EXHIBIT A

TECHNICAL EXHIBIT

Globalstar Licensee LLC Petition for Declaratory Ruling

 TABLE OF CONTENTS

I. Introduction ...................................................................................................................... 1

II. Space Segment Description ............................................................................................. 1

III. Ground Segment Description.......................................................................................... 8

IV. Compliance with Commission Technical Rules .......................................................... 10

V. Protection of In-Band and Adjacent-Band Services ................................................... 13

ii
 TECHNICAL EXHIBIT

I. Introduction

Globalstar Licensee LLC (together with Globalstar, Inc., “Globalstar”) is petitioning for

U.S. market access for the operation of a 48-satellite next-generation non-geostationary satellite

orbit (“NGSO”) mobile satellite service (“MSS”) system (with up to six in-orbit spares) filed

with the International Telecommunication Union (“ITU”) by the Republic of France under the

name AST-NG-C-3 (the “C-3 System”). Globalstar provides this Technical Exhibit as a

supplemental attachment to its Petition for Declaratory Ruling. While Schedule S of Form 312

discloses the basic technical and operational parameters for the C-3 System following

deployment, this exhibit provides an overview of Globalstar’s C-3 System architecture and

operations as required by Section 25.114(d), Section 25.137(b), Section 25.143(b), and other

relevant sections of the Commission’s Part 25 rules.

II. Space Segment Description

General. Globalstar’s existing non-geostationary satellite orbit (“NGSO”) MSS system

in the Big LEO band utilizes a “bent-pipe” architecture with satellites that receive and transmit

voice and data traffic. Globalstar’s current constellation consists of its remaining first-

generation HIBLEO-4 satellites and 24 French-authorized HIBLEO-X satellites. These

satellites are configured in a Walker constellation in eight orbital planes at 52 degrees

inclination and 1414 km altitude.1 The Commission’s Space Bureau recently authorized

Globalstar to launch and operate 17 replacement HIBLEO-4 satellites, with the launch of the

1
Notification of GUSA Licensee LLC of Repositioning of NGSO Space Stations, SES-
MOD-20170112-00029 (Jan. 12, 2017) (“GUSA Licensee LLC Notification”); Notification of
Globalstar Licensee LLC of Repositioning of NGSO Space Stations, SAT-MOD-20171020-
00141 (Oct. 20, 2017).
first eight of these satellites planned for 2025.2 Once launched, Globalstar will reposition its

space stations to operate in a Walker-32 configuration, with four satellites in each of eight

orbital planes at 52 degrees inclination and 1414 km altitude.

Globalstar began work on the next-generation C-3 System satellites in October 2023.

Like Globalstar’s existing MSS satellites, the 48 C-3 System satellites (plus up to six in-orbit

spares) will be bent-pipe repeaters. The C-3 System satellites have an expected lifespan of at

least 12.5 years and will operate at the same orbital altitude, at the same inclination, and over

the same frequency bands as Globalstar’s previously authorized HIBLEO-4 and HIBLEO-X

satellites.

Orbital parameters. Globalstar will operate the C-3 System simultaneously and in

conjunction with its existing HIBLEO-4 and HIBLEO-X deployments. Following deployment,

the C-3 System satellites will be positioned in a Walker-48 configuration, with four satellites in

each of twelve identical orbital planes equally spaced around the Equator. The C-3 System

orbital parameters account for the HIBLEO-4 and HIBLEO-X deployments by maximizing

separation between satellites and minimizing feeder link contention. The C-3 System satellites

will operate at a 52 degree inclination at a height of 1414 km. (See Table 1 below.) The full

orbital parameters for the C-3 System are provided in Schedule S.

2
Globalstar License LLC Application for Modification of Non-Geostationary Mobile
Satellite Service System Authorization, Order and Authorization, ICFS File No. SAT-MOD-
20230804-00192, DA 24-825 (rel. Aug. 16, 2024) (“Replacement HIBLEO-4 Order”);
Application for Modification of Non-Geostationary Mobile Satellite Service System
Authorization (S2115) to Launch and Operate Replacement Satellites, Globalstar Licensee
LLC, ICFS File No. SAT-MOD-20230804-00192 (filed Aug. 4, 2023).

2
 Table 1: C-3 System Orbital Parameters for Operating Satellites

Attitude Inclination, Planes RAAN Satellites In-Plane Number

degrees Spacing, per Plane Separation, of
degrees degrees Satellites
1414 km 52 12 30 4 90 48

Globalstar’s C-3 System satellites will generally be launched into an initial orbital

altitude of approximately 485 km. Some later-launched C-3 satellites may be launched into a

higher initial orbital altitude – as high as 680 km – in order to expedite deployment to 1414 km.

C-3 satellites will undergo initial “health checks” at their initial orbital altitude that will involve

the testing of all relevant systems. After these initial health checks, the Telemetry, Tracking,

and Command (“TT&C”) links as well as high-speed Payload Control Links in the C band

(“PCLs”) (described further below at 6) will be used for telemetry and commanding and further

health check at any altitude, as necessary.

All but six C-3 System satellites that are launched will be raised in phases from their

insertion orbit to their operational altitude at 1414 km. As indicated above, six C-3 satellites

will serve as in-orbit spares at an orbital altitude of approximately 680 km at a 52 degree

inclination.3 (See Table 2 below.) Each of these C-3 System in-orbit spares will undergo

payload testing involving transmissions in Globalstar’s licensed service link, feeder link, and

TT&C spectrum. Some or all of the C-3 satellites may also be subject to this payload testing at

their insertion orbit or at interim orbits during their elevation to 1414 km.

3
The orbital parameters for Globalstar’s C-3 System in-orbit spares are provided in the
Schedule S fields for orbital planes 13-18.

3
 Table 2: C-3 System Orbital Parameters for In-Orbit Spares

Attitude Inclination, Planes RAAN Satellites In-Plane Number

degrees Spacing, per Plane Separation, of Spare
degrees degrees Satellites
680 km 52 6 60 1 N/A 6

Platform description. Each of Globalstar’s C-3 System satellites will have a mass (wet)

of approximately 850 kg and will have dimensions of approximately 3.7m (length) x 14m

(width) x 1.4m (height) (with deployed solar array). Each of these satellites will have the

following sub-systems:

• Payload: direct radiating user link phased array, channelizer, and feeder link
amplifiers and antennas
• TTC-RF subsystem
• Data-handling subsystem containing the data management subsystem and its
associated software
• Attitude and orbit control subsystem
• Electrical power subsystem (including solar array and battery)
• Thermal control subsystem
• Electric propulsion subsystem

With respect to propulsion, the C-3 System satellites will utilize electric propulsion

(“EP”) provided by two xenon-based Hall-effect thrusters, similar to the electric propulsion to

be used in Globalstar’s recently approved replacement HIBLEO-4 satellites.4

Frequencies and operational parameters. As shown below in Table 3, the C-3 System

satellites will use the same licensed frequencies for MSS service links as Globalstar’s existing

satellites: 1610-1618.725 MHz (Earth-to-space) and 2483.5-2500 MHz (space-to-Earth).5 The

4
See Replacement HIBLEO-4 Order ¶ 15.
5
Iridium is authorized to share spectrum with Globalstar at 1617.775-1618.725 MHz.
Globalstar is authorized to operate its MSS service uplink in the United States only up to
1618.725 MHz, adheres to that limitation globally, and currently does not seek to expand its
operations above that frequency. Globalstar’s C-3 space stations (like its HIBLEO-4 and

4
C-3 System satellites will also use the same licensed C-band spectrum for feeder links and

Telemetry, Tracking, and Command (“TT&C”) as Globalstar’s current satellites: 5091-5250

MHz (Earth-to-space) and 6875-7055 MHz (space-to-Earth). As described below, TT&C for

the C-3 System satellites will be provided over different portions of the C band than the TT&C

for Globalstar’s HIBLEO-4 and HIBLEO-X satellites.

Table 3: HIBLEO-4 MSS Bands

Band Use and Direction

1610-1618.725 MHz MSS Service Uplink
2483.5-2500 MHz MSS Service Downlink
5091-5250 MHz TT&C and Feeder Uplink
6875-7055 MHz TT&C and Feeder Downlink

The C-3 System satellites are capable of dynamic beam shaping, including emulating as

needed Globalstar’s existing satellite system downlink (and uplink) performance. The C-3

System satellites are also capable of higher gain and higher EIRP operations and a more robust

signal strength on the ground.

Specifically, the C-3 System satellites will transmit higher EIRP spot beams within

Globalstar’s licensed MSS downlink spectrum at 2483.5-2496 MHz. These spot beams are

dynamically formed based on user traffic, using digital beamforming technology, and their

particular EIRP will vary depending on different user services and demand. This dynamic

beamforming and beam-hopping design enables efficient and intensive use of the Big LEO

MSS downlink spectrum, directing satellite power and the higher EIRP spot beams to specific

user locations as needed, with these spot beams configured roughly every millisecond to serve

HIBLEO-X satellites), however, will be physically capable of receiving and processing MSS
signals throughout the entire 1610-1626.5 MHz frequency band.

5
end users. Globalstar notes that within the 2496-2500 MHz downlink band segment subject to

the Commission’s power flux density limits in Section 25.208(v) of its rules, the C-3 System

satellites’ dynamic beams will operate at EIRP levels that comply with those limits.

Within the 2483.5-2500 MHz downlink band, the C-3 System satellites’ spot beams

will be transmitted over band segments composed of varying multiples of 200 kHz bandwidth

channels, including segments as wide as one to two megahertz. The specific channelizations

will vary depending on different user services and demand. A dynamic allocation of

bandwidth from the feeder uplink spectrum at 5091-5250 MHz to the service downlink beams

at 2483.5-2500 MHz enables efficient use of that service downlink spectrum.

For the C-3 System service uplinks at 1610-1618.725 MHz, there are a large number

of fixed LHCP and RHCP beams, covering the satellite’s field of view. The small size of

these uplink beams enables higher gain-over-noise temperature for users in those beams.

With respect to channelization, as with the C-3 System service downlink, these uplink beams

will occupy band segments composed of varying multiples of 200 kHz bandwidth channels,

including segments as wide as one to two megahertz. A dynamic allocation of bandwidth

from each of the beams to the feeder link allows efficient use of feeder downlink spectrum at

6875-7055 MHz.

Globalstar’s feeder link and TT&C operations in the C band – including the division of

bandwidth between feeder link and TT&C traffic channels – will also be dynamic in nature.

For C-3 System operations there will be 36 telemetry frequency blocks, each occupying 200

kHz and all using Left Hand Circular Polarization (“LHCP”). The allocation of two telemetry

frequencies to each satellite will be reconfigurable on orbit. There will be up to four high-

speed PCLs for uplink operations (occupying up to 10 MHz) and one PCL for downlink

6
operations (occupying 1.4 megahertz), with all such links on LHCP or Right Hand Circular

Polarization (“RHCP”).6 The location of these PCL bands is reconfigurable on orbit. The

feeder link traffic channels will be in multiples of 200 kHz bandwidth and as indicated above

will be mapped dynamically to 200 kHz channel-based band segments in Globalstar’s service

uplink and downlink bands as needed. As a result, C-band traffic channel usage over the C-3

System will appear more like a set of narrowband carriers than the current set of eight broader

bandwidths over the HIBLEO-4 and HIBLEO-X deployments.

Schedule S of this Petition includes the full operating parameters for the C-3 System

satellites, including frequency plans, polarizations,7 saturation flux density, EIRP, EIRP

density, peak gain, and G/T.8 In addition, as required under the Commission’s rules, the

antenna gain contours and beam patterns for the C-3 System satellites’ transmit and receive

beams (service links, feeder links, and TT&C) are provided in Exhibit C, associated with

Schedule S for this Petition.

Avoidance of self-interference. Globalstar will avoid inter-system interference

between the C-3 System and its existing HIBLEO-4 and HIBLEO-X MSS operations through

precise global management and common network control systems. To prevent self-

interference on Globalstar’s licensed feeder link spectrum in the C band, the C-3 System will

6
PCLs are used for high-data rate command uploads and telemetry downloads to and
from the satellite payload, such as the dynamic beamforming coefficients and related telemetry.
7
Polarization for the receiving and transmitting beams of the C-3 satellites is not
switchable. In Schedule S, however, it is not possible to input a “No” response into the relevant
field for polarization switchability for most of these beams, so Globalstar provided no response
in those fields.
8
In the main narrative of this Petition, Globalstar requests a waiver of the Commission’s
Schedule S requirements to the extent necessary. Given the C-3 System’s dynamic
beamforming and channelization, Globalstar in Schedule S provides representative data for
certain system parameters. See Petition at 23-24.

7
be phased relative to the HIBLEO-4 and HIBLEO-X deployments such that there are more

than two degrees of separation between two satellites as seen from any of the gateway

antennas. This offset alignment will prevent collinearity events between the C-3 System and

the HIBLEO-4 and HIBLEO-X deployments. With respect to Globalstar’s user links at 1610-

1618.725 MHz/2483.5-2500 MHz, Globalstar will utilize dynamic frequency management to

operate orthogonally and avoid assigning the same frequencies to the C-3 System and

HIBLEO-4/HIBLEO-X deployments in overlapping service areas.

III. Ground Segment Description

Gateway earth stations. Globalstar’s existing MSS network currently utilizes a total of

28 gateway earth station facilities in 18 countries that handle the feeder link traffic.9 Each

gateway earth station provides between 700,000 and 1 million square miles of coverage over

the surface of the Earth. In the United States and its territories, Globalstar now operates

gateway earth stations in Clifton, Texas; Naalehu, Hawaii; Reno, Nevada; Sebring, Florida;

Wasilla, Alaska; and Barrio of Las Palmas, Cabo Rojo, Puerto Rico.

In conjunction with deployment of the C-3 System, Globalstar will deploy

approximately 90 additional ground station antennas that are dedicated to communicating with

the C-3 constellation.10 These C-3 ground antennas will be installed at approximately 35

different gateway earth station facilities located in at least 25 countries and territories around

the world. This C-3 deployment will occur at existing Globalstar gateway locations as well as

at approximately twelve new gateway sites. In particular, Globalstar’s C-3 ground segment

9
Globalstar last year terminated services to the three gateways in Russia due to that
nation’s ongoing aggression against Ukraine.
10
Prior to launch of the C-3 System satellites, a small number of C-3 earth station antennas
will likely be initially tested and validated through communications with Globalstar's existing
HIBLEO-4 and HIBLEO-X satellites.

8
will include five existing gateway locations in the United States that will be upgraded to

support this new MSS deployment constellation, as well as new gateway facilities located in

Hawaii and additional locations.

Satellite control/TT&C. Globalstar’s C-3 satellites will be controlled by redundant

satellite operations control centers (“SOCCs”) located in Covington, Louisiana and Toulouse,

France, with an additional backup facility located in Milpitas, California.

Mobile end-user terminals. The C-3 System will communicate with mobile end-user

terminals operating within this system’s coverage footprint. The C-3 System satellites’ ability

to transmit higher and lower EIRP beams will expand Globalstar’s range of MSS products and

services and support next-generation satellite-enabled direct-to-devices features to additional

Apple devices.

Globalstar’s overall MSS space and ground system architecture is shown below in

Figure 1.

9
 Figure 1: Globalstar C-3 Network Diagram

*Includes 0.095 MHz of shared spectrum with Iridium.

IV. Compliance with Commission Technical Rules

Globalstar’s C-3 System satellites will comply with all applicable technical rules for the

Big LEO MSS band, including those relating to MSS coverage, power flux density (with

exceptions for the higher EIRP service downlink beams, as detailed below and in Schedule S),

frequency tolerance, the mean power of emissions, cessation of radio emissions, and orbital

debris mitigation.

10
 MSS coverage. The C-3 System will comply with the Commission’s Big LEO MSS

geographic coverage requirements contained in Section 25.143(b)(2) of its rules.11

Power flux density. The C-3 System is designed to comply with the Commission’s

power flux density (“PFD”) limit in the 2496-2500 MHz band (Section 25.208(v)),12 but will

exceed the ITU coordination threshold levels below 2496 MHz.13 Compliance with PFD limits

and coordinated levels will be managed by dynamically adjusting the beam transmit power for

the beam elevation angle pointing.

The C-3 System PFD at the Earth’s surface in the 6875-7055 MHz band will comply

with the limits specified by the ITU and Section 25.208(n) of the Commission’s rules, with

substantial margins.14 Globalstar will maintain such compliance by sizing the feeder downlink

output power amplifiers and setting the specification of the roll-off for the feeder downlink

antennas to meet the PFD requirements.

Frequency tolerance. The C-3 System will meet the Commission’s frequency tolerance

requirement in Section 25.202(e).15 The carrier frequency of each new satellite transmitter will

be maintained within 0.002 percent of the reference frequency, as required by Section

25.202(e).

Mean power of emissions. The C-3 System will meet the Commission’s limits on the

mean power of emissions in Section 25.202(f).16

11
47 C.F.R. § 25.143(b)(2).
12
47 C.F.R. § 25.208(v).
13
International Telecommunication Union Radio Regulations, Appendix 5 Annex 1, Table
5-2.
14
47 C.F.R. § 25.208(n).
15
47 C.F.R. § 25.202(e).
16
47 C.F.R. § 25.202(f).

11
 Cessation of radio emissions. The C-3 System will meet the Commission’s Section

25.207 requirement that they be capable of ceasing radio emissions by the use of appropriate

devices.17 Specifically, Globalstar will be able to direct its proposed satellites to cease all

emissions by ground command.

Frequency reuse. The C-3 System satellites will meet the full frequency reuse

requirement for its feeder link operations at 5091-5250 MHz and 6875-7055 MHz, in

compliance with Section 25.210(f) of the Commission’s rules.18

Coordination with Federal operations. To the degree necessary, Globalstar will

coordinate C-3 System operations with the National Telecommunications and Information

Administration (“NTIA”) to protect any Federal operations in the Big LEO MSS band from

harmful interference and ensure that Globalstar’s operations in this spectrum are technically

compatible with federal uses.

Orbital debris mitigation and satellite de-orbiting. With respect to orbital debris

mitigation, Globalstar is subject to direct and effective regulatory oversight by the Republic of

France. In addition, Globalstar expects that the C-3 System will ultimately meet all applicable

Commission requirements for orbital debris mitigation contained in Section 25.114(d)(14) of

its rules, including the Commission’s five-year de-orbiting requirement.19 Globalstar provides

all necessary information regarding its compliance with these orbital debris mitigation

requirements in the Orbital Debris Mitigation Exhibit, Exhibit B to this Petition.

17
47 C.F.R. § 25.207.
18
47 C.F.R. § 25.210(f).
19
47 C.F.R. § 25.114(d)(14).

12
V. Protection of In-Band and Adjacent-Band Services

Just like its existing MSS satellites, Globalstar’s C-3 System satellites will avoid

harmful interference to other services that are currently in or adjacent to the 1610-1618.725

MHz and 2483.5-2500 MHz bands, including co-channel Broadband Radio Service (“BRS”)

and Broadcast Auxiliary Service (“BAS”) licensees and adjacent-band radio astronomy.

Globalstar will also continue to take all practical steps to safeguard radio astronomy stations

from harmful interference as required by Section 25.213(a) of the Commission’s rules as well as

optical ground-based astronomy.20

20
47 C.F.R. § 25.213(a).

13
 ENGINEERING CERTIFICATION

I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in Globalstar Licensee LLC’s Petition for Declaratory

Ruling, that I am familiar with Part 25 of the Commission’s rules, that I have either prepared or

reviewed the engineering information submitted in this Petition, and that it is complete and

accurate to the best of my knowledge and belief.

/s/ Wen Doong

Wen Doong
Senior Vice President of
Engineering & Operations
Globalstar, Inc.

Dated: February 14, 2025