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

I !l ¡ 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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