Attachment Question 37 Exhibit

This document pretains to SAT-LOA-20170301-00028 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017030100028_1190237

Federal Communications Commission Washington, D.C. 20554 November 21, 2017 _ Mr. Bruce A. Olcott Jones Day 51 Louisiana Ave. NW Washington, DC 20001 Re: The Boeing Company, IBFS File No. SAT—LOA—20170301—00028 and SAT—AMD— 20170929—00137 (Call Sign $2993) Dear Mr. Olcott: On March 1, 2017, The Boeing Company (Boeing) filed an application for authority to construct, deploy, and operate a non—geostationary satellite orbit (NGSO) fixed—satellite service (FSS) system using Ka—band and V—band frequencies.‘ On July 25, 2017 Boeing responded to a letter from the Satellite Division seeking clarification of certain aspects of this application." On September 29, 2017, Boeing filed an amendment to its application to update various system parameters." Nonetheless, with regard to Boeing‘s proposed V—band inter—satellite links (ISLs) certain aspects of the proposed system operation remain unclear. To aid in the Commission‘s evaluation of Boeing‘s application, please provide updated and additional information as detailed below.* In its July 25 response letter, Boeing stated in item 7(c) that it is "seeking authority to operate its V—band ISL transmission both within its constellation and also with any GSO satellites that operate using V—band spectrum." Boeing stated further that with respect to its own constellation it proposes to operate its V—band ISL transmissions "between its LLEO and its high—ailtitude satellites, and between its individual LEO satellites"" In item 8(a) however, Boeing stated that it is requesting authority to operate its V—band ISL transmission "from LEO to GSO andfrom LEO to high—altitude NGSO..." without mentioning operations between individual LEO satellites.© We note also that in Table III—3 of the narrative portion of the initial application‘ Boeing provided various parameters for ISLs that we interpret to represent transmissions between its low—Earth orbit (LEO) satellites and both its high—altitude NGSO satellites as 1 SAT—LOA—20170301—00028 (Initial Application). 2 See Letter from Jose P. Albuquerque, Chief, Satellite Division, to Bruce A. Olcott, Jones Day, IBFS File No. IBFS File No. SAT—LOA—20170301—00028 (Call Sign $2993) (April 11, 2017) and response from Bruce A. Olcott, Jones Day, to Jose P. Albuquerque, Chief, Satellite Division, IBFS File No. IBFS File No. SAT—LOA—20170301—00028 (Call Sign $2993) (July 25, 2017) (July 25" Letter). 3 SAT—AMD—20170920—00137 (A4mendment). * 47 CFR § 25.111(a). 5 July 25® letter at p. 6. 6 July 25® letter at p. 7. 7 Initial Application Narrative at p. 23. This section was not updated in the subsequent Amendment.


Document Created: 2016-06-21 13:18:09
Document Modified: 2016-06-21 13:18:09
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