PAC Coordination Affidavits Submission

0339-EX-ST-2009 Text Documents

Panasonic Avionics Corporation

2009-12-18ELS_103397

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 December 18, 2009 ELECTRONIC FILING James R. Burtle, Chief Experimental Licensing Branch Office of Engineering and Technology Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Panasonic Avionics Corporation – Coordination Affidavit; Call Sign WD9XQT (ELS File No. 0339-EX-ST-2009) Dear Mr. Burtle: Panasonic Avionics Corporation (“PAC”), by its attorneys, hereby submits coordination affidavits from the satellite operator of the Horizons-1 satellite that reflects adjacent satellite operators’ consent for the proposed operations in the above-referenced application for experimental special temporary authority. PAC filed similar coordination affidavits from the operator of the Galaxy 17 and Galaxy 19 satellites yesterday and plans to file coordination affidavits from operators of other requested satellite points of communication shortly. PAC requests that the above-referenced application be granted as soon as possible and accepts that any near-term grant will be only for communication with the coordinated satellite points of communication. When additional satellite points of communication are coordinated, PAC will submit coordination affidavits and requests that its authority be extended to communicate with such satellites accordingly.

December 18, 2009 SQUIRE, SANDERS & DEMPSEY L.L.P. Page 2 Please feel free to contact the undersigned with any questions. Sincerely, PANASONIC AVIONICS CORPORATION ___/s/ Carlos M. Nalda___________________ Carlos M. Nalda Joshua T. Guyan Squire, Sanders & Dempsey L.L.P. 1201 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Its Attorneys Enclosure

December 16, 2009 L’V @ INTELSAT. Federal Communications Commission International Bureau 445 12th Street, S.W. Washington, D.C. 20554 To Whom It May Concern: This letter certifies that Horizons Satellite LLC ("Horizons") is aware that Panasonic Avionics Corporatxon ("PAC") is seeking FCC authorization to access Horizons 1 at 127° WL,‘ as an authorized point of communication, for its eXConnect Ku—band acronautical mobile—satellite service ("AMSS") system using transmit/receive antennas that are not strictly compliant with the FCC‘s antenna gain requirements." However, as described below, the terminals comply with the FCC‘s two—degree spacing rules by maintaining off—axis EJRP spectral density levels below those set forth in analogous Ku—band earth statlons onboard vessels ("ESV") and vehicle—mounted earthstations ("VMES") rules? Horizons 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. The MELCO antenna is a mechanically—steered Cassegrain antenna with an elliptical profile 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). The Aura LE antenna is a mechanically steered, flat—plate AES with two transmit/receive apertures that is similarly designed to meet the technical requirements imposed on U.S. and international AMSS opentmns The basic ‘ Horizons Satellite LLC owns and operates the Horizons 1 satellite, which is licensed by Ministry of Internal Affairs and Communications ("MIC") of Japan. * See 47 CFR §25.209. * See 47 CFR §25.222. * 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. Intelsat Corporation of4 3400 International Drive NW, Washington DC 20008—3008 USA wanwintelsatcom T+1 202:9444800 F+1Zé9447808

characteristics of the MELCO and Aura LE antenna are 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 % INTELYAT (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 @ 5 deg Elevation 47.2 dBW 48.0 dBW @ 90 deg Elevation G/T 11 dB/K @ 5 deg Elevation 8.0 dB/K @ 11.2 to 11.7GHz 14 dB/K @ 90 deg Elevation 9.3 dB/K @ 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 1—sigma 0.25 deg 1—sigma 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 aireraft. 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 informationis augmented with higher rated data from an inertial sensor package that is integrated with the antenna and compensates for INS errors that result from latency and bending ofthe airframe between the aircraft INS unit and the antenna. The pointing accuracy of the MELCO reflector is 0.25 deg 1—sigma and the pointing accuracy of the EMS Aura LE antenna will be less than 0.2 deg 1—sigma. Pointing error will be continuously monitored and if it ever exc?eds 0.5 degrees, then transmissions will be automatically inhibited within 100 ms. 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 will be: 15—25log10 (® + 0.2) dBWMAkHz for 15°<Oz7° —6 dBWMAkHz for 7°<@9.2° 18—25log10(® + 0.2) dBW/4 kHz for 9.2°<0 <48° —24 dBW/4 kHz for 48° <© <85° —14 dBW/4 kHz for 85°<@ <180° where ® is the angle in degrees from the line connecting the focal point ofthe antenna to the orbital location of the target satellite. 5 See 47 C.F.R. § 25.222(a)(7) (Ku—band ESVs) and § 25.226(b)(1)(iv)(B)(Ku—band VMESs). Intelsat Corporation pase 28 3400 International Drive NW, Washington DC 20008—3006 USA wawwintelsat.com T+1 202—944—6800 F41 251»9%4-;;3‘9‘5 mJ

The eXConnect system will limit off—axis EIRP spectral density to no more than this level through various means, including: (i) limiting transmit power spectral density by controlling the transmit power of the terminal and by selecting appropriate carrier bandwidths; (i) 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 4 INTELSAT when the pointing offset exceeds a threshold of 0.5 deg. ‘The specific transmit power, bandwidth and skew angle thresholds will be selected based on the desired terminal transmission rates, coverage area, and satellite performance. Based on the foregoing factors, 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, 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 §25.209 and §25.212(c) of the Commission‘s Rules, at all off—axis angles up to and including 6 degrees off—axis angle. PAC‘s conservative approach of including antenna pointing offsets in selecting the maximum power levels defined above ensures that the operation of these antennas, with the associated off—axis EIRP density envelope, will not cause unacceptable interference into adjacent satellites. The undersigned further certifies that the maximum downlink satellite EIRP density of 13.0 dBW/4KHz, operational level of the Ku—band AMSS network operated by PAC, is routinely used at 2—degree spacing without causing unacceptable interference to adjacent satellite operators. . Furthermore, in order to prevent unacceptable interference into adjacent satellites, Horizons and PAC acknowledge that the antennas will 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. Horizons and PAC confirm that the use of the above antennas will not cause unacceptable interference into adjacent satellites in accordance with the FCC‘s two—degree spacing policy and accept 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. If the use of this antenna should cause unacceptable interference into other systems, PAC has agreed that it will terminate transmission immediately upon notice from the affected parties. Intesat Corporation e3 0 3400 International Orive NW, Washington DC 20008—3006 USA wnvwwintelsat.com T+1 202—944—6800 F PsEeahi ~*)

Sincerely, XosAb uglWon 16 Droouber 2009 Jc\sé\fklimquerque \ | Date for Horizons Satellite LLC INTELSAT. Acceptance by Panasonic Avionics Corporation: PAC testifies that the information provided to Horizons and reflected in this affidavit is true and accurate to the best of PAC‘s knowledge. 7 * iz yz e 17j aaryZ s ~. ALL 4 [ _AE 7 Paul Saraffe — Date «Panasonic Avionics Corporation eXConnect Systems Engineering Acceptance by EchoStar Satellite Services: EchoStar Satellite Services agrees to the use of the PAC MELCO and Aura LE antennas, provided the power density into the antenna flange is adjusted such that compliance with the uplink off—axis EIRP density limits stated in this letter is assured, with respect to EchoStar satellites and the associated satellite networks that are within +/— 6 degrees orbital spacing from Horizons 1 at 127° WL. David Bair Date © Senior Vice President EchoStar Intelsat Corporation Page 4 of 4 3400 international Orive NW, Washington DC 20008—3006 USA vewwiintelsat.com T +1 202—944—6800 f +1 202.944—7898

December 16, 2009 & inteisat Federal Communitations Commission < International Bureau 445 12th Stzeet, S.W. Washington, D.C. 20554 To Whom It May Concern: This letter certifies that Horizons Satellite LLC ("Horizons") is aware that Panasonic Avionics Corporation ("PAC") is seeking FCC authorization to access Horizons 1 at 127° WL,‘ as an authorized point of communication, for its eXConnect Ku—band aeronautical mobile—satellite service (""AMSS") system hsing transmait/receive antennas that are not strictly compliant with the FCC‘s anterma gain requirements." However, as described below, 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 vehiclé—mounted earth stations ("VMES") rules. Horizons understands that PAC plans to operate two AMSS antenna types: (i) the MELCO anternas previously operated with the Connexion by Bocing system; and (ii) the Aura LE antenna designed specifically for the eXConnect system and manufactured by EMS Technologies. The MELCO anteina is a mechanically—steered Cassegrain anteona with an ellipti¢al profile 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 2000723 (File No. SES—MOD—20030512—00639). The Aura LE antenna is a mechanically steered, flatplate AES with two transmit/receive apertures that is similarly designed to meet the technical requirements imposed on U.S. and international AMSS operations." The basic ‘ Horizons Satellite LLC owns and operates the Horizons 1 satellite, which is licensed by Ministry of Internal Affairs and Communications ("MIC") ofJepan. * See 47 CFR §25.209. * See 47 CFR §25.222. ‘The Aura LE antenna‘s two transmit/receive apertures are coherently combined to form a single beam. At very low clevation angles, only the front aperture is used due to blockage. This allows intiiet Comorzion 2400 Interational Dve NW, Wistingion DC 200082006 USA vewnintalsstcom T1 202—000—5000 54RAEsk

characteristics ofthe MELCO and Aura LE antenna are also sutmmarized in Table L. 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 GHzto 14.4 GHz Rx: 10.7 GHz to 12.75 GHz Rx: 11.2 GHz to 12.8 GHz 1 iNegmnont % INTELSAT (11.7—12.2 GHz in the U.S.) (11.7—12.2GHz in the U.8.) Aperture Size 2 Apertures of35" X 6" each 23.6" X7.7" EIRP 42.5 dBW @ 5 deg Elevation 47.2 dBW 48.0 dBW @ 90 deg Elevation GT 11 dB/K @ 5 deg Elevation $.0 dB/K @11.2 to 11.7GHz 14 dB/K @ 90 degElevation 9.3 dB/K @ 11.9 to 12.8GHz Tracking Rate 40 deg/sec in Azimuth 40 degisec in Azimuth 25 deg/sec in Elevation 25 deg/sec in Elevation Az Pointing Accuracy 0.2 deg 1—sigma 0.25 deg 1—sigma Both the MELCO and Aura LE antennas are designed to maintain pointing towards the intended satellite through the full renge of meneuvers carried out by commercial aireraft. The antermas are pointed based on aircreft position and aititude information obtained from the ARINC 429 data bus, which is standard on commercial atrcraft. This information‘is augmentéd with higher rated data from an inertial sensor package that is integratedwith the antenna and compensates for INS érrors that result from latency and bending ofthe airframe between the atreraft INS unit and the antenna. The pointing accuracy ofthe MELCO reflector is 0.25 deg 1—sigma and the pointing accuracy of the EMS Aura LE antenna will beless than 0.2 deg 1—sigme. Pointing error will be continuously monitored and if it ever excgeds 0.5 degiees, then transmissions will be automatically inhibited within 100 ms: 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(e)(1)(i). The effective offaxis EIRP spectral density generated by a conforming terminal will be: 15—25log10 (@+0.2) dBWAkHz for 15°<®5<"° —6 dBW/MkHz for 7°<059.2° 18—25log10(@ +0.2) dBW/MAkHz for 92°<@548° ~24 dBW/MA kHz for 48°<O<B85° 14 dBWMAkHz for $5°<@<180° the antennato maintain high performance over a large range ofelevation angles between 5 degrees and 90 degress 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). fntesat Corporeten 3400 nteration Drive MA, Washington DC—20008—3008 USA venrvclotasat.com T +1 202—544—5000 PEAdK

where ® is the angle in degrees from the line connecting the focal point ofthe antenna to the orbital location ofthe target satellite. The eXConnect system will limit offaxis EIRP spectral density to no more than this level through various means, including: (i) limiting transmit power spectral density by controlling the transmit power of the terminal and by selecting appropriate carriet bandwidths; (ii) controlling the off—axis gain of the antenna & mnteis Talong 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 selected based on the desired terminal transmmission rates, coverage area, and satellite performance. Based on the foregoing factors, the MELCO antenna will operate at a maximum input power density at the anterna waveguide flange of —21.6 dBW MA kHz, employing BPSK modulation; and the Aure LE anterna will operate ata meximum ioput power density at the antenna waveguide flange of —15.1 dBW /4 kHz, employing BPSK modulation. Even in the rare cireumstance when transmitting at pointing offects equivalent to their design tolerences, 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 §25.209 and §25.212(c) of the Commission‘s Rules, at all off—axis angles up to and including 6 degrees off—axis angle.© PAC‘s conservative approach of including antenna pointing ‘offsets in selecting the maximum power levels definedabove ensures that the operation of ‘these antermas, with the associated off—axis EIRP density envelope, will not cause unacceptable interference into adjacent satellites. The undersigned further cerfifies that the maximum downlink satellite EIRP density of 13.0 dBW/4KHz, operational level of the Kn—band AMSS network operated by PAC, is routinely used at 2—degree spacing without causing unacceptable interference to adjacent satellite operators. Furthermore, in order to prevent tnacceptable interference into adjacent satellites, Horizons and PAC acknowledge that the antennas will be installed in complience with the technical, operational and performance requirements ofPart 25 ofthe FCC Rules and any requirements set forth in the licenses granted by the FCC for the above AMSS antenna system. Horizons and PAC confirm that the use of the sbove antennas will not cause unacceptable interference into adjatent satellites in accordance with the FCC‘s two—degree spacing policy and accept that these antennas will not require morte protection from adjacent satellites compared to an earth station employing an antenna conforming to the FCC antenna performance standards defined in Section 25209 of the FCC rules. If the use of this antenna should cause unacceptable interference into other systems, PAC has agreed that it will terminate trensmission. immediately upon notice from the affected partiss. Intabet Comoration 5 2400 himatonal bive NW; Washington 5C 20008—3008 USA weredntalsatdoms T+1 2025446800 F +4HalKe

Sincerely, "Eose,Albuuwom Jo@buquerque 16 W 20M for Horizons Setellite LLC @ INTELSAT Acceptance by Panasonic Avionics Corporation: PAC testifies that the information provided to Horizons and teflected in this affidavit is tus and accurate to the best ofPAC‘s knowledge. //}/M-//» Daee !L. Pee3 Paul Sa:affe * Dite * Panasonic Avionics Corporafion eXConnect Systems Engineering Accéptance by SESAmericom: ° SES Americom agrées to the use ofthe PAC—MELCO and Aura LE antennas with the above power density into the antenneflange and the uplink EIRP density level as stated in this letter, with respect to SES sateilites and the associated satellite networks that are within +/— 6 degrees orbital spacing from Horizons 1 at 127° WL. Kfm\ktzfin& {f 1210 9 Krish Jonnalagadda 0 ate Manager, Spectrum Development SES Americom Intasst Corporaton P 400 ntemationd Diive M Weshington DC 200082008 USA unwenlntalsatcom T+1 2029444000 F+‘ SACE


Document Created: 2009-12-18 17:06:51
Document Modified: 2009-12-18 17:06:51
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