Attachment ViaSat - Request for

ViaSat - Request for

REQUEST submitted by ViaSat

request for confidential treatment

2015-12-23

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

IBFS_SATMOD2014110500121_1120612

                                                                  555 Eleventh Street, N.W., Suite 1000
                                                                  Washington, D.C. 20004-1304
                                                                  Tel: +1.202.637.2200 Fax: +1.202.637.2201
                                                                  www.lw.com

                                                                  FIRM / AFFILIATE OFFICES
                                                                  Abu Dhabi       Moscow
                                                                  Barcelona       Munich
                                                                  Beijing         New Jersey
                                                                  Boston          New York
                                                                  Brussels        Orange County
June 4, 2013                                                      Chicago         Paris
                                                                  Doha            Riyadh
                                                                  Dubai           Rome
VIA ELECTRONIC FILING                                             Frankfurt       San Diego
                                                                  Hamburg         San Francisco
                                                                  Hong Kong       Shanghai

Ms. Marlene H. Dortch                                             Houston         Silicon Valley
                                                                  London          Singapore
Secretary                                                         Los Angeles     Tokyo
Federal Communications Commission                                 Madrid          Washington, D.C.
445 12th Street, SW                                               Milan

Washington, DC 20554


               Re:     Response to Request for Additional Information in Connection with Letter
                       of Intent Application of ViaSat, Inc., IBFS File No. SAT-LOI-20130319-
                       00040, Call Sign S2902

Dear Ms. Dortch:

       In response to the Commission’s request letter dated May 9, 2013, ViaSat, Inc.
(“ViaSat”) hereby supplements the above-referenced Letter of Intent to provide additional
information regarding the authority under which the ViaSat-2 satellite will operate.

        As indicated in the Letter of Intent, the ViaSat-2 satellite will operate under the authority
of the government of the United Kingdom. As to RF matters, on behalf of ViaSat’s wholly-
owned subsidiary, ViaSat Satellite Holding, Ltd. (“Satellite Holding”), Ofcom submitted a
coordination request with the ITU in connection with this network (UK-KA-1) on May 4, 2011.
Attached is a letter from Ofcom confirming the ITU submission. This United Kingdom ITU
filing covers the frequency bands for which authority is sought in the Letter of Intent.

        As to non-RF matters, the United Kingdom Outer Space Act applies to UK nationals
(i) launching or procuring the launch of a space object, (ii) operating a space object, or (iii)
carrying out any activity in outer space. 1 In accordance with the Outer Space Act, authority from
the UK Space Agency is expected to be sought for launch and space operations for ViaSat-2
closer to the time of launch by ViaSat UK Ltd (“ViaSat UK”), a private limited company formed
under the laws of the United Kingdom and which has a base of operations in the UK. ViaSat UK
is a wholly owned subsidiary of Satellite Holding. Founded in 1996 and employing
approximately 60 people at its headquarters in Wareham Dorset England, ViaSat UK directly

1
        Outer Space Act, 1986 c. 38, §§ 1, 2 (U.K.); see also Revised Guidance for Applicants
        Outer Space Act 1986, available at
        http://www.bis.gov.uk/assets/ukspaceagency/docs/osa/osa-guidance-for-applicants-
        january-2013-lh.pdf.


DC\2608157.1


Ms. Marlene H. Dortch
June 4, 2013
Page 2




supports the delivery and marketing of ViaSat Inc.’s satellite services. ViaSat UK also serves as
the point of presence for ViaSat’s U.K.-based space-related activities, and designs, develops,
manufactures and provides through-life support of information assurance and cyber security
products and services.

         It is expected that ViaSat UK will procure the launch and will be the party responsible for
contracting with a third party for telemetry tracking and control (“TT&C”) of the ViaSat-2
satellite. ViaSat believes that sufficient ties with the United Kingdom will exist to provide the
UK Space Agency the basis for issuing an authorization because of the procurement of the
spacecraft’s launch through a ViaSat entity based in the UK, and because this entity will also be
responsible for TT&C of the spacecraft. ViaSat has been informed by UK Space Agency
representatives that a space activities license should be sought no more than one year prior to
launch.

       If you have any questions regarding this submission, please feel free to contact the
undersigned.



                                              Respectfully submitted,

                                                     /s/

                                              John P. Janka
                                              Elizabeth R. Park

cc:       Fern Jarmulnek
          Alyssa Roberts

Attachment




DC\2608157.1


File Number: SSU3625


22 May 2013


Federal Communications Commission                                  Stephen Limb
                                                                   International Frequency Co-ordination
International Bureau
                                                                   Direct line:     + 44 20 7981 3091
Fax: + 1 202 418 1208
                                                                   Direct fax:      + 44 20 7981 3208
                                                                   Mobile:          + 44 7818 075 102

                                                                   ifc.enquiries@ofcom.org.uk



Dear Mrs Jarmulnek

Subject – VIASAT SATELLITE HOLDINGS LIMITED



This letter is a response regarding the letter received by ViaSat, Inc IBFS File No. SAT-LOI-
20130319-00040 dated May 9, 2013.

The Administration of the United Kingdom would like to confirm to the Federal
Communications Commission that satellite filing UK-KA-1 located at the 70°W.L. orbital
location was submitted to the ITU on 04.05.2011 for Operating Agency: 196, VIASAT
SATELLITE HOLDINGS LIMITED.

It would be appreciated if you would acknowledge receipt of this fax and confirm that you are
now satisfied that we have provided the required responses to your queries raised.

Yours faithfully




Stephen Limb BSc(Eng) MPhil CEng MIET

cc.    ViaSat





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Document Modified: 2016-01-05 10:59:03

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