Attachment Narrative

This document pretains to SAT-MOD-20141105-00121 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2014110500121_1067602

Exhibit A Description of Proposed Minor Modification ViaSat files this application for a minor modification to its market access authorization for the ViaSat-2 satellite. See FCC File No. SAT-LOI-20130319-00040, Call Sign: 2902. ViaSat has entered into a contract for the construction of the satellite, and this application seeks to modify the market access authorization to conform the authorized parameters to the corresponding technical parameters in the contract. ViaSat is currently authorized to access the United States market using the ViaSat-2 GSO spacecraft, under the authority of the United Kingdom at 69.9º W.L. using the 18.3-19.3 GHz and 19.7-20.2 GHz downlink bands, and the 28.1-29.1 GHz and 29.5-30.0 GHz uplink bands. 1 The satellite is intended to provide a range of communications services to both businesses and consumers, with the mix of services and end users being driven by market demand. No change in either the authorized frequencies or the orbital location is sought by this modification application. Schedule S Technical Information and Waiver Requests The attached Technical Annex and the associated Schedule S contain the salient technical details of the modified parameters. ViaSat is providing the Schedule S information consistent with the Commission’s recently adopted amendments to Part 25, which significantly reduce the informational requirements on satellite applicants. 2 ViaSat-2 employs a large number of identical spot beams for two beam types that will be used for communications links. For these two beam types ViaSat is providing the predicted antenna gain contours for one transmit and one receive representative spot beam for each of the two beam types. In addition, ViaSat is providing isoline gain contours, in both uplink and downlink directions, that depict, on a composite basis across the entire coverage area, the 1 The ViaSat-2 satellite also is being constructed with the capability of operating in the 17.7-18.3 GHz and 27.5-28.1 GHz bands but for which U.S. market access is not being sought at this time. See, e.g., Telesat Canada, IBFS File No. SAT-PPL-200605016- 00061, at 1 n.2 (filed May 16, 2006; granted Jan. 18, 2007) (disclosing existence of Ka- band payload on Anik F3 but not seeking market access using the Ka-band payload and providing only technical information regarding the C- and Ku-band operations); see also Establishment of Policies and Service Rules for the Mobile Satellite Service in the 2 GHz Band, Report and Order, 15 FCC Rcd 16127, ¶ 86 (2000) (“2 GHz Order”) (clarifying that market access application requirements apply only to relevant system capabilities for communications to or from the United States, and not to system capabilities for communications wholly outside of the United States). 2 Comprehensive Review of Licensing and Operating Rules for Satellite Services, Report and Order, 28 CC Rcd 12403 (2013) (“2013 Part 25 Reform Order”).

maximum gain of all spot beams that may be operated within that area. 3 Similarly, because these antenna beam types are replicated multiple times to form the coverage area of the satellites, ViaSat is providing antenna beam characteristics for these representative beams in lieu of replicating the beam information for each beam. ViaSat seeks a waiver of Section 25.114(c)(4) of the Commission’s rules and the Schedule S requirements to the extent necessary to depict the antenna gain contours and beam characteristics in this manner. The representative beam information in Table S7 of the Schedule S reflects the maximum EIRP for all identical transmit beams, and the maximum G/T and minimum saturation flux density for all identical receive beams. This information regarding the representative beams, taken with the composite isoline diagram identifying the maximum possible gain across the coverage area, provides the Commission with all data required to assess compatibility with adjacent spacecraft, while reducing the type of filing burdens on applicants that the Commission sought in amending the satellite application requirement in the 2013 Part 25 Reform Order. In addition, ViaSat requests a technical waiver of the cross-polarization isolation requirement in Section 25.210(i) of the Commission’s rules. More specific information supporting this waiver request is contained in the Technical Annex in Section 13. 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 entities and their respective affiliates beneficially owned 10 percent or more of ViaSat’s voting stock as of July 25, 2014: Beneficial Owner Citizenship Voting Percentage The Baupost Group, L.L.C. Massachusetts 23.8% 10 St. James Avenue Suite 1700 Boston, MA 02116 FPR Partners LLC Delaware 10.3% 199 Fremont Street 25th Floor San Francisco, CA 94105- 2261 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. 3 47 C.F.R. § 25.114(c)(4)(vii) (option (iii) for geostationary satellites with large numbers of identical fixed spot beams). 2

Directors Mark D. Dankberg, Chairman, CEO Robert Bowman 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 Bruce Dirks, Senior VP, Treasury & Corporate Development Shawn Duffy, Senior VP, CFO, CAO Kevin Harkenrider, Senior VP – Broadband Services H. Stephen Estes, Senior VP – Enterprise Services Steven R. Hart, Executive VP – Engineering, Chief Technical Officer Keven Lippert, Executive VP, General Counsel, Secretary Mark J. Miller, Executive VP, Chief Technical Officer Ken Peterman, Senior VP – Government Systems John Zlogar, VP – Commercial Networks 3


Document Created: 2014-11-05 13:24:14
Document Modified: 2014-11-05 13:24:14
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