the number ofGSs in areas with heavy traffic. In this case, the GS service area and the GS-aircraft distance will be reduced along with their maximum transmit EIRP.

Note that the terms inside the bracket in Equation (7) represent the average aircraft antenna roll offin elevation and azimuth for each bin over the CONUS and the sum ofthe terms inside the bracket is the average aircraft antenna roll-off in elevation and azimuth over the CONUS. Then, it can be seen from Table A.l0 that with plane antenna roll-off of-15 dB and plane EIRP of3 W, the RoT into the GEO-arc will be ~ 0.44%. Therefore, to ensure RoT ofless than 0.5%, it is reasonable to define a rule set forth in Equation (8) below: 89:~106 ( I 9,(8, '1')) ::; -47 dBW1Hz, (8) l=1 dB

A-22