AMC-21 Coordination

SUPPLEMENT submitted by SES Americom, Inc.

AMC-21 Coordination Letters

2009-05-29

This document pretains to SES-AFS-20090515-00589 for Amendment Foreign Satellite App on a Satellite Earth Station filing.

IBFS_SESAFS2009051500589_714100

A SES SATELLITES (GIBRALTAR) LIMITED 14 May 2009 Federal Communications Commission International Bureau 445 12"" Street, S.W. Washington, DC 20554 Subject: Engineering Certification of SES Satellites (Gibraltar) Ltd. To whom it may concern: This letter certifies that SES Satellites (Gibraltar) Ltd. ("SES Gibraltar") is aware that SES Americom, Inc. ("SES Americom") will be amending its pending application for a License to operate a network of fixed hub stations and Earth Stations on Vessels ("ESV") in the Ku—band frequencies, call sign E060335, to: (1) substitute KVH Industries, Inc. ("KVH") as applicant, and (2) add the AMC—21 satellite as a point of communication. The AMC—21 satellite at 124.9° W.L. is licensed by Gibraltar/United Kingdom and is on the FCC Permitted Space Station List to serve the United States (ITU Designation AM—SAT 125W). KVH will be operating transmit/receive ESV antennas with AMC—21 within the frequency range having center downlink frequency 11.72 GHz, center uplink frequency 14.020 GHz, 36 MHz bandwidth, horizontal polarization in the downlink, and vertical polarization in the uplink. Specifically, KVH will be deploying ESV antennas witha diameter of 60 cm that in some respects do not comply with Section 25.222 ofthe FCC‘s rules. The nominal pointing accuracy for this installed antenna will be less than or equal to +/— 0.6 degrees. All emissions from the ESV shall automatically cease within 100 ms ifthe angle between the orbital location ofAMC—21 and the axis of the main lobe of the ESV antenna exceeds 1 degree and transmission will not resume until such angle is equal to or less than 0.6 degrees. The 1 degree and 0.6 degree values do not conform to Sections 25.222(a)(6) and (a)(7) ofthe FCC ESV rules. Otherwise, the ESV terminals will operate in compliance with the technical, operational and performance requirements of the FCC‘s ESV rules and any requirements set forth in the license granted by the FCC for the above antennas. The ESV terminals operate with a CDMA transmission scheme such that the aggregate uplink interference into neighboring satellites results from the combined effects ofmultiple transmitting earth station antennas. Importantly, the ESV terminals also employ a spread spectrum modulation scheme that significantly reduces the maximum off—axis EIRP density produced by SES Satellites (Gibraltar (Limited) Four Research Way Princeton NJ 08540 USAtef{1) 609 987 4194 krishjonnalagadda@ses.com ‘Registered in Gibraltar under Number 57393. Registered Office at 28 Irish Town P.0. .Box 15, Gibraltar

individual terminals. Thus, even taking into account the maximum pointing error of the terminals (0.6°), the aggregate transmissions from the ESV terminals still comply with the off—axis EIRP density mask set forth in Section 25.222(a)(1) with N=1. Actually, pointing errors as large as 1° may occur before emissions cease. However, calculating apgregate interference based on the maximum pointing error of 0.6° is acceptable because, at any point in time, there will be multiple simultaneous transmitting antennas with the different pointing errors. The satellite EIRP density of the carriers will not exceed 10 dBW/AKHz. Furthermore, except as described above, these antennas will be installed in compliance with the technical, operational and performance requirements ofPart 25 of the FCC rules and any requirements set forth in the licenses granted by the FCC for the above antennas. SES Gibraltar and KVH acknowledge that the use ofthe above non—conforming antennas has the potential to cause unacceptable interference into adjacent satellites in accordance with the FCC‘s 2—degree spacing policy and will not seek any additional protection compared to the case of an earth station employing an antenna that fully conforms to the FCC rules. However, under the conditions defined ab0ve, satellites at 2° spacing or more will not expenence unacceptable interference. Furthermore, KVH states that ifthe use of this antenna should cause unacceptable interference into other systems, KVH will terminate transmissions immediately upon notice from the affected parties. Finally, SES Gibraltar acknowledges that it will include the subject non—conforming earth station operations in all future satellite network coordinations. Sincerely, Krish Jonnalagadda Manager, Spectrum Development SES Americom 4 Research Way Princeton NJ 08540 Tel: (609) 987 4194 SES Satelmes {Gibraltar (Limited) Four Research Way Princston NJ 08540 USAtel (1) 609 987 4194 krish.jonnalagadda@ses.com . Registered‘n Gibraltar under Number 57393. Registered Office at 28 Irish Town P.0. .Box 15, Gibraltar

— Acceptance by KVH Industries, Inc. KVH testifies that the information provided to SES and reflected in this Affidavit letter is true and accurate to best ofKVH ‘s knowledge. WW —_ Mey 25,2009 Fellise Feingol Date Vice President, General Counsel KVH Industries, Inc Acceptance by INTELSAT: Intelsat agrees to opération of the above antenna with the technical parameters described herein with respect to Galaxy—18 at 123°W, and Galaxy—27 at 129°W longitudes which have a nominal geocentricseparation oftwo (2) degrees and four (4) degrees, respectively, from AMC—21. g{Abuquerqqu}"q% | Date: 4—4 Ma.)l ,?/003 Senior Director, Spectrum Engineering INTELSAT bES Satellites (Gibraitar (Limited) Four Research Way Princeton NJ 08540 USAtel (1) 609 987 4194 krishJonnalagadda@ses.com Registered in Gibraltar under Number 57393. Registered Office at 28 Irish Town P.0. .Box 15, Gibraltar >

ASES SATELLITES (GIBRALTAR) ‘LIMITED . 14 May 2009 Federal Communications Commission International Bureau 445 12"" Street, S.W. Washington, DC 20554 Subject: Engineering Certification of SES Satellites (Gibraltar) Ltd. To whom it may concern: This letter certifies that SES Satellites (Gibraltar) Ltd. ("SES Gibraltar") is aware that SES Americom, Inc. ("SES Americom") will be amending its pending application for a License to operate a network of fixed hub stations and Earth Stations on Vessels ("ESV*") in the Ku—band frequencies, call sign E060335, to: (1) substitute KVH Industries, Inc. ("KVH"") as applicant, and (2) add the AMC—21 satellite as a point of communication. The AMC—21 satellite at 124.9° W.L. is licensed by Gibraltar/United Kingdom and is on the FCC Permitted Space Station List to serve the United States (ITU Designation AM—SAT 125W), KVH will be operating transmit/receive ESV antennas with AMC—21 within the frequency range having center downlink frequency 11.72 . GHz, center uplink frequency 14.020 GHz, 36 MHz bandwidth, horizontal polarization in the downlink, and vertical polarization in the uplink. Specifically, KVH will be deploying ESV antennas with a diameter of 60 cm that in some respects do not comply with Section 25.222 of the FCC‘s rules. . The nominal pointing accuracy for this installed antenna will be less than or equal to +/— 0.6 degrees. All emissions from the ESV shall automatically cease within 100 ms ifthe angle between the orbital location of AMC—21 and the axis ofthe main lobe ofthe ESV antenna — exceeds 1 degree and transmission will not resume until such angle is equal to or less than 0.6 _ degrees, The 1 degree and 0.6 degree values do not conform to Sections 25.222(a)(6) and (a)(7) ofthe FCC ESV rules. Otherwise, the ESV terminals will operate in compliance with the technical, operational and performance requirements ofthe FCC‘s ESV rules and any requirements set forth in the license granted by theFCC for the above antennas, The ESV lerminals operate with a CDMA transmission scheme such that the aggregate uplink interference into neighboring satellites results from the combined effects of multiple transmitting earth station antennas. Importantly, the ESV terminals also employ a spread spectrum modulation scheme that significantly reduces the maximum off—axis EIRP density produced by individual terminals. Thus, even taking into account the maximum pointing error of the terminals i 1 SES Satelltes (Ghraitar (Limiled) Four Research Way Princeton NJ 08540 USAtel (1) 609 987 4194 krish.Jonnalagadda@ses.com Registered in Gibraitar under Number 57393. Registered Office at 28 trish Town P.O. .Box 15, Gibraltar

(0.6"), the aggregate transmissions from the ESV terminals still comply with the off—axis EIRP density mask set forth in Section 25.222(a)(1) with N=1. Actually, pointing errors as large as 1° may occur before emissions cease. However, calculating agpregateinterferencebased on the maximum pointing eror of 0.6° is acceptable because, at any point in time, there w111 be multiple simultaneous transmitting antennas with the different pointing errors. The satellite EIRP density of the carriers will not exceed 10 dBW/AKHz. Purthermore, except as described above, these antennas will be installed in compliance with the technical, operational and performance requirements ofPart 25 ofthe FCC rules and any requirements set forth in the Iicenses granted by the FCC for the above antennas. SES Gibraltar and KVH acknowledge that the use of the above non—conforming antennas has the potential to cause unacceptable interference into adjacent satellites in accordance with the FCC‘s 2—degree spacing policy and will not seek any additional protection compared to the case of an earth station employing an antenna that fully conforms to the FCC rules. However, under the conditions defined above, satellites at 2° spacing or more will not experience unacceptable interference. Furthermore, KVH states that ifthe use of this antenna should cause unacceptable interference — into other systems, KVH will terminate transmissions immediately upon notice from the affected parties. Finally, SES Gibraltar acknowledges that it will include the subject non—conforming earth station operations in all future satellite network coordinations. ‘Sincerely, poc m \< € d ow\ma(-fl"afi ~ kg—g’/ Krish Jonnalagadda Manager, Spectrum Development SES Americom 4 Research Way Princeton NJ 08540 Tel: (609) 987 4194 SES Sateliites (Gibraitar {Limiled) Four Research Way Princeton NJ 08540 USAte! (1) 609. 987 4194 krish.jonnalagadda@ses.com Registered in Gibraltar under Number 57393. Registered Office at 28 Isish Town P.O. .Box 15, Glbraltar

Acceptance by KVH Industries, Inc. KVH testifies that the information provided to SES and reflected in this Affidavit letter is true accurateftq best of KVH ‘s knowledge. R. : N\QA Wm{ 23, 2009 Felise Feingold Date Vice President, General Counsel KVH Industries, Inc f Acceptance by Horizons—1 Satellite LLC: Horizons—1 Satellite agrees to operation of the above antenna with the technical parameters described herein with respect to Horizons 1 at 127°W longitude which has a nominal geocentric separation oftwo (2) degrees from AMC—21. @‘Aflu@fifl, @'%/Jose Albuquerque Date: ©5.35. 09 for Horizons—1 Satellite LLC SES Satelites (Gibraltar (Limied) Four Research Way Princeton NJ 08540 USAtel(1) 609 887 4194 krishjonnalagadda@ses.com Registered in Cilbraltar under Number 57303. Registered Office at28 trish Town P.0. .Box 15, Gioraltar


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Document Modified: 2019-04-14 08:06:18
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