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REPLY TO COMMENTS submitted by RaySat, Inc.

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2006-08-17

This document pretains to SES-LIC-20060629-01083 for License on a Satellite Earth Station filing.

IBFS_SESLIC2006062901083_523814

SHULMAN maul s— :mms ufs fncs ge ‘s stt se Cts 78 x SX AMk T2 Ak in y L BC LE B# r EC wh. @2 22 m£~£~ o y ow us T4 se on enT orms ECKER,PA. s Aut ies M doltiam SA NowT ie dnc uy E. K . F4 TCO RL" mas kllmk Eouke sSS fentetr HGu" Reabers" Ts ~hew ifea imgcrame Gbn Ese se bhenechstgpecom August 17, 2006 Marlene H. Dortch RECEIVED Secretary Federal Communications Corinission AUG 1 7 2006 clo Natek, Inc. 236 Massachusetts Avenue, N Fedinl Communeaton Comiasion Suite 110 oftesct Seentoy Washington, D.C. 20002 Re: In the Matter offApplication ofRaySat,Inc. for Authority to Operate 4,000 In—Motio® Mobile Satellite Antennas in the 14.0 — 14.5 GHz and 11.7—— 12.2 GHZ Frequency Bands Eile No. SES—LIC—20060629—01083 Dear Ms. Dortch: Enclosed please find arjoriinal and four copies ofthe Reply Comments filed by RaySat,Inc.in the above—refergnced proceeding. Also enclosed please id an additional copy. Please date—stamp this copy and retum it to the coutier. Please direct any questigns conceming this filing to the undersigned at (301) 230— 6569. Respectfully submitted. Pruc A IDNBO/ne Bruce A. Henoch Counsel for RuySat, Ic. Enclosure 1i9e Resite k Redile Mantand 2o ze To: oob asoat + : ioh 210201 Watingon, D: Offc: 200 #2.000 + Gecils Mayland Offe: 101)67%998# TomComer Vinina Offes: P0 tsz00 Emal nfif@sapecom + Incrnce wevstuinanogencom

RECEIVED Before the FEDERALICOMMUNICATIONS COMMISSION Aub 1 T 2006 Washington, D.C. 20564 hS comnisinn In the Matter of se at eentay Application of RaySat, Inc. f@ File No. SES—L1C—20060629—01083 To Operate 4,000 In—Motion obile Satellte Antennas in the 14.0; and 11.7—— 12.2 GHz Freque RaySat, Inc. (‘RaySach , the applicant in the above—referenced proceeding,‘ through its attomey, hereby slbmit its Reply to the comments filed by ViaSat,Inc." RaySat fled its Application tahruthorize the use of ts StealthRay in—motion satelite antenna system. ViaSat‘s Coffments appear to have been filed for the purpose of forcing RaySat to use ViaSat‘s own mdem products in liew of others on the market. ViaSatis known in the industry as gne df I the original developers of spread spectrum modems, which are currently used with §everal other mobile communications systems.. RaySat has no objection tusing spread stfectrum technology, but it also recognizes the value of qualifying its antenna with as Boad a range of systems as possible, rather than restrcting the user‘s choice, as would be ViaSat‘s preference. This would have the added benefit of maximizing the antenna‘s applications o include local, state, and federal emergency ! Application ofRaySat, Inc. for Authority to Operate 4,000 In—Motion Mobile Satellte Antennas in the 14.0—— 14.5 Glf and 11.7— 12.2 GHz Frequency Bands, File No. SES— L1C—20060629—01083 (filed J e 26, 2006) ("Application"). * Comments of ViaSat, Itc., the Matter ofRaySat,Inc. for Authority to Operate 4,000 In—Motion Mobile Satellie Antt mas in the 14.0—— 14.5 GHe and 11.7 — 12.2 GHz Frequency Bands, File No, Sl 1—1C—20060620—01083, filed August 4, 2006 (‘Comments‘).

response units,transportation mpanies, Border Patrol, and others whose needs are beiter served with other netwof ks. The RaySat network 1 be managed using the customary VSAT industry practices of carefully deploying and monitoring all remote sites and coordinating any interference issues with adjacg t satellte operators. In addition, RaySat has shown in its Application that the StealthRay meets the off—axis emission limitsfor either spread spectrum or non—spread carrien Real—world operations ave demonstrated most of ViaSat‘s concemns to be unfounded. As the Commissi is aware, RaySat has been conducting several market studies using the StealthRay s rem featuring numerous users under varying operating conditions since August 2005 urstant to an experimental lcense. These studies have shown that RaySat‘s links are bust under real—world conditions, and no claims of adjacent satellte iterference ie been received. RaySat has done extensive testing during this period, and these st dies have shown that the performance of the StealthRay: is well within the parametrs d scribed in the Application. Thus, there is no need fbr the Commission to give any weight to ViaSat‘s Comments, particularly becausg they contain a significant number of errors and incorrect assumptions and also display & Tundamental misunderstanding of the way the RaySat system operates. As will be d ussed in detail below, the ViSat Comments do not present any issues of significa e to the Commission, and they can and should be ignored. RaySat will address eat of ViaSat‘s contentions in turn:

1 Use of Unspre Signal Does Not Increase Interference Potential ViaSat‘s initial claim i (hat the RaySat system does not adequately protect adjacent satelites from interfe nce die to the use of a "simple unspread modem"" (%e., a modem manufactured by Othei than ViaSa). This claim is incorrect for several reasons. First, the Application does not imit the RaySat system to SCPC carriers only. Indeed, RaySat is in the process of intdgrating the StealthRay antenna with multiple VSAT systems currently on the mark that offer both spread and non—spread spectrum solutions. The VSAT vendors ire aware of the coding and modulation requirements and are developing compatible prof lucts to support those requirements." These VSAT systems provide a central contt 1 system with the full capability to monitor and control the bandwidth, frequency, and [power levels of the StealthRay remotes. Second and more impo antly, ViaSat‘s Comments leaves the misimpression that the RaySat system utilizes a s ple SCPC modem link with no central management. This is not true. As discussed elow, users of the RaySat systems are all served through central hubs, which manage st tem parameters such as bandwidth, power, and modulation. These hubs are al staffed with highly trained personnel, who are knowledgeable about the setti up of power levels as well as the frequency and * Further, the use of S PC cariers does not preclude a lack of a central control. On the contrary, SCPC madern are fully capable of integrating a full Network Management System (°NMS® and numerous vendors offer such a eapability. For example,the SCPC moderh vet kdor Comtech offer a NMS called Vipersat. This system offers automatic control of the andwidth frequency and power levels of each modem in the field. The command contrg and monitoring capabilities of this NMS are comparable with the abilities of most VSAT NMS systems.

bandwidth requirement neces to meet FCC limits. These personnel also have the ability remotely to shut dawn dhy antenna suspected of causing interference. The RaySat hub operatirs will be well—versed in the operational imitations of the StealthRay antenna. Specifically, the RaySat hub operators will enforce the PSD limitations required to meet C@mmission requirements. ‘The hub operators will be able to identify any user operating or modulation schemes that are incompatible with these requirements and will be dble shut down the service by refusing to bring up a carrier. This will be an operational regbirement contained for all hub operators. Thus, even for systems without an NMS, the fmote users will b affirmatively constrained to operations within the limitations establisied by the FCC. In addition, many satellite operators now require that each remote site tested by the operator to verify compliance, or at a minimum a test report be provifed to the operator, prior to any remote being allowed to access the network. Thesé mgisures provide another layer of protection against porential interference. IL. Thereds k of Central Control® ViaSat also argues thatthe lack of "one" specific central control pointleaves the system open for user abuse, sih as the ability of the remote users to control bandwidth modulation and coding.* Thislis not accurate. First,although there is nosingle central control point governing the enfire network of RaySat users, each and every user remote is controlled by a central hub fadilty, as discussed above. In addition, ViaSat‘s stirement that the link is bandwidth—limited only looks at the portion of the link from the rethote to the hub and is therefore incorrect. In fact, in the * Comments at 23.

overall system, the carier frorl the hub to the remote (the forward link) uses more power than bandwidih. This is dte tothe larger size ofthe hub antenna, the small remote antenna size, the use of QPSKbr higher order modulation, and high FEC rates. Additionally, the data rate reqiirements from the hub to the remote are much greater than the data rate from the remote the hub. All of these factors make the overall power utiization for the forward l ater than the bandwidth utilization on the forward link. In fact the power utilization orfthe forward link will make the overall network space segment consumption pover dbminated. ‘Thus,there is no economic benefit fo a remote user to decrease the return link‘s bandwidth or increase is power. Further, the RaySat hu operators have knowledge of the operating limitations of the modem and will enforgeth¢ modulation, FEC, power, and bandwidth limitations imposed upon remote usets, mentioned above, the RaySat hub operators will be able to recognizeuses that are incolfpatible with FCC standards and will shut down the service in such cases by refusif to bring up a carrier ViaSat further claims that the "lack of a central control point.. severely limits the ability of adjacent satelliteisers totrack incidents ofinterference," because, according to ViaSat, the adjacght operator would need to contact "several different control points"®to determife source of interference.® Again, this is not accurate. First, we must note that each ald every adjacent satellite operator has thoroughly examined the RaySat applicatipn and has concluded that the RaySat system will not cause harmful iterference.° fthe satellite operators themselves — who obviously should * Comments at 3. ® See Application, Exhibit 1.

be the most concerned abdut potecting their users from interference — have approved the parameters ofthe system, it shpuld be oflitle practical concern to ViaSat. It must be rememberedithat the RaySat antenna will automatically mute transmission if the pointing erior exceeds 0.5 degrees, thus making adjacent satelite interference exceedingly unlikly." And in the unlikely event that an antenna causes harmfulinterference to a user @f an adjacent satelite, simple procedures can be used to identify the party causing Suchinterference, whether or not an NMS is in use. For example, the affected hserwill likely frst contact ts satellite operator with details aboutthe satellte,the interferie frequency, bandwidth, polarization, and other relevant circumstances. The satellite owher can then contact the operators of the two adjacent satellites, who are able quicklylto check their database to determine whether such a carrier is registered on their sulgllite, thus enabling the source of interference to be quickly identified and cortectef.. Even if there is no NMS, the hub operator can simply shut down the forward cartier (from the hub to the remote) which will automatically mute the remote transmit. In this scgpario there is no advantage between operating with a NMS or operating without one RaySat would also noteViaSat‘s contradictorystatements regarding positional tracking eapabilitis.. ViaSat laims that it is not in favor of a publicly—accessible database containing tracking difa but is stll in favor of requiring RaySat to submit As mentioned above, RaySal has beenoperating the system pursuant to an experimental license since Augtist 2005, and no instances ofinterference have been reported.

information regarding "tracking capabilities, cluding "logging of terminal locations."* As RaySat noted in its Applicition, its system is designed primarily for government and military use as well as in significant commercial enterprise settings such as commuter rail Hines, ‘The commuter trains opgrate over short distances, usually less than 60 miles, on a specified railline, making the tof tracking data unnecessary, and Government and military users are generally opflosed to the use of tracking data for security reasons. Further, the use of Rayat‘s system over the past year under an experimental Hicense has yielded no examplds ofinterference into other systems, and use of similar systems such as Ku—Band Station aboard Vessel (‘ESV") systems, VSAT networks, and Satellite—News@ithering systems over the past several years has demonstrated a history of Virtibllyinterference—free operations vis—t—vis fixed satellte users. In light of these factorsJRaySat views tracking capabilities as unnecessary and, in the case of most users, impractical. uL. THE ACCURACY OF THE RAYSAT ANTENNA IS 0 PREVENT INTERFERENCE INTO ADJACENT The StealthRay usés a gombination of an energy detector, built in gyroscopes and azimuth scanning precisely to fack the satellite. The offset from the satellite peak is determined from both the enerfly detector and the positional information from the gyroscopes. This system warlieven with rotational motion on the antenna, as all motion is taken into account by the gyfpscopes. When the positional error reaches 0.5 degrees, the anterna initiates command to mute the output. * Comments at 4 and n.9;

al motion imparted on the antenna, the azimuth scan is 20.35 degrees. This is contolled by the information from the gyros. When there is rotational movement imparted bn the antenna, the offset angle is detected by the gyros; however, due to mechanical faftors such as drive torque limitations, tracking errors can be introduced. For this anilysip we consider the nominal antenna scanning and the rotational rate of the antenna be independent of each other. The nominal aimuth sganning is driven by a sinusoidal function with a peak amplitude of0.35 degrees,; Thi§ gives a Root Mean Square (RMS) deviation from zero degrees of 0.25 degrees. "The $cond factor is the random error caused by tracking at different speeds. If a worst—calg rotational movement of 60 degrees/second is assumed, this results in a peak error of OB degrees as measured in lab tests. Purther, the high rotational rate occurs infrequerlfly and is assumed to lay on the 3 sigma level; This gives a standard deviation of 0.13 d s. From the above resultsive can calculate the overall standard deviation, which can be obtained by: Sigma = [(0.25)"2 + (OB3)°2]0.5 . degrees =0.28 degrees The specified error limit of 0.Sklegrees is 1.78 sigma, which occurs 7.5% ofthe time while the vehicle is turning.. Afsuming that the vehicle is turning 5% of h time, then the outage, even under these sever conditions, is stllless than 0.4% of the time, much lower than the figures cited by ViaS@

TV VIASATS LINK BUDGETS CALCULATIONS ARE INCORRECT Link budgets are attsljed and show thatall FCC off—axis emissions requirements can be met with SCPC type cafriers while providing an adequate link margin of 1.70B. The suppositions provifled by ViaSat are not accurate.. First, ViaSat assumes a threshold Eb/No of3.1dB; With advanced Forward Eror Correcting Codes (FEC) used by modem manufactures, a tyfllcal modem utilized by RaySat will achieve a threshold Eb/No of 2.00B. This alone iitfproves by 1.1dB the link budget margins provided by ViaSat. In addition, there are @her FEC techniques currently on the market that promise even better Eb/No perfor such as Low Density Parity Check (LDPC) codes. Additionally, the interffrence levels assumed by ViaSat are pessimistic. Also, the narrow bandwidth of the carigts allows them to be located in areas that have minimal levels of interference. In addition, as noted aBive, RaySat has been operating the StealthRay system under an experimental license §ince August 2005, and has been operating satisfactorily during this entire period, thus Showing that ViaSat‘s thcortical assumptions are overly conservative "The table below shows§ sample RaySat link budget, at 128 kbps. This ink budget shows that RaySat‘s anfénna achieves a link margin of 1.74B at this data rate.

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¥. For the reasons discusged herein, the Commission should disregard the Comments filed by ViaSat, and RaySat‘s/hpplication should be granted without condition. Respectfully submitted, RAYSAT, INC. By Ai Bruce A. Henoch Shalman, Rogers, Gandal, Pordy & Ecker P.A. 11921 Rockville Pike Suite 300 Rockville, MD 20852 (301) 230—5569 Its attomey Date: August 17, 2006

CERTIH TION OF PERSON RESPONSIBLE FOR PREP G ENGINEERING INFORMATION SUBME D IN THESE REPLY COMMENTS Ihereby certfy that I am the hinically qualified person responsible for preparation of the engincering information tained in these Reply Comments, that I am familiar with Part 25 of the Commission‘s les (47 CFR Part 25),that I have either prepared or reviewed the enginecring int ation submitted in these Reply Comments, and that it is complete and accurate to the st of my knowledge. | r’; [E> By: Keancth G. Ryan, PE Vice President Skjei Telecom, Inc. kewemo. m weoms Date: August 17, 2006 2.

Certificate of Service "The undersigned here certifies that true and complete copy of the foregoing Reply Comments filed by RayBat, Inc. n file number SES—LIC—20060629—01083 were served on this date by U.8. 1. postage prepaid, on the following: Elizabeth R. Park Stefanie Alfonso—Frank Latham & Watkins LLP 555 Eleventh Street, NW. Suite 1000 Washington, D.C. 20004 Counselfor ViaSat, Inc. Thomas E. Barron Executive Vice President Parsons Transportation Group, Inc. 1133 15° Street, NW. Washington, D.C. 20005—2701 Date: August 17, 2006 33.


Document Created: 2006-08-24 16:08:58
Document Modified: 2006-08-24 16:08:58
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