Federal Communications Commission DA 09-428 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Northrop Grumman Space & Mission Systems 
Corporation 
Applications for Authority to 
Operate a Global Satellite System Employing 
Geostationary Satellite Orbit and 
Non-Geostationary Satellite Orbit Satellites 
in the Fixed-Satellite Service 
in the Ka-band and V-band
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File Nos. SAT-LOA-19970904-00080
SAT-AMD-19971222-00219
SAT-AMD-20031104-00324
SAT-AMD-20040312-00030
SAT-AMD-20040719-00136
SAT-AMD-20051118-00227
SAT-AMD-20070209-00033
(NGSO System – Call Sign S2254)
File Nos. SAT-LOA-19970904-00081
SAT-AMD-20040312-00032
SAT-AMD-20040719-00138
SAT-AMD-20051118-00230
SAT-AMD-20070209-00030
(73° W.L. – Call Sign S2256) 
File Nos. SAT-LOA-19970904-00082
SAT-AMD-20040312-00033
SAT-AMD-20040719-00140
SAT-AMD-20051118-00232
SAT-AMD-20070209-00031
(68.5° E.L. – Call Sign S2257)
File Nos. SAT-LOA-19970904-00083
SAT-AMD-20040312-00034
SAT-AMD-20040719-00139
SAT-AMD-20051118-00231
SAT-AMD-20070209-00032
(116.5° E.L. – Call Sign S2258)
File Nos. SAT-LOA-19970904-00084
SAT-AMD-20040312-00031
 SAT-AMD-20040719-00137
SAT-AMD-20051118-00229
SAT-AMD-20070209-00029
(125° W.L. – Call Sign S2255)
File No.   SAT-WAV-19971222-00220
Federal Communications Commission DA 09-428
ORDER AND AUTHORIZATION
Adopted:  February 23, 2009 Released:  February 24, 2009
By the Acting Chief, International Bureau:
TABLE OF CONTENTS
Paragraph No.
I. INTRODUCTION ..................................................................................................................................1
II. BACKGROUND ....................................................................................................................................3
A. V-band ..............................................................................................................................................3
B. Ka-band ............................................................................................................................................7
C. Northrop Grumman Applications...................................................................................................10
1. Procedural History ...................................................................................................................10
2. Comments ................................................................................................................................17
III. DISCUSSION .......................................................................................................................................22
A. Processing Framework ...................................................................................................................22
1. V-band......................................................................................................................................23
2. Ka-band....................................................................................................................................31
a. NGSO Component.............................................................................................................31
b. GSO Component ...............................................................................................................35
B. Qualifications .................................................................................................................................36
1. Legal and Financial Qualifications ..........................................................................................37
2. Technical Qualifications ..........................................................................................................38
a. V-band Allocations............................................................................................................38
(i) V-band Uplink ............................................................................................................38
(ii) V-band Downlink........................................................................................................40
b. The Ka-band Plan..............................................................................................................45
(i) Ka-band Uplink...........................................................................................................45
(ii) Ka-band Downlink......................................................................................................48
c. NGSO Satellites ................................................................................................................52
(i) V-band Operations......................................................................................................53
(ii) Ka-band Operations ....................................................................................................69
(iii) Replacement Satellites................................................................................................77
d. GSO Satellites ...................................................................................................................78
(i) V-band Operations......................................................................................................79
(ii) Ka-band Operations ....................................................................................................82
(iii) Increased Power Operations in the 18.8-19.3 GHz and 28.6-29.1 GHz 
Frequency Bands.........................................................................................................91
e. Tracking, Telemetry, and Command Function..................................................................94
f. Orbital Debris Mitigation ..................................................................................................96
g. Inter-Satellite Links.........................................................................................................103
C. License Conditions .......................................................................................................................104
1. Milestone Schedule................................................................................................................104
2. License Term .........................................................................................................................106
3. Reporting Requirements ........................................................................................................107
4. International Coordination .....................................................................................................108
5. Bond.......................................................................................................................................109
IV. CONCLUSION AND ORDERING CLAUSES.................................................................................111
Federal Communications Commission DA 09-428 
I. INTRODUCTION
1. By this Order, we grant Northrop Grumman Space & Mission Systems Corporation 
(Northrop Grumman) authority for a satellite system consisting of three non-geostationary satellite 
orbit (NGSO) satellites and four geostationary satellite orbit (GSO) satellites.1 These satellites will 
provide fixed-satellite service (FSS) in the Ka- and V-bands.2 Specifically, we authorize Northrop 
Grumman to construct three NGSO satellites that will operate in the frequency bands outlined in the 
chart below.  We also authorize Northrop Grumman to construct, launch and operate four GSO 
satellites at the orbital locations and frequency bands identified in the chart.  Authorizing this 
combined NGSO and GSO satellite system will give Northrop Grumman an opportunity to provide 
customers access to a variety of advanced broadband and interactive satellite communications 
services.
Architecture Authorized Frequencies Operating Authority3
NGSO Satellites 47.2-50.2 GHz (Earth-to-space)
37.5-42.0 GHz (space-to-Earth)
29.5-30.0 GHz (Earth-to-space)
28.6-29.1 GHz (Earth-to-space)
19.7-20.2 GHz (space-to-Earth)
18.8-19.3 GHz (space-to-Earth)
Co-Primary
Co-Primary 
Secondary 
Primary 
Non-conforming 
Primary 
GSO Satellites Located 
At 125° W.L., 73° W.L.,
47.2-50.2 GHz (Earth-to-space)
37.5-42.0 GHz (space-to-Earth)
Co-Primary 
Co-Primary 
  
1 These applications were originally filed by TRW, Inc. pursuant to a filing “cut-off date” announced by the 
Commission.  Satellite Policy Branch Information:  Applications Accepted For Filing: Cut-Off Established for 
Additional Space Station Applications and Letters of Intent in the 36-51.4 GHz Frequency Band, Public 
Notice, Report No. SPB-89, 12 FCC Rcd 10450 (1997) (V-band Cut-off Notice).  In 2002, the Commission 
approved the transfer of control of TRW’s authorizations and pending applications to Northrop Grumman 
Corporation. Application of TRW Inc., Transferor and Northrop Grumman Corporation, Transferee, For 
Consent to Transfer of Control of Authorization to Construct, Launch and Operate a Ka-Band Satellite System 
in the Fixed-Satellite Service, Order and Authorization, 17 FCC Rcd 24625 (Int'l Bur., Sat. Div., 2002) (TRW 
Transfer of Control Order).  TRW later changed its name to Northrop Grumman Space & Mission Systems 
Corporation.  See Letter to Marlene H. Dortch, Secretary, FCC from Stephen D. Baruch, Counsel to Northrop 
Grumman Space & Mission Systems Corp. (Jan. 10, 2003).  At that time, Northrop Grumman requested an 
exemption from the application “cut-off date” with respect to the TRW applications, to preserve the filing 
status of these applications.  See Application File No. SAT-WAV-19971222-00220.   In light of the 
Commission’s subsequent decision that transfers of control will no longer affect an application’s processing 
status (see Amendment of the Commission’s Space Station Licensing Rules and Policies, Mitigation of Orbital 
Debris, First Report and Order and Further Notice of Proposed Rulemaking, IB Docket Nos. 02-34 and 02-54, 
18 FCC Rcd 10760, 10814 (para. 140) (2003) (First Space Station Licensing Reform Order)), we dismiss the 
request as moot and conform the applicant’s name to reflect the change in control.
2 The term “Ka-band” refers to the space-to-Earth (downlink) communications in the 17.7-20.2 GHz band and 
the corresponding Earth-to-space (uplink) communications in the 27.5-30.0 GHz frequency band.  The term 
“V-band” refers to the space-to-Earth (downlink) communications in the 37.5-42.5 GHz band and the 
corresponding Earth-to-space (uplink) communications in the 47.2-50.2 GHz frequency band.
3 Space stations operating in primary services are protected against interference from stations of secondary 
services.  Stations operating in a secondary service cannot cause harmful interference to or claim protection 
from harmful interference from stations of a primary service.  Co-primary services have equal rights to operate 
in  particular frequencies.  Non-conforming services may be provided only on a non-harmful interference basis 
to any authorized Federal, non-Federal, or non-U.S.-licensed services and may not claim interference 
protection from those services.
Federal Communications Commission DA 09-428
3
68.5° E.L., and 116.5° E.L. 29.25-30.0 GHz (Earth-to-space)
28.6-29.1 GHz (Earth-to-space)
28.35-28.6 GHz (Earth-to-space)
19.7-20.2 GHz (space-to-Earth)
18.8-19.3 GHz (space-to-Earth)
18.3-18.8 GHz (space-to-Earth)
Primary 
Secondary 
Primary 
Primary 
Non-conforming 
Primary 
2. We deny, however, Northrop Grumman’s request to launch and operate its NGSO 
satellites due to orbital debris mitigation concerns.4 Once Northrop Grumman has finalized its end-
of-life disposal plan for the NGSO satellites, it may file an application to launch and operate these 
satellites.  Nevertheless, we address issues relating to Northrop Grumman’s proposed NGSO 
operations in this Order so we will be in a position to act expeditiously should Northrop Grumman 
file a request for launch and operating authority for the NGSO satellites.  We also deny Northrop 
Grumman’s request for a waiver of the bond requirement for its GSO satellites.
II. BACKGROUND
A. V-band
3. In July 1997, the Commission released a Public Notice establishing a cut-off for 
space station applications proposing to use the V-band.5 In response to the Public Notice, 14 entities 
filed applications for 17 satellites, including Northrop Grumman.  These applicants proposed GSO 
and/or NGSO systems.6  
4. In December 1998, the Commission released the V-band Allocation Order, where it 
allocated two gigahertz of spectrum for FSS in the 37.6-38.6 GHz and 40.0-41.0 GHz frequency 
bands for downlinks, and two gigahertz in the 48.2-50.2 GHz frequency band for uplinks.7 The V-
band Allocation Order also re-allocated the 47.2-48.2 GHz band for exclusive non-Federal use.8
5. In November 2003, the Commission adopted the V-band Second Report and Order.9  
  
4 See para. 102, below.
5 V-band Cut-off Notice, 12 FCC Rcd at 10450.  The original cut-off date was August 21, 1997, but was later 
extended to September 26, 1997.  Clarification and Corrections to Public Notices, Report Nos. SPB-88 and 
SPB-89, Establishing Deadlines for Applications, Letters of Intent, and Amendments to Applications in the 2 
GHz and 36-51.4 GHz Frequency Bands, Public Notice, 12 FCC Rcd 12050 (Int'l Bur., 1997); Extension of 
Cut-off Dates for Applications, Letters of Intent, and Amendments to Applications in the 2 GHz and 36-51.4 
GHz Frequency Bands, Public Notice, Report No. SPB-99 (Sept. 4, 1997). 
6 Ten applicants subsequently withdrew their applications.  The Commission dismissed the applications filed 
by three other applicants.  Northrop Grumman is the only remaining V-band applicant.  
7 Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz 
and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 
40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless 
Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz Frequency Bands for 
Government Operations, Report and Order, IB Docket No. 97-95, 13 FCC Rcd 24649 (1998)  (V-band 
Allocation Order).  See also Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-
38.5 GHz, 40.5-41.5 GHz and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and 
Mobile Allocations in the 40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz 
Frequency Band for Wireless Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz 
for Government Operations, Further Notice of Proposed Rulemaking, IB Docket No. 97-95, 16 FCC Rcd 
12244 (2001) (V-band Further Notice).
8 See V-band Allocation Order, 13 FCC Rcd at 24671 (para. 41).
9 Allocation and Designation of Spectrum for Fixed-Satellite Services in the 37.5-38.5 GHz, 40.5-41.5 GHz 
and 48.2-50.2 GHz Frequency Bands; Allocation of Spectrum to Upgrade Fixed and Mobile Allocations in the 
(continued....)
Federal Communications Commission DA 09-428
4
In that Order, the Commission made various changes in V-band designations and allocations that 
reflected decisions made at the 2000 and 2003 World Radiocommunication Conferences.  The 
Commission also adopted power flux density (PFD) limits for both GSO and NGSO V-band 
systems.10
6. In May 2003, the Commission released the First Space Station Licensing Reform 
Order, adopting new licensing procedures designed to allow it to process satellite applications 
significantly faster than it could previously, while maintaining adequate safeguards against 
speculation.11 The Commission concluded that continuing to analyze pending V-band applications 
under the processing procedure previously in effect would frustrate these goals.  The Commission 
directed the International Bureau to analyze all pending V-band applications pursuant to the 
procedures adopted in the First Space Station Licensing Reform Order.  In this regard, the 
Commission directed the Bureau to treat all pending V-band applications as though they were filed 
at the same time.  The Commission further directed the Bureau to divide the V-band FSS spectrum 
between GSO systems and NGSO systems based on the proportion of qualified GSO applicants and 
NGSO applicants.  The Bureau would then assign qualified GSO applicants to the orbit locations 
they requested in the “GSO-designated” portion of the band.  In cases where two applicants 
requested the same orbital location, the Bureau would subdivide the GSO spectrum between them.  
The Commission also directed the Bureau to divide the NGSO portion of the V-band equally among 
the qualified NGSO applicants.12
B. Ka-band
7. In May 1997, the International Bureau licensed 13 GSO applicants and one NGSO 
applicant to operate satellite systems as part of the first Ka-band FSS processing round.13 Consistent 
with the Commission’s 1996 decision to divide the 27.5-30.0 GHz portion of the Ka-band among 
several services, the Bureau authorized the GSO systems in one range of Ka-band spectrum and the 
NGSO system in another.14  
8. In October 1997, the Bureau established a second processing round for FSS Ka-band 
systems.15 At that time, the Commission also adopted its Ka-band Third Report and Order
  
(...continued from previous page)
40.5-42.5 GHz Frequency Band; Allocation of Spectrum in the 46.9-47.0 GHz Frequency Band for Wireless 
Services; and Allocation of Spectrum in the 37.0-38.0 GHz and 40.0-40.5 GHz for Government Operations, 
Second Report and Order, IB Docket No. 97-95, 18 FCC Rcd 25428 (2003) (V-band Second Report and 
Order).
10 V-band Second Report and Order, 18 FCC Rcd at 25470-72 (promulgating 47 C.F.R. § 25.202(a) (1) fn. 15 
and 47 C.F.R. § 25.208(q) - (u)).
11 First Space Station Licensing Reform Order, 18 FCC Rcd at 10865 (para. 279).  
12 Id.
13 Assignment of Orbital Locations to Space Stations in the Ka-band, Order, 13 FCC Rcd 1030 (Int’l Bur. 
1997).  See also Teledesic Corp., Order and Authorization, 12 FCC Rcd 3154 (Int’l Bur. 1997) (authorizing 
Teledesic Corp. to launch and operate a NGSO FSS system in the Ka-band).  Teledesic subsequently 
surrendered its NGSO authorization.  Letter to Marlene H. Dortch, Secretary, FCC, from Mark A. Grannis, 
Counsel to Teledesic (June 27, 2003).  In addition, a number of GSO licensees surrendered their licensees.
14 Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission’s Rules to Redesignate the 27.5-29.5 GHz 
Frequency Band, to Reallocate the 29.5-30.0 GHz Frequency Band, to Establish Rules and Policies for Local 
Multipoint Distribution Service and for Fixed Satellite Services, First Report and Order and Fourth Notice of 
Proposed Rulemaking, 11 FCC Rcd 19005 (1996) (Ka-band Plan Order).
15 See Public Notice Satellite Policy Branch Information:  Satellite Applications Accepted for filing in the Ka-
band, Cut-Off Established for Additional Applications in the 28.35-28.6 GHz, 29.1-30 GHz, 17.7 - 18.8 GHz, 
and 19.3 - 20.2 GHz Frequency Bands, Report No. SPB-106, 13 FCC Rcd 8020 (Int’l Bur. 1997). 
Federal Communications Commission DA 09-428
5
establishing technical requirements, licensing qualifications, and service rules for GSO FSS and 
NGSO FSS systems in the Ka-band.16 The Bureau subsequently licensed 11 companies to operate 
Ka-band GSO satellites at 34 orbital locations.  The Bureau deferred action on the second round Ka-
band NGSO applications,17 however, until the Commission established principles by which multiple 
NGSO FSS systems could share the NGSO-designated portion of the spectrum.18
9. In July 2003, the Commission adopted an Order establishing a sharing method for 
non-Federal Ka-band FSS NGSO systems.19 Under this sharing method, all Ka-band NGSO systems 
will have access to the entire NGSO-designated spectrum, except during in-line interference 
events.20 When two NGSO FSS systems cannot avoid an in-line interference event, the operators 
must divide the available spectrum equally for the duration of the event, unless the operators agree to 
a different sharing arrangement.21 The Ka-band NGSO Order also adopted a technical definition to 
support the sharing method, a default mechanism, and various service rules.
C. Northrop Grumman Applications
1. Procedural History
10. In September 1997, pursuant to the announcement of the V-band application filing 
window, Northrop Grumman filed applications for authority to establish a global V-band FSS 
system.  This system was to use 15 NGSO satellites in medium Earth orbit (MEO) and four GSO 
satellites.  In December 1997, in response to the filing cut-off for the second processing round for 
Ka-band applications, Northrop Grumman amended its V-band filings to include Ka-band 
frequencies on all 19 of its satellites.
11. In 2001, as part of the second Ka-band processing round, the Bureau granted 
Northrop Grumman authority to construct, launch, and operate four GSO Ka-band satellites.22 The 
Bureau deferred action on the V-band and Ka-band NGSO portions of the 1997 applications.  
Northrop Grumman later decided not to proceed with the authorized GSO Ka-band satellites and 
  
16 See Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission's rules to Redesignate the 27.5-29.5 
GHz Frequency Band, to Reallocate the 29.5-30.0 GHz Frequency Band, to Establish Rules and Policies for 
Local Multipoint Distribution Service and for Fixed-Satellite Services, Third Report and Order, CC Docket 
No. 92-297, 12 FCC Rcd 22310 (1997) (Ka-band Third Report and Order).  In that Order, the Commission 
observed that the 27.5-30.0 GHz and 17.7-20.2 GHz band is allocated internationally and domestically for a 
number of uses.  To address these different uses, the Commission adopted a band plan that divides the bands 
into several segments, each of which is designated for primary use by GSO FSS, NGSO FSS, and other
services.  Id. at 22366.
17 Six NGSO applications were filed in the second Ka-band processing round.  Subsequently, Motorola Global 
Communications, Inc., Hughes Communications, Inc., Lockheed Martin Corp., and SkyBridge II, LLC 
withdrew their applications. contactMEO Communications, LLC, now operating as ATCONTACT 
Communications, LLC, was granted a license in April 2006 for a system composed of both NGSO and GSO 
satellites.  See contactMEO Communications, LLC, Order and Authorization, 21 FCC Rcd 4035 (Int'l Bur. 
2006).  For ease of reference, we will refer to this entity as ATCONTACT in this Order.  Northrop Grumman 
is the only remaining NGSO Ka-band applicant.
18 Ka-band Third Report and Order, 12 FCC Rcd at 22325.
19 Establishment of Policies and Service Rules for the Non-Geostationary Satellite Orbit, Fixed Satellite 
Service in the Ka-band, Report and Order, 18 FCC Rcd 14708 (2003) (Ka-band NGSO Order).  
20 See 47 C.F.R. § 25.261(b).  An “in-line” interference event occurs when the physical alignment of one
system’s earth station and another systems’s NGSO satellite causes unintentional transmissions in either 
transmission direction.
21 Ka-band NGSO Order, 18 FCC Rcd at 14717.
22 TRW, Inc., Order and Authorization, 16 FCC Rcd 14407 (Int'l Bur. 2001).
Federal Communications Commission DA 09-428
6
surrendered these licenses in 2003.23
12. In March 2004, Northrop Grumman amended its pending V-band/NGSO Ka-band 
applications in response to the Commission’s January 29, 2004 Public Notice inviting V-band 
applicants to amend their pending applications to conform to the Commission’s revised V-band 
allocation and technical rules.24 In these amendments, Northrop Grumman proposed to:  (1) change 
the orbital configuration to a combination of three highly-elliptical orbit (HEO) NGSO satellites and 
four GSO satellites; (2) relocate some of the GSO satellites to different orbital locations; (3) change 
its V-band spectrum plan to conform with the V-band Second Report and Order; (4) operate its GSO 
satellites in portions of the Ka-band; (5) provide additional or revised technical information 
concerning system operation, and (6) update ownership information.25
13. On May 18, 2004, the International Bureau’s Satellite Division dismissed Northrop 
Grumman’s amended application as incomplete on two grounds.26 First, the Division stated that the 
NGSO portion of the application did not comply with Section 25.145(c)(3) of the Commission’s 
rules. 27 This rule requires NGSO applicants to submit a casualty risk assessment if, as Northrop 
Grumman proposed, “planned post-mission disposal involves atmospheric re-entry of the 
spacecraft.” Second, the Division stated that Northrop Grumman failed to submit the required 
interference analysis demonstrating that its proposed GSO satellites are compatible with the 
Commission’s two-degree orbital spacing environment.28 The Division also noted that Northrop 
Grumman had requested to operate its GSO satellites in Ka-band spectrum designated for NGSO use 
only or for NGSO use on a primary basis, and cautioned Northrop Grumman that it had failed to 
demonstrate that its proposed Ka-band GSO satellites could operate compatibly with NGSO systems 
in this spectrum.29
14. Subsequently, the Satellite Division determined that the Commission’s rules 
regarding the casualty risk assessment and two-degree interference analysis were subject to 
reasonable but conflicting interpretations.  Consequently, the International Bureau issued Public 
Notices to clarify these requirements.30 In the Notices, the Bureau stated that it would dismiss 
  
23 See Letter from Stephen D. Baruch, Counsel to Northrop Grumman Space & Mission Systems Corp. to 
Secretary, FCC (Mar. 5, 2003).
24 See International Bureau Invites Applicants to Amend Pending V-band Applications, DA 04-234, Report No. 
SPB-199 (Jan. 29, 2004) (V-band Amendment Public Notice).
25 See Application of Northrop Grumman, File No. SAT-AMD-20040312-00030 (NGSO March 2004 
Amendment), Application of Northrop Grumman, File No. SAT-AMD-20040312-00031 (119° W.L. March 
2004 Amendment), Application of Northrop Grumman, File No. SAT-AMD-20040312-00032 (89° W.L. 
March 2004 Amendment), Application of Northrop Grumman, File No. SAT-AMD-20040312-00033 (15° 
E.L. March 2004 Amendment), Application of Northrop Grumman, File No. SAT-AMD-20040312-00034, 
(116.5° E.L. March 2004 Amendment) (March 2004 Amendments).
26 See Letter to Peter Hadinger, Northrop Grumman Space & Mission Systems Corp., from Thomas S. Tycz, 
Chief, Satellite Division, FCC, 19 FCC Rcd 8870 ( May 18, 2004) (May 18 Letter).
27 47 C.F.R. § 25.145(c)(3).
28 47 C.F.R. § 25.140(b)(2).
29 May 18 Letter, 19 FCC Rcd at 8871.
30 Public Notice, International Bureau Satellite Division Information, Report No. SPB-208, Orbital Debris 
Mitigation: Clarification of 47 C.F.R. sections 25.143(b), 25.145(c) (3), 25.146(i)(4) and 25.217(d) Regarding 
Casualty Risk Assessment for Satellite Atmospheric Reentry, 19 FCC Rcd 10714 (Int’l Bur., Sat. Div., 2004) 
(Orbital Debris Public Notice); Public Notice, International Bureau Satellite Division Information: 
Clarification of 47 C.F.R. § 25.140(b)(2), Space Station Application Interference Analysis, Report No. SPB-
207, 19 FCC Rcd 10652 (Int’l Bur., Sat. Div., 2004) (2004 Two-Degree Spacing Public Notice).  
Federal Communications Commission DA 09-428
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applications that do not contain this information on a going-forward basis, but that it would afford 
pending applicants an opportunity to amend their applications to comply with the clarified 
requirements.  The Division reinstated Northrop Grumman’s applications and those of other situated 
applicants, on its own motion, and gave all applicants an opportunity to file conforming 
amendments.31 In response, Northrop Grumman submitted a two-degree interference analysis and a 
revised orbital debris mitigation plan and casualty risk assessment for each application.32 Northrop 
Grumman also submitted additional technical information to support its claim that its GSO satellites 
will not cause interference to NGSO satellites of other non-Federal systems in the Ka-band.  In 
response to a Division request, it also submitted information regarding its efforts to avoid in-orbit 
collisions with a similar system proposed by ATCONTACT.33 Thereafter, the Commission’s orbital 
debris mitigation disclosure rules became effective.34 Northrop Grumman amended its applications 
to provide additional technical information in accordance with the new rules.35
15. In February 2007, Northrop Grumman filed further amendments to each of its 
pending applications.36 In these amendments, Northrop Grumman proposed a change in orbital 
location for three GSO satellites.  Additionally, Northrop Grumman proposed to add Ka-band 
spectrum to various GSO satellites.  In each of these amendments, Northrop Grumman also sought 
to increase power levels in the 18.8-19.3 GHz and 28.6-29.1 GHz bands to levels consistent with a 
four-degree orbital spacing framework.  Finally, Northrop Grumman withdrew its request for a 
waiver of Section 25.202(g)37 to allow transfer-orbit and emergency-mode on-orbit TT&C links in 
the 4/6 GHz (C-band).  In sum, in its 2007 Amendments, Northrop Grumman requests authority to 
operate its system as follows:
  
31 Letter to Peter Hadinger, Northrop Grumman Space & Mission Systems Corporation, from Thomas S. Tycz, 
Chief, Satellite Division, FCC, DA 04-1725 (June 16, 2004) (June 16 Letter). See also Mobile Satellite 
Ventures Subsidiary LLC, Order and Authorization, 20 FCC Rcd 9752, 9756 (paras. 10-11) (Int’l Bur., 2005). 
See also Mobile Satellite Ventures Subsidiary LLC, Order, 19 FCC Rcd 18133 (Sat. Div., Int’l Bur. 2004), and 
Letter to James Talens, contactMEO Communications, LLC, from Thomas S. Tycz, Chief, Satellite Division, 
FCC (June 16, 2004).  
32 See Applications of Northrop Grumman, File Nos. SAT-AMD-20040719-00136, SAT-AMD-20040719-
00137,  SAT-AMD-20040719-00138,  SAT-AMD-20040719-00140, SAT-AMD-20040719-00139 (July 2004 
Amendments).  
33 Letter to Marlene Dortch, Secretary, FCC, from Stephen D. Baruch, Counsel to Northrop Grumman Space & 
Mission Systems Corp. (May 12, 2005).
34 Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 (2004) (Orbital Debris Order).  
See also Public Notice, International Bureau Satellite Division Information, Disclosure of Orbital Debris 
Mitigation Plans, Including Amendment of Pending Applications, Report No. SPB-112 (Oct. 13, 2005). 
35 Northrop Grumman Space and Mission Systems Corporation, File Nos. SAT-AMD-20051118-00227, 229, 
230, 231, 232 (filed Nov. 18, 2005) (2005 Amendments).
36 Northrop Grumman Space and Mission Systems Corporation, File Nos. SAT-AMD-20070209-00029 (125° 
W.L. 2007 Amendment); SAT-AMD-20070209-00030 (73° W.L. 2007 Amendment); SAT-AMD-20070209-
00031 (68.5° E.L. 2007 Amendment); SAT-AMD-20070209-00032 (116.5° E.L. 2007 Amendment); SAT-
AMD-20070209-00033 (NGSO 2007 Amendment); all filed February 9, 2007 (2007 Amendments).
37 47 C.F.R. § 25.202(g).
Federal Communications Commission DA 09-428
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Architecture Proposed Frequencies Proposed Operating 
Authority38
NGSO Satellites 47.2-50.2 GHz (Earth-to-space)
37.5-42.0 GHz (space-to-Earth)
29.5-30.0 GHz (Earth-to-space)
28.6-29.1 GHz (Earth-to-space)
19.7-20.2 GHz (space-to-Earth)
18.8-19.3 GHz (space-to-Earth)
Primary Basis 
Primary Basis 
Secondary or Non-Unacceptable 
Interference Basis
Primary Basis
Secondary or Non-Unacceptable 
Interference Basis 
Primary Basis
GSO Satellites Located 
at 125° W.L., 73° W.L.,
68.5° E.L., and 116.5° E.L.
47.2-50.2 GHz (Earth-to-space)
37.5-42.0 GHz (space-to-Earth)
29.25-30.0 GHz (Earth-to-space)
28.6-29.1 GHz (Earth-to-space) 
28.35-28.6 GHz (Earth-to-space) 
19.7-20.2 GHz (space-to-Earth)
18.8-19.3 GHz (space-to-Earth)
Primary Basis
Primary Basis
Primary Basis
Secondary Basis
Primary Basis
Primary Basis
Non-harmful Interference Basis  
16. To implement the proposed system, as amended, Northrop Grumman requests 
several waivers of Commission rules.  These include: (1) a contingent partial waiver of the 
Commission's bond requirement to permit it to post a single NGSO bond to cover the entire system; 
(2) a waiver of Section 25.156(d)(3) to allow the Commission to consider both the NGSO and GSO 
components concurrently and the V-band and Ka-band components concurrently; (3) a waiver of 
Section 25.202(g) to place its on-orbit TT&C links in the Ka-band rather than in both Ka- and V-
band; (4) a waiver of Section 25.140(b)(2), to the extent necessary, to allow increased-power 
operations in the 18.8-19.3 GHz and 28.6-29.1 GHz bands consistent with a four-degree orbital 
spacing regime; (5) a waiver of the Commission's Ka-band Plan to operate its NGSO satellites in the 
19.7-20.2 GHz and 29.5-30.0 GHz frequency bands on a secondary or “non-unacceptable 
interference basis”; and (6) a waiver of the Commission's Ka-band Plan to permit it to operate its 
GSO FSS satellites in the NGSO-designated 18.8-19.3 GHz frequency band on a “non-harmful 
interference basis.”39
2. Comments
17. We first placed Northrop Grumman’s applications on Public Notice in August 
2004.40  EchoStar filed a Petition to Deny and SES Americom filed a Petition to Deny or Dismiss.41  
  
38 See, e.g., 2007 Amendments at 4-5, Table 1.  In its chart, Northrop Grumman lists the 47.2-50.2 GHz and
37.5-42.0 GHz frequency bands as “Primary.”  The Table of Frequency Allocations, Section 2.106 of the 
Commission’s rules, indicates that these frequencies are allocated to FSS on a “co-primary” basis.  47 C.F.R. § 
2.106.  Further, Northrop Grumman requests authority to operate its GSO satellites on a “non-harmful 
interference basis” in the 18.8-19.3 GHz band and its NGSO satellites on a secondary or “non-unacceptable 
interference basis” in the 19.7-20.2 GHz band.  The appropriate operating status in these bands is “non-
conforming.”  See note 3, above.
39 NGSO March 2004 Amendment at 23-27. 
40 See Policy Branch Information, Satellites Space Applications Accepted for Filing, Public Notice, Report No. 
SAT-00234 (Aug. 13, 2004).
41 Petition to Deny of EchoStar Satellite LLC, filed Sept. 13, 2004 (EchoStar Petition to Deny); Consolidated 
Petition to Deny or Dismiss of SES Americom, Inc., filed Sept. 13, 2004 (SES Americom Petition to Deny).
Federal Communications Commission DA 09-428
9
Northrop Grumman filed a Consolidated Opposition to the EchoStar and SES Americom petitions.42  
EchoStar and SES Americom filed replies to Northrop Grumman’s opposition.43
18. EchoStar argues that, because we permitted Northrop Grumman to provide 
additional technical showings in support of its application instead of dismissing it, we should have 
done the same with applications EchoStar filed proposing similar GSO FSS operations.44  
Alternatively, EchoStar suggests that the Bureau should grant EchoStar’s petition for reconsideration 
of the dismissal of its applications, reinstate its applications, and process the applications in 
accordance with the Commission’s “first-come, first-served” policy.45 EchoStar argues that under 
this policy, EchoStar’s applications are first-in-time and thus have processing priority over Northrop 
Grumman’s applications, which seek to use two of the orbital locations that EchoStar requested in 
the same frequency band.46  
19. EchoStar further states that the Commission should grant EchoStar’s Petition for 
Rulemaking to redesignate the NGSO spectrum in the 18.8-19.3 GHz and 28.6-29.1 GHz bands for 
both GSO and NGSO operations, and to develop sharing criteria for co-frequency NGSO/GSO 
operations.47 EchoStar claims that addressing GSO/NGSO sharing issues would avoid future 
disputes and would effectively manage available spectrum.48
20. SES Americom asserts that Northrop Grumman’s proposal conflicts with the 
Commission’s Ka-band Plan Order, and that Northrop Grumman has not justified a waiver of the 
plan.49 SES Americom states that we cannot consider Northrop Grumman’s application until the 
Commission determines whether, and under what conditions, NGSO systems can operate in GSO 
Ka-band spectrum on a secondary basis,.50
21. In April 2007, we placed Northrop Grumman’s 2007 Amendments on Public 
Notice.51 No comments were received in response to these amendments.
III. DISCUSSION
A. Processing Framework
22. Northrop Grumman’s proposed satellite system consists of NGSO and GSO 
components, with each component operating in both the Ka-band and V-band.  Operations in the V-
band and Ka-band are governed by separate processing and service rules.  Further, NGSO and GSO 
satellites are governed by separate processing and service rules.  Consequently, we will analyze the 
four components of Northrop Grumman’s proposed system separately.  Because we are acting on all 
portions of Northrop Grumman’s system in this Order, however, its request for a waiver of Section 
  
42 Northrop Grumman, Consolidated Opposition to Petitions to Deny or Dismiss, filed Sept. 28, 2004 
(Northrop Grumman Opposition).
43 EchoStar Satellite LLC, Consolidated Reply to Oppositions to Petitions to Deny, filed Oct. 8, 2004 
(EchoStar Reply).  Consolidated Reply of SES Americom, filed Oct. 8, 2004 (SES Americom Reply).
44 EchoStar Petition to Deny at 6.
45 EchoStar Petition to Deny at 7.
46 Id.
47 EchoStar Petition to Deny at 9.
48 Id.
49 SES Americom Petition to Deny at 1, citing Ka-band Plan Order, 11 FCC Rcd at 19005.
50 SES Americom Petition to Deny at 7.
51 See Policy Branch Information, Satellites Space Applications Accepted for Filing, Public Notice, Report No. 
SAT-00434 (Apr. 6, 2007).
Federal Communications Commission DA 09-428
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25.156(d)(3) of the Commission’s rules, which would allow us to proceed with all components on 
parallel processing tracks, is moot.
1. V-band
23. In the First Space Station Licensing Reform Order, the Commission adopted new 
processing rules for space station applications.  Specifically, it adopted a first-come, first-served 
approach for GSO applications, under which it grants an application if the applicant is qualified and 
the proposed satellite will not cause harmful interference to a previously licensed satellite or to a 
satellite proposed in a previously-filed application.52 Further, the Commission adopted a "modified 
processing round” approach for NGSO applications.  Under this approach, when an NGSO 
application is filed, the Commission issues a public notice announcing a filing deadline for 
additional NGSO applications to be considered concurrently with the first application, and then 
divides the available spectrum equally among the qualified NGSO applicants filing by the cut-off
date.53
24. As noted, in adopting these new licensing procedures, the Commission directed the 
International Bureau to treat all then-pending V-band applications filed in the 1997 processing round 
as if they were filed at the same time.54 Consistent with newly adopted Section 25.156(d)(5) of its 
rules, the Commission further directed the Bureau to divide the spectrum proportionally between 
qualified GSO and NGSO applicants and to subdivide the GSO and NGSO spectrum, respectively, 
where there were conflicts between qualified GSO or NGSO applicants.55
25. Northrop Grumman is the only remaining V-band applicant.56 Its proposed system 
includes both GSO and NGSO satellites.  Thus, under the framework set out in the First Space 
Station Licensing Reform Order and the Commission's rules, we would divide the V-band spectrum 
in half, designating one-half to NGSO operations and the other half to GSO operations.  Next, 
because there would be no conflicts among requested orbital locations, we would assign Northrop 
Grumman's proposed GSO satellites to its requested locations.  Further, to accommodate multiple 
entry pursuant to Section 25.157(e)(2) of the rules, we would assign Northrop Grumman’s NGSO 
constellation to only one-third of the V-band NGSO spectrum and make the remaining NGSO 
spectrum available to other NGSO systems in an additional processing round.57 Northrop Grumman, 
however, requests authority to operate both the NGSO and GSO components of its system 
throughout all of the V-band spectrum allocated in the United States for FSS uplinks and throughout 
most of the V-band spectrum allocated in the United States for FSS downlinks.58
26. Given the design of Northrop Grumman's proposed system and the manner in which 
it will operate, we find that a waiver of Sections 25.156(d)(5) and 25.157(e)(2) is warranted.  The 
Commission may waive its rules and policies where particular facts make strict compliance 
  
52 First Space Station Licensing Reform Order, 18 FCC Rcd at 10792-10805 (paras. 71-108).
53 First Space Station Licensing Reform Order, 18 FCC Rcd at 10774 (paras. 23-34).
54 First Space Station Licensing Reform Order, 18 FCC Rcd at 10865 (para. 279).
55 Id.
56 See note 6, above. 
57 Section 25.157(e)(2) provides that where there are one or two applications in a processing round , the 
Commission will assign each applicant to 1/3 of the available spectrum, and will conduct an additional 
processing round to assign the remaining spectrum.  47 C.F.R. § 25.157(e)(2).
58 In the United States, the 47.2-50.2 GHz and 37.5-42.5 GHz bands are allocated to FSS on a co-primary basis 
for uplink and downlink operations, respectively.  Northrop Grumman requests authority to operate in the 
47.2-50.2 GHz uplink band, and in the 37.5-42.0 GHz downlink band.  NGSO March 2004 Amendment at 5, 
Table 1.
Federal Communications Commission DA 09-428
11
inconsistent with the public interest.59 In doing so, the Commission may take into account more 
effective implementation of overall policy on an individual basis, and whether a deviation from the 
general rule will better serve the public interest.60 We conclude that waiving the band segmentation 
provisions in Sections 25.156(d)(5) and 25.157(e)(2) of the Commission's rules is warranted here.  
Allowing Northrop Grumman to operate its NGSO and GSO satellites throughout the V-band 
spectrum as proposed:  (1) will not contravene the purpose of the band-splitting approach, which was 
to accommodate all qualified GSO and NGSO applicants in cases where co-frequency NGSO-like 
and GSO-like applications are filed simultaneously, and (2) will not preclude additional entry by 
either GSO or NGSO applicants in the V-band.
27. The Commission adopted the first-come, first-served processing procedure for GSO-
like applications because granting the first-filed application would not preclude additional entry in 
that band.  This is because the Commission's rules require GSO satellites operating in the same 
frequency band to operate compatibly at two-degree orbital intervals.61 At two-degree spacings, 
more than a dozen GSO satellites can provide service to the United States in the same frequency 
band.  In contrast, the Commission has not adopted a wholesale set of rules under which NGSO 
systems can use the same spectrum or under which hybrid GSO/NGSO systems can use the same 
spectrum without causing mutual harmful interference.  Although the Commission has adopted 
specific NGSO/NGSO and NGSO/GSO sharing criteria in certain frequency bands through 
rulemakings, this is not the case in many bands, including the V-band.  In these cases, band-
segmentation allows the Commission to accommodate multiple entrants.
28. Here, however, granting Northrop Grumman authority to operate its NGSO and 
GSO satellites throughout the requested V-band spectrum will not preclude additional entry in the V-
band.  Northrop Grumman proposes to operate its three NGSO satellites in "highly elliptical orbit," 
with one NGSO satellite in each of three orbital planes. The altitude of Northrop Grumman's 
proposed highly elliptical orbit (HEO) satellites at their apogees is such that the HEO satellite 
appears nearly stationary when viewed from the Earth.  This architecture reduces the potential for 
“in-line” interference events with other systems.  Further, when an in-line interference event occurs, 
Northrop will switch operations to one of its GSO satellites.  This will allow another V-band system 
to continue to operate across the entire V-band spectrum at all times.  Thus, multiple systems similar 
to Northrop Grumman's in design can operate in the same frequency bands if their operators 
coordinate their orbits.  In this way, Northrop Grumman can operate its HEO and GSO satellites in 
the same frequency bands and we can license additional GSO and HEO satellites in the same band.
29. In the past, we have granted NGSO systems access to the entire frequency band 
when doing so will not preclude additional entry.62 In these circumstances, we have treated NGSO 
systems under a first-come, first-served approach and have not instituted a processing round.  Given 
the opportunities for additional V-band entrants afforded by Northrop Grumman's system design, we 
waive the band segmentation requirements.  Thus, we allow Northrop Grumman’s hybrid system to 
operate across its requested frequencies and will process Northrop Grumman’s applications on a 
  
59 Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (Northeast Cellular); 47 C.F.R. § 1.3.
60 WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969) (WAIT Radio).
61 See 47 C.F.R. § 25.140(b)(2).
62 See Space Imaging, LLC, Declaratory Order and Order and Authorization, 20 FCC Rcd 11964, 11969 
(para. 13) (Int'l Bur., 2005) (the Bureau can grant waivers of the NGSO-like satellite system processing rules 
in cases where band segmentation is not necessary to preclude an applicant from unreasonably restricting 
further entry into the frequency band).  See also Lockheed Martin Corporation, Order and Authorization, 20 
FCC Rcd 11023, 11028 (para. 15) (Int'l Bur., 2005); Digital Globe, Inc., Order and Authorization, 20 FCC 
Rcd 15696, 15699 (paras. 7-8) (Int'l Bur., 2005).
Federal Communications Commission DA 09-428
12
first-come, first-served basis.63
30. Northrop Grumman is the only remaining applicant in the 1997 V-band Processing 
Round and, thus, has "first-in-line" status.  No other satellites or satellite systems are authorized to 
operate in the V-band.  Consequently, granting Northrop Grumman access to its requested V-band 
spectrum will not cause interference to any previously licensed satellite system or to a system 
proposed in a previously filed application.  Accordingly, we grant Northrop authority to operate its 
GSO satellites and NGSO satellites throughout its requested V-band spectrum.
2. Ka-band
a. NGSO Component
31. As noted above, the portion of Northrop Grumman’s 1997 amendment requesting 
Ka-band NGSO authority is still pending.  The Bureau deferred action on the pending Ka-band 
NGSO satellite applications filed in the second Ka-band application processing round until the 
Commission completed a rulemaking on technical rules for Ka-band NGSO systems.  As a result of 
that rulemaking, the Commission required Ka-band NGSO systems to share the NGSO-designated 
Ka-band spectrum by employing mechanisms designed to avoid in-line interference events between 
NGSO systems.64 In situations where an in-line interference event is unavoidable, the Commission 
required operators to employ mechanisms enabling them to divide the spectrum equally among the 
affected systems for the duration of the event.  We will process that portion of Northrop Grumman’s 
application proposing NGSO operations in the 18.8-19.3 GHz and 28.6-29.1 GHz bands designated 
for primary NGSO use pursuant to these rules.65 In other words, we will permit Northrop Grumman 
to operate NGSO satellites throughout the entire Ka-band spectrum designated for primary NGSO 
use by employing mechanisms designed to avoid in-line interference events with other NGSO 
systems. 
32. The in-line interference avoidance mechanism adopted in the Ka-band Order 
applies only to NGSO operations in the 18.8-19.3 GHz and 28.6-29.1 GHz bands.66 It does not 
apply to the 19.7-20.2 GHz or the 29.5-30.0 GHz bands in which Northrop Grumman proposes to 
operate its NGSO satellites on a non-conforming and secondary basis, respectively.   Rather, Section 
25.157 of the Commission’s rules applies to these bands.67 Sections 25.157(c) and (e)  require us to 
establish a processing round for NGSO applications in these bands and divide the available spectrum 
among the qualified applicants in that processing round.68 Northrop Grumman, however, requests 
authority to operate its NGSO satellites throughout the 19.7-20.2 GHz and 29.5-30.0 GHz bands.  
33. Given the design of Northrop Grumman's proposed NGSO operations and the 
  
63 47 C.F.R. §§ 25.156(d)(5), 25.157(e)(2).  If Northrop Grumman does not implement its GSO satellites, 
however, we may revisit this issue.
64  Ka-band NGSO Order, 18 FCC Rcd at 14708.  See para. 9, above.
65 The Commission had not completed the Ka-band NGSO rulemaking proceeding at the time it adopted the 
band segmentation licensing approach for NGSO systems in the First Space Station Licensing Reform Order.  
The Commission stated in the First Space Station Licensing Reform Order that since the record in the Ka-band 
NGSO  rulemaking proceeding was fully developed, it would complete that rulemaking rather than apply a 
band segmentation approach to the pending Ka-band NGSO applications.  In addition, the Commission 
directed the Bureau to award Ka-band NGSO licenses pursuant to the processing mechanism adopted in the 
Ka-band NGSO Report and Order. See First Space Station Licensing Reform Order, 18 FCC Rcd at 10865-66 
(para. 280).
66 Ka-band NGSO Order, 18 FCC Rcd at 14708, fn.1.
67 47 C.F.R. § 25.157.
68 47 C.F.R. §§ 25.157(c), (e).
Federal Communications Commission DA 09-428
13
manner in which it will operate, we find that a waiver of Section 25.157 is warranted.  Northrop 
Grumman’s NGSO satellites will employ a mechanism designed to permit multiple NGSO systems 
to operate in the same spectrum by limiting the number of in-line interference events between NGSO 
systems and dividing the spectrum among the affected NGSO systems during such an event.   We 
see no reason to prevent  Northrop Grumman from taking advantage of this multiple-entry 
architecture in all portions of the Ka- FSS-band in which it seeks to operate.  
34. As noted, we have granted NGSO systems access to the entire frequency band when 
doing so will not preclude additional entry.69 In these circumstances, we have treated NGSO 
systems under a first-come, first-served approach and have not instituted a processing round.   
Consequently, as we did for the Northrop Grumman’s proposed V-band operations, we waive the 
processing round and band segmentation requirements and will process Northrop Grumman’s 
request to operate its NGSO satellites in the 19.7-20.2 GHz and 29.5-30.0 GHz bands on a first-
come, first-served basis.  
b. GSO Component
35. Northrop Grumman applied to add Ka-band capacity to its proposed GSO V-band 
satellites in March 2004.  Because Northrop Grumman filed these amendments after the Commission 
reformed its processing procedures, we analyze the Ka-band portion of the GSO satellites under a 
“first come, first served” procedure.  There are no other Ka-band GSO satellites licensed to operate 
at any of Northrop Grumman’s requested orbital locations.  Further, there are no prior-filed Ka-band 
GSO applications requesting authority to operate at these locations.  Consequently, we grant 
Northrop Grumman’s Ka-band GSO requests. 
B. Qualifications
36. All applicants requesting authority to launch and operate a satellite space station 
must present information sufficient to establish their legal, technical, and financial qualifications to 
hold a Commission license.  The regulations set forth in Part 25 of the Commission’s rules govern 
FSS applicants and licensees.70
1. Legal and Financial Qualifications
37. Based on the record, we find no evidence that Northrop Grumman lacks the legal 
qualifications under our rules to hold a Commission license.71  In its First Space Station Licensing 
Reform Order, the Commission eliminated the financial requirements then in place and replaced 
them with a bond requirement.72 We discuss the bond requirement in paragraphs 109-110, below, 
which we include as a condition of Northrop Grumman’s license.
2. Technical Qualifications
a. V-band Allocations
(i) V-band Uplink
38. The 47.2-50.2 GHz band in which Northrop Grumman proposes to operate V-band 
  
69 See para. 29, above.
70 In the First Space Station Licensing Reform Order, the Commission emphasized that even in cases where it 
decided not to apply  the new satellite processing rules to particular applications, the remainder of the rules 
adopted in the proceeding, such as safeguards against speculation, would apply.  First Space Station Licensing 
Reform Order, 18 FCC Rcd at 10866 (paras. 281-83).
71 See also TRW Transfer of Control Order, 17 FCC Rcd at 24628-29 (paras. 8-12) (discussion of Northrop 
Grumman's legal qualifications as a general matter).
72 First Space Station Licensing Reform Order, 18 FCC Rcd at 10823-24 (paras. 162-165).
Federal Communications Commission DA 09-428
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uplinks is allocated, on a co-primary basis, to the fixed service (FS), mobile service (MS), and the 
Fixed-Satellite Service (FSS). The FSS allocation requires FSS operators to limit use of the 47.2-
48.2 GHz portion of the band to gateways.73 Further, the allocation identifies the 48.2-50.2 GHz 
portion of the band to  high-density applications for FSS, such as user terminals.74 Further, Federal 
FS, MS, and FSS systems are allocated to operate in the 48.2-50.2 GHz portion of this band. For 
ease of reference, the uplink V-band allocations are depicted as follows:
Frequency Band
(Bandwidth, in megahertz)
47.2-48.2 GHz
(1000)
48.2-50.2 GHz
(2000)
Non-Federal
Service
FS
FSS 
MS
FS
FSS 
MS
Federal
Service
No Allocations FS
FSS
MS 
39. We note that, in accordance with Article 5, Footnotes 5.149, 5.340 and 5.555 of the 
ITU Radio Regulations, the 48.94-49.04 GHz band is also allocated to the radio astronomy service 
on a primary basis in all ITU Regions.75 Footnote 5.555 is incorporated in the U.S. Table of 
Frequency Allocations.76 We also note that, in accordance with Article 5, Footnote 5.552 of the ITU 
Radio Regulations, the ITU has urged Administrations to take all practical steps to reserve the 47.2-
49.2 GHz band for feeder links for the broadcasting-satellite service operating in the 40.5-42.5 GHz 
band in all ITU Regions.77 In addition, in accordance with Article 5, Footnote 5.516B of the ITU 
Radio Regulations, the 48.2-50.2 GHz band is identified for use by high-density applications in the 
fixed-satellite service (Earth-to-space) in ITU Region 2.78 ITU coordination will be required to 
protect these services.  National coordination will be required with radio astronomy stations in the 
  
73 Gateways are earth station complexes consisting of multiple interconnecting earth station antennas 
supporting the communication routing and switching functions of an FSS system as a whole.  See 47 C.F.R. § 
25.201.  Further, operators may use FSS gateways in this band only if the licensee has:  (1) coordinated earth 
station downlink operations in the 37.5-40.0 GHz band (see V-band Second Report and Order, 18 FCC Rcd at 
25436 (para. 17) and 25441-42 (paras. 30-33)) and (2) obtains a license under Part 101 of the Commission's 
rules or an agreement from a Part 101 licensee for the area in which an earth station is to be located.  Satellite 
earth station facilities in this band may not be ubiquitously deployed and may not be used to serve individual 
consumers.  47 C.F.R. § 25.202 n.15.
74 See 47 C.F.R. § 2.106, fn. 5.516B.
75 See ITU Radio Regulations, Article 5, Footnotes 5.149, 5.340 and 5.555.  For the purpose of frequency 
allocation, the International Telecommunication Union (ITU) has divided the world into three Regions. ITU 
Region 1 includes Europe, Africa, territories of the former U.S.S.R. in Asia, as well as portions of the Arctic, 
Atlantic and Pacific Oceans. ITU Region 2 includes North and South America. ITU Region 3 includes 
Southern Asia, Australia, New Zealand, and some Pacific Islands.
76 See 47 C.F.R. § 2.106, fn. 5.555.
77 See ITU Radio Regulations, Article 5, Footnote 5.552.
78 See ITU Radio Regulations, Article 5, Footnote 5.516B, and Resolution 143 (WRC-2007).  In accordance 
with Article 5, Footnote 5.516B of the ITU Radio Regulations, the other V-band uplink frequencies that have 
been identified for use by high-density applications in the fixed-satellite service are 47.5-47.9 GHz (space-to-
Earth) in ITU Region 1, 48.2-48.54 GHz (space-to-Earth) in ITU Region 1, and 49.44-50.2 GHz (space-to-
Earth) in ITU Region 1.
Federal Communications Commission DA 09-428
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48.94-49.04 GHz band.  Finally, the 2007 World Radio conference (WRC-2007) adopted a 
resolution establishing out-of-band protection criteria for the Earth Exploration Satellite Service 
(Passive) operating in the 50.2-50.4 GHz band.  Under this Resolution, FSS systems operating in the 
adjacent 49.7-50.2 GHz (Earth-to-space) frequency band must meet specified out-of-band emission 
limits.79
(ii) V-band Downlink
40. In the V-band downlink band at 37.5-42.0 GHz, the Commission adopted “soft 
segmentation” as a sharing method between the FS and FSS services.80 “Soft-segmentation” 
encourages high-density FS deployment below 40 GHz by requiring satellite operators to meet more 
restrictive power flux density (PFD) limits in this portion of the band, and encourages high-density 
FSS deployment above 40 GHz by permitting more liberal PFD limits in this band.  The PFD limits 
are different for GSO FSS systems and NGSO FSS systems.  Further, the Commission restricted the 
37.5-40.0 GHz band to FSS gateway operations81 to protect the designated high density FS 
operations in this band and identified the 40.0-42.0 GHz band for high-density applications for 
FSS.82
41. The downlink allocations are depicted as follows:
Frequency
Band
(Bandwidth, 
in megahertz)
37.5-38.0
GHz
(500) 
38.0-38.6
GHz
(600 )
38.6-39.5 
GHz
(900)
39.5-40.0
GHz
(500)
40.0-40.5
GHz
(500)
40.5-41.0
GHz
(500)
41.0-42.0 
GHz
(1000)
42.0-42.5 
GHz
(500)
Non-Federal
Service
FS 
FSS 
MS
FS 
FSS 
MS
FS 
FSS 
MS
FS 
FSS 
MS
FSS 
MSS
BS
BSS
FSS
fs
ms
mss
BS 
BSS
FS
FSS
MS
FS
BS
BSS
MS
Federal
Service
FS
MS
SRS
(downlink)
FS
MS
No 
Allo-
cations
FSS
MSS
EESS
(downlink)
eess
(uplink)
FSS
MSS
SRS
(uplink)
FSS
mss
No 
Allo-
cations
No
Allo-
cations
42. As mentioned in the V-band Second Report and Order,83 rain fade has a significant 
impact on radio propagation at 40 GHz.84 Because of the high rain fade, higher PFD levels and other 
ameliorative techniques are necessary, at times, to maintain adequate satellite performance, even for 
gateway operations in the 37.5-40.0 GHz band.  Thus, although the Commission adopted a PFD 
  
79 See ITU Resolution 750 (WRC-2007).  See also Article 5, Footnote 5.BA03 (WRC-2007).
80 See V-Band Second Report and Order, 18 FCC Rcd at 25432 (para. 8).
81 In addition, as noted above, use of this band by the fixed-satellite service is limited to gateway earth station 
operations.  See 47 C.F.R. § 25.202(a)(1) fn. 15, 16.  See also V-band Second Report and Order, 18 FCC Rcd 
at 25436 (para. 17) and 25441-42 (paras. 30-33).
82 See 47 C.F.R. § 2.106, Footnote 5.516B.
83 V-band Second Report and Order, 18 FCC Rcd at 25440-41 (para. 29).
84 Id.
Federal Communications Commission DA 09-428
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limit in the V-band Second Report and Order, it has permitted PFD limits to exceed this level on a 
case-by-case basis.  Additionally, this issue will be addressed in a rulemaking that will establish 
specific criteria for evaluating when, and to what extent, PFD levels may exceed the specified "clear-
air" levels in the 37.5-40.0 GHz band.85 We discuss this PFD issue in more detail below.86
43. In addition, we note that, in accordance with the ITU Radio Regulations, the 
downlink frequencies identified for use by FSS high-density applications are 40-40.5 GHz (space-to-
Earth) in all ITU Regions, and 40.5-42 GHz (space-to-Earth) in ITU Region 2.87 We encourage, but 
do not require, Northrop Grumman to use these bands for any high-density applications it chooses to 
implement.  If Northrop Grumman chooses to implement other FSS applications in these bands, it 
will be required to coordinate with other applicants/licensees who have planned or implemented 
high-density applications in these bands.
44. Further, the Federal Space Research Service (SRS) will operate on a co-primary 
basis in portions of the V-band.  In this regard, NTIA submitted a letter in the V-Band proceeding in 
2004, indicating that the Space Exploration Initiative of 1989 identified the 37.0-37.5 GHz and 40.0-
40.5 GHz frequency bands for use by space research systems to be implemented in support of U.S. 
initiatives to provide a permanent manned presence in Earth orbit (on or near the moon) and to begin 
manned exploration of the planet Mars. 88 The letter also states that the 1992 World Administrative 
Radio Conference (WARC 1992) adopted a downlink allocation for SRS in the 37.0-37.5 GHz band, 
an uplink allocation for SRS in the 40.0-40.5 GHz band, and an allocation at 37-38 GHz for space 
research systems to be implemented in support of Very Long Baseline Interferometry (VLBI) by 
satellite.  The letter further states that when operating manned spacecraft over distances as far 
removed from the Earth as Mars, it might be necessary to combine the received signals 
simultaneously from more than one receiving site, e.g., Goldstone, CA and Socorro, NM, to achieve 
mission objectives.89 For those reasons, NTIA proposes to protect seven SRS sites from FSS V-band 
operations: Goldstone, California; Green Bank, West Virginia; Guam; Merritt Island, Florida; 
Wallops Island, Virginia; and White Sands and Socorro, New Mexico.  
b. The Ka-band Plan
(i) Ka-band Uplink
45. The Commission completed its proceeding involving the 27.5-30.0 GHz frequency 
band in 1996.  At that time, the Commission segmented the band and designated specified portions 
for terrestrial operations, feeder link operations for mobile-satellite service (MSS) systems, service 
link operations for GSO FSS systems, and service link operations for NGSO FSS systems.90  
Significantly, the Commission adopted discrete designations for NGSO FSS systems and GSO FSS 
  
85 See V-Band Second Report and Order 18 FCC Rcd at 25440-41 (paras. 28, 29).
86 See para. 54, below. 
87 See ITU Radio Regulations, Article 5, Footnote 5.516B, and Resolution 143 (WRC-2007). In addition, in 
accordance with Article 5, Footnote 5.516B of the ITU Radio Regulations, the V-band downlink frequencies 
that have been identified for use by high-density applications in the fixed-satellite service are 39.5-40.0 GHz 
(space-to-Earth) in ITU Region 1 (Europe). 
88 See letter from Frederick R. Wentland, Associate Administrator, Office of Spectrum Management, NTIA, to 
Edmond J. Thomas, Chief, Office of Engineering and Technology, FCC (Mar. 24, 2004) (NTIA Letter), at 1.  
See also Amendment of the Commission’s Rules Regarding the 37.0-38.6 GHz and 38.6-40.0 GHz Bands, 
Third Notice of Proposed Rulemaking; ET Docket No. 95-183 and PP Docket No. 93-253, 19 FCC Rcd 8232 
(2004).
89 NTIA Letter at 1-2.
90 Ka-band Plan Order, 11 FCC Rcd 19005.
Federal Communications Commission DA 09-428
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systems, while adopting shared designations for other services.  As relevant here, the Commission 
designated the 28.35-28.6 GHz and 29.25-30.0 GHz bands to GSO FSS (Earth-to-space) on a 
primary basis, with NGSO FSS services (Earth-to-space) permitted on a secondary basis.91 It also 
designated the 28.6-29.1 GHz band to NGSO FSS (Earth-to-space) on a primary basis.92 In adopting 
the Ka-band Plan, the Commission stated that “[t]he plan … designates co-frequency sharing in band 
segments where the Commission and the parties have concluded it is technically feasible.”93
46. The uplink plan is depicted as follows:
Frequency Band
(Bandwidth, 
in megahertz) 
28.35-28.6 GHz
(250)
28.6-29.1 GHz
(500)
29.25-29.5 GHz
(250)
29.5-30.0 GHz
(500)
Non-Federal
Service
GSO FSS
ngso fss
NGSO FSS
gso fss
GSO FSS GSO FSS
ngso fss
47. We note that in accordance with Article 5, Footnote 5.516B of the ITU Radio 
Regulations, the Ka-band uplink frequencies identified for use by high-density applications in the 
fixed-satellite service are 28.35-28.45 GHz (Earth-to-space) in ITU Region 2, 28.45-28.94 GHz 
(Earth-to-space) in all ITU Regions, 28.94-29.1 GHz (Earth-to-space) in ITU Regions 2 and 3, 
29.25-29.46 GHz (Earth-to-space) in ITU Region 2, and 29.46-30.0 GHz (Earth-to-space) in all ITU 
Regions.94 We also note that in accordance with Article 5, Footnote 5.538 (WRC-2007) of the ITU 
Radio Regulations, the 29.999-30.0 GHz band is allocated to the FSS (space-to-Earth) on a primary 
basis for beacon transmissions intended for uplink power control.  Such space-to-Earth transmissions 
shall not exceed an equivalent isotropically radiated power of +10 dBW in the direction of adjacent 
satellites on the geostationary-satellite orbit.95
(ii) Ka-band Downlink
48. The Commission also adopted rules for non-Federal users involving the space-to-
Earth (downlink) FSS allocation at 18.3-20.2 GHz.  In this regard, the Commission designated the 
18.3-18.8 GHz band and the 19.7-20.2 GHz band for primary use by GSO FSS and the 18.8-19.3 
GHz downlink segment for primary NGSO FSS use.96  The Commission originally permitted GSO 
  
91 Ka-band Third Report and Order, 12 FCC Rcd at 22310.
92 Ka-band Plan Order, 11 FCC Rcd at 19030.
93 Ka-band Plan Order, 11 FCC Rcd at 19024.
94 See ITU Radio Regulations, Article 5, Footnote 5.516B, and Resolution 143 (WRC-2007).  In accordance 
with Article 5, Footnote 5.516B of the ITU Radio Regulations, the other Ka-band uplink frequencies that have 
been identified for use by high-density applications in the fixed-satellite service are 27.5-27.82 GHz (Earth-to-
space) in ITU Region 1. 
95 See Ka-band Plan Order, 11 FCC Rcd at 19005; and ITU Radio Regulations, Article 5, Footnote 5.538 
(WRC-2007).
96 Redesignation of the 17.7-19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations in the 
17.7-20.2 GHz and 27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-
17.8 GHz and 24.75-25.25 GHz Frequency Bands for the Broadcast Satellite Service Use, Report and Order, 
15 FCC Rcd 13430, 13432 (2000) (18 GHz Order).  In redesignating the 18.3-18.58 GHz band for FSS 
primary operations, the Commission also adopted provisions designed to ensure the orderly migration and 
timely reimbursement of FS stations operating in the band.  Redesignation of the 17.7-19.7 GHz Frequency 
Band, Blanket Licensing of Satellite Earth Stations in the 17.7-20.2 GHz and the 27.5-30.0 GHz Frequency 
(continued....)
Federal Communications Commission DA 09-428
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and NGSO systems to operate on a secondary basis in those portions of the band where that 
architecture did not have primary status.97 In the 18 GHz Order, however, the Commission 
eliminated the secondary designations after concluding that "secondary use of the 18 GHz band is 
not viable because it would unreasonably inhibit high-density deployment of these services and limit 
the use of spectrum by primary users of the bands."98 The Commission confirmed these conclusions 
on reconsideration, stating that removing secondary operations lessens the potential for harmful 
interference to the primary services and avoids disruptions that could occur to users of secondary 
services.99
49. The downlink plan is depicted as follows:
Frequency Band
(Bandwidth, in 
megahertz) 
18.3-18.8 GHz
(500)
18.8-19.3 GHz
(500)
19.7-20.2 GHz
(500)
Non-Federal
Service
GSO FSS NGSO FSS GSO FSS
50. In addition, Federal GSO and NGSO systems operate throughout the 17.8-20.2 GHz 
frequency band.  These systems operate in accordance with the PFD limits contained in the ITU 
Radio Regulations.100 Non-Federal systems must be coordinated with these Federal systems in 
accordance with Footnote US334 to the Table of Allocations.101 As set forth in the Ka-band NGSO 
Report and Order, each NGSO FSS licensee must complete coordination with all other operational 
NGSO FSS licensees and with Federal FSS systems, prior to the launch of its first satellite.102  
Additionally, GSO satellites that operate in the 18.6-18.8 GHz band must comply with Footnote 
US255 to the Table of Frequency Allocations, which prescribes PFD limits for the 18.6-18.8 GHz 
band to protect the Earth Exploration-Satellite Service (passive).103
  
(...continued from previous page)
Bands, and the Allocation of Additional Spectrum in the 17.3-17.8 GHz and 24.75-25.25 GHz Frequency 
Bands for Broadcast Satellite Service Use, Second Order on Reconsideration, 17 FCC Rcd 24248 (2002).  
97 Ka-band Plan Order, 11 FCC Rcd at 19035 (para. 77).
98 18 GHz Order, 15 FCC Rcd at 13456-57 (para. 55).
99 Redesignation of the 17.7-19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations in the 
17.7-20.2 GHz and the 27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 
17.3-17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite Service Use, First Order on 
Reconsideration, 16 FCC Rcd 19808, 19821 (2001).
100 See 18 GHz Order, 15 FCC Rcd at 13473.  The PFD limits in the 18.3-18.6 GHz band are -115/-105 dB 
(W/m²) in any one megahertz band, depending on the angle of arrival.  There are no power flux-density limits 
in the 19.7-20.2 GHz band.  See Letter from William T. Hatch, National Telecommunications and Information 
Administration, to Dale Hatfield, Chief, Office of Engineering and Technology, FCC (Mar. 29, 2000). 
101 47 C.F.R. § 2.106, fn. US 334.
102 Ka-band NGSO Report and Order, 18 FCC Rcd at 14722.  See also 47 C.F.R. § 2.106, fn. US 334.  A 
licensee may initiate coordination under US 334 by submitting a letter request to the Commission.  A system is 
deemed operational when at least one of its satellites reaches its intended orbit and initiates transmission and 
reception of radio signals. 
103 47 C.F.R. 2.106, fn. US255 (as revised in the 18 GHz Order, 15 FCC Rcd at 13489) states:  In addition to 
any other applicable limits, the power flux-density across the 18.6-18.8 GHz band produced at the surface of 
the Earth by emissions from a space station under assumed free-space propagation conditions shall not exceed 
(continued....)
Federal Communications Commission DA 09-428
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51. Further, in accordance with Article 5, Footnote 5.516B of the ITU Radio 
Regulations, the Ka-band downlink frequencies identified for use by high-density applications in the 
fixed-satellite service are 18.3-19.3 GHz (space-to-Earth) in ITU Region 2, and 19.7-20.2 GHz 
(space-to-Earth) in all ITU Regions.104 Accordingly, we encourage, but do not require, Northrop 
Grumman to use these bands for any high-density applications it chooses to implement.  If Northrop 
Grumman chooses to implement other FSS applications in these bands, it will be required to 
coordinate with other applicants/licensees who have planned/implemented high-density applications 
in these bands.105
c. NGSO Satellites 
52. For reasons discussed below, we find Northrop Grumman technically qualified to 
construct its NGSO FSS satellites, pending submission of additional information regarding its orbital 
debris mitigation plans. 106 We will authorize Northrop Grumman to launch and operate its NGSO 
satellites once it submits the requisite orbital debris mitigation information.  Nevertheless, we 
address technical issues relating to Northrop Grumman’s proposed NGSO operations in this Order 
so we will be in a position to act expeditiously on any request by Northrop Grumman for launch and 
operating authority.
(i) V-band Operations
53. Northrop Grumman proposes to operate its NGSO satellites in the 37.5-42.0 GHz 
(downlink) and 47.2-50.2 GHz (uplink) frequency bands that are allocated to FSS on a co-primary 
basis.  No comments or objections were filed regarding operations in this band.   For the reasons 
discussed below, we find that Northrop Grumman’s proposed NGSO V-band operations comply 
with the Commission’s technical requirements now in place for this new service, but condition grant 
to require Northrop Grumman to comply with any technical requirements that may be applicable in 
the future.  Further, we require Northrop Grumman to coordinate with other co-primary services 
operating in the NGSO V-band spectrum as described below.
54. First, we find that Northrop Grumman’s NGSO downlink operations, based on data 
provided in Northrop Grumman’s Technical Annex,107 meet the PFD limits contained in Section 
25.208(r), (s), and (t) of the Commission’s rules in the 40.0-42.0 GHz band.108 The NGSO 
operations in the 37.5-40.0 GHz band, however, exceed the “clear-air” PFD limits for elevation 
angles between approximately 11 and 22 degrees.  Nevertheless, since Northrop Grumman’s system 
employs very narrow antenna beams, it should be possible for Northrop Grumman to operate only 
those satellite antenna beams that can be received by earth stations at sufficiently high elevation 
angles to meet the PFD limits.  Because Northrop Grumman did not submit a waiver request to 
operate at PFD limits above the specified values, we will permit Northrop Grumman to operate its 
NGSO satellites in the 37.5-40.0 GHz band only when the NGSO satellites meet the clear-air PFD 
  
(...continued from previous page)
–95 dB (W/m2) for all angles of arrival. This limit may be exceeded by up to 3 dB for no more than 5 percent 
of the time.  See also 47 C.F.R. § 25.208(d).
104 See ITU Radio Regulations, Article 5, Footnote 5.516B, and Resolution 143 (WRC-2007).
105 In addition, Article 5, Footnote 5.519 (WRC-2007) of the ITU Radio Regulations, allocates the 18.3-18.4 
GHz band to the meterological satellite service (space-to-Earth) on a primary basis in Regions 1 and 3.  
106 See paras. 96-102, below.
107 See NGSO March 2004 Amendment, Technical Appendix at 18, Figure 7.  See also NGSO 2007 
Amendment, Technical Appendix, Section 6.
108 See 47 C.F.R. §§ 25.208(r), (s), (t).
Federal Communications Commission DA 09-428
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limits, i.e., at elevation angles to the NGSO satellites that are greater than 22 degrees.
55. Aside from PFD limits, the Commission has not adopted specific service rules for 
NGSO V-band operations.  In the First Space Station Licensing Reform Order, the Commission 
stated that, rather than delaying licensing in cases where it had adopted a domestic allocation for a 
particular service but had not adopted specific service rules in Part 25, it would license systems 
based on specified default rules.109 Section 25.217(b)(1) of the Commission's rules contains a list of 
the default rules that apply to NGSO-like satellites.110 The Commission also stated that, absent Part 
25 rules, it would require licensees to comply with any applicable ITU technical requirements.111  
Thus, Northrop Grumman's V-band NGSO system must comply with the applicable default rules and 
any applicable ITU requirements.  We note, however, that the Commission also stated that any 
license issued under the default rules will be subject to any subsequent service rules it adopts.112
Consequently, we require Northrop Grumman to modify its operations, if necessary, to bring them 
into conformance with any service rules the Commission may later adopt.
56. The default rules applicable to Northrop Grumman’s proposed V-band NGSO 
system are Sections 25.142(d) (prohibition of exclusionary agreements); 25.143(b)(2)(ii) and 
25.143(b)(2)(iii) (geographic service area requirements); 25.204(g) (earth station uplink 
requirements during rain fade conditions); 25.210(c) (ability to change transponder flux densities by 
ground command); 25.210(d) and 25.210(f) (full frequency reuse); 25.210(i) (cross-polarization 
isolation requirements); 25.210(k) (antenna measurements); and 25.210(l) (reporting requirements).  
We address these requirements below.  
57. Prohibition of Exclusionary Agreements.  Section 25.142 (d) of the Commission’s 
rules113 prohibits Commission licensees from acquiring or enjoying any right to distribute service by 
virtue of any concession, contract, or arrangement with an affiliated company that is denied to other 
U.S. operators.  Nothing in Northrop Grumman’s application suggests that Northrop Grumman has 
acquired any such rights.  Once licensed, Northrop Grumman must continue to abide by this policy.
58. Geographic Service Area Requirements.  Section 25.143(b) requires NGSO systems 
to be capable of serving locations as far north as 70 degrees latitude and as far south as 55 degrees 
latitude for at least 75 percent of every 24-hour period.114 It also requires NGSO systems to be 
capable of providing continuous service throughout the 50 states, Puerto Rico and the U.S. Virgin 
Islands.115  
59. Northrop Grumman acknowledges that its NGSO satellites do not adequately cover 
the far southern latitudes.  It asserts, however, that the combined coverage of its hybrid NGSO/GSO 
satellites meets the NGSO coverage requirements.116 We find that while Northrop Grumman has not 
shown that it complies with the letter of the Commission's NGSO coverage requirements, it has 
provided a sufficient basis for a waiver of that requirement.  As noted above, waivers may be granted 
  
109 First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 52).
110 47 C.F.R. § 25.217(b)(1).
111 First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 52).
112 First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 52). See also 47 C.F.R. § 
25.217(e).
113 47 C.F.R § 25.142(d).
114 47 C.F.R § 25.143(b)(2)(ii).
115 47 C.F.R § 25.143(b)(2)(iii).
116 NGSO March 2004 Amendment at 18-19.  See also NGSO 2007 Amendment, Technical Appendix, Section 
6.
Federal Communications Commission DA 09-428
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if the relief requested would not undermine the policy objective of the rule in question and would 
otherwise serve the public interest.117 In this case, because the footprints of Northrop Grumman’s 
four GSO satellites extend well south of the required 55 degrees latitude in the southern hemisphere, 
a waiver will not undermine the policy objective of the rule in question.  If Northrop Grumman 
chooses not to construct any of is GSO satellites, however, it should address its compliance with the 
NGSO coverage requirement in its modification application to change its system design.
60. Compensation for Rain Fade. Section 25.204(g) of the Commission’s rules requires 
earth stations to employ uplink adaptive power control or other methods of fade compensation to 
enable the station to meet the desired performance while reducing potential interference to other 
networks.118  We defer our determination of whether Northrop Grumman’s complies with this 
requirement until we receive an earth station application seeking authority to communicate with 
Northrop Grumman’s V-band NGSO system.
61. Switchable Transponder Flux Densities.  Northrop Grumman's proposed V-band 
NGSO satellites will not use transponders, but rather will demodulate and remodulate signals in a 
processor.  As a result, Northrop Grumman's satellite, as proposed, will not employ any transponders 
that do not comply with Section 25.210(c) of the Commission’s rules.  
62. Full Frequency Reuse.  Sections 25.210(d) and (f) of the Commission’s rules require 
NGSO satellite systems to employ state-of-the-art full frequency reuse either through the use of 
orthogonal polarizations within the same beam and/or the use of spatially independent beams.119  
Northrop Grumman has demonstrated that each of the beams on its NGSO satellites meet this 
requirement by using orthogonal polarization in all operating bands.120
63. Cross-polarization Isolation.  Section 25.210(i) of the Commission’s rules requires 
all FSS space stations to be designed to provide a cross-polarization isolation such that the ratio of 
the on-axis co-polar gain to the cross-polar gain of the antenna in the assigned frequency band is at 
least 30 dB within its primary coverage area.121 Northrop Grumman has demonstrated that it has 
designed its NGSO space stations to provide at least 30 dB cross-polarization isolation within their 
primary coverage area.122
64.  Reporting Requirements.  Section 25.210(k) of the Commission’s rules requires 
licensees to measure each space station antenna’s co-polarized and cross-polarized performance and 
to report this data to the Commission within thirty days after the licensee completes preliminary in-
orbit testing.123 Section 25. 210(l) of the Commission’s rules requires licensees to submit reports on 
June 30th of each year, detailing the status of space station construction and, once launched, the 
operating status of each transponder.124 We require Northrop Grumman to submit all required 
reports in a timely manner.125
  
117 See para. 26, above, citing WAIT Radio, 418 F.2d at 1157.
118 47 C.F.R § 25.204(g).
119 47 C.F.R. §§ 25.210(d), (f).
120 See NGSO March 2004 Amendment, Technical Appendix at 2, 5-12.
121 47 C.F.R. § 25.210(i).
122 See NGSO March 2004 Amendment, FCC Form 312, Schedule S, Section S7(g).  See also NGSO 2007 
Amendment, FCC Form 312, Schedule S, Section S7(g).
123 47 C.F.R. § 25.210(k).
124 47 C.F.R. § 25.210(l).
125 See para. 107, below.
Federal Communications Commission DA 09-428
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65. Applicable ITU Requirements.  The 37.5-38.0 GHz band is allocated for the Federal 
Space Research Service (SRS) on a co-primary basis.  Consequently, we will require Northrop 
Grumman to coordinate its NGSO operations with all co-primary Federal SRS operations prior to 
launch of its first satellite.  In particular, we will require Northrop Grumman’s FSS downlink 
transmissions to protect licensed Federal SRS facilities operating in the 37.5-38.0 GHz band.  To this 
end, we will require Northrop Grumman and SRS facilities to coordinate their operations based on 
Recommendation ITU-R SA.1396, “Protection Criteria for the Space Research Service in the 37-38 
GHz and 40-40.5 GHz Bands.”  More specifically, the ITU Recommendation includes criteria 
designed to protect SRS earth stations that operate in the 37.0-38.0 GHz band from harmful 
interference that would be caused if the total time during which the power density of noise-like 
interference or the total power of CW-type interference in any single band or in all sets of bands 1 
hertz wide, is greater than –217 dB(W/Hz) at the input terminals of the earth station receiver for a 
period exceeding 0.001% of the time for manned missions, and 0.1% of the time for all other space 
research missions.  The ITU Recommendation also includes criteria designed to protect SRS space 
stations that operate in the 40.0-40.5 GHz band from harmful interference that would be caused if 
the total power density of noise-like interference or the total power of CW-type interference in any 
single band or in all sets of bands 20 hertz wide, is greater than –193 dB(W/20 Hz) at the input 
terminals of the space station receiver, with the amount of time of exposure to the interference 
limited to 0.1% of the time for both manned and unmanned missions.  The Recommendation allows 
levels exceeding these protection criteria on a case-by-case basis.  To adequately protect SRS 
facilities, we will not permit Northrop Grumman to begin operations in the 37.5-38.0 GHz and 40.0-
40.5 GHz bands until it has successfully coordinated its operations with licensed SRS operations
pursuant to Recommendation ITU-R SA.1396.126  
66. Last, we recognize that in 2007, the ITU addressed an out-of-band interference issue 
between co-primary V-band Federal and non-Federal service.  Specifically, the ITU adopted a 
resolution specifying that the level of unwanted emissions from the transmit power density at the 
input of a fixed-satellite service earth station antenna in the 49.7-50.2 GHz (Earth-to-space) 
frequency band falling into the 50.2-50.4 GHz EESS (Passive) band shall not exceed -20 dBW/200 
MHz for VSAT/user-type terminals and -10 dBW/200 MHz for gateway/hub applications under 
clear sky conditions.127 The WRC-2007 resolutions became effective on January 1, 2009.  As noted, 
the Commission has stated that, absent Part 25 rules, it will require licensees to comply with any 
applicable ITU technical requirements.128 Thus, if the Commission has not adopted service rules 
when Northrop Grumman brings its system earth stations into operation, we will require Northrop 
Grumman’s earth stations to comply with the ITU emission limits.129
67. Additional Coordination with NTIA. Further, NTIA has informed us of several 
locations where it expects to implement co-primary terrestrial facilities for the military in the 37.5-
38.6 GHz band.130 We require Northrop Grumman to coordinate with NTIA in this band as well.  As 
with all Federal/non-Federal sharing, coordination is to be effectuated through the Interdepartmental 
Radio Advisory Committee (IRAC) and its Frequency Assignment Subcommittee (FAS).
  
126 Any future FSS space station applicants in this band must provide a showing in their applications that their 
downlink operations will not interfere with any previously licensed SRS receiving earth stations.  See V-band 
Second Report and Order, 18 FCC Rcd at 25445 (para. 39).
127 See ITU Resolution 750 (WRC-2007) and ITU Radio Regulations, Article 5, Footnote 5.BA03 (WRC-
2007).
128 See para. 55, above.
129 Given the three-to-five year construction period required for most space stations, we do not expect 
Northrop Grumman to file applications for system earth stations before the ITU rules become effective.  
130 See NTIA Letter at Enclosure 2.
Federal Communications Commission DA 09-428
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68. Consequently, we find that Northrop Grumman’s proposed NGSO V-band 
operations comply with all applicable Commission requirements, ITU requirements, or, in the case 
of geographic service area  requirements, that a waiver is warranted.  We therefore grant Northrop 
Grumman authority to construct its proposed NGSO satellites in these bands, subject to the 
conditions discussed above.
(ii) Ka-band Operations
69. Northrop Grumman proposes to use several portions of the Ka-band for NGSO 
operations.  First, it seeks to use the 18.8-19.3 GHz (downlink) and 28.6-29.1 GHz (uplink) 
frequency bands for communications links between its users and its NGSO satellites.131 These 
operations are consistent with the Ka-band Plan, which designates these bands for primary NGSO 
operations.  Moreover, we find that Northrop Grumman’s proposed operations comply with the 
applicable PFD limits in Section 25.208(e) of the Commission rules and in ITU Article 21.16 (Table 
21-4).132 Further, for the same reasons discussed in paragraphs 58-59, above, we grant Northrop 
Grumman a waiver of the geographic service area requirements in Sections 25.145(1) and (2) of the 
Commission’s rules for its NGSO Ka-band satellites.133 Thus, we grant Northrop Grumman 
authority to construct the NGSO satellites that it proposes to operate in this band.  Once we issue 
Northrop Grumman launch and operating authority in this band, it will be required to coordinate its 
operations with Federal systems in the 18.8-19.3 GHz frequency band in accordance with Footnote 
US334 to the Table of Frequency Allocations before it launches its first NGSO satellite.134 Further, 
Northrop Grumman must comply with the spectrum sharing method adopted in the Ka-band NGSO 
Order when in-line interference events occur with other Ka-band NGSO systems.135
70. Northrop Grumman requests a waiver of the Ka-band Plan to operate its NGSO 
satellites on a non-interference basis in the 19.7-20.2 GHz (downlink) and 29.5-30.0 GHz (uplink) 
frequency bands designated for primary GSO FSS use.136 Northrop Grumman asserts that its 
satellites will meet the equivalent power flux density (EPFD) limits in Article 22 of the ITU Radio 
Regulations and that the satellites’ downlink EPFD levels are at least 15 dB lower than the values 
specified in Article 22.  Consequently, Northrop Grumman concludes that “[t]his means that no 
unacceptable interference would be caused to the GSO networks with primary designations in those 
bands….”  It also states that it will not claim interference protection from GSO FSS operations in 
these bands.137
71. SES Americom argues that Northrop Grumman’s compliance with Article 22’s 
EPFD limits does not justify its requested waiver.  SES Americom states the Commission has not 
considered or adopted the ITU’s international EPFD limits and that Northrop Grumman has not 
  
131 NGSO March 2004 Amendment at 18; and at 5, Table 1.  
132 See 47 C.F.R. § 25.208(e).  See also First Space Station Licensing Reform Order, 18 FCC Rcd at 10784.  
See also NGSO 2007 Amendment, Technical Appendix, Table 6, Figure 6, and Section 6.  WRC-07 modified 
the power flux density limits for certain types of NGSO constellations operating in the 18 GHz band.  
Northrop Grumman is required to meet these limits.
133 47 C.F.R. § 25.145(1), (2).  These rules are identical to the default rules that apply to V-band NGSO 
operations.  
134 47 C.F.R. § 2.106, fn. US 334.
135 Ka-band NGSO Order, 18 FCC Rcd at 14714.  As set forth in Part 25 of our rules, Northrop Grumman 
must also request authority for Earth-to-space transmissions in an earth station application.  47 C.F.R. § 
25.115.  In the 18 GHz Order, the Commission authorized blanket licensing for NGSO FSS earth stations in 
the bands in which NGSO FSS is designated primary status.  See 18 GHz Order, 15 FCC Rcd at 13432.
136 NGSO March 2004 Amendment at 26.
137 NGSO March 2004 Amendment at 26-27.
Federal Communications Commission DA 09-428
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justified the use of these limits domestically.138 As discussed below, we find that Northrop 
Grumman has justified use of Article 22 EPFD limits.
72. The Ka-band Plan authorizes NGSO operations on a secondary basis to GSO 
operations in the 29.5-30.0 GHz band.  Because Northrop Grumman proposes to operate its NGSO 
satellites on a secondary basis in this band, no waiver is required.  As a secondary user, however,
Northrop Grumman’s operations shall not cause harmful interference to primary GSO operations, 
nor can Northrop Grumman claim protection from harmful interference caused by GSO operations.  
In analyzing requests to operate on a secondary basis, the Commission has always required 
applicants to demonstrate that their proposed secondary operations are not likely to cause 
interference to primary operations.139 To do otherwise would create an unacceptable likelihood of 
disruption to primary services.
73. Our review of Northrop Grumman’s technical showing indicates that Northrop 
Grumman’s uplink NGSO operations are not likely to interfere with GSO operations in the 29.5-30.0 
GHz band.  Because there are no Part 25 rules governing NGSO operations in this band, we require 
Northrop Grumman to comply with the relevant ITU requirements.140 Northrop Grumman’s 
technical demonstration in its March 2004 Amendment uses computer simulation software 
developed in accordance with specifications outlined in ITU-R Recommendation S.1503 and 
demonstrates that the maximum uplink EPFD limits calculated for its NGSO satellites satisfy the 
requirements of Article 22 of the ITU Radio Regulations.141 We note, however, that in April 2005, 
the ITU released a later version of this Recommendation (S.1503-1).  Therefore, we require 
Northrop Grumman to file a certification within 30 days of the date of this Order stating that it is still 
compliant with the ITU EPFD limits.  Moreover, Article 22.5I of the ITU Radio Regulations 
provides that if the associated EPFD limits are met, the NGSO FSS satellite system is considered 
coordinated with GSO networks.  Thus, we conclude that if Northrop Grumman continues to meet 
the ITU EPFD limits, there is little likelihood that its NGSO operations will interfere with GSO 
operations.  We therefore find sufficient basis to grant Northrop Grumman’s request to operate its 
NGSO satellites in the 29.5-30.0 GHz band on a secondary basis.  
74. In contrast, the 19.7-20.2 GHz downlink band for non-Federal systems is designated 
for GSO only, with no secondary designation for non-Federal NGSO operations.  Northrop 
Grumman therefore requests a waiver to operate its NGSO satellites in this portion of the band.  As 
noted previously, waivers may be granted if the relief requested would not undermine the policy 
objective of the rule in question, and would otherwise serve the public interest. 142 Further, in 
analyzing requests for non-conforming spectrum uses, the Commission has indicated it would 
generally grant such waivers “when there is little potential for interference into any service 
authorized under the Table of Frequency Allocations and when the non-conforming operator accepts 
  
138 SES Americom Petition to Deny at 6.
139 See, e.g., Qualcomm, Inc., Memorandum Opinion and Order, and Authorization, 4 FCC Rcd 1543 (1989) 
(authorizing mobile-satellite service on a secondary basis in the 14 GHz band and on a non-conforming basis 
in the 12 GHz band).
140 First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 52).
141 NGSO March 2004 Amendment, Attachment D at 50.  Northrop Grumman’s calculation assumed five 
NGSO users operating in the same frequency channel within GSO 1.55 degrees beam.  According to Northrop 
Grumman, the maximum uplink EPFD levels are: 0.7m: -176.2 dB (W/m2/40 kHz); 1.2 m: -185.73 dB 
(W/m2/40 KHz).  Id. Commission staff reviewed Northrop Grumman’s calculations, verified their accuracy, 
and found that the proposed operations fall within the corresponding limits defined in Article 22 of the ITU 
Radio Regulations.
142 47 C.F.R. § 1.3.  See also WAIT Radio, 418 F.2d 1153; Northeast Cellular, 897 F.2d 1166.
Federal Communications Commission DA 09-428
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any interference from authorized services.”143
75. Northrop Grumman, relying on its computer simulation software, demonstrates that 
the operations of its NGSO satellites in the 19.7-20.2 GHz band meet the ITU EPFD limits in Article 
22, Tables 22-1C and 22-4B.  As noted above, the ITU considers a NGSO FSS system that meets 
these EPFD limits to be fully coordinated with respect to any GSO FSS network.144  In light of the 
ITU rules and our verification of Northrop Grumman’s software calculations, we find that Northrop 
Grumman’s operations should not affect primary non-Federal GSO operations in the band.  As a 
further assurance against unacceptable interference to GSO operations, we will require Northrop 
Grumman to publish its NGSO satellites’ ephemeris data in the North American Aerospace Defense 
Command’s (NORAD’s) two-line format on a Northrop Grumman-maintained web site and to 
update this data every three days.145 Consequently, we find that granting a waiver to allow Northrop 
to operate NGSO satellites in the 19.7-20.2 GHz band will not undermine the objective of the rule to 
protect primary services and will serve the public interest by allowing Northrop Grumman to offer 
consumers a range of broadband and interactive services. We will also require Northrop Grumman
to comply with any service rules the Commission may later adopt.   
76. Further, Northrop Grumman must coordinate its Ka-band NGSO satellites with 
Federal GSO and NGSO systems in this frequency band in accordance with Footnote US334 to the 
Table of Frequency Allocations prior to the launch of its first satellite.  As a non-conforming user, 
Northrop Grumman’s operations will be on a non-harmful interference basis, and Northrop 
Grumman will not be protected from interference from other allocated non-Federal and Federal 
operations in this band.  In addition, as a non-conforming user, Northrop Grumman shall not cause 
harmful interference to any authorized Federal GSO or NGSO FSS system, and shall immediately 
cease operations upon notification of such harmful interference resulting from its operations.  
Similarly, Northrop Grumman must also coordinate with specific GSO earth stations pursuant to 
ITU Article 9, No. 9.7A.
(iii) Replacement Satellites
77. In the Ka-band NGSO Report and Order, the Commission adopted a blanket 
licensing procedure that authorizes the construction and launch of all satellites in the constellation.  
This includes satellites needed to replace those that fail or are retired prior to the end of the license 
term.146 This follows the procedure used for NGSO constellations in other frequency bands.147 The 
blanket licensing procedure provides licensees with the ability to replace satellites in their fleets 
  
143 Fugro-Chance, Inc., Order and Authorization, 10 FCC Rcd 2860 (para. 2) (Int'l Bur. 1995) (authorizing 
non-conforming mobile-satellite service in the 4/6 GHz band); see also Motorola Satellite Communications, 
Inc., Order and Authorization, 11 FCC Rcd 13952, 13956 (para. 11) (Int'l Bur. 1996) (authorizing service to 
fixed terminals in bands allocated to the mobile-satellite service); Geostar Positioning Corp., Order and 
Authorization, 4 FCC Rcd 4538 (para. 7) (1989) (authorizing service to radiodetermination satellite service 
terminals in a band allocated to the fixed-satellite service).
144 See para. 73, above.
145 See Ka-band NGSO Order, 18 FCC Rcd at 14720.  Ephemeris data is information that will allow a GSO 
operator to locate an NGSO constellation at any given time.  To avoid in-line interference events, the 
Commission requires Ka-band NGSO FSS licensees and Ku-band NGSO licensees operating in the 10.75-14.5 
GHz band to provide such data.  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, ET Docket No. 98-206, First Report and Order and Further Notice of Proposed Rulemaking, 16 FCC 
Rcd 4096, 4138 (para. 102) (2000).
146 Ka-band NGSO Order, 18 FCC Rcd at 14726.
147 See, e.g., 47 C.F.R. § 25.142(a)(5) (for the “Little LEO” service) and 47 C.F.R. § 25.143(c) (for the “Big 
LEO” service).
Federal Communications Commission DA 09-428
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promptly and to avoid any service disruptions to their customers.  Thus, we issue Northrop 
Grumman a blanket license for the Ka-band component of its NGSO constellation.  In addition, we 
extend blanket licensing, and its benefits,  to Northrop Grumman’s V-band NGSO component.  
Consequently, we authorize Northrop Grumman to construct three hybrid Ka-band/V-band NGSO 
FSS satellites and to maintain this constellation until the end of the license period.  Any replacement 
satellites that Northrop Grumman launches before the end of the constellation’s license term must be 
technically identical to those in service, including the frequency bands and orbital parameters, and 
may not result in a net increase in the number of operating satellites.
d. GSO Satellites
78. In addition to its request for NGSO satellite system authority, Northrop Grumman 
seeks authority to operate a GSO FSS satellite at each of four orbital locations (125° W.L., 73° W.L., 
68.5° E.L. and 116.5° E.L.), in both the V-band and the Ka-band.  As discussed below, we find 
Northrop Grumman’s proposed GSO satellites meet the Commission’s technical and service rules.  
We discuss V-band and Ka-band operations separately below.
(i) V-band Operations
79. Northrop Grumman proposes to operate its four GSO satellites in the 37.5-42.0 GHz 
(downlink) and 47.2-50.2 GHz (uplink) frequency bands, which are allocated on a co-primary basis 
to FSS.  No comments or objections were filed regarding these operations.  Thus, we allow Northrop 
Grumman to operate in these bands, provided that it meets all the technical requirements applicable 
to these bands, including those in the default rules.148
80. To comply with our rules, Northrop Grumman must show that its GSO V-band 
satellite operations will meet two-degree orbital spacing requirements.  The Commission has stated 
that it will apply the two-degree spacing requirements that it applies to GSO satellites in the C-band, 
Ku-band, Ka-band, and to proposed GSO satellites in other frequency bands.149 Northrop Grumman 
indicates that its V-band operations are consistent with operations in a two-degree spacing 
environment.150 Because there are no authorized co-frequency V-band GSO FSS satellites within 
two-degrees of Northrop Grumman’s proposed orbital locations, Northrop Grumman conducted a 
two-degree compatibility analysis using the characteristics of its own satellites.151 Our review of this 
analysis confirms Northrop Grumman's conclusion that its proposed satellites are two-degree 
compatible.152 We also find that Northrop Grumman's proposed V-band operations meet the PFD 
limits for operations in the 37.5-42.0 GHz band specified in Sections 25.208 (q), (s), and (u) of the 
Commission’s rules and in ITU Article 21.16 (Table 21-4).153 Further, with the exception of the 
geographic service area requirement, the same default rules apply to Northrop Grumman’s GSO V-
band operations as apply to its NGSO operations.  For the reasons discussed in paragraphs 56-64 
above, we find that Northrop Grumman’s proposed GSO operations similarly comply with these 
  
148 47 C.F.R. § 25.217(c).  See also First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 
52). 
149 First  Space Station Licensing Reform Order, 18 FCC Rcd at 10808 (para. 119).
150 See 116.5° E.L. July 2004 Amendment, Annex 1 at 5.  See also 125° W.L. 2007 Amendment, 73° W.L. 
2007 Amendment, 68.5° E.L. 2007 Amendment, 116.5° E.L. 2007 Amendment, Attachment A.
151  See 116.5° E.L. July 2004 Amendment, Annex 1 at 5, 125° W.L. 2007 Amendment, 73° W.L. 2007 
Amendment, 68.5° E.L. 2007 Amendment, 116.5° E.L. 2007 Amendment, Attachment A.  See also 2004 Two-
Degree Spacing Public Notice, 19 FCC Rcd at 10952.  
152 NGSO July 2004 Amendment, Annex 1 at 1-5.
153 See 47 C.F.R. §§ 25.208(q), (s), and (u), ITU Article 21.16 (Table 21-4) of the ITU Radio Regulations.  See 
also First Space Station Licensing Reform Order, 18 FCC Rcd at 10784 (para. 52).
Federal Communications Commission DA 09-428
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rules.  Last, as noted above, we require Northrop Grumman’s GSO operations to comply with 
applicable ITU or Commission requirements governing out-of-band earth station emission limits.154
81. Further, Northrop Grumman must complete coordination with all Federal FSS systems 
operating in the 37.5-42.0 GHz and 47.2-50.2 GHz frequency bands prior to launch of its first 
satellite.  Finally, we limit Northrop Grumman's operations in the 37.5-40.0 GHz and 47.2-48.2 GHz 
portions of the V-band to gateway operations, consistent with the requirements in Footnote 15 of 
Section 25.202(a)(1) of the Commission Rules.155
(ii) Ka-band Operations
82. Northrop Grumman proposes to operate all four GSO FSS satellites in the 18.3-18.8 
GHz (downlink), 19.7-20.2 GHz (downlink), 28.35-28.6 GHz (uplink), and 29.25-30.0 GHz (uplink) 
bands, which are designated for primary use for GSO operations.  Northrop Grumman also proposes 
to operate all four GSO satellites in the 28.6-29.1 GHz (uplink) and 18.8-19.3 GHz (downlink) 
frequency bands.  The 28.6-29.1 GHz band is designated for GSO FSS use on a secondary basis with 
respect to primary NGSO FSS operations.  The 18.8-19.3 GHz band does not contain a designation 
for GSO FSS operations and thus can only be authorized for use by GSO satellites on a non-
conforming basis.  Northrop Grumman requests waivers of the Ka-band Plan to allow GSO use of 
the 28.6-29.1 GHz and 18.8-19.3 GHz frequency bands.156
83. We find that Northrop Grumman’s proposed operations in the primary GSO Ka-band 
frequencies comply with all requirements for GSO satellites in Part 25 of the Commission's rules.  
First, we find that Northrop Grumman’s analyses show that its GSO FSS satellites are compatible 
with a two-degree orbital spacing environment.157 Further, we find that Northrop Grumman’s 
proposed operations comply with the applicable PFD limits in Sections 25.138(a)(6),  25.208(c), and 
25.208(d) of the Commission rules, as well as ITU Article 21.16 (Table 21-4) of the ITU Radio 
Regulations.158 Accordingly, we grant Northrop Grumman authority to operate its four proposed 
GSO satellites in the GSO Ka-band frequencies.  We condition this authority, however, on Northrop 
Grumman coordinating its operations with Federal systems in accordance with Footnote US334 to 
the Table of Frequency Allocations.159
84. Next, we analyze Northrop Grumman's request to operate its GSO satellites in those 
portions of the Ka-band designated for primary NGSO use.  In support of its waiver request to 
permit these operations, Northrop Grumman states that its GSO FSS satellites will comply with 
applicable PFD limits in Section 25.208(e) of the Commission rules and Article 21.16 (Table 21-4) 
of the ITU Rules and Regulations.160 Northrop Grumman also states that its GSO component will 
facilitate spectrum sharing among NGSO systems because Northrop Grumman will switch its NGSO 
operations to a GSO satellite during an in-line event.  This will allow other NGSO systems to 
  
154 See para. 66, above.
155 See 47 C.F.R. § 25.202(a)(1), fn. 15.
156 See NGSO March 2004 Amendment at 27.
157 125° W.L. 2007 Amendment, Technical Appendix, Attachment B-1; 73° W.L. 2007 Amendment, Technical 
Appendix Attachment B-2; 68.5° E.L. 2007 Amendment, Technical Appendix Attachment B-3, 116.5° E.L. 
2007 Amendment, Technical Appendix Attachment B-4.
158  See 47 C.F.R. §§ 25.138(a)(6) and 25.208(c),(d) and Article 21.16 (Table 21-4) of the ITU Radio 
Regulations.  See 125° W.L. 2007 Amendment, Technical Appendix, Attachment B-1; 73° W.L. 2007 
Amendment, Technical Appendix, Attachment B-2; 68.5° E.L. 2007 Amendment, Technical Appendix 
Attachment B-3, 116.5° E.L. 2007 Amendment, Technical Appendix, Attachment B-4.
159 47 C.F.R. § 2.106, fn. US 334.
160 47 C.F.R. § 25.208(e), Article 21.16 (Table 21-4) of the ITU Radio Regulations.
Federal Communications Commission DA 09-428
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operate across the entire designated Ka-band spectrum during an NGSO to NGSO in-line event 
rather than reducing spectrum use, as would otherwise be required.  Thus, Northrop Grumman 
argues that granting a waiver will not undermine the purpose of the rule designating the 18.8-19.3 
GHz and 28.6-29.1 GHz frequency bands for primary NGSO FSS use.161
85. EchoStar and SES Americom observe that the Commission previously denied an 
EchoStar application to operate GSO satellites in spectrum designated for Ka-band NGSO services 
because EchoStar's commitment to shut off its GSO satellites upon notification of a “concrete risk of 
harmful interference” was not sufficient to ensure that NGSO satellites would not receive harmful 
interference.162 EchoStar and SES Americom assert that EchoStar's proposal to cease operations 
during an in-line interference event is analogous to Northrop Grumman's proposal to switch its 
traffic to a GSO satellite and that we should similarly deny Northrop Grumman’s applications.163  
Although SES Americom recognizes that Northrop Grumman provides a technical analysis while 
EchoStar did not, SES Americom maintains that the technical analysis is not relevant because the 
Commission has not established protection criteria for Ka-band NGSO systems.164 SES Americom 
also asserts that accepting Northrop Grumman’s application before the Commission conducts a 
rulemaking to permit GSO operations in NGSO-designated bands gives Northrop Grumman unfair 
“first-in-line” date priority over other potential applicants.165
86. We find that Northrop Grumman has provided adequate justification for a waiver of 
the Ka-band Plan to the extent such a waiver is necessary.  We first address Northrop Grumman's 
request for waiver of the Ka-band Plan in the 28.6-29.1 GHz (uplink) frequency band.  This band 
contains a secondary designation for GSO FSS uplink operations.  Consequently, Northrop 
Grumman does not need a waiver of the Table of Frequency Allocations to operate in this spectrum 
on a non-interference basis.  We will permit Northrop Grumman’s GSO satellites to operate in this 
band if these operations do not interfere with primary NGSO operations.  Technical studies to 
develop interference criteria between GSO and NGSO systems have not been completed.166 We 
recognize that, without established NGSO FSS interference protection criteria, satellite operators 
cannot fully assess the impact of proposed GSO operations on NGSO operations.  Nevertheless, we 
note that Northrop Grumman has provided a quantitative demonstration of how its GSO satellites 
will protect NGSO systems in the 28.6-29.1 GHz frequency band.  Northrop Grumman’s analysis 
included potential interference from its GSO satellites into the NGSO satellite design proposed by 
ATCONTACT, and the low-Earth orbit satellite design proposed by SkyBridge II, which has since 
been withdrawn.167 Northrop Grumman analyzed the potential interference between each of these 
systems in terms of the Interference-to-Noise Ratio, IO/NO assuming a minimum topocentric line of 
sight angular separation of ten degrees.  Based on the worse case scenarios, Northrop Grumman 
calculated a IO/NO of -31.3 dB with respect to the ATCONTACT system and an IO/NO of -15 dB 
with respect to the SkyBridge II system.  This corresponds to a DT/T of 0.07% and 3.16%, 
  
161 NGSO March 2004 Amendment at 22, 27.
162 SES Americom Petition at 7-8; EchoStar Petition at 5-6.
163 EchoStar Reply at 2-4. 
164 SES Americom Petition at 8-9.  
165 SES Americom Petition at 10-11; SES Americom Reply at 9-10.
166 See Astrolink International, LLC, Order and Authorization, 16 FCC Rcd 20124, 20127 (Int’l Bur. 2001). 
167 See, e.g., 119° W.L. July 2004 Amendment, at Annex 3.  SkyBridge II LLC withdrew its Ka-band NGSO 
FSS application in October  2004. Public Notice, Policy Branch Information, Report No. SAT-00252, 19 FCC 
Rcd 20950 (Int’l Bur. 2004).  See also 125° W.L. 2007 Amendment, Technical Appendix, Attachment C-1; 
73° W.L. 2007 Amendment, Technical Appendix, Attachment C-2; 68.5° E.L. 2007 Amendment, Technical 
Appendix, Attachment C-3, 116.5° E.L. 2007 Amendment, Technical Appendix, Attachment C-4.
Federal Communications Commission DA 09-428
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respectively.  These values are well below the 6% threshold that triggers coordination between 
satellite systems under the relevant ITU Radio Regulations.  Therefore,  we conclude that the 
Northrop Grumman satellite system will not cause harmful interference to the ATCONTACT system 
nor would it have to the SkyBridge II system.  Neither SES Americom nor EchoStar has provided 
any technical analyses to disprove Northrop Grumman’s demonstration nor do we have any reason 
to believe that Northrop Grumman’s study is flawed.  
87. In contrast, the Table of Frequency Allocations limits the use of the 18.8-19.3 GHz 
band – which Northrop Grumman proposes for GSO downlink operations – to NGSO downlink 
operations.168 The Commission stated that secondary GSO operations would be feasible only if an 
NGSO receiver does not point at the geostationary orbit.169 It further stated that pointing flexibility 
allows NGSO licensees to use fewer satellites in their constellations and that it would not constrain 
such flexibility to facilitate NGSO sharing with non-primary GSO operations.170 Northrop 
Grumman’s NGSO orbital characteristics are such that the NGSO receive earth stations within its 
own system will never point toward the geostationary arc.  Furthermore, Northrop Grumman’s 
technical analysis, discussed above, demonstrates that its downlinks on its GSO FSS satellites would 
not cause harmful interference to any of the then-pending proposed non-Federal NGSO FSS 
systems.171 Finally, allowing Northrop Grumman to switch to its GSO satellites during in-line 
events between its NGSO satellites will facilitate NGSO operations in this band.
88. We also conclude that EchoStar's applications are not similarly situated with Northrop 
Grumman's.  While both entities requested a waiver of the Ka-band plan to operate GSO satellites in 
NGSO-designated spectrum, EchoStar -- in contrast to Northrop Grumman -- did not provide a 
technical analysis to support its waiver request.  Generally, the Commission requires applicants 
proposing non-conforming operations to demonstrate that their proposed operations will not cause 
interference into allocated services.  Instead, EchoStar asserted that it did not need to provide a 
technical analysis because it would terminate operations upon notification that its GSO operations 
were posing a "concrete risk of harmful interference" to NGSO operations.172 It also asserted that a 
waiver was justified because the NGSO-designated band, which was not being used, would 
otherwise remain fallow.173 The Division rejected these assertions, citing several pending 
applications proposing NGSO operations in this band (including Northrop Grumman's) and noting 
that EchoStar had not justified a departure from the Commission's policy to ensure that allocated 
services do not receive any interference from non-conforming services.174 In contrast, Northrop 
Grumman's application included an undisputed technical showing that it would not interfere with 
NGSO operations.  While Northrop Grumman submitted this showing in an amendment to its initial 
application, this information was in the record when the Division reviewed the merits of Northrop 
  
168 47 C.F.R. § 2.106, fn. NG 165. 
169 18 GHz Order, 15 FCC Rcd at 13458-9. 
170 Id.
171 See NGSO July 2004 Amendment, 119° W.L. July 2004 Amendment, 89° W.L. July 2004 Amendment, 15° 
E.L. July 2004 Amendment, and 116.5° E.L. July 2004 Amendment at Annex 3.  See also 125° W.L. 2007 
Amendment, Technical Appendix, Attachment C-1; 73° W.L. 2007 Amendment, Technical Appendix, 
Attachment C-2; 68.5° E.L. 2007 Amendment, Technical Appendix, Attachment C-3, 116.5° E.L. 2007 
Amendment, Technical Appendix, Attachment C-4.
172 See, e.g., EchoStar Satellite Corporation, Application for Authority to Construct, Launch, and Operate a 
Geostationary Satellite Using Ka-band Frequencies at 121° W.L., File No. SAT-LOA-20030827-00180, at 15 
(EchoStar Application), denied in EchoStar Satellite LLC, Memorandum Opinion and Order, 19 FCC Rcd 
7846 (Sat. Div., Int’l Bur. 2004) (EchoStar Order).
173 EchoStar Application at 16.
174 EchoStar Order, 19 FCC Rcd at 7853.
Federal Communications Commission DA 09-428
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Grumman's proposal. 
89. Further, SES Americom's argument that Northrop Grumman’s compliance with the 
ITU EPFD limits does not provide justification for a waiver is misplaced. We do not rely on 
Northrop Grumman's EPFD assertions, but rather base our waiver grant on our review of its 
interference analysis as set forth above.  Finally, we do not agree with SES Americom that giving 
Northrop Grumman “first-in-line” status is unfair.  Other potential applicants were free to file 
substantially complete applications with adequately supported requests for waiver of the Ka-band 
plan, just as Northrop Grumman did.175
90. Therefore, we grant Northrop Grumman a waiver of Section 2.106 of the 
Commission’s rules to operate its GSO satellites on a non-conforming basis in the 18.8-19.3 GHz 
frequency band and grant it authority to operate its proposed GSO satellites in the 28.6-29.1 GHz 
band on a secondary basis.  We require Northrop Grumman to accept interference from all 
operations with superior status in these bands, including Federal GSO and NGSO systems, and to 
terminate operations if it causes harmful interference to any superior-status service.  Further, we 
require Northrop Grumman to terminate GSO operations in order to avoid an in-line interference 
event between one of its GSO satellites and other systems’ NGSO satellites.  Northrop Grumman 
must also coordinate with Federal GSO and NGSO FSS systems in the 18.8-19.3 GHz band in 
accordance with Footnote US334 to the Table of Frequency Allocations.  We condition this 
authority, however, on Northrop Grumman complying with any interference criteria that may be 
adopted by the Commission.
(iii) Increased Power Operations in the 18.8-19.3 GHz and 
28.6-29.1 GHz Frequency Bands
91. In its most recent amendments, Northrop Grumman proposes to increase the power 
levels on its GSO satellites in the 18.8-19.3 GHz and 28.6-29.1 GHz frequency bands.  Northrop 
Grumman states that it requests this change because it seeks to provide emergency and homeland 
security operations during disasters in these bands.176 Northrop Grumman indicates that these 
operations will require earth station terminals as small as 0.25 meters in diameter and that these 
small antennas require somewhat higher operating powers.177 Northrop Grumman states that 
although the increased power still complies with applicable Commission rules, the combination of 
earth station size and power makes the earth stations best suited to a four-degree orbital spacing 
environment.  Northrop Grumman therefore suggests that the Commission adopt four-degree orbital 
spacing for GSO satellites operating in these bands.178 Northrop Grumman also requests a waiver of 
Section 25.140(b)(2) of the Commission’s rules,179 which requires applicants to provide an 
interference analysis demonstrating the compatibility of the proposed system with GSO satellites
two-degrees away.
92. The Commission adopted a two-degree orbital spacing framework for Ka-band GSO 
  
175 Indeed, ATCONTACT applied for, and was granted, a similar waiver to operate GSO Ka-band satellites in 
the portion of the Ka-band designated for primary NGSO operations.  See contactMEO Communications, 
LLC, 21 FCC Rcd at 4047-48.  EchoStar and SES Americom objected to the grant of ATCONTACT’s 
secondary/non-conforming GSO operations for the same reasons they object to Northrop Grumman’s 
secondary/non-conforming GSO operations.  These arguments were rejected in the order granting 
ATCONTACT’s application.  Id.
176 See, e.g., 125° W.L. 2007 Amendment at 10-13.
177 See, e.g., 125° W.L. 2007 Amendment at 11.
178 See, e.g., 125° W.L. 2007 Amendment at 10-13.
179 See, e.g., 125° W.L. 2007 Amendment at 11.  See also 47 C.F.R. § 25.140(b)(2).
Federal Communications Commission DA 09-428
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satellites in the Ka-band Third Report and Order.180 Even assuming Northrop Grumman had filed a 
Petition for Rulemaking, which is the correct procedural vehicle to revisit the Commission’s Ka-
band decision, it has not persuaded us to consider increasing orbital spacings for GSO satellites in 
the 18.8-19.3 GHz and 28.6-29.1 GHz bands.  The downlink frequency band at 18.8-19.3 GHz does 
not contain a designation for GSO satellites and the uplink frequency band at 28.6-29.1 GHz 
contains only a secondary designation for GSO satellites.181 This means that GSO satellite 
operations cannot cause harmful interference to or claim protection from NGSO operations in these 
bands, which have a primary designation in both bands.  We attempt to accommodate the provision 
of disaster-related relief services, where possible.  We are reluctant to approve such services, 
however,  where they could be subject to interference and could be required to be terminated upon 
notification of interference into NGSO operations.  We note that GSO satellites provide disaster-
related relief services in many other bands that contain a two-degree orbital spacing framework, 
including that portion of the Ka-band spectrum designated for GSO operations on a primary basis.  
93. Nevertheless, we grant Northrop Grumman a waiver of Section 25.140(b)(2) of the 
Commission’s rules to permit it to operate at its proposed higher power levels with small antennas 
on a conditional basis.182 No other GSO satellites are now operating or are authorized to operate 
within four-degrees of Northrop Grumman’s proposed satellites in the 18.8-19.3 GHz and 28.6-29.1 
GHz bands.183 Thus, allowing Northrop to operate at its proposed power levels will not affect any 
other GSO operator at this time.  We require Northrop Grumman, however, to protect the operations 
of any two-degree compliant GSO operator that operates in these bands in the future.  Further, 
Northrop Grumman may not claim protection against interference to its operations caused by a two-
degree compliant GSO operator in these bands.  Finally, given the secondary/non-conforming status 
of GSO operations in these bands, we require Northrop Grumman to notify its customers who are 
using antennas that are not two-degree compliant, in writing, that service is being provided on a non-
conforming or secondary basis in these bands, that Northrop Grumman will be required to terminate 
operations if its operations cause harmful interference to a service designated  to use these bands on 
a primary basis, and that Northrop Grumman cannot claim protection against interference caused by 
any operations with superior operating status.
e. Tracking, Telemetry, and Command Function
94. Section 25.202(g) of the Commission’s rules requires FSS systems to operate their 
tracking, telemetry, and command (TT&C) links at the edges of the frequency bands in which they 
are providing service.184 The rule further provides that operators should select frequencies, 
polarization, and coding to minimize interference into other satellite networks and within their own 
satellite system.  Northrop Grumman represents that each of its NGSO and GSO satellites will 
conduct TT&C at the edges of the NGSO Ka-band using one or two TT&C channels on each 
satellite with channel bandwidths of two megahertz.185
  
180 Ka-band Third Report and Order, 12 FCC Rcd  at 22319.
181 Indeed, as previously noted, the Commission eliminated the secondary designation for GSO downlinks at 
18.8-19.3 GHz because it concluded that allowing secondary operations would inhibit use by primary users.  
18 GHz Order, 15 FCC Rcd at 13432.
182 Northrop Grumman must still file license applications for any earth stations it seeks to operate in 
conjunction with its GSO satellites.
183 ATCONTACT Communications, LLC has the only licensed GSO system in the 18.8-19.3 GHz and 28.6-
29.1 GHz bands.  None of its GSO satellites are authorized less than four-degrees away from Northrop 
Grumman’s GSO satellites.
184 47 C.F.R. § 25.202(g).
185 See, e.g., 125° W.L. 2007 Amendment, Technical Appendix at 14.
Federal Communications Commission DA 09-428
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95. Northrop Grumman asks us to grant a waiver of Section 25.202(g) to allow it to use 
TT&C frequencies in just one of the frequency bands used in which it is providing service—that is, 
the Ka-band NGSO FSS service bands—to allow it to take advantage of the efficiencies of a hybrid 
V-band/Ka-band system.186 Northrop Grumman’s request for a waiver of Section 25.202(g) is 
unnecessary.  Section 25.202(g) does not require Northrop Grumman to conduct TT&C operations at 
the band edges of both the Ka- and V-bands.  The rule requires only that TT&C operations occur at 
the band edges of an FSS band in which it is providing service.  We find Northop Grumman in 
compliance with this rule.
f. Orbital Debris Mitigation
96. An applicant for a space station license must submit a description of the design and 
operational strategies that it will use to mitigate orbital debris, including a statement detailing post-
mission disposal plans for space stations at the end of their operating life.187 Northrop Grumman 
included an orbital debris mitigation plan in its amended application.188 Thereafter, the Satellite 
Division released a Public Notice clarifying information that must be included in an applicant’s 
casualty risk assessment if the planned post-mission disposal involves atmospheric re-entry of 
spacecraft.189 Northrop Grumman further amended its application, consistent with the Public Notice, 
with respect to the proposed controlled re-entry of its NGSO FSS satellites during post-mission 
disposal of the spacecraft.190 Northrop Grumman further amended its applications in February 2007 
and submitted an erratum to each of the four GSO amendments that consisted of an updated orbital 
debris plan for each of these satellites.191
97. In its orbital debris mitigation plan, Northrop Grumman represents that it will 
incorporate vehicle design and operational techniques to minimize orbital debris.192 It states that its 
system design will minimize the possibility of collision between satellites and other known objects.  
Further, Northrop Grumman states that its spacecraft design will also consider, and to the extent 
practicable, limit the probability that collisions with items smaller than one centimeter in diameter 
could cause a loss of control, and thereby prevent intended means of post-mission disposal.193 In 
addition, Northrop Grumman states that critical components of its system will be designed to 
minimize vulnerability to high-speed particles and untracked debris that may result in loss of satellite
control.194
98. As a general matter, although the risk of collision between the satellites is extremely 
low, the Commission has indicated that in cases in which orbital parameters for proposed satellite 
systems are similar to those of other operating systems, such that the two systems may have an 
  
186 NGSO March 2004 Amendment at 25-26.
187 Orbital Debris Order, 19 FCC Rcd 11567, 11619; 47 C.F.R. § 25.145.  See also 47 C.F.R. § 25.114(d) (14).
188 See SAT-AMD-20031104-00324.  See also March 2004 Amendments.
189 Orbital Debris Public Notice, 19 FCC Rcd 10714 (June 16, 2004).
190 See July 2004 Amendments.
191 See Errata to 125° W.L. 2007 Amendment, 73° W.L. 2007 Amendment, 68.5° E.L. 2007 Amendment, 
116.5° E.L. 2007 Amendment, all filed on March 19, 2007.
192 See, e.g., NGSO July 2004 Amendment, Annex 2.  See also 116.5° July 2004 Amendment, Annex 2.  See 
also errata to 125° W.L. 2007 Amendment; 73° W.L. 2007 Amendment; 68.5° E.L. 2007 Amendment; 116.5° 
E.L. 2007 Amendment.
193 Id.
194 Id.
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increased risk of physical collision, further review may be warranted.195 In April 2005, the Division 
asked Northrop Grumman and ATCONTACT  to provide written explanations regarding measures 
they will take to avoid in-orbit collisions between the NGSO satellites in their constellations that 
have similar orbital parameters.196 In response, Northrop Grumman and ATCONTACT state that 
operational conditions, i.e., initial orbital parameters, and ongoing coordination will ensure that the 
two systems’ operations are physically compatible.197
99. According to Northrop Grumman, its GSO FSS satellites at the end of mission will 
be raised to an orbit with perigee altitude of at least 300 km above the GSO operational altitude.  
Although this proposal is consistent with prior practices, the Commission’s new end-of-life disposal 
rule requires the disposal perigee altitude of the GSO spacecraft to be no lower than that calculated 
using the Interagency Space Debris Coordination Committee (“IADC”) formula.198 Although a 
perigee 300 kilometers above the geostationary altitude is typically sufficient to meet the IADC 
formula, a 300 kilometer increase may be insufficient depending on spacecraft design.  Pursuant to 
the new rule, Northrop Grumman is required to make certain that the disposal perigee altitude of its 
GSO spacecraft complies with this requirement.
100. To ensure adequate disposal altitude for its GSO FSS satellites, Northrop Grumman 
assures the Commission that it will budget enough fuel to ensure that these satellites are properly 
disposed of at the end of life.  Northrop Grumman also states that after end-of-life disposal, all 
remaining energy sources will be depleted or deactivated.  This includes depleting remaining fuel, 
venting pressurized systems, discharging batteries and deactivating other safety systems.199
101. At end of mission of its NGSO FSS satellites, Northrop Grumman plans to de-orbit 
its NGSO FSS satellites through controlled re-entry by using a series of maneuver burns.  Northrop 
Grumman states that the deorbit process will be designed to assure that the satellite is stable and 
under control throughout the deorbit process.200 Northrop Grumman has identified an open area in 
the southern Pacific Ocean as the projected geographic region of the debris field.201 Northrop 
Grumman also states that authorities for shipping lanes and airline routes in the area of the debris 
field will be notified of the event.
102. This case is one of the first in which we have addressed a system’s plans to dispose 
of satellites using controlled atmospheric reentry, at end-of-life.  According to Northrop Grumman, 
its system is still in the design process.  Given the stage of development for its NGSO constellation, 
Northrop Grumman’s application does not provide more detailed information concerning end-of-life 
operations, such as detailed operational plans, methods for coordination with relevant government 
  
195 See, e.g., Orbital Debris Order, 19 FCC Rcd at 11588.
196 Letter to Peter Hadinger, Northrop Grumman Space & Missions Systems Corp., from Robert Nelson, Chief, 
Satellite Engineering Branch (Apr. 27, 2005).  See also Letter to David Drucker, Manager, contactMEO 
Communications, LLC from Robert Nelson, Chief, Satellite Engineering Branch (Apr. 27, 2005).
197 Letter to Marlene Dortch, Secretary FCC, from Stephen D. Baruch, Attorney for Northrop Grumman Space 
& Mission Systems Corporation (May 12, 2005); Letter to Marlene Dortch, Secretary, FCC, from James M. 
Talens, Attorney for contactMEO Communications, LLC (May 12, 2005).
198 47 C.F.R. § 25.283.  IADC formula: 36,021 km + (1000·C
R·A/m), where CR is the solar pressure radiation 
coefficient of the spacecraft, and A/m is the Area to mass ratio, in square meters per kilogram, of the 
spacecraft.  
199 See NGSO July 2004 Amendment at Annex 2; 116.5° E.L. July 2004 Amendment at Annex 2.  See also
errata to 125° W.L. 2007 Amendment; 73° W.L. 2007 Amendment; 68.5° E.L. 2007 Amendment; 116.5° E.L. 
2007 Amendment.
200 Id.
201 Id. 
Federal Communications Commission DA 09-428
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agencies, and insurance arrangements.  We believe that a more detailed review of these issues is 
warranted as system design progresses, and prior to authorization of launch and operating authority.  
Until such a review can be completed, we are not in a position to conclude that either the disposal of 
Northrop Grumman’s NGSO satellites, or the launch that would necessitate disposal, are in the 
public interest.  Accordingly, we require Northrop Grumman to file, no later than 30 days following 
completion of the Critical Design Review milestone for its NGSO satellites, an application to modify 
its license, specifying its end-of-life operations.  This application should provide detailed 
information concerning all aspects of the proposed disposal plan.  Because the United States is 
potentially strictly liable for any damage caused on the surface of the Earth by re-entering Northrop 
Grumman satellites, we would anticipate that such a plan would involve insurance policies listing the 
United States as an additional insured party.  Authority to launch and operate the satellites, as 
specified in this Order, will be granted if the information submitted demonstrates that Northrop 
Grumman’s end-of-life disposal plans are in the public interest.
g. Inter-Satellite Links
103. Northrop Grumman suggests that it may use optical inter-satellite links on its NGSO 
satellites, although it does not propose any specific frequencies.202 Under these circumstances, no 
further action is necessary at this time.203
C. License Conditions 
1. Milestone Schedule
104. To ensure that licensees remain able and committed to implementing their planned 
satellites and do not hold scarce orbit and spectrum resources to the exclusion of other entrants, the 
Commission imposes milestone schedules on each licensed satellite.  If a licensee fails to meet any 
of these milestones, the license becomes null and void.  These milestones are set forth in Section 
25.164 of the Commission’s rules and are slightly different for GSO FSS satellites and NGSO FSS 
satellite constellations.204 Northrop Grumman notes these differences and proposes that the earlier of 
the applicable milestones apply to its hybrid NGSO/GSO system.205
105. Licensees of satellite systems that include both GSO and NGSO components are 
required to construct the GSO portions of their system within the GSO milestones and the NGSO 
portion of their system within the NGSO milestones.206 NGSO licensees must meet five 
milestones:  (1) enter into a binding non-contingent contract to construct the satellite system within 
one year of licensing; (2) complete critical design review of the licensed system within two years of 
licensing; (3) begin construction of the first satellite in the licensed system within two years, six 
months of licensing; (4) launch and operate the first satellite within three years, six months; and (5) 
bring all of the licensed satellites into operation within six years of licensing.207 GSO licensees must 
  
202 See NGSO March 2004 Amendment, Technical Appendix at 2.
203 The Commission’s Table of Frequency Allocations addresses frequencies between 9 KHz and 400 GHz.  47 
C.F.R. § 2.102. Optical frequencies are above 400 GHz.  The ITU Radio Regulations do not include any 
allocations above 275 GHz.  However, Footnote 5.565 of the Radio Regulations Table of Frequency 
Allocations lists a number of potential uses of these frequencies and urges consideration of the uses until such 
time a table of allocations is developed in those bands.
204 47 C.F.R. §§ 25.164(a) and (b).
205 NGSO March 2004 Amendment at 20 and n. 27.
206 Amendment of the Commission’s Space Station Licensing Rules and Policies, First Order on 
Reconsideration and Fifth Report and Order, 19 FCC Rcd 12637, 12655 (2004) (Space Station Licensing 
Reform First Reconsideration Order).
207 47 C.F.R. § 25.164(b).
Federal Communications Commission DA 09-428
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meet four milestones:  (1) enter into a binding non-contingent contract to construct the licensed 
satellite(s) within one year of licensing; (2) complete critical design review within two years of 
licensing; (3) begin construction of the satellite(s) within three years; and (4) launch and operate the 
satellite(s) within five years of licensing.208 In addition, licensees must submit certifications of 
milestone compliance on or before the date for completion of each milestone.209 Northrop Grumman 
has provided no reason to deviate from Commission policy for hybrid GSO/NGSO systems by 
consolidating the GSO and NGSO milestones.  Indeed, doing so could result in confusion as to 
which milestones have been met and which part of the authorization is cancelled in the event 
Northrop Grumman fails to meet a milestone.  Thus, we incorporate separate NGSO and GSO 
milestones in this license.210 Northrop Grumman is, of course, free to proceed with both components 
of its system on parallel tracks if it wishes to do so.
2. License Term
106. The license term for both GSO FSS and NGSO FSS satellites is 15 years.  The term 
for each GSO satellite begins on the date the licensee certifies to the Commission that the satellite 
has been placed in orbit and its operations conform to the conditions in its authorization.211 For 
NGSO FSS satellites, the term commences when the licensee certifies to the Commission that its 
initial satellite has been placed in orbit and is operating in compliance with its authorization.212  
Consequently, the time at which the license term begins to run will likely vary for Northrop 
Grumman’s GSO FSS and NGSO FSS satellites.
3. Reporting Requirements
107. Northrop Grumman must follow the Part 25 rules for reporting requirements for 
FSS systems, including an annual report describing the status of satellite construction and anticipated 
launch date, and the use made of each transponder on its in-orbit satellites.213 Northrop Grumman 
must file this report on June 30 of each year, containing information current as of May 31 of that 
year.  Additionally, within 30 days after preliminary in-orbit testing is completed, Northrop 
Grumman must submit antenna measurements of both co-polarized and cross-polarized performance 
on all antennas employed by space stations both within the primary coverage area, to facilitate 
coordination with other Commission licensees, and outside the primary coverage area, to facilitate 
international frequency coordination with other Administrations.214
4. International Coordination
  
208 47 C.F.R. § 25.164(a).
209 47 C.F.R. §§ 25.164(c), (d), and (e).
210 Because we are not granting Northrop Grumman launch or operating authority for its NGSO constellation 
at this time, we will not include those milestones in this Order.  Rather, we will impose them at the time we 
grant launch and operating authority.  Further we note that, in the V-band Second Report and Order, the 
Commission deferred certain V-band issues to a future rulemaking—including conditions under which FSS 
operations in the 37.5-40.0 GHz band can exceed the clear-air PFD limits to compensate for rain fade.  V-band 
Second Report and Order, 18 FCC Rcd at 25440-41 (para. 29).  Although this authorization only allows 
Northrop Grumman to operate its system consistent with the clear-air PFD limits that have already been 
established, any proposed modification to Northrop Grumman’s system that exceeds these clear-air PFD limits 
would be subject to any future rules that deal with this issue. 
211 47 C.F.R. § 25.121(d)(1).
212 47 C.F.R. § 25.121(d)(2).
213 See 47 C.F.R. §§ 25.210(l), 25.217(b)(1), and 25.217(c)(1).
214 See 47 C.F.R. §§ 25.210(k), 25.217(b)(1), and 25.217(c)(1).
Federal Communications Commission DA 09-428
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108. In general, we will follow the applicable advance publication, coordination, due 
diligence and notification procedures as set forth in the ITU Radio Regulations in coordinating 
Northrop Grumman’s satellites with other affected administrations.  No protection from interference 
caused by radio stations authorized by other administrations is guaranteed unless coordination 
procedures are timely completed or, with respect to individual administrations, by successfully 
completing coordination agreements.  In order to do so, we require that Northrop Grumman provide 
the Commission with the international coordination information specified in our rules.215 This 
information shall include, but is not limited to, providing the Satellite Division a copy of all 
operator-to-operator summary records and/or coordination arrangements obtained from all 
coordination meetings with foreign commercial satellite operators.  This information should be 
submitted with a request for confidential treatment and Administration-to-Administration approval.  
Northrop Grumman will be responsible for all cost recovery fees associated with any ITU filings on 
behalf of its system.
5. Bond 
109. In the First Space Station Licensing Reform Order, the Commission eliminated the 
financial requirements then in place and replaced them with a bond requirement.216 The bond 
requirement is intended to deter speculative space station applications and ensure that satellites are 
timely launched and service is provided to customers.  Entities awarded a license for an NGSO 
satellite constellation must execute a $5 million performance bond, and entities awarded a license for 
a GSO satellite must execute a $3 million performance bond for each satellite, payable to the U.S. 
Treasury, within 30 days of the date the license is granted.217 In the case of hybrid GSO/NGSO 
systems in which the GSO satellites operate in the same frequencies as the NGSO satellites, 
licensees may post a single $5 million bond.218 The bond is payable upon failure to meet any 
implementation milestone in the license, where adequate justification for extending the license is not 
provided.219  In its First Space Station Licensing Reform Order, the Commission stated that it would 
entertain requests for complete or partial waivers of this bond requirement, but limited its discussion 
to waivers "for satellite operators proposing satellites designed to provide public safety services."220
110. Northrop Grumman seeks a partial waiver of this requirement. Northrop Grumman 
asserts we should not require it to post bonds for each GSO satellite because it is only seeking a 
single system license. 221 Rather, Northrop Grumman asserts that we should require it to post only 
the $5 million bond applicable to NGSO systems.  In clarifying that it would require a $5 million 
bond for hybrid GSO/NGSO systems operating in the same frequency band, the Commission noted 
that if the licensee intends to operate the GSO satellites in a different frequency band than the NGSO 
satellite, it must post a $3 million bond for each GSO satellite.  Northrop Grumman has presented no 
justification for waiving this requirement, which is designed to ensure that operators are financially 
able to implement and are committed to implementing all the spectrum they have authority to use.  
Thus, we require Northrop Grumman to post a $3 million bond for each of its four GSO satellites 
and a $5 million bond for its NGSO constellation.  Failure to post any of these bonds within 30 days 
of the grant of this license will render the authorization for that component of Northrop Grumman’s 
  
215 47 C.F.R. § 25.111(b).
216 First Space Station Licensing Reform Order, 18 FCC Rcd at 10824.
217 47 C.F.R. §§ 25.165(a)(1), (2).
218 47 C.F.R. § 25.165(a)(3).
219 First Space Station Licensing Reform Order, 18 FCC Rcd at 10826.
220 First Space Station Licensing Reform Order, 18 FCC Rcd at 10825.
221 See, e.g., NGSO March 2004 Amendment at 13.
Federal Communications Commission DA 09-428
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system null and void.
IV. CONCLUSION AND ORDERING CLAUSES
111. Upon review of Northrop Grumman Space & Mission Systems Corporation’s 
application, as amended, we find that Northrop Grumman Space & Mission Systems Corporation is 
qualified to be a Commission licensee and that, pursuant to Section 309 of the Communications Act 
of 1934, as amended, 47 U.S.C. §309, grant of this application will serve the public interest, 
convenience, and necessity.  Accordingly, IT IS ORDERED, that Application File Nos. SAT-LOA-
19970904-00080, SAT-AMD-19971222-00219, SAT-AMD-20031104-00324, SAT-AMD-
20040312-00030, SAT-AMD-20040719-00136, SAT-AMD-20051118-00227, SAT-AMD-
20070209-00033 (Call Sign S2254); SAT-LOA-19970904-00081, SAT-AMD-20040312-00032, 
SAT-AMD-20040719-00138, SAT-AMD-20051118-00230, SAT-AMD-20070209-00030 (Call Sign 
S2256); SAT-LOA-19970904-00082, SAT-AMD-20040312-00033, SAT-AMD-20040719-00140, 
SAT-AMD-20051118-00232, SAT-AMD-20070209-00031 (Call Sign S2257); SAT-LOA-
19970904-00083, SAT-AMD-20040312-00034, SAT-AMD-20040719-00139, SAT-AMD-
20051118-00231, SAT-AMD-20070209-00032 (Call Sign S2258); and SAT-LOA-19970904-00084, 
SAT-AMD-20040312-00031, SAT-AMD-20040719-00137, SAT-AMD-20051118-00229, SAT-
AMD-20070209-00029 (Call Sign S2255) ARE GRANTED, to the extent indicated herein and are 
subject to the conditions specified in this Order.
112. IT IS FURTHER ORDERED that Application File No. SAT-WAV-19971222-
00220 IS DISMISSED as moot.
113. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation is authorized to construct three NGSO FSS satellites (Call Sign S2254) capable of using 
the 28.6-29.1 GHz (uplink) and 18.8-19.3 GHz (downlink) frequency bands on a primary basis, the 
29.5-30.0 GHz (uplink) frequency band on a secondary basis, and the 37.5-42.0 GHz (downlink) and 
47.2-50.2 GHz (uplink) frequency bands on a co-primary basis. This authorization is subject to the 
technical specifications in Northrop Grumman Space & Mission Systems Corporation’s applications, 
the Commission’s rules, unless waived herein, the terms and conditions in this Order, and any 
technical requirements applicable to part or all of any of these frequency bands that the Commission 
may adopt in any future proceeding.  Northrop Grumman shall complete coordination with all 
Federal FSS systems in the 18.8-19.3 GHz frequency band under 47 C.F.R. § 2.106, Footnote US 
334, prior to the launch of its first NGSO FSS satellite in the 18.8-19.3 GHz (downlink) frequency 
band.
114. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s NGSO FSS operations in the 29.5-30.0 GHz band must not cause harmful interference 
to any Federal or non-Federal systems authorized to operate on a primary basis in the 29.5-30.0 GHz 
frequency band.  Further, Northrop Grumman Space & Mission Systems Corporation must accept 
any interference from primary systems, and must terminate operations immediately upon notification 
of harmful interference.  Further, Northrop Grumman Space & Mission Systems Corporation’s 
NGSO FSS operations in the 29.5-30.0 GHz band are subject to any rules the Commission adopts 
governing NGSO FSS satellite operations in spectrum designated for GSO FSS primary use.
115. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s request for a waiver of the Ka-band Plan IS GRANTED, and Northrop Grumman 
Space & Mission Systems Corporation is authorized to construct three NGSO FSS satellites (Call 
Sign S2254) capable of operating in the 19.7-20.2 GHz (downlink) frequency band on a non-
conforming basis.  Northrop Grumman Space & Mission Systems Corporation’s NGSO FSS 
operations in the 19.7-20.2 GHz band must accept any interference from any non-Federal or Federal 
station authorized to use the 19.7.-20.2 GHz band.  In addition, Northrop Grumman Space & 
Mission Systems Corporation’s NGSO FSS operations in the 19.7-20.2 GHz band shall not cause 
harmful interference to any authorized space station operating in compliance with the Table of 
Allocations and the Ka-band Plan, or authorized Federal FSS GSO or NGSO system.  Northrop 
Federal Communications Commission DA 09-428
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Grumman Space & Mission Systems Corporation shall immediately cease NGSO FSS operations in 
the 19.7-20.2 GHz band upon notification of such harmful interference resulting from its operations.  
Northrop Grumman Space & Mission Systems Corporation shall complete coordination with Federal 
FSS systems in the 19.7-20.2 GHz band  under 47 C.F.R. § 2.106, Footnote US334 prior to the 
launch of its first NGSO FSS satellite in the 19.7-20.2 GHz (downlink) frequency band.
116. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s NGSO FSS satellite operations in the 18.8-19.3 GHz, 19.7-20.2 GHz, 28.6-29.1 GHz, 
and 29.5-30.0 GHz frequency bands are subject to the sharing method with non-Federal systems 
specified in the Establishment of Policies and Service Rules for the Non-Geostationary Satellite 
Orbit, Fixed Satellite Service in the Ka-band, Report and Order, 18 FCC Rcd 14708 (2003).
117. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must submit, no later than 30 days following the date of its Critical Design Review 
milestone for its NGSO satellite system, an application to modify its authorization for construction 
specifying its end-of-life operations for its NGSO FSS satellites.  
118. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation IS AUTHORIZED to construct and launch four GSO FSS satellites, and to operate one 
satellite at each of the 125° W.L. (Call Sign S2255), 73° W.L. (Call Sign S2256), 68.5° E.L. (Call 
Sign S2257), and 116.5º E.L. (Call Sign S2258) orbital locations, using the 47.2-50.2 GHz (uplink) 
and 37.5-42.0 GHz (downlink) frequency bands on a co-primary basis; the 29.25-30.0 GHz (uplink), 
28.35-28.6 GHz (uplink), 19.7-20.2 GHz (downlink), 18.3-18.8 GHz (downlink) frequency bands on 
a primary basis; and the 28.6-29.1 GHz band on a secondary basis; subject to the technical 
specifications in its applications, the Commission’s rules, unless waived herein, the terms and 
conditions in this Order, and any technical requirements applicable to part or all of any of these 
frequency bands that the Commission may adopt in any future proceeding.
119. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s GSO FSS satellites must not cause harmful intereference to any Federal or non-
Federal station authorized to operate on a primary basis in the 28.6-29.1 GHz frequency band and 
must accept any interference from these systems, and must terminate operations immediately upon 
notification of harmful interference.  Further, Northrop Grumman Space & Mission Systems 
Corporation’s operations are subject to any rules the Commission adopts governing GSO FSS 
satellite operations in spectrum designated for NGSO FSS primary use.
120. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s request for a waiver of the Table of Allocations, 47 C.F.R. § 2.106, IS GRANTED, 
and Northrop Grumman Space and Mission Systems Corporation IS AUTHORIZED to operate its 
four GSO FSS satellites in the 18.8-19.3 GHz band on a non-conforming basis.  Northrop Grumman 
Space and Mission Systems Corporation’s GSO FSS operations in the 18.8-19.3 GHz  must accept 
any interference from any Federal or non-Federal station authorized to use the 18.8-19.3 GHz 
frequency band.  In addition, Northrop Grumman Space and Mission Systems Corporation’s GSO 
FSS operations in the 18.8-19.3 GHz band shall not cause harmful interference to any authorized 
space station operating in compliance with the Table of Allocations and the Ka-band Plan, or 
authorized Federal FSS GSO or NGSO system, and shall immediately cease operations upon 
notification of such harmful interference resulting from its operations.  Northrop Grumman Space & 
Mission Systems Corporation’s GSO FSS operations in the 18.8-19.3 GHz band are subject to any 
rules the Commission adopts governing GSO FSS satellite operations in spectrum designated for 
NGSO FSS primary use.
121. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s request for a waiver of Section 25.140(b)(2) of the Commission’s rules, 47 C.F.R. § 
25.140(b)(2), to permit it to operate antennas as small as 0.25 meters at the powers proposed in its 
application IS GRANTED subject to the condition that Northrop Grumman Space & Mission 
Systems Corporation notify its customers, in writing, prior to commencement of service in the 28.6-
Federal Communications Commission DA 09-428
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29.1 GHz and 18.8-19.3 GHz bands on a GSO satellite, that service in these bands is being provided 
on a non-interference basis to other services authorized in these bands, that the service may be 
degraded as the result of interference from other authorized services, and that service will be 
terminated if Northrop Grumman Space & Mission Systems Corporation’s operations cause harmful 
interference to any authorized service.
122. IT IS FURTHER ORDERED that, pursuant to Section 1.3 of the Commission's 
Rules, 47 C.F.R. § 1.3, Northrop Grumman Space & Mission Systems Corporation IS GRANTED a 
waiver of Sections 25.143(b)(2)(ii) and (iii), 25.145(c)(1) and (2), and 25.217(b)(1) of the 
Commission's Rules, 47 C.F.R §§ 25.143(b)(2)(ii) and (iii); 25.145(c)(1) and (2); and 25.217(b)(1), 
for purposes of using the four GSO satellites authorized in this Order to meet the geographic service 
area requirements applicable to its NGSO satellites.
123. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation IS GRANTED a waiver of Sections 25.156(d)(5), 25.157(c)(2), and 25.157(e)(2) of the 
Commission’s rules, 47 C.F.R. §§ 25.156(d)(5), 25.157(c)(2), and 25.157(e)(2), for purposes of 
processing its applications.
124. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s request for a waiver of Section 25.156(d)(3) of the Commission’s rules, 47 C.F.R. § 
25.156(d)(3), IS DISMISSED AS MOOT.
125. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must coordinate its downlink operations in the 17.8-20.2 GHz band with the U.S. 
Federal systems, including Federal operations to earth stations in foreign countries, in accordance 
with Footnote US334 to the Table of Frequency Allocations, 47 C.F.R. § 2.106.  In addition to 
meeting the terms of the coordination agreement, the non-conforming Northrop Grumman GSO 
operations at 18.8-19.3 GHz and NGSO operations at 19.7-20.2 GHz shall not cause harmful 
interference to, nor claim protection from, present and future Federal, non-Federal, International 
GSO and NGSO systems or any non-conforming services previously authorized on a non-harmful 
interference basis and shall immediately cease operations upon notification of such harmful 
interference resulting from its operations.
126. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must abide by the terms specified in FCC News Release , DA 04-234, Report No. SPB-
199 (May 28, 2002) (“FCC and Industry Canada Sign Arrangement on Principles Governing Use of 
37.5-42.5 GHz Band”).
127. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation may not begin V-band downlink operations in the 37.5-38.0 GHz and 40.0-40.5 GHz 
frequency bands until it has successfully coordinated these operations with Federal Systems Space 
Research Service (SRS) facilities, pursuant to Recommendation ITU-R SA 1396, “Protection 
Criteria for the Space Research Service in the 37-38 GHz and 40-40.5 GHz Bands.”
128. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must coordinate with Federal operations in the 37.5-38.6 GHz, 39.5-41.0 GHz, and 
48.2-50.2 GHz frequency bands through the Interdepartmental Radio Advisory Committee and its 
Frequency Assignment Subcommittee.
129. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its NGSO FSS satellites in the 37.5-42.0 GHz band consistent with the 
power flux-density requirements of 47 C.F.R. § 25.208(r), (s), and (t) and Article 21 of the 
International Telecommunication Union Radio Regulations.
130. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its GSO FSS satellites in the 37.5-42.0 GHz band consistent with the 
power flux-density requirements of 47 C.F.R. § 25.208(q), (s), and (u) and Article 21 of the 
Federal Communications Commission DA 09-428
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International Telecommunication Union Radio Regulations.
131. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its GSO and NGSO FSS satellites in the 18.8-19.3 GHz band consistent 
with the power flux-density requirements of 47 C.F.R § 25.208(e) and Article 21 of the International 
Telecommunication Union Radio Regulations.
132. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its 125° W.L., 73° W.L., 68.5° E.L., and 116.5° E.L. GSO FSS satellites in 
the 18.3-18.8 GHz band consistent with the power flux-density requirements of §§ 47 C.F.R. 2.106, 
fn.US255, 47 C.F.R. 25.138(a)(6), 47 C.F.R. 25.208(c), and 47 C.F.R. 25.208(d).
133. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its 125° W.L., 73° W.L., 68.5° E.L., and 116.5°E.L. GSO FSS satellites in 
the 19.7-20.2 GHz, 28.35-28.6 GHz, 29.25-30.0 GHz bands consistent with the power flux-density 
requirements of 47 C.F.R. § 25.138(a)(6).
134. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must operate its NGSO FSS satellites in the 19.7-20.2 GHz and 29.5 -30.0 GHz bands at 
least 15 dB below the equivalent power flux-density requirements of Article 22 of the International 
Telecommunication Union Radio Regulations.
135. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s use of beacons intended for uplink power control in the 29.999-30.0 GHz band shall 
not exceed an equivalent isotropically radiated power of +10 dBW in the direction of adjacent 
satellites on the geostationary-satellite orbit in accordance with Article 5, Footnote 5.538 (WRC-
2007) of the ITU Radio Regulations.
136. IT IS FURTHER ORDERED that, in accordance with International 
Telecommunication Union Resolution 750, Northrop Grumman Space & Mission Systems 
Corporation must operate its earth stations transmitting to GSO and NGSO FSS satellites in the 49.7-
50.2 GHz band so that the level of unwanted emissions from the transmit power density at the input 
of a fixed-satellite service earth station antenna in the band 49.7-50.2 GHz falling into the 50.2-50.4 
GHz EESS (Passive) band shall not exceed -20 dBW/200 MHz for VSAT/user-type terminals and -
10 dBW/200 MHz for gateway/Hub applications under clear sky conditions.  During fading 
conditions, these transmit power density levels can be exceeded by the amount that is needed to 
maintain link availability during fading conditions.  Northrop Grumman Space & Mission Systems 
Corporation’s operations in the 49.7-50.2 GHz band will be subject to any other service rules that the 
Commission adopts for this band.
137. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must coordinate its NGSO FSS satellite system in the 19.7-20.2 GHz band with specific 
earth stations in geostationary-satellite networks in the fixed-satellite service that are located within 
the United States for domestic service or outside the United States for international service, under 
No. 9.7A of Article 9 of the International Telecommunication Union Radio Regulations.
138. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must coordinate its operations in the 48.94-49.04 GHz band with radio astronomy 
stations operating on a co-primary basis in this band.
139. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must coordinate its operations in the 18.3-18.4 GHz band with the meterological 
satellite service, which is authorized to operate GSO satellites on a co-primary basis in this band in 
Regions 1 and 3.
140. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s operations in the 37.5-40.0 GHz (downlink) and 47.2-48.2 GHz (uplink) frequency 
bands are limited to communications with gateway earth stations, in accordance with Footnote 15 of 
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47 C.F.R. §25.202(a)(1).
141. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation, in accordance with 47 C.F.R § 25.210(k), must, within 30 days after preliminary in-
orbit testing is completed, submit antenna measurements of both co-polarized and cross-polarized 
performance on all antennas employed by space stations both within the primary coverage area and 
outside the primary coverage area.
142. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation, in accordance with 47 C.F.R § 25.111(b), must prepare the necessary information for 
submission to the ITU to initiate and complete the advance publication, international coordination, 
due diligence, and notification process of this satellite system, in accordance with the International 
Telecommunication Union Radio Regulations.  This information must include, but is not limited to, 
providing the Satellite Division a copy of all operator-to-operator summary records and/or 
coordination arrangements obtained from all coordination meetings with foreign commercial satellite 
operators.  This information should be submitted with a request for confidential treatment and 
Administration-to-Administration approval.  Northrop Grumman Space & Mission Systems 
Corporation shall be held responsible for all cost recovery fees associated with these ITU filings.  No 
protection from interference caused by radio stations authorized by other administrations is 
guaranteed unless coordination and notification procedures are timely completed or, with respect to 
individual administrations, by successfully completing coordination agreements.  Any radio station 
authorization for which coordination has not been completed may be subject to additional terms and 
conditions as required to effect coordination of the frequency assignments of other administrations.
143. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation must maintain an electronic web site bulletin board to list the satellite ephemeris data, 
for each satellite in the Ka-band (and V-band) NGSO constellation, using the North American 
Aerospace Defense Command (NORAD) two-line orbital element format.  The orbital elements shall 
be updated at least once every three days.
144. IT IS FURTHER ORDERED, that by March 26, 2009, Northrop Grumman Space & 
Mission Systems Corporation must file a certification with the Satellite Division that demonstrates, 
based on computer simulation software developed in accordance with specifications outlined in ITU-
R Recommendation S.1503-1, the maximum uplink EPFD limits calculated for its NGSO satellites 
satisfy the requirements of Article 22 of the International Telecommunication Union Radio 
Regulations.
145. IT IS FURTHER ORDERED that the license term for each GSO FSS and NGSO 
FSS space station is fifteen years, as set forth in 47 C.F.R. § 25.121.
146. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation, in accordance with 47 C.F.R § 25.210(l), must file an annual report describing the 
status of satellite construction and anticipated launch date, and a detailed description of the use made 
of each of its in-orbit satellites.  Northrop Grumman Space & Mission Systems Corporation must file 
this report on June 30 of each year, containing information current as of May 31 of that year.
147. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation’s authorization to construct an NGSO satellite constellation shall become NULL and 
VOID, with no further action on the Commission's part, in the event its space stations are not 
constructed in accordance with the technical parameters and terms and conditions of this 
authorization by the following dates:
Milestone Deadline
Enter Non-contingent Satellite Manufacturing Contract for System February 24, 2010
Complete Critical Design Review of System February 24, 2011
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Begin Physical Construction of First NGSO Satellite August 24, 2011
148. IT IS FURTHER ORDERED that each of Northrop Grumman Space & Mission 
Systems Corporation’s four authorizations to construct, launch, and operate GSO satellites at the 
125º W.L, 73º W.L., 68.5º E.L., and 116.5º E.L. orbital locations shall become NULL and VOID, 
with no further action on the Commission's part, in the event the space station at issue is not 
constructed, launched, and placed into operation in accordance with the technical parameters and 
terms and conditions of this authorization by the following dates:
Milestone Deadline
Enter Non-contingent Satellite Manufacturing Contract February 24, 2010
Complete Critical Design Review February 24, 2011
Begin Physical Construction February 24, 2012
Launch and Operate February 24, 2014
149. IT IS FURTHER ORDERED, that Northrop Grumman Space and Mission Systems 
Corporation’s request for a partial waiver of the Commission’s bond requirement, 47 C.F.R § 
25.165, IS DENIED.  Northrop Grumman Space & Mission Systems Corporation must file bonds in 
the amounts of $5 million for the NGSO system and $3 million for each of the four GSO satellites, 
pursuant to the procedures set forth Section 25.165 of the Commission’s rules, 47 C.F.R. § 25.165, 
within 30 days of the release date of this Order.
150. IT IS FURTHER ORDERED that Northrop Grumman Space & Mission Systems 
Corporation is afforded thirty days from the date of the release of this order and authorization to 
decline this authorization as conditioned.  Failure to respond within that period will constitute formal 
acceptance of the authorization as conditioned.
151. This Order is issued pursuant to Section 0.261 of the Commission's rule on 
delegated authority, 47 C.F.R. § 0.261, and is effective upon release.
FEDERAL COMMUNICATIONS COMMISSION
John V. Giusti
Acting Chief
International Bureau