Attachment Response

Response

REPLY TO COMMENTS submitted by ViaSat, Inc.

Response

2006-08-29

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

IBFS_SESLIC2006062901083_525000

Before the RECE'VED FEDERAL ‘OMMUNICATIONS COMMISSION y 9 g ppp; Washington, DC 20554 FedealConmunicaten Conniston In the matter of ) OffesotSecntay ) Application ofRaySat, Inc. for Ahority to ): File No. SES—LIC—20060620—01083 Operate 4,000 In—Motion Mobile tellite ) Antennasin the 14.0—14.5 GHz ank N9 03 RECEIVED 12.2 GHz Frequency Bands ) ) AUG 3 0 2006 Satelite Diision RE SPONSE OF VIASAT, INC. IntormationalBurceu ViaSat,Inc. ("VieSH") submits the following response to the reply comments of RaySat, Inc. (‘RaySat)! in conneg ron with the above—captioned application for authority to operate vehicle—mounted anteanas i the Ku band.".In its Comments, ViaSat identifies a number of technical deficiencies in RaySat s proposed system, which, if operated as described in the Application, could result in harmfil interference to adjacent satellite networks." RaySat‘s Reply does not adequately address the is hes raised by ViaSat, and casts further doubt on whether RaySat‘sproposed system can opdfate without eausing interference to adjacent satellites. Moreaver, RaySat! suggestion that ViaSat‘s Comments are based on a desire to "force‘" RaySat to use ViaSat‘s sat flite modem products is both baseless and inaccurate." ViaSat supports the development a wide range of satellite antenna and modem technologies, ‘— Reply Comments of RaySat,In . Application ofRaySat, Inc.for Authority to Operate 4,000 In—Motion Mobile Satellie Ant mas in the 14.0—14.5 GHz and 11,7—12.2 GHz Frequency Bands, File No. SES—L1C—2000 (629—01083 (Aug. 17, 2006) ("Reply‘). Application ofRaySat, Inc. for uthority to Operate 4,000 In—Motion Mobile Satellite Antennas in the 14.0—14.5 GHz nd 11.7—12.2 GHz Frequency Bands, File No. SES—LIC— 20060629—01083, Public Notic§ Report No. SES—00834 (rel.July 5, 2006) (the "Application") 5. Comments of ViaSat,Inc. to Agplication, File No. SES—LIC—20060620—01083 (Aug. 4, 2006) ("ViaSat Comments). * Reply at 1.

as demonstrated by it comments it other proceedings.\ ViaSat references spread spectrum technology in its Comments to the pplication only to distinguish RaySat‘s proposal from technical scenarios in which the i sition of antenna pointing accuracy requirements is unnecessary to protect adjacent sat llites from interference.® RaySat incorreetly credits ViaSat as being "known in the industry a$ ne ofthe original developers of spread spectrum modems."" In fact, the concept and implement tion of spread spectrum technology predates World War 11 While it is trie that ViaSat has de foped modem technology for mobile antennas that use spread spectrum modulation techniques; is also truethat the vast majority of ViaSat‘s commercial VSAT business and reventies is c posed ofproducts that use single channel per carrier (‘SCPC") modems, which are mug tike those modems that RaySat proposes to use. ViaSat expressly does not oppose RaySat use of SCPC technology. ViaSat‘s concerns regarding RaySat‘s Application relate to the otentil interference that RaySat‘s particular system, as described in the Application, éoul pose to other Ku band users. 5. Comments of ViaSat, Inc., Ser ce Rules and Procedures to Govern the Use ofAeronautical Mobile Satellite Service Earth ationsin Frequency Bands Allocated to the Fixed Satellte Service, IB Docket No. 0520 7 (filed July 5, 2005) ("ViaSat AMSS Comments) (advocating off—axis EIRP dn y limits in the AMSS context that are technology neutral); Comments of ViaSat, Inc. m dment ofParts 2 and 25 ofthe Commission‘s Rules to Allocate Spectrum in the Ku an Extended Ku Bands to the Vehicle Mounted Earth Station Sutellite Service ("VES") in a hared Primary Basis and to Adopt Licensing and Service Rules for VMES Operations in e Ku and Exiended Ku Bands, RM 11336 at 6 (fled Aug. 21, 2006) ("ViaSat VES Comment ‘) (proposing antenna pointing accuracy requirements that accommodate a wide range of I ind mobile earth station systems and reflect technical differences in such technologie®. ViaSat Comments at 4—5. Reply at 1. Actress Hedy Lamarr is créditet by some sources as one ofthe inventors of spread spectrum communications, See, eg.h /Jen wikipedia.ore/wikiHedy Lamare and httpswwwsss— mas.com/shistors.html (visited August 22, 2006).

+. RAYSAT FAILS TO DFI 1ONSTRATE HOW IT WILL PROTECT ADJACENT SATELLITE NETWORI FROM INTERFERENCE FROM ITS NON— CONFORMING ANTE S RaySat‘s use of no¥conforming antenna technology presents a problem because RaySat has not adequately addresg¢d how it will constrain the potential for interference created by the use ofnon—conforming antdimas.. Because RaySat‘s proposed antenna does not comply with the off—axis EIRP densitylimits set forth in Section 25.209 of the Commission‘s rules, RaySat must demonstrate thatits tem as a whole is designed to operate in a manner that does not cause harmful interference. In its Reply, RaySaf fils to address this deficiency.. RaySat simply indicates that its proposed antenna could beused with a number of VSAT systems using both spread and non— spread spectrum solutions that wof 14 have the capabilityto monitor the bandwidth, frequency and power levels of RaySat‘s remtc antennas." 1t is insufficient merely to indicate that the system is capable of preventing inf ference when used with the appropriate modem, without committing to use such a modem: Likewise, RaySat notion that it could use a modem that can employ a central control point is distinguishable frop in a certification in the Applicationthat the system will operate using a central control poif 1. RaySat reiterates in the Reply that ts system users would be served through central hubs, buf that "there is no single central control point goveming the entire network of RaySat users."" ‘Thus, RaySat still does not indicate how t, as the licensce, intends to manage the diverse hublperations. Instead, RaySatstates that it would rely on hub °/ Reply at3. ® 14 ot3, 4

and satellite operators to verify c plianceof remote operations." IL TRACKING REQUIRE ENTS ON RAYSAT‘S PROPOSED NETWORK ARE NECESSARY TO ISOLATE AND HELP RESOLVE ANY INCIDENTS OF TERFERENCE In its Comments, aSat asks the Commission to require RaySatto demonstrate thatits system has the ability to tr k terminal locations for potential review in the event interference issues arise."" RaySal responds to ViaSat‘s inquiry regarding RaySat‘s ability to track terminal locations and operal ng parameters by stating that it "views tracking capabilities as unnecessary and, in the case of me t users, impractical."" RaySat‘s sweeping assertion that operation of ESVs, VSATs and sat ellite news gather ("SNG") terminals in recent history have been virtually interference—fide is ntruc. Based on ViaSat‘s extensive experience operating Ku band VSAT networks, ViaSat knob s first hand that mobile and transportable antennas in the Ku band can cause, and have caused, eal and harmful interference.". Without the abilityto track the locations and operating paranietert of mobile terminals, Ku band users may have difficulty or may even be unable to resolve int ference from such terminals. For this reason, ViaSat has consistently endorsed a requirema t for tracking terminal locations for all carriersto enforce interference protections."" Consig ent with ts views that there should not be a publicly " tdat4,5. " ViaSat Comments at 4. " Reply at 7. "* The Satellite Users Interference Reduction Group lists a number of interference events, including interference generat by satellite news gathering (*SNG") and VSAT terminals. See hitpiliwwnsuire.orw/.) Adgitionally, ViaSat has observed instances ofinterference from ESV terminals and SNGs. ViaSat VES Comments at $:9; ‘aSat AMSS Comments at 22; ViaSat, Inc. Reply Comments, Service Rules and Procedures Govern the Use ofAeronautical Mobile Satellite Service Earth Stations in Frequency B ds Allocated to the Fixed Satellte Service, 1B Docket No. 05—20 at 19—21 (filed Aug. 3, 2005)

accessible database containing tra ed data,"" ViaSat does nor sugwest that RaySat be required to make public any actual tracking d Wta. 111. RAYSATS LINK BUDe ET CALCULATION is INCoNSISTENT witH its APPLICATION RaySat‘ link budek t calculation is inconsistent with its Application, which states its system will operate using Rate 1/3 FEC and BPSK modulation." The link budgets that RaySat includes in its Reply are b ed on a modem with a higher rate of 5/16 FEC and assume that typical modem used in its s tem will achieve a threshold Eb/No 0f2.0dB."" Based on RaySat‘s assumptions, RaySat‘s l ic budget calculation reflects a lower input power density and a bandwidth that is 6.6% higher thd m is reflected in the Application. Thus, RaySat‘s link budget calculation does not reflectthe emi sion designator for the 128 kbits‘s operation described in its Application. Moreover, RaySat dges not provide a link budget calculation for the 512 kbits‘s emission designator in the Appli fon. In addition, RaySat hsserts in the Reply that there is no economic benefit for a remote user to decrease the retum link‘s bandwidth or increase its power because the overall power utilization for the forward I hi is greater than the bandwidth utilization on the forward link."" While RaySat may be able o balance power and bandwidth based upon the coding rates and modulation selected for the f ard link, and thereby operate within the off—axis power 14. ViaSat notes that the link budg:: calculations ViaSat submitted were reasonable and consistent with the data in Ray t‘s Application. Because RaySat did not provide link budgets with the pertinent valut , ViaSat chose a reasonable Eb/No for rate 1/3 TPC FEC from the set of available commt rcial satellite modems for which ViaSat had data. Reply at 9. RaySat‘s assued threshold rate represents a Rate 5/16 FEC modem that is approximately 0.4dB lower that the performance specifications ofwidely—available commercial Rate 5/16 FEC mot lems. Reply at 5.

density limits, RaySat does nd thatits proposed system is capabld ofoperating in this manner. Iv. conCLUsION For the reason‘ d ibed herein and in ViaSat‘s Comments, the Commission should require RaySat to cure the ical deficiencies in Applications and to resolve the potential interference wnech b the Commission grants RaySat‘s requested authority. Respectfully submitted. %lh’i Park Stefanie Alfonso—Frank LATHAM & WATKINS LLP 555 Eleventh Street, N.W. Suite 1000 Washington, D.C. 20004 Telephone: (202) 637—2200 Counselfor ViaSat, Inc. Filed: August 29, 2006

ENGH EIRING INFORMATION CERTIFICATION I hereby cert t I am the technically qualified person responsible for reviewing the enincering i ation contined in the foregoing submission, that I am familian with Part 25 ofthe Commi rules, that Ihave either prepared or reviewed the engincering information submitted in t ing, and that it is complete and accurate to the best omy knowledgeand belief Daryl T. Hunter,PE. ViaSat, Inc. 6155 El Camino Real CarlsbadCA 92000—1609 Dated: August 29, 2006

RTIFICATE OF SERVICE 1, Stefanie Alfons@fFrank, hereby certify that on this 29° day of August, 2006, served a true copy of the foregoifie Comments of ViaSat,Inc. by first class mail, postage pre— paid upon the following: Bruce A. Henoch Shulman Rogers Gandal Pordy & Ecker 11921 Rockville Pike Suite 300 Rocksille, MD 20854 Pm tror Stefahie Alfonso—Frank


Document Created: 2006-08-30 15:08:05
Document Modified: 2006-08-30 15:08:05
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