Attachment Exhibit A SAT-LOI-20170307-00036

Attachment Exhibit A

This document pretains to SAT-LOI-20170307-00036 for Letter of Intent on a Satellite Space Stations filing.

IBFS_SATLOI2017030700036_1199833

EXHIBIT A

PETITION FOR DECLARATORY RULING

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of )
)
ViaSat, Inc. )
) File No. _________________
Petition for Declaratory Ruling to )
Access the U.S. Market Using a Non-U.S. )
Licensed 17/24 GHz Satellite at 115.0º W.L. )
)
)

PETITION FOR DECLARATORY RULING

Christopher Murphy John P. Janka
Associate General Counsel, Regulatory Elizabeth R. Park
Affairs Jarrett S. Taubman
Daryl T. Hunter LATHAM & WATKINS LLP
Senior Director, Regulatory Affairs 555 Eleventh Street, NW, Suite 100
Christopher Hofer Washington, DC 20004
Director, Regulatory Affairs
VIASAT, INC. Counsel to ViaSat, Inc.
6155 El Camino Real
Carlsbad, CA 92009

TABLE OF CONTENTS

I. GRANT OF VIASAT’S PETITION WILL SERVE THE PUBLIC INTEREST ...............2

A. Services to be Supported ..........................................................................................2

II. DISCO II SHOWING – SECTION 25.137(A) ....................................................................3

A. Effect on Competition in the United States .............................................................4
B. Spectrum Availability ..............................................................................................5
C. National Security, Law Enforcement, and Public Safety Matters ...........................6

III. LEGAL AND TECHNICAL INFORMATION – SECTION 25.137(b).............................6

A. Legal Qualifications .................................................................................................6
B. Technical Qualifications ..........................................................................................6
C. Orbital Debris Mitigation.........................................................................................6

IV. ADDITIONAL REQUIREMENTS – SECTION 25.137(D) ..............................................8

A. Milestones and Bond Requirement ..........................................................................8
B. Reporting Requirements ..........................................................................................8
C. Ownership Information ............................................................................................8

V. WAIVER PURSUANT TO SECTION 304 OF THE COMMUNICATIONS ACT ........10

VI. CONCLUSION ..................................................................................................................10

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of )
)
ViaSat, Inc. )
) File No. _________________
Petition for Declaratory Ruling to )
Access the U.S. Market Using a Non-U.S. )
Licensed 17/24 GHz Satellite at 115.0º W.L. )
)
)
)

PETITION FOR DECLARATORY RULING

ViaSat, Inc. (“ViaSat”) files this Petition for Declaratory Ruling (“Petition”)

seeking to serve the United States with a satellite operating under authority of The Netherlands at

115.0° W.L. (the “VIASAT-RDBS1” satellite), and operating in the 17/24 GHz Broadcasting-

Satellite Service (“17/24 GHz Service”). 1 Specifically, ViaSat seeks to provide a new generation

of broadband services to CONUS, Hawaii and Alaska. This Petition includes the information

required by 47 C.F.R. § 25.137 for applicants seeking U.S. market access from non-U.S.-

licensed spacecraft. 2 Technical information relating to the spacecraft is provided on Schedule S

1
The Establishment of Policies and Service Rules for the Broadcasting-Satellite Service at
the 17.7-17.7 GHz Frequency Band and at the 17.7-17.8 GHz Frequency Band
Internationally, and at the 24.75-25.25 GHz Frequency Band for Fixed Satellite Services
Providing Feeder Links to the Broadcasting-Satellite Service and for the Satellite
Services Operating Bi-directionally in the 17.3-17.8 GHz Frequency Band, Report and
Order and Further Notice of Proposed Rulemaking, 22 FCC Rcd 8842 (2007) (“17/24
GHz Report and Order”).
2
See 47 C.F.R. § 25.137. Consistent with the Commission’s 2015 Part 25 Reform Order,
this request is styled as a Petition for Declaratory ruling. See Comprehensive Review of
Licensing and Operating Rules for Satellite Services, Second Report and Order, 30 FCC
Rcd 14713, at ¶ 250 (2015) (specifying that “all requests for market access by the space
station operator must be submitted through a petition for declaratory ruling”) (“2015 Part

and in narrative form in the associated Attachment A, Technical Information to Supplement

Schedule S (the “Technical Annex”).

I. GRANT OF VIASAT’S PETITION WILL SERVE THE PUBLIC INTEREST

ViaSat has previously demonstrated its qualifications as a Commission licensee of

spacecraft and earth station networks. ViaSat has a long history and extensive expertise in

providing and developing satellite communications technologies for both commercial and

military uses, as well as improving the performance and bandwidth efficiency of satellite

networks.

Granting this Petition will serve the public interest in several important respects,

including by facilitating the provision of innovative satellite-based broadband services to U.S.

consumers. ViaSat currently provides satellite-based broadband services using an existing fleet

of satellites, including WildBlue-1 at the nominal 111º W.L. orbital location and ViaSat-1 at the

nominal 115º W.L. orbital location. Those satellites serve approximately 700,000 residences and

small businesses, and what soon will be about 2,000 aircraft, including United Airlines,

American Airlines, JetBlue, Virgin American, and the United States government’s senior

executive service fleet. ViaSat’s existing service provides a competitive alternative to terrestrial

broadband offerings and makes it possible to enjoy high-speed broadband connections on board

aircraft.

A. Services to be Supported

ViaSat seeks authority to provide the “new generation of broadband services” to

U.S. consumers that the Commission contemplated when it established the 17/24 GHz Service in

25 Reform Order”). In its response to Question 17.b of the accompanying FCC Form
312, ViaSat has selected “Letter of Intent to Use Non-U.S. Licensed Satellite to Provide
Service in the United States” because the FCC Form 312 has not yet been updated to
reflect the direction provided in the 2015 Part 25 Reform Order.
2

2007. 3 These advanced broadband services will complement the services that ViaSat currently

provides from the same nominal orbital location. Services will be provided on subscription or

non-common carrier basis. ViaSat does not intend to provide point-to-multipoint distribution of

video programming to consumers in the United States, whether on a subscription or a public

basis (i.e., “DBS-like services”). 4

ViaSat has demonstrated its commitment to developing technologies that make

efficient use of spectrum, responding to customers’ needs for high-quality broadband service

offerings. Grant of this Petition will play a vital role in providing innovative broadband services

by enabling the use of currently-fallow spectrum at 115º W.L.

II. DISCO II SHOWING – SECTION 25.137(A)

On behalf of ViaSat’s wholly-owned subsidiary, ViaSat Netherlands B.V., the

Radiocommunications Agency of The Netherlands has submitted an ITU coordination request

for a 17/24 GHz satellite at 115º W.L. 5 Because this spacecraft will operate under the authority

of The Netherlands, and will provide services covered by U.S. commitments under the WTO

3
17/24 GHz Report and Order at ¶¶ 1, 189.
4
17/24 GHz Report and Order at ¶¶ 38, 40 & n.115. Because ViaSat is not seeking to
provide DBS-like services, it would not be subject to the 17/24 GHz service rules
applicable to providers of video programming. See, e.g., 47 C.F.R. § 25.225 (geographic
service requirements for space stations used to provide video programming directly to
consumers); id. at § 25.601 (equal employment opportunities requirements in Part 76 of
the Commission’s rules applicable to satellite operators providing video programming
directly to the public on a subscription basis); id. at § 25.701 (requirements regarding
channel set asides, political broadcasting, children’s programming, and public file
requirements applicable to satellite operators distributing or offering video programming
directly to consumers or video programming distributors). Although the geographic
service requirements in Section 25.225 are not applicable to ViaSat’s request, due to
limitations of the Schedule S, ViaSat answered in the affirmative the question regarding
whether the applicable service area coverage requirements have been met.
5
See 47 C.F.R. § 25.137(c)(3).
3

technological innovation. The Commission consistently has relied on these same public interest

benefits in granting similar requests. 10

B. Spectrum Availability

This Petition proposes market access using 17.3-17.7 GHz and 24.75-25.25 GHz

frequencies at 115.0º W.L.— a location designated for satellites in the 17/24 GHz Service. 11 The

VIASAT-RDBS1 satellite would also be capable of operating at 17.7-17.8 GHz for earth station

receive operations outside of the United States, consistent with the Commission’s designation of

this band segment for international services. ViaSat does not seek market access for 17.7-17.8

GHz.

ViaSat’s request for market access using 17.3-17.7 GHz and 24.75-25.25 GHz

frequencies at 115.0º W.L. does not conflict with any existing Commission authorization for a

satellite network in these bands. 12 As demonstrated in the Technical Annex, operation of the

satellite is consistent with the Commission’s policies articulated in the 17/24 GHz Report and

Order and the Space Station Licensing Reform Order regarding processing of applications for

GSO-like spacecraft. 13 As detailed in the following sections, this request also is consistent with

Commission spectrum policies.

10
See, e.g., Digital Broadband Applications Corp., 18 FCC Rcd 9455 (2003); Pegasus
Development Corp., 19 FCC Rcd 6080 (2004); DIRECTV Enterprises, LLC, Request for
Special Temporary Authority for the DIRECTV 5 Satellite, 19 FCC Rcd 15529 (2004).
11
17/24 GHz Report and Order at ¶¶ 70, 73, Appendix F.
12
See Public Notice, Policy Branch Information Actions Taken, Rept. No. SAT-01220, DA
No. 17-218, at 2 (rel. Mar. 8, 2017).
13
See 17/24 GHz Report and Order, at ¶¶ 8, 73; Amendment of the Commission’s Space
Station Licensing Rules and Policies, 18 FCC Rcd 10760, at ¶ 113 (2003).
5

C. National Security, Law Enforcement, and Public Safety Matters

Grant of this Petition is consistent with U.S. national security, law enforcement,

and public safety considerations. The satellite’s authorization from The Netherlands will be held

by ViaSat Netherlands B.V., a wholly owned subsidiary of ViaSat. ViaSat has a long history of

providing satellite communication service to U.S. government and military users.

III. LEGAL AND TECHNICAL INFORMATION – SECTION 25.137(B)

A. Legal Qualifications

ViaSat’s legal qualifications are set forth in this Petition and in the attached Form

312. Specifically, the Petition and attached Form 312 demonstrate ViaSat’s satisfaction of the

applicable requirements for space station applicants set forth in Section 25.114 of the

Commission’s rules. 14 As noted above, ViaSat holds several Commission licenses, and its legal

qualifications are a matter of record before the Commission.

B. Technical Qualifications

The attached Form 312, Schedule S, and Technical Annex (including an orbital

debris mitigation showing) include the required Part 25 technical information. As discussed in

further detail in the Technical Annex, the station-keeping volume of the satellite does not overlap

with other satellites located at the same nominal location. No ground spare is currently planned.

C. Orbital Debris Mitigation

Section 25.137 of the Commission’s rules requires market access applicants to provide an

orbital debris mitigation showing. 15 In the case of applications seeking U.S. market access via

non-U.S.-licensed space stations, the Commission has concluded that this requirement can be

satisfied by showing that the satellite system’s debris mitigation plans are subject to direct and

14
See 47 C.F.R. § 25.114.
15
See id. §§ 25.114(d)(14), 25.137(b).
6

effective regulatory oversight by the satellite system’s national licensing authority. 16 The

Commission has determined that this requirement may be satisfied by referencing an English

language version of the debris mitigation rules or regulations of the national licensing authority

and indicating the current status of the national licensing authority’s review of its debris

mitigation plans. 17

The VIASAT-RDBS1 satellite will be operated under the authority of The Netherlands,

and will be subject to the Netherlands’ Space Activities Act, 18 which provides that a license

application will be refused where it does not sufficiently ensure safety, protect the environment

in outer space, and satisfy related international obligations. 19 Accordingly, as part of the

licensing process, ViaSat will submit to The Netherlands information similar to that set forth in

Section A.10 of the attached Technical Annex, which describes ViaSat’s plan for safe flight as

well as ViaSat’s strategy for mitigating orbital debris. ViaSat expects that The Netherlands,

consistent with its past practice, will evaluate this information with reference to: (i) the Space

16
Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 ¶¶ 94, 95
(2004) (“Orbital Debris Second Report and Order”).
17
Id. at ¶ 95; Globalstar Licensee LLC, GUSA Licensee LLC, GCL Licensee LLC, Order,
DA 11-520 ¶¶ 30-32 (rel. Mar. 18, 2011) (concluding that French Space Operations law
and technical regulations provide for direct and effective regulation of debris mitigation
measures by France, resulting in a finding that Globalstar provided adequate orbital
debris mitigation showing); O3b Limited, IBFS File No. SES-LIC-20100723-00952, Call
Sign E100088, Condition 90045 (granted Sept. 25, 2012) (determining that O3b’s request
for a waiver of Section 25.283(c) for unvented pressure vessels was unnecessary, finding
that O3b is subject to direct and effective regulation by the United Kingdom concerning
orbital debris mitigation); see also ViaSat, Inc., IBFS File No. SAT-MOD-20141105-
00121, Condition 4 (granted Apr. 15, 2015).
18
See United Nations Office for Outer Space Affairs, Selected Examples of National Laws
Governing Space Activities: Netherlands (translation of Netherlands Space Activities Act
of June 13, 2006), available at
http://www.unoosa.org/oosa/en/ourwork/spacelaw/nationalspacelaw/netherlands/space_a
ctivities_actE.html.
19
Id. § 6.
7

Debris Mitigation Guidelines of the United Nations Committee on the Peaceful Uses of Outer

Space; (ii) the Space Debris Mitigation Guidelines of the Inter-Agency Space Debris

Coordination Committee; (iii) ITU Recommendation ITU-R S.1003; (iv) the European Code of

Conduct for Space Debris Mitigation; and (v) applicable ISO Standards. ViaSat submits that the

requirements of Sections 25.114(d)(14) and 25.283(c) are therefore satisfied. Should the

Commission nevertheless choose to conduct an independent review of ViaSat’s safe flight and

orbital debris mitigation plans, pertinent information is set forth in Section A.10 of the attached

Technical Annex.

IV. ADDITIONAL REQUIREMENTS – SECTION 25.137(D)

A. Milestones and Bond Requirement

ViaSat plans to implement the spacecraft in compliance with the Commission’s

current milestone and surety bond requirements. 20

B. Reporting Requirements

ViaSat will comply with all applicable reporting requirements for the spacecraft

once this Petition is granted.

C. Ownership Information

ViaSat is a Delaware corporation and a publicly traded company headquartered at 6155

El Camino Real, Carlsbad, California 92009. As a publicly traded company, the stock of ViaSat

is widely held. Based on publicly available SEC filings, the following entity and its affiliates

beneficially owned 10 percent or more of ViaSat’s voting stock as of January 27, 2017:

20
See Comprehensive Review of Licensing and Operating Rules for Satellite Services, IB
Docket No. 12-267, Second Report and Order, FCC 15-167 (rel. Dec. 17, 2015).
8

Beneficial Owner Citizenship Voting Percentage
The Baupost Group, L.L.C. Massachusetts 22.85%
10 St. James Avenue
Suite 1700
Boston, MA 02116

No other stockholders are known by ViaSat to hold 10 percent or more of ViaSat’s voting

stock.

The following are the officers and directors of ViaSat, all of whom can be reached c/o

ViaSat, Inc., 6155 El Camino Real, Carlsbad, CA 92009.

Directors

Mark D. Dankberg, Chairman, CEO
Richard A. Baldridge
Frank J. Biondi Jr.
Dr. Robert W. Johnson
B. Allen Lay
Dr. Jeffrey M. Nash
John P. Stenbit
Harvey P. White

Officers/Senior Management

Mark D. Dankberg, Chairman, CEO
Richard A. Baldridge, President, COO
Melinda Del Toro, Senior VP, People & Culture
Bruce Dirks, Senior VP, Treasury & Corporate Development
Shawn Duffy, Senior VP, CFO, CAO
Kevin Harkenrider, Senior VP – Commercial Networks
Keven K. Lippert, Executive VP, General Counsel, Secretary
Mark J. Miller, Executive VP, Chief Technical Officer
Ken Peterman, Senior VP – Government Systems
Douglas Abts, VP Strategy Development, Satellite Services
Robert Blair, VP, Deputy General Counsel

9

V. WAIVER PURSUANT TO SECTION 304 OF THE COMMUNICATIONS ACT

In accordance with Section 304 of the Communications Act of 1934, as amended,

ViaSat hereby waives any claim to the use of any particular frequency or of the electromagnetic

spectrum as against the regulatory power of the United States because of the previous use of the

same, whether by license or otherwise.

VI. CONCLUSION

For the foregoing reasons, granting ViaSat’s Petition seeking to access the United

States using a satellite in the 17/24 GHz Service under the authority of The Netherlands will

serve the public interest, convenience, and necessity. ViaSat respectfully requests that the

Commission promptly grant this Petition.

Respectfully submitted,

/s/
Christopher Murphy John P. Janka
Associate General Counsel, Regulatory Elizabeth R. Park
Affairs Jarrett S. Taubman
Daryl T. Hunter LATHAM & WATKINS LLP
Senior Director, Regulatory Affairs 555 Eleventh Street, NW, Suite 100
Christopher Hofer Washington, DC 20004
Director, Regulatory Affairs
VIASAT, INC. Counsel to ViaSat, Inc.
6155 El Camino Real
Carlsbad, CA 92009

10

ATTACHMENT A
Technical Information to Supplement Schedule S

A.1 SCOPE AND PURPOSE

The purpose of this Attachment is to provide the Commission with the technical characteristics of
the VIASAT-RDBS1 satellite. This attachment contains the information required by 47 C.F.R.
§25.114 and other sections of the FCC’s Part 25 rules that cannot be entered into the Schedule S
submission.

A.2 GENERAL DESCRIPTION

The VIASAT-RDBS1 satellite will operate at the 115.0° W.L. orbital location and will provide
17/24 GHz BSS services primarily to CONUS, Alaska and Hawaii through its “CONUS+” beam.
A second beam will provide service to Mexico. The CONUS+ beam will downlink in the 17.3-
17.7 GHz band, while the Mexico beam will downlink in the 17.7-17.8 GHz band. The satellite
will be operated under the authority of The Netherlands. ViaSat is not seeking market access to
serve the United States at 17.7-17.8 GHz. Technical characteristics of the Mexico beam are
provided in this Attachment and Schedule S solely for informational purposes. Uplink
transmissions serving both downlink beams will use the 24.75-25.25 GHz band; the lower 400
MHz providing feeder-links to the CONUS+ beam and the upper 100 MHz providing feeder-
links to the Mexico beam. Uplink transmissions will occur from the dryer, southwestern region
of the U.S. (e.g., outside of Las Vegas) in order to minimize uplink rain fade effects.

The 500 MHz of spectrum on both uplink and downlink will be channelized into 32 channels of
26 MHz nominal bandwidth each. The lower twenty-six channels will be used with the
CONUS+ beam, while the upper six channels will be used with the Mexico beam. Dual
frequency re-use of both the uplink and downlink spectrum is achieved through the use of
orthogonal circular polarizations. There is no frequency offset between cross-polarized
channels.

1

All 32 active communications transponders will use combined TWTAs (2 x 150 Watts each)
giving a total saturated RF power per transponder of 300 Watts. This produces peak EIRP levels
of 60.3 dBW in both the CONUS+ beam and the Mexico beam after taking account of line
losses. The EIRP over the service area of the CONUS+ beam varies to account for different rain
attenuation characteristics and to comply with the PFD limits of 47 C.F.R. §25.208(w).

Spacecraft TT&C functions will take place at the lower edges of the 17/24 GHz frequency bands
for all mission phases. On-station TT&C operations will be conducted from the USA. TT&C
sites have not yet been selected, but are anticipated to be located in southwestern U.S.

A.3 FREQUENCY AND POLARIZATION PLAN

The satellite’s frequency plan is provided in the associated Schedule S form. A fixed translation
frequency of 7450 MHz is used between all uplink and downlink channels.

Circular polarization is used on both the uplink and downlink with the downlink polarization being
orthogonal to the uplink polarization. Full frequency re-use is achieved through the use of dual
orthogonal polarizations. This satisfies the requirements of §25.210(f) of the FCC’s Part 25 rules
(the “Rules”). In accordance with §25.210(i) of the Rules, the minimum cross-polarization
isolation will be 25 dB.

A.4 PREDICTED SPACE STATION ANTENNA GAIN CONTOURS

The VIASAT-RDBS1 satellite’s antenna gain contours for the receive and transmit beams are
provided in GXT format and embedded in the associated Schedule S submission. The beams
used for TT&C operations have gain contours that vary by less than 8 dB below peak across the
surface of the visible Earth. Therefore, gain contours for these beams (beams CMD and TLM)
have not been included in the associated Schedule S form.

A.5 TT&C INFORMATION

The information provided in this section complements that provided in the associated Schedule S
submission.

2

The VIASAT-RDBS1 satellite’s TT&C sub-system provides for communications during pre-
launch, transfer orbit and on-station operations, as well as during spacecraft emergencies. The
TT&C sub-system will operate at the lower edges of the 17/24 GHz bands for all phases of the
mission.

During transfer orbit and on-station emergencies the TT&C signals will be received and
transmitted by the satellite using a combination of antennas on the satellite that create a near
omni-directional gain pattern. During normal on-station operation the TT&C signals will be
received and transmitted via an Earth-coverage horn antenna on the Earth (+Z) face of the
spacecraft. A summary of the TT&C subsystem characteristics is given in Table A.5-1.

Table A.5-1: TT&C Performance Characteristics
Command/Ranging Frequencies 24,751 MHz
(All mission phases) 24,753 MHz
Uplink Flux Density Between -80 and -60 dBW/m2
Pseudo-omni antenna during transfer orbit and on-
station emergencies;
Satellite Receive Antenna Types
Earth coverage horn antenna during normal on-
station operations.
RHCP for pseudo-omni antenna;
Polarization of Satellite Receive Antennas
RHCP for Earth-coverage horn antenna.
Telemetry/Ranging Frequencies 17,301 MHz
(All mission phases) 17,303 MHz
Pseudo-omni antenna during transfer orbit and on-
station emergencies;
Satellite Transmit Antenna Types
Earth coverage horn antenna during normal on-
station operations.
RHCP for pseudo-omni antenna;
Polarization of Satellite Transmit Antennas
RHCP for Earth-coverage horn antenna.
15 dBW (pseudo-omni antenna);
Maximum Downlink EIRP
25 dBW (Earth-coverage horn antenna).

A.6 CESSATION OF EMISSIONS

All downlink transmissions can be turned on and off by ground telecommand, thereby causing
cessation of emissions from the satellite, as required by § 25.207 of the FCC’s rules.

3

A.7 LINK BUDGETS

Four representative link budgets are shown in Tables A.7-1 through A.7-4; two for the CONUS+
beam and two for the Mexico beam. For each beam, two representative modulation schemes
have been used: 1) QPSK modulation with 3/4 FEC rate and 2) 8PSK modulation with 3/4 FEC
rate; both with an occupied bandwidth of 25.8 MHz. For all link budgets, uplink transmissions
are assumed to occur from an earth station located near Las Vegas, NV.

For the CONUS+ beam, the link budgets show both clear sky and rain-faded links to two specific
receive earth station locations (New York and Los Angeles). For the Mexico beam, the link
budgets assume the receive location is located in Mexico City. For all link budgets, the effect of
any uplink rain fade is assumed to be minimized due to the combination of the feeder link earth
station’s uplink power control capability and the satellite’s automatic level control function.

As demonstrated in Section A.8, the downlink power flux density on the Earth’s surface will not
exceed the valued specified in §25.208(w). In addition, the associated feeder-link earth station
transmissions will not exceed the EIRP density limits in §25.223. Because VIASAT-RDBS1 will
be located at the precise location identified in the four-degree grid, satisfaction of these criteria
demonstrates compliance with §25.140(b) of the Rules. The link budgets also serve to demonstrate
that the satellite network would be compatible with a hypothetical co-frequency spacecraft four
degrees away that is in compliance with the technical rules for 17/24 GHz spacecraft with the same
receiving and transmitting characteristics as the VIASAT-RDBS1 satellite, consistent with
§25.140(b) of the Rules. The assumed interference environment used in the development of the
link budgets is described in detail in section A.8.

4

A.8 FOUR DEGREE COMPATIBILITY

There are no Commission-licensed, or proposed, 17/24 GHz BSS space stations within four
degrees of the 115° W.L. orbital location.

The demonstration of four-degree compatibility is housed in the link budgets contained in Tables
A.7-1 through A.7-4. The link budgets show the end-to-end link performance taking into
account the assumed interference environment, which is described below.

All link budgets assume pairs of interfering adjacent satellites nominally located at 4° and 8°
from the requested orbital location 1 and transmitting digital carriers. The adjacent networks are
assumed to be transmitting with an uplink input power density of -56.5 dBW/Hz. The interfering
downlink EIRP density assumed is dependent on the receive location. For the New York link
budget, each adjacent satellite is assumed to be transmitting so as to cause a PFD level of -118
dBW/m2/MHz at the victim receive antenna, consistent with §25.208(w)(2), whereas for the Los
Angeles link budget, the assumed interfering PFD level at the victim receive antenna is -121
dBW/m2/MHz, consistent with §25.208(w)(3). For the Mexico beam link budget, the adjacent
satellites are assumed to be transmitting so as to cause a PFD level of -115 dBW/m2/MHz at the
victim receive antenna, consistent with §25.208(w)(4). Finally, it is assumed that all wanted and
interfering earth station antennas have a sidelobe pattern of 29-25 log(θ).

Tables A.7-1 through A.7-4 demonstrate that the proposed services can successfully operate
given the assumed interference environment and with reasonably high link availabilities. As
discussed above in Section A.7, with the assumption that the adjacent satellites have similar
technical characteristics to the VIASAT-RDBS1 satellite, the link budgets also serve to show
that the interference into the adjacent satellite networks is also acceptable.

1
To account for station-keeping tolerances, the actual geocentric orbital separations used in the interference
calculations were 3.9° and 7.9°.

9

A.9 PFD ANALYSES

A.9.1 CONUS+ Beam (17.3-17.7 GHz Band)

The maximum operational PFD level that the CONUS+ beam will transmit is -115.54
dBW/m2/MHz. This occurs in the southeast portion of CONUS. Figure A.9-1 shows the
geographic location of the maximum PFD occurrence, as well as the CONUS+ beam’s -118
dBW/m2/MHz, -121 dBW/m2/MHz and -124 dBW/m2/MHz PFD contours. The diagram
demonstrates that the CONUS+ beam is in compliance with §25.208(w) since:

• No PFD levels occurring within the region defined by §25.208(w)(1) exceed the -115
dBW/m2/MHz limit;

• No PFD levels occurring within the region defined by §25.208(w)(2) exceed the -118
dBW/m2/MHz limit;

• No PFD levels occurring within the region defined by §25.208(w)(3) exceed the -121
dBW/m2/MHz limit;

• No PFD levels occurring within the region defined by §25.208(w)(4) exceed the -115
dBW/m2/MHz limit.

10

A.9.2 Mexico Beam (17.7-17.8 GHz Band)

The Mexico beam transmits in the 17.7-17.8 GHz band.

§25.208(c) contains Power Flux Density (“PFD”) limits that apply in the 17.7-17.8 GHz band. The
PFD limits of §25.208(c) are as follows:

• -115 dB(W/m2) in any 1 MHz band for angles of arrival between 0 and 5 degrees above the
horizontal plane;

• -115+(δ-5)/2 dB(W/m2) in any 1 MHz band for angles of arrival δ (in degrees) between 5
and 25 degrees above the horizontal plane; and

• -105 dB(W/m2) in any 1 MHz band for angles of arrival between 25 and 90 degrees above
the horizontal plane.

The maximum downlink EIRP density that the Mexico beam is capable of producing is 47.0
dBW/MHz. The shortest distance from the satellite to the Earth is 35,786 km (i.e., at the
equator), which corresponds to a spreading loss of 162.06 dB. Therefore, the maximum possible
PFD at the Earth’s surface could not exceed -115.06 dBW/m2/MHz (i.e., 47-162.06), which is
less than the most stringent §25.208(c) PFD limit of -115 dBW/m2 that applies at elevation
angles of 5° and below. Accordingly, compliance with the PFD limits of §25.208(c) for the
Mexico beam is assured at all angles of arrival.

A.10 ORBITAL DEBRIS MITIGATION PLAN

The spacecraft manufacturer for the VIASAT-RDBS1 satellite has not yet been selected and
therefore ViaSat’s Orbital Debris Mitigation Plan is necessarily forward looking. ViaSat will
incorporate the material objectives of §25.114(d)(14) of the Commission’s Rules into the design
of the satellite through the satellite’s Technical Specifications, Statement of Work and Test
Plans. The Statement of Work will include provisions to review orbital debris mitigation as part
of the preliminary design review (“PDR”) and the critical design review (“CDR”) and to
incorporate its requirements, as appropriate, into its Test Plan, including a formal Failure Mode
Verification Analysis (“FMVA”) for orbital debris mitigation involving particularly the TT&C,
12

propulsion and energy systems. Any updates to the Orbital Debris Mitigation Plan will be
reflected in any modification application needed to conform the satellite to the spacecraft
manufacturing contract.

A.10.1 Spacecraft Hardware Design

Although the VIASAT-RDBS1 satellite has not been fully designed, ViaSat does not expect that
the satellite will undergo any release of debris during its operation. Furthermore, all separation
and deployment mechanisms, and any other potential source of debris are expected to be retained
by the spacecraft or launch vehicle.

ViaSat will assess and limit the probability of the satellite becoming a source of debris by
collisions with small debris or meteoroids of less than one centimeter in diameter that could
cause loss of control and prevent post-mission disposal. ViaSat will take steps to limit the
effects of such collisions through shielding, the placement of components, and the use of
redundant systems. ViaSat will incorporate a rugged TT&C system with regard to meteoroids
smaller than 1 cm through redundancy, shielding, separation of components and physical
characteristics. The VIASAT-RDBS1 satellite will include two near omni-directional antennas
mounted on opposite sides of the spacecraft. These antennas will be extremely rugged and
capable of providing adequate coverage even if struck, bent or otherwise damaged by a small or
medium sized particle. ViaSat plans to locate the command receivers and decoders and
telemetry encoders and transmitters within a shielded area and provide redundancy and physical
separation for each component. The VIASAT-RDBS1 satellite will carry a rugged propulsion
system capable of withstanding collision with small debris.

A.10.2 Minimizing Accidental Explosions

ViaSat and its spacecraft manufacturer will assess and limit the probability of accidental
explosions during and after completion of mission operations. The satellite will be designed to
ensure that debris generation will not result from the conversion of energy sources on board the
satellite into energy that fragments the satellite. The propulsion subsystem pressure vessels will
be designed with high safety margins. Bipropellant mixing is prevented by the use of valves that

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prevent backwards flow in propellant lines and pressurization lines. All pressures, including
those of the batteries, will be monitored by telemetry. At end-of-life and once the satellite has
been placed into its final disposal orbit, ViaSat will remove all stored energy from the spacecraft
by depleting any residual fuel, leaving all fuel line valves open, venting the pressure vessels and
the batteries will be left in a permanent state of discharge.

A.10.3 Safe Flight Profiles

In considering current and planned satellites that may have a station-keeping volume that
overlaps the VIASAT-RDBS1 satellite, ViaSat has reviewed the lists of FCC licensed satellite
networks, as well as those that are currently under consideration by the FCC. In addition,
networks for which a request for coordination has been published by the ITU within ±0.15° of
115.0° W.L. have also been reviewed.

Based on these reviews, there are two operational satellites within ±0.15° from 115.0° W.L:
Eutelsat’s EUTELSAT 115 WEST B satellite operated nominally at 114.9° and ViaSat’s
VIASAT-1 satellite operated nominally at 115.1° WL. Both of these satellites operate with an
east-west station-keeping of ±0.05°.

There are no pending applications before the Commission for a satellite to be located at an
orbital location in the immediate vicinity of 115° W.L. With respect to ITU networks, ViaSat is
not aware of any satellite with an overlapping station-keeping volume with the VIASAT-RDBS1
satellite that is the subject of an ITU filing and that is either in orbit or progressing towards
launch.

Based on the preceding, ViaSat seeks to locate the VIASAT-RDBS1 satellite at 115.0° W.L. and
operated with an east-west station-keeping tolerance of ±0.05°. This eliminates the possibility of
any station-keeping volume overlap with the operational Eutelsat and ViaSat satellites. ViaSat
concludes there is no requirement to physically coordinate the VIASAT-RDBS1 satellite with
another satellite operator at the present time.

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A.10.4 Post-Mission Disposal

At the end of the operational life of the VIASAT-RDBS1 satellite, ViaSat will maneuver the
satellite to a disposal orbit with a minimum perigee of 300 km above the normal GSO
operational orbit. This proposed disposal orbit altitude exceeds the minimum required by
§25.283, which is calculated below.

The input data required for the calculation is as follows:

Total Solar Pressure Area “A” = 91 m2
“M” = Dry Mass of Satellite = 3346 kg
“CR” = Solar Pressure Radiation Coefficient = 1.5

Using the formula given in §25.283, the Minimum Disposal Orbit Perigee Altitude is calculated
as follows:

= 36,021 km + 1000 x CR x A/m
= 36,021 km + 1000 x 1.5 x 91/3346
= 36,062 km
= 276 km above GSO (35,786 km)

Thus, the designed disposal orbit of 300 km above GSO exceeds the required minimum by a
margin of 24 km. Maneuvering the satellite to the disposal orbit will require 15 kg of propellant,
and this quantity of fuel, taking account of all fuel measurement uncertainties, will be reserved to
perform the final orbit raising maneuvers.

A.11 SECTION 25.264 PREDICTIVE GAIN INFORMATION

In accordance with §25.264(a)(6), predictive gain information need not be submitted until 60
days after completion of critical design review for the space station, and is not provided in this
application. Calculations of PFD levels with respect to locations of prior-filed U.S. DBS space
stations based on such predicted gain data also need not be submitted until that time.

__________________________________

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CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING
ENGINEERING INFORMATION

I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in this pleading, that I am familiar with Part 25 of the

Commission’s rules, that I have either prepared or reviewed the engineering information

submitted in this pleading, and that it is complete and accurate to the best of my knowledge and

belief.

/s/
¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯
Stephen D. McNeil
Telecomm Strategies Canada, Inc.
Ottawa, Ontario, Canada
(613) 270-1177

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Document Created: 2017-03-07 11:50:32
Document Modified: 2017-03-07 11:50:32

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