Attachment ex parte

This document pretains to SAT-PDR-20020425-00071 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2002042500071_402477

k.L,‘ LCENVED KMH K | e 5 ~HI September 21, 2004 ser 2 2 2004 t ; reseat Communicaton Commiasion fceot Seaniy HAND.DELIVER In?! Burgay Ms. Marlene H. Dortch e 3 Offce of the Secretary $EP 29 209 Federal Communications Commission Eus 445 12" Streat, S.W. FTONtOffice Washington, DC 20554 Re: Report No. SPB—196; SAT—PDR—20020425—00071 Dear Ms. Dortch: in these proceedings, the FCC is considering various proposals for new DBS orbial locations that would be spaced only 4.5 degrees away from existing DBS orbital locations, thereby halving the current separation. To date,the materials submifted to the FCC appear to have fecused on the impact of such proposals on conventional DBS service to small satelite dishes mounted on subscribers‘ homes. However, there is a growing DBS submarket— service to moblle platforms such as cars, boats, and commercial and private aleraft — that must also be considered. The ECC has recognized that moblle applications fll within the defintion of DBS service, and that such applcations are,just k stationary applications, worthy of inteference protection. Indeed, the FCC has even considered whether addional measures were necessary to protect mobile receivers." As discussed below, the proposed "tweener" satelltes would have an even more serious and detrmental affect on such moble plattorms than they would on fixed antennas. KVH Industries, Inc. is an infernational leader in designing and manufacturing innovative satellte television antennas for moblle applications on land or sea. KVH has been bringing DBS service to moble consumers since 1995, and the company now supplies more in— motion satelite television systems fothe marine and landmoblle markets than any other manufacturerin the world. Tens ofthousands of beat, RV, and motor coach owners enjoy digtat—qualty television programming thanks to KV‘‘s famly of award—winning TracVision® antennas. Most recenty, KVH has applied is technological leadership to the automotive maket to develop the Trac¥ision AS, an advanced hyb phased—array antenna wih a profie small enough (approximately five inches high)that it can be attached to most standard roof racks of SUVs, mini—vans, vans, and knury cars." Regardiess of vehicle motion, ! goo.a0. 2 a 50 and rerestia i 5 EreavencyRanas,Fest Reportand Order and Furter Nobceof Proposed Rule Making, 16 Kiintste, inc. i Eooa0%0, 4173 (2000) considaing whether eilonal measures were necessary t rotct 0 Enteise Center $BS senvice o area agant NGSC es snstems} mgdetom, nt ooo | * A picure o the TrecvisonAS uns ataches to is atr usa Camd m oo s sser Bo‘s fuc sors500s w S00t £ inniiscon

IA < T TracVision AS automatically finds and tracks the DBS satelite and relays the signals to any standard invehicle passenger video display system, providing relable and uninterrupted reception on open roads throughout the continental United States. Since theirinception, DBS operations in the United States have been charactorized by the use of high—power satelites and nine degree ortital spacing. KVH designed its advanced mobile antenna systems to operate in this environment. in designing such systems, KVA faces two challenges that are not relevant to stationary DBS antennas, First the antennal radome must have a low profile to decrease drag on the moving vehicle. Second,the antenna must be able to track the apparent satelite position as the vehicle moves. As a resut,the antenna beam pattems for mobile receive antennas are asymmetrical, with broader gain in the elevation axis (due to the smaller near dimension) compensated to some extent by the design in the azimuth direction. Even with state—Fthe—arttechnology, the inherent imitations of a moble environment resultin smaller inmargins and lower avalabilty than can be expected for fxed antennas operating in the same area. To date, lower margins and availablity have not been a problem for moblle DBS receive systems, as they were contemplated in the design of mobile systems and viewers are accustomed to moblle services that are somewhatless robust than stationary services. However,i the orbial spacing of DBS satelltes were halved from nine degrees to 4.5 degrees, the ink would be signifcantly degraded — to the point where in many citesthe signal could not be received even in clear sky conditions using the antennas already designed and deployed. The example lnk budget below shows the sensitviy ofthe TracVision antenna to interference from satelites with 4.5 degree spacing." The diference in of—asis dicrimination ofthe TracVision antenna with orbial spacing of nne degrees versus 4.degreas is dramatl — over 8 dB. This decreases the rato of the desired signal to ntorfering signals from adjacent satelites (or °C/)from 18 dB to 9.5 dB. As shown in the example below, the presence of a "weener" satelite resuts in negathve Ink margin, which means thatte lik does not close and the subscriber receives no signal even in clear sky condiions. Link Budget — Washington, DC Chear Siy Rain On wits— Raln was GlearSky dog Down dog Uplink GN (thermab, aB Transmit power. cBW 14 ma ma 4 Transmi osses. c8 20 20 20 20 Ground antemna gain, 06 ses ses ces ses Antenna poining loss. d EB a5 <5 <5 The in budget assumes thatth weane sataite operais atthe EIRP levels ht war ied wih the TV for the USAT—S1 HOD—A and IOMBSS—1 sataites,a wel as .1 degre stator—keeping(ota) and no recave anienna misponing.

Cloar Siy Rain n wias. Raln was ClearSky _dog Down deg Free space loss, aB EH 288 268 2088 Amospheri oss. dB <2 a2 o2 _2 Upinicrain ls, a8 00 o0 00 00 Sateite 67.daik so 20 20 a0 Bendwdth, dbiz 430 130 430 130 Botzmann‘s constan, dowhiek 228 208 2258 208 Total Ulink GN 27 EA EsA 27 Downlink CN Satelite EIRP (4S), aBWas thermat, 08 mite sse sse ses sos Free space loss dB 200 200 200 200 Amaspheri loss, ds 02 42 42 Downlnk rainloss. B 50 00 45 Rain temp increase, o6 o0 a0 20 Rev. antenna pointng loss, iB 45 45 45 Radome loss, dB 44 44 44 . Ground G, dbiK 105 105 105 105 Bandwith, iiz REt 430 30 430 Batzmann‘s constant, cowhizk 288 228 z0e zes Total Downlin on 128 128 93 s3 Totals Upink GN (hemal, ds 274 274 2 2 Downink GN themmal, dB 128 128 EH 83 xpolintererence, dB 192 192 192 192 Ac.c8 20 z0 z0o |_zoo Aggregate Ofom 809. ASL c 180 180 180 180 Aagregale Gilfom 4.5—de9. ASL c8 w0 as seo as Total ASL, dB 180 s3 180 a9 iemetocs foa es ai a7 Required GiteD: db Ts Ts Ts 1s Margin, iB 2s a7 as 4s

Tens of thousands of mobile craft currentl recaive service from U.S. DBS satelites, and we expect DBS service for vehicles to become even more popularin the nearfture. The ECC has recognized that this use is consistent with the DBS service rules and is worthy of protection from Interference. The introduction of "weener® DBS satelites would increase Interference to the point where there would be no ink margin remaining and service to thousands of deployed antennas would be interupted, at least occasionall if not, permanently. The result for moble DBS system manufacturers and consumers would be devastating, and what is currently a promising and growing application of DBS technology wil be stifed in is infancy. Under these circumstances, the FGC should dismiss any request for authorty to operate a DBS satelite spaced at less than nine degrees fom existing U.S. operations. KVH strongly urges the FCC to do so as quickly as possible in order to avoid creating uncertainty that could delay further innovation in mobile DBS technology. Sincerely, mMkeh— Martin Kits van Heyningen PresidentCEo Attachment

The TracVision A5 satellite TVantenna offers a patented, sleek, and rugged design that houses KVH‘s innovative bhybridphased—array antenna technology.


Document Created: 2004-10-06 17:31:04
Document Modified: 2004-10-06 17:31:04
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