Amendment

0168-EX-CN-2016 Text Documents

Row 44, Inc.

2016-11-21ELS_184738

Amendment to Experimental License Application

Row 44, Inc. (“Row 44”) hereby amends its pending experimental licensing application
(File No. 0168-EX-CN-2016) in response to the correspondence from OET staff dated October
20, 2016, and in light of an additional coordination certification letter received from EchoStar
Satellite Operating Corporation (“EchoStar”), the operator of an additional desired satellite point
of communications for the experimental program. The pending application is amended in the
following respects:

(1) Additional justification is provided to support a nationwide area of operation;

(2) The AMC-2 satellite at W.L. is added to the points of communication requested
with the support of an operator coordination certification letter signed by
EchoStar;

(3) Requested operating parameters are added to Form 442 for the hub antennas
located at North Las Vegas, Nevada and Woodbine, Virginia, and additional
technical information not included in Form 442 is also provided;

(4) Additional technical information is provided with respect to the four target
satellites;

(5) Additional operating information concerning the aircraft terminals is provided.

1. Justification for Nationwide Operating Authority

By seeking “nationwide” authority, Row 44 is not requesting the authority to deploy
antennas widely throughout the country. Instead, it is asking permission to use one or, at most,
two antennas at any geographic point within CONUS for the purpose of testing antenna
operating performance and Part 25 Rule compliance under as many real world operating
scenarios as possible. The extensive operational range for these two antennas is necessitated by
the fact that each will be mounted on an aircraft, and the goals of the testing require that they be
subject to a variety of operating conditions in terms of altitude, pitch and skew angle relevant to
the range of satellites necessary to permit use on flight routes throughout CONUS. Only one
antenna is likely to be used in flight at one time, and the use will be transient, not continuous.
The initial and primary aircraft used for experimental testing will be an HU-16B Albatross test
aircraft (US registration N44HQ). If a second aircraft is added later in the testing program, it
would be an early stage installation on a commercial airliner with the intent of assessing
performance on the exact type of aircraft on which in-flight Internet connectivity service will be
offered.

2. Addition of the AMC-2 Satellite to the Experimental License Application

As noted in the foregoing section, one of the purposes of the experimental program is to
assess performance using a range of satellites, allowing full CONUS coverage for in-flight
operations. For this reason, the initial application requests access to space segment on AMC-1 at
129 W.L., SES-1 at 101 W.L. and AMC-9 at 83 W.L. These points of communication
provide a broad arc for in-flight communications encompassing a range of U.S. flight routes.
Row 44 had intended also to include the AMC-2 satellite, operated by EchoStar, located at the
85 W.L. orbital location, but filed the application before the necessary coordination certification
letter was received. As that letter has now been obtained, Row 44 is amending the application to
add this satellite. See Attachment 1, Letter from Pat Amodio, Director, Spectrum Development,
EchoStar. The inclusion of a second satellite with expansive Eastern CONUS coverage will
allow testing of satellite hand-offs in areas where demand for connectivity is high.

3. Operating Parameters for Hub Antennas in Nevada and Virginia

The initial application filed by Row 44 describes two Ground Earth Station locations
(three antennas) that will serve as hubs for the experimental program. One is licensed to Hughes
Network Systems (Call Sign E940460) and located in North Las Vegas, Nevada. The second is
licensed to SES (Call Signs E900448 & E140054) and located at Woodbine, Virginia. In
response to the OET staff request referenced above, Row 44 is amending its Form 442 to provide
full detail concerning the relevant operating parameters of these earth stations. In addition, a
summary of the Ground Station parameters, including some information not included in Form
442, is provided in the chart below. See also Updated Form 442.

N. Las Vegas Woodbine Woodbine
Parameter (E940460) (E900448) (E140054)
57.8 @ 11.95 GHz 59.2 @ 12 GHz 57.3 @ 11.95 GHz
Receive/Transmitter antenna gain (dbi)
59.3 @ 14.25 GHz 60.2 @ 14 GHz 59.0 @ 14.25 GHz

0.22 Degrees (Rx)
Beamwidth of Rx/Tx antenna at the half-power points 0.2 Degrees 0.14 Degrees
0.18 Degrees (Tx)

113.9 - 221.8 154.2 - 255.6 154.2 - 254.9
Receive/Transmitter antenna azimuth Degrees Degrees Degrees

Elevation of Receive/Transmitter antenna AMSL (meters) 591.6 198.7 203.1

Elevation of Receive/Transmitter antenna AGL (meters) 8.5 11.0 8.5

4. Additional Satellite Technical Parameters

Satellite coverage (Narrow Beam (NB) or Earth Coverage (EC)). See Attachment 2,
Satellite Coverage Contours.

Values for Each Satellite
Parameter
AMC-9 AMC-2 SES-1 AMC-1
Peak Receive antenna gain (Vertical Pol) (dbi) 34.6 30.9 33.6 34.1

Peak Receive antenna gain (Horizontal Pol) (dbi) 34.6 33.6 33.9 34.2

Peak Transmit antenna gain (Vertical Pol) (dbi) 34.6 33.0 34.4 33.9

Peak Transmit antenna gain (Horizontal Pol) (dbi) 34.6 33.3 35.4 33.1

5. Additional Remote Aircraft-Mounted Antenna Parameters

Parameter Value
32.2 @ 11.95 GHz
Receive/Transmit antenna gain (dbi)
33.6 @ 14.25 GHz

2.3 @ 11.95 GHz
Beamwidth of Rx/Tx antenna at the half-power points
2.0 @ 14.25 GHz

Maximum height of the aircraft during flight 41,000 feet

Attachment 1
Coordination Certification Letter from Pat Amodio, Director, Spectrum Development, EchoStar

Attachment 2
Satellite Coverage Contours

Document Created: 2016-11-21 10:50:32
Document Modified: 2016-11-21 10:50:32

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC