Attachment ViaSat Commission le

ViaSat Commission le

REQUEST submitted by IB, FCC

Commission letter Aug 15 2016

2016-08-15

This document pretains to SAT-MOD-20160527-00053 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2016052700053_1146238

                                   Federal Communications Commission
                                         Washington, D.C. 20554


                                                       August 15, 2016

John P. Janka
Latham & Watkins
555 Eleventh Street, NW
Suite 1000
Washington, D.C. 20004

                                                            Re: ViaSat, Inc.
                                                            IBFS File No. SAT—MOD—20160527—00053
                                                            Call Sign: $2902

Dear Mr. Janka:

        This letter requests additional information regarding ViaSat, Inc.‘s pending request to modify its
grant of U.S. market access for the ViaSat—2 space station at the 69.9° W.L. orbital location by adding the
27.5—28.1 GHz (Earth—to—space) and 17.7—18.3 GHz (space—to—Earth) frequency bands to its grant of
market access. To assist with the processing of this application, we request that ViaSat provide the
following information:‘

          1) For the frequency band 17.7—17.8 GHz (space—to—Earth) please provide the predicted
             transmitting antenna off—axis gain information specified in Section 25.264(a) of the
             Commission‘s rules, 47 CFR § 25.264(a). In addition, please perform the power flux—density
               (pfd) calculations based upon this off—axis antenna gain information as specified in Section
               25.264(b) and identify each prior—filed U.S. Direct Broadcast Satellite (DBS) space station at
               whose location the coordination threshold pfd level of —117 dBW/m?/100 kHz is exceeded.
               Although ViaSat considers the 61.5° W .L. ITU Region 2 Broadcasting—Satellite Service
               (BSS) Plan location in its application, its pfd calculations must take into account all prior—
               filed U.S. DBS space stations as defined in Section 25.264(b)(1).

          2) Please provide an interference analysis as described in Section 25.140(b)(4)(iii) of the
             Commission‘s rules, 47 CFR § 25.140(b)(4)(iii), demonstrating that ViaSat‘s proposed
             operations in the 17.7—17.8 GHz (space—to—Earth) band will not cause more interference to
               any current or future 17/24 GHz BSS satellite networks than if the applicant were located at
               the precise Appendix F orbital location from which it seeks to offset. ViaSat‘s orbital
               location, 69.9° W.L., is offset 1.1 degrees from the 71° W.L. Appendix F orbital location."
               Accordingly, ViaSat‘s operations from this location must be at pfd levels that are reduced
               from those specified in Section 25.208(c) in accordance with the following calculation
               methodology:




147 CFR § 25.111(a).

> The Establishment ofPolicies and Service Rulesfor the Broadcasting—Satellite Service at the 17.3—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 Bandfor Fixed Satellite
Services Providing Feeder Links to the Broadcasting—Satellite Service andfor 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 Red 8842, Appendix
F (rel. May 4, 2007).


        For a given location on the surface of the Earth at which the required pfd reduction value needs to
be determined, calculate the topocentric angular separation ‘¢ of the 71° W.L. and 67° W.L.
geostationary orbital locations, and the corresponding off—axis gain GCO1(¢) of the antenna specified in
Section 25.224(a)(1) of the Commission‘s rules at that angular separation. For the same location on the
surface of the Earth, also calculate the topocentric angular separation of the 67° W.L. and 69.9° W .L.
geostationary orbital locations, and the gain of the antenna GCO2(¢) specified in Section 25.224(a)(1) of
the Commission‘s rules at that angular separation. Then, perform the subtraction GCO2(¢) — GCO1(¢).
The result is the required reduction in pfd from the value specified in Section 25.208(c).

         Please demonstrate that under all atmospheric conditions, and for all angles of arrival, the pfd
levels at the Earth‘s surface from ViaSat‘s transmissions in the 17.7—17.8 GHz (space—to—Earth) band will
not exceed these calculated levels anywhere within the United States and its Territories.

        ViaSat must amend its market access request to address this request for additional information by
September 13, 2016. Failure to do so may result in the dismissal of ViaSat, Inc.‘s request pursuant to
Section 25.112(c) of the Commission‘s rules, 47 CFR § 25.112(e).


                                                  Sincerely,


                                            xseAlbugu
                                              ose P. Albugu rque
                                               Chief, Satellite Division
                                                  International Bureau



Document Created: 2016-08-15 16:34:04
Document Modified: 2016-08-15 16:34:04

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