Response to Request for Additional Information 9May 15, 2009)

0076-EX-RR-2009 Text Documents

HNS License Sub, LLC

2009-05-15ELS_98281

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               LERMAN
               SENTER
              | PLLC



   WASHINGTON, DC                                                               STEPHEN D. BARUCH
                                                                                   202.416.6782
                                                                            SBARUCH@LERMANSENTER.COM




                                            May 15, 2009
BY HAND DELIVERY AND ELECTRONIC POSTING
Marlene H. Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, S.W.
Washington, D.C. 20554

                       Re: HNS License Sub, LLC, File No. 0076—EX—RR—2009, Ref. No. 8313

Dear Ms. Dortch:


        On April 6, 2009, the Commission‘s Office of Engineering and Technology, wrote to HNS
License Sub, LLC ("Hughes") requesting additional information pertaining to antennas and
frequencies used by Hughes under Call Sign WE2XEW — the license to which the above—referenced
renewal application pertains. See Correspondence from D. Young, OET, Correspondence Ref. No.
8313. On May 6, 2009, Hughes requested an extension of time, to May 15, to gather and provide
the information sought in Mr. Young‘s April 6 request.

       Hughes‘s response to the April 6 request is enclosed with this letter.

       Please do not hesitate to let me know if there are any questions or if any additional
information is required in relation to Correspondence Ref. No. 8313 and Hughes‘s renewal
application for Call Sign WE2XEW.

                                              Respectfully s




                                              Counsel for HNS License Sub, LLC

Enclosure
cc (by e—mail): Douglas Young
                Steven Doiron




                          2000 K STREET NW. SUITE 600 | WASHINGTON, DC 20006—1809
                         TEL 202.429.8970 | FAX 202.293.7783 WWW.LERMANSENTER.COM


Response of HNS License Sub, LLC to Request for Additional Information in Ref. No. 8313

The following is the response of HNS License Sub, LLC ("Hughes") to the April 6, 2009 request
from the Commission‘s Office of Engineering and Technology (Ref. No. 8313) for additional
information regarding Hughes‘s operations under Call Sign WE2XEW.

The following specific questions are asked:

   (a) What new antennas are currently in use on the license for Call Sign WE2XEW, and in what
       quantity?

In 2005, Hughes began a test and development program dealing with satellite communication
systems capable of operating while the terminal is in motion. Being an area of potential interest to
its customers, Hughes used its program to investigate how its existing products could best be
adapted for use in a mobility environment. In partnership with General Dynamics, Hughes installed
a gyro—stabilized antenna on a General Motors Corporation ("GMC") Hummer vehicle for use in
system tests and customer demonstrations. The technical characteristics of this terminal formed the
basis for the lead application for this Call Sign WE2XEW (and its predecessor temporary
authorization under Call Sign WC9XET). The original Hummer—based terminal remains in
demonstration service to this day.

Since the original grant by OET of the experimental license, Hughes has undertaken a variety of
tests with different antenna products from various manufacturers in order to assess the performance
of these products when integrated into the Hughes VSAT system. These have all been short term
tests with the equipment being returned to the antenna vendor at the conclusion of the test cycle. In
each case, the characteristics of the antenna in question and nature of operation by Hughes were
such that the transmissions remained within the level of transmissions authorized under the
WEZXEW license. Some of these tests have included terminals in Ka band (pursuant to a 2007
license modification) as well as terminals located on ships and airplanes (pursuant to 2008 and 2009
license modifications). In each case, Hughes obtained all necessary permission from OET prior to
the start of these tests. In each case, the test equipment has been decommissioned upon completion
of the tests.

Most recently, Hughes has conducted tests in collaboration with Row 44, Inc. ("Row 44") regarding
the use of satellite receive equipment in an aeronautical environment. These tests have been for the
most part completed and Row 44 has now transitioned authorization for its pre—deployment testing
to an STA granted to it by the International Bureau in March 2009. For the near term, the AeroSat
HR6400 antenna that Hughes described in detail in its March 12, 2009 submission in connection
with File No. 0013—EX—ML—2009 may continue to be used at static locations in conjunction with
Row 44. At present, there are two of the AeroSat antennas in periodic use under Call Sign
WE2XEW, and it is possible that one or two units of a different model antenna with the same
technical characteristics as the AeroSat antenna could be employed for use in the Row 44 static
testing.

In conclusion, while Hughes has tested a variety of different antennas under its current authorization
(as appropriately modified), during the current license term, only the original General Dynamics
antenna model has been used under the authorization for more than a few months. In conjunction


with the instant application for renewal of its experimental license, Hughes has not added any
antenna models to its authorization that were tested for short periods of time but that are no longer
in use. This includes the AeroSat HR6400 antenna and potential equivalent antennas (as described
in connection with File No. 0013—EX—ML—2009) remain in short—term use for static ground tests, as
this use is expected soon be transitioned to a Row 44 authorization.

   (b) List all frequencies for which the emission 1M60G7D will be used.

The carrier with the emission designator IM60G7D is used in the 14—14.5 GHz transmit band,
subject to the geographical limitations and conditions imposed in the current license for Call Sign
WEZXEW. Although Hughes has no mobility applications operating at this time in the Ka—band
frequencies at 29.5—30 GHz, it is conceivable that 1 M60G7D is an emission code that Hughes could
use in the future in that band.

   (c) Demonstrate how the AeroSat antenna, at an EIRP density level of 13.5 dBW/4 kHz, will
       satisfy the off—axis density levels that the General Dynamics antenna emits in the elevation
       plane.

The antenna being used by Hughes and Row 44 pursuant to the 2009 modification of license under
Call Sign WE2XEW is a product developed and designed by AeroSat. This antenna is a rectangular
micro—horn array which is mechanically steered so as to be kept pointed toward the satellite.

For the case where the terminal is operated from locations on the same longitude as the satellite
with which it communicates, the GSO arc is at that point parallel to the horizon of the aircraft. As a
result, the antenna array has its widest width along the GSO arc, thus providing maximum
protection to adjacent satellites.

However, when the aircraft is at a longitude different than that of the satellite with which it is
communicating and accounting for motion of the aircraft, the GSO arc will have both an azimuth as
well as an elevation component. Were the widest width of the AeroSat antenna to be tied to the
azimuth of the aircraft only, there would be an increase in interference toward the GSO arc as the
longitude away from the satellite increased. This change would be proportional to the increase in
the elevation component of the GSO arc at that location. As a consequence of the reduction in the
array width in the direction of the GSO, there would be an increase in off—axis gain and a resulting
increase in interference to adjacent satellites.

To guard against this effect, the AeroSat antenna was designed so that the array‘s waveguide feed
can rotate in yaw (on the polarization axis) by up to 25 degrees and meet the requirements of
25.209. This rotation of the waveguide feed ensures that the maximum array width is always
parallel to the GSO arc, thus ensuring that the variations in elevation component do not result in an
increase in interference to adjacent satellites. This same system ensures that aircraft movements do
not result in a change in the array size toward the GSO arc.


To ensure that the adjacent satellites are protected from interference levels beyond those authorized
in Section 25.134 of the FCC‘s rules, the antenna system will disable the transmitter if the amount
of array tilt exceeds the 25 degree capability designed into the antenna subsystem.




                                                               ‘Steven Doiron
                                                                Senior Director, Regulatory Affairs
                                                                Hughes Network Systems, LLC
                                                                   and HNS License Sub, LLC
                                                                11717 Exploration Lane,
                                                                Germantown, MD 20876

                                                            Dated: May 15, 2009



Document Created: 2009-05-15 17:29:02
Document Modified: 2009-05-15 17:29:02

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