Coordination Agmt Intelsat

0100-EX-ML-2008 Post Grant Documents

HNS License Sub, LLC

2008-09-26ELS_93583

                                         June 5, 2008




 Federal Communications Commission
 International Burcau
 445 12th Street, SW.
 Washington, D.C. 20554

         Re: Engineering Certification of Intelsat

 To Whom It May Concern:

         This letter certifies that Intelsat is aware that Row 44, Inc. ("Row 44") is secking
 a blanket authorization from the Federal Communications Commission ("FCC") for
 authority to operate, on a non—conforming, non—harmful—interference basis,
 transmit/receive antennas for aeronautical mobile—satellite services ("AMSS") using
 fixed—satellite service ("FSS") frequencies pursuant to ITU RR 5.504A. Row 44 is
 seeking an FCC authorizationto utilize Intelsat‘s Horizons 1 satellites at 127° W.L.

        Intelsat understands that Row 44‘s transmit/receive antenna is an AMSS stecrable
 antenna manufactured by Aerosat Corporation designed to provide bi—directional
 broadband services to aircraft in flight. It supports reception and transmissionin the
 11.7—12.2 GHz /14.0—14.5 GHz band respectively, with independent linear polarized array
 antennas to and from a geostationary satellite in space. The antenna is a 64—element
 phased array that is 7"in height with an antenna face that is 24.375". The antenna
 operates under gimbaled motor control to orient the antenna in azimuth, elevation and
 polarization and achieves a + 0.2 degree pointing accuracy during active tracking of the
; intended satellite. The antenna complies with Section 25.209 of the FCC‘s Rules with
 respect to the off—axis co—polarization gain in the plane of the geostationary satellite orbit
 and to the off—axis cross polarization gain, provided the skew angle (i.e., the angle
 between the antenna azimuth plane and the direction along the GSO at the corresponding
 satellite location) does not exceed 25°. The actual skew angle is constantly monitored by
 the antenna control system and the aircraft—transmitter will be muted in the event that this
 skew angle of 25° is exceeded.

        When communicating with the Horizons 1 satellite, Row 44 will operate its
 antenna within the 14.0—14.5 GHz FSS uplink band and the 11.7—12.2 GHz FSS downlink
 band with a maximum equivalent isotropically radiated power (EIRP) of 40.6 dBW. At
 the maximum power the associated power spectral density at the antenna flangeis —14
 dBW/4kHz and is compliant with FCC—rules.


       Intelsat further accepts that the forward downlink (hub‘ to AES) maximum EIRP
density is 13 dBW/4 kHz, which is routinely used at 2—degree spacing without causing
unacceptable interference to adjacent satellite operators. Row 44 will maintainthe
forward downlink EIRP density and the off—axis EJRP spectral density by tight control of
system operationthat includes:                                                                        *

         1)      maintaining rms pointing error to be < 0.2 degrees, relative to the intended
                 satellite;
        2)       fault detection that terminates transmissions when out of tolerance
                 conditions (including the antenna pointing error) are detected; and
        3)       continuous monitoring/oversight by ground network operations center
                 (NOG).
        Intelsat acknowledges that the use of the above referenced transmit/receive
antenna by Row 44, installed and operated in accordance with the above conditions
should not cause unacceptable interference into adjacent satellites operating in
accordance with FCC‘s two—degree spacing policy, and is consistent with existing
coordination agreements with all adjacent satellite operators. Intelsat itself operates two
satellites with Ku—band capacity within six degrees of Horizons 1 (Galaxy 10R at 123°
W.L. and Galaxy 27 at 129° W.L.). If the FCC authorizes the operations proposed by
Row 44 in its application, Intelsat will include the antenna, as described above, in all
future satellite network coordinations with other adjacent satellite operators. Row 44
shall comply with all such coordination agreements reached by the satellite operators.

       In order to prevent unacceptable interference into adjacent satellites, Intelsat has
been informed, and Row 44 acknowledges, that the antennas will be installed and
operated in accordance with the above conditions and/or any other operational
requirements specified in the FCC license ultimately granted to Row 44. If the use of this




‘ The hub stations being used for this service are licensed to HNS License Sub LLC under Call Signs
E000166 and E940460


HNS is working with Row 44, Inc. to test remote
aeronautical Earth station equipment operating in
conjunction with a Hub antenna (Call Sign E940460 in North
Las Vegas, Nevada) licensed to HNS.



Document Created: 2008-09-24 10:54:55
Document Modified: 2008-09-24 10:54:55

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