Telstar 14 addition

0339-EX-ST-2009 Post Grant Documents

Panasonic Avionics Corporation

2010-03-11ELS_105284

                                                                      Squire, Sanders & Dempsey L.L.P.

                                                                      Suite 500
                                                                      1201 Pennsylvania Avenue, N.W.
                                                                      Washington, DC 20004-2401
                                                                      Office:      +1.202.626.6600
                                                                      Fax:         +1.202.626.6780


                                                                                Direct Dial: +1.202.626.6659
                                                                                             cnalda@ssd.com


March 11, 2010

VIA ELECTRONIC FILING

Anthony Serafini
Experimental Licensing Branch
Office of Engineering and Technology
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re:    Panasonic Avionics Corporation, Call Sign WD9XQT, File No. 0339-EX-ST-2009;
       Addition of Satellite Point of Communication

Dear Mr. Serafini:

        In accordance with instructions from the staff, Panasonic Avionics Corporation (“PAC”)
hereby seeks to include an additional satellite point of communication in the above-referenced
authorization. PAC seeks to communicate with the Telstar 14 satellite at 63º W.L. The attached
affidavit from the satellite operator confirms that PAC’s authorized operating characteristics are
within the coordinated parameters of the satellite, which was previously used for Ku-band
aeronautical mobile-satellite service (“AMSS”) operations of the Connexion by Boeing system.

       Please feel free to contact me with any questions you may have regarding this matter.

                                             Sincerely,

                                             PANASONIC AVIONICS CORPORATION

                                                     /s/ Carlos M. Nalda
                                             ________________________________
                                             Carlos M. Nalda
                                             Squire, Sanders & Dempsey L.L.P.
                                             1201 Pennsylvania Avenue, N.W.
                                             Washington, D.C. 20004

                                             Its Attorneys

Attachment


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          II 18
Robert Condurso                                                         135 Routes 202/206
Director, Government and Regulatory Affairs                             Bedminster, NJ 07921
                                                                        U.SA
                                                                       Tel: +1 (908) 698-4882
                                                                       Fax: +1 (9P8) 719-0226
                                                                        E-mail: rcondurso~telesat.com
February 8, 2010

Federal Communications Commission
International Bureau
445 12th Street, S.W.
Washington, D.C. 20554


To Whom It May Concern:

This letter certifies that Telesat Canada ("Telesat") is aware that Panasonic Avionics Corporation
("PAC") is seeking FCC authorization to access the Telstar 14 satellite at 63° WL,l as an
authorized point of communication, for its eXConnect Ku-band aeronautical mobile-satellite
service ("AMSS") system using transmit/receive antennas that are not strictly compliant with the
FCC's antenna gain requirements.
                                  2 However, as described below, Telesat believes that the
terminals comply with the FCC's two-degree spacing rules by maintaining off-axis EIRP spectral
density levels below those set forth in analogous Ku-band earth stations onboard vessels ("ESV")
and vehicle-mounted earth stations ("VMES") rules.3

Telesat understands that PAC plans to operate two AMSS antenna types: (i) the MELCO antennas
previously operated with the Connexion by Boeing system; and (ii) the Aura LE antenna designed
specifically for the eXConnect system and manufactured by EMS Technologies. We understand
that the MELCO antenna is a mechanically-steered Cassegrain antenna with an elliptical profie
that was previously examined by the FCC and authorized for AMSS operations in experimental
Call Sign WC2XVE (File No. 0002-EX-PL-2004) and commercial blanket license Call Sign
E000723 (File No. SES-MOD-20030512-00639). We understand that the Aura LE antenna is a
mechanically steered, flat-plate AES with two transmit/receive apertures that is similarly designed

1 Telesat, through its subsidiary Telesat Brasil Capacidade de Satelites Ltda., operates the Telstar
14 satellite pursuant to a license issued by BraziL. Telstar 14 has been granted FCC authority to
serve the United States.
2 See 47 CFR §25.209.

3 See 47 CFR §25.222.



                                                                                          Page i of 4


to meet the technical requirements imposed on U.S. and international AMSS operations.4 The
                      the MELCO and Aura LE antennas, as specified by the manufacturers, are
basic characteristics of

also summarized in Table 1.

                                  Table 1. Aura LE and MELCO Antenna Characteristics
            Characteristic                        EMS Aura LE                       MELCO Reflector
      Frequency                            Tx: 14.0 GHz to 14.5 GHz        Tx: 14.0 GHz to 14.4 GHz
                                           Rx: 10.7 GHz to 12.75 GHz       Rx: 11.2 GHz to 12.8 GHz
                                       .
                                           (11.7-12.2 GHz in the U.S.)     (11.7-12.2 GHz in the U.S.)
      Aperture Size                        2 Apertures of 35" X 6" each    25.6" X 7.7"
      EIRP                                 42.5 dBW (l 5 deg Elevation     47.2 dBW
                                           48.0 dBW (l 90 deg Elevation
      G/T                                  11 dB/K (l 5 deg Elevation      8.0 dB/K (l 11.2 to 11.7GHz
                                           14 dB/K (j 90 deg Elevation     9.3 dB/K (j 11.9 to 12.8GHz
      Tracking Rate                        40 deg/sec in Azimuth           40 deg/sec in Azimuth
                                           25 deg/sec in Elevation         25 deg/sec in Elevation
      Az Pointing Accuracy                 0.2 deg I-sigma                 0.25 deg I-sigma

Based on our review of the technical specifications and conversations with PAC, we understand
that both the MELCO and Aura LE antennas are designed to maintain pointing towards the
intended satellite through the full range of maneuvers carried out by commercial aircraft. The
antennas are pointed based on aircraft position and attitude information obtained from the ARINC
429 data bus, which is standard on commercial aircraft. This information is augmented with
higher rated data from an inertial sensor package that is integrated with the antenna and
compensates for Inertial Navigation System ("INS") errors that result from latency and bending of
the airframe between the aircraft INS unit and the antenna. The pointing accuracy of the MELCO
reflector is 0.25 deg I-sigma and the pointing accuracy of the EMS Aura LE antenna will be less
than 0.2 deg I-sigma. Pointing error will be continuously monitored and if it ever exceeds 0.5
degrees, then transmissions will be automatically inhibited within 100 ms.5


The FCC's off              axis    EIRP spectral density limits for analogous ESV and VMES operations are
defined by Sections 25.222(a)(1) and 25.226(a)(1)(i). The effective off-axis EIRP spectral density
generated by a conforming terminal wil be:


            15-25loglo (0 + 0.2)             dBW/4 kHz for       1.5° :S 0 :S JO

           -6                                dBW/4 kHz for       7° .( 0 .( 9.2°
            18-25logio(0 + 0.2)              dBW/4 kHz for       9.2° .( 0 :S 48°
           -24                               dBW/4 kHz for      48° .( 0 :S 85°



4 The Aura LE antenna's two transmit/receive apertures are coherently combined to form a single
beam. At very low elevation angles, only the front aperture is used due to blockage. This allows
the antenna to maintain high performance over a large range of elevation angles between 5 degrees
and 90 degrees while maintaining a low profile for aerodynamic integration with an aircraft.
5 See 47 C.F.R. § 25.222(a)(7) (Ku-band ESVs) and § 25.226(b)(1)(iv)(B)(Ku-band VMESs).



                                                                                                   Page 2 of 4


        -14                         dBW/4 kHz for       850.( 0 :S 1800


where 0 is the angle in degrees from the line connecting the focal point of the antenna to the orbital
location of the target satellite.

We have been advised by PAC that the eX   Connect system wil   limit off-axis EIRP spectral density
to no more than these levels through various means, including: (i) limiting transmit power spectral
density by controlling the transmit power of the terminal and by selecting appropriate carrier
bandwidths; (ii) controlling the off-axis gain of the antenna along the GSO by inhibiting
transmissions when the skew angle exceeds a specified threshold; and (iii) controlling pointing
error and inhibiting transmissions when the pointing offset exceeds a threshold. of 0.5 deg. The
specific transmit power, bandwidth and skew angle thresholds will be select.ed based on the
desired terminal transmission rates, coverage area, and satellite performance.

Based on the foregoing factors and discussions with PAC, we understand that the MELCO antenna
will operate at a maximum input power density at the antenna waveguide flange of -21.6 dBW /4
kHz, employing BPSK modulation; and the Aura LE antenna will operate at a maximum input
power density at the antenna waveguide flange of -15.1 dBW /4 kHz, employing BPSK
modulation. Even in the rare circumstance when transmitting at pointing offsets equivalent to their
design tolerances, we believe that these antenna terminals are compliant with the off-axis EIRP
density level requirements specified in Sections 25.222 and 25.226, or the combined effect of
Sections 25.209 and 25.212(c) of the FCC's rules, at all off-axis angles up to and including 6
degrees off-axis angle. PAC has advised us that it includes antenna pointing offsets in selecting
the maximum power levels defined above to ensure that the operation of these antennas, with the
associated off-axis EIRP density envelope, wil not cause unacceptable interference into adjacent
satellites.

Based on the above advice and understandings, Telesat agrees that the use of the above antennas
wil not cause unacceptable interference into adjacent satelltes in accordance with the FCC's
two-degree spacing policy, and that these antennas will not require more protection from adjacent
satellites compared to an earth station employing an antenna conforming to the FCC antenna
performance standards defined in Section 25.209 of the FCC rules. PAC has represented to
Telesat that the antennas wil be installed in compliance with the technical, operational and
performance requirements of Part 25 of the FCC rules and any requirements set forth in the
licenses granted by the FCC for the above AMSS antenna system. If the use of these antennas
should cause unacceptable interference into other systems, PAC has agreed that it will terminate
transmission immediately upon notice from the affected parties.

Telesat further states that the maximum downlink satellite EIRP density of 13.0 dBW/4KHz, the
operational level of the Ku-band AMSS network operated by PAC, is routinely used by satellte
operators during frequency coordination at two-degree spacing without causing unacceptable
interference to adjacent satellite operators.




                                                                                            Page 3 of 4


Finally, Telesat confirms that the PAC Ku—band AMSS operations described above fall within the
operating parameters previously coordinated with adjacent satellite operators within +/— 6 degrees
of Telstar 14. Since the Telstar 14 satellite commenced commercial operations, Ku—band
operations have been supported that are consistent with these coordination agreements. Telesat
has no current plans to alter the coordinated operating parameters for the Telstar 14 satellite.

Sincerely,

         Z7



   #          t/f           LaaaA ,m\\                        ? M           ‘:,2—-@ l ff?

Robert Condur®o                                        Date      9
for Telesat Canada




Acceptance by Panasonic Avionics Corporation:

PAC testifies that the information provided to Telesat Canada and reflected in this affidavit is true
and accurate to the best of PAC‘s knowledge,



  IOCMLK K";J)W                                                 I— eb —2010
Paul Saraffe ‘                                                Date
Panasonic Avionics Corporation
eXConnect Systems Engineering




                                                                                            Page 4 of 4



Document Created: 2010-03-11 13:31:51
Document Modified: 2010-03-11 13:31:51

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