Attachment Permit-But-Disclose

Permit-But-Disclose

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Raysat Antenna

Permit-but-Disclose

2007-12-28

This document pretains to SES-AMD-20070620-00839 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2007062000839_616968

202-434-7400 fax Carlos M. Nalda I 202 434 7333 I cmnalda@mintz.com www.mintz.com December 28.2007 GILEDIACCEPTED VIA HAND DELIVERY ORIGI DEC 2 8 2007 Marlene H. Dortch Federal Comcnunsations hrnm&)w, Secretary OMce of the Secretary Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: Raysat Antenna Systems, LLC, Application for Authority to Operate 400 In-Motion Mobile Satellite Antennas in the 14.0-14.5 GHz and 11.7-12.2 GHz Frequency Bands, Call Sign E060101, File Nos. SES- LIC-20060629-01083, SES-AMD-20070620-00839 - Notice of Ex Parte Presentation Dear Ms. Dortch: On December 27,2007, David Gross and Ilan Kaplan of Raysat Antenna Systems, LLC, along with Carlos Nalda of Mintz Levin, met with Aaron Goldberger of Chairman Martin’s office to discuss issues raised in the above-captioned application proceeding.” The issues discussed in the meeting are reflected in the attached written presentation. Pursuant to section 1.1206(b) of the Commission’s rules, two copies of this submission are being filed with the Office of the Secretary. A copy is also being served electronically to Mr. Goldberger. Please feel free to contact the undersigned with any questions regarding this submission. Sincerely, A Carlos M. Nalda Counsel to Raysat Antenna Systems, LLC Attachment cc (w/ att.): Aaron Goldberger I/ This proceeding has been designated “permit-but-disclose” for purposes of the Commission’s exparte rules. See Public Notice, Report No. SES-00923 (May 2 , 2007).

CERTIFICATE OF SERVICE I, Stefani Watterson, hereby certify that on this 28th day of December 2007, served a true copy of the foregoing “Notice of Ex Parte Presentation” by first class mail, postage pre-paid upon the following: Elizabeth R. Park Latham & Watkins LLP 555 Eleventh Street, N.W. Suite 1000 Washington, D.C. 20004 Sonny Ellis Parsons Transportation Group Inc. 1133 Fifteenth Street, N.W. Washington, DC 20005-2701

RSsat Antenna Systems Meeting with Aaron Goldberger Chairman Martin’s Office December 27,2007

RAS LMSS Licensing 0 Background 0 RAS Licensing Issue Effect of VMES Rulemaking 0 Conclusion The FCC may grant RAS’s LMSS blanket license application without regard to the status of the VMES rulemaking proceeding. ppt n enna 2 Systems

Background RAS has developed a low-profile, vehicle- mounted, mobile two-way broadband earth station az Transmit operations in Ku-band LMSS spectrum (14.0-14.5 GHz) on a secondary basis 8 Receive operations in 11.7-12.2 GHz band on an unprotected, non-interference basis Main users are military and government entities -2 U.S. Military and National Guard units -~& Other agencies Other applications 1 e: News organizations 3

Background (cont’d) bxperimental Licensing Experimental STA - March and June 2005 (WCSXCU) Experimental License - August 2005 (WD2XTB, expired August 1, 2007) (Limited Market Study authority added) G? Experimental STA - August 2007 (WCSXZA) (expires February 2,2008) Experimental STA -November 2007 (WDSXCQ) (expires May 28,2008) (new antenna model) International Bureau Licensing LMSS blanket license application - filed June 2006, amended June 2007 (pending) ppt n enna 4 Systems

BAS Licensing Issue More than 100 organizations (mainly U S . Government and military) have tested RAS’s StealthRay antenna U S . Government and private sector customers are concerned about RAS’s FCC licensing status q~ U S . military wants RAS antennas fielded immediately T U S . military must train in United States, but current experimental status limits deployment and use 31 Full commercial deployment for private sector use not possible under experimental license Existing experimental status unnecessarily constrains the ability of U S . Government and private sector customers to benefit from RAS’s innovative service ppt n enna Systems

Effect of VMES Rulemaking Licensing secondary LMSS operations is consistent with existing FCC rules and precedent 2 The VMES NPRM proposes rules for primary VMES operations only The VMES NPFW does not propose to alter the ability of the FCC to authorize secondary LMSS operations RAS has applied for authority to operate LMSS earth stations on a secondary basis (up to 400 terminals) Consideration of the VMES NPRM should not delay or otherwise affect RAS’s application ppt n enna 6 Systems

Conclusion . RAS’s LMSS application is consistent with existing; Y allocations and FCC precedent e Secondary operations in the 14.0-14.5 GHz band * Unprotected operations in the 11.7-12.2 GHz band RAS’s proposed LMSS operations have been fully coordinated and will not cause harmful interference The FCC may grant RAS’s LMSS blanket license .. application without regard to the status of the VMES I. rulemaking proceeding 7

Additional Slides RAS Protection of Adjacent Satellites

Protection of Adjacent Satellites RAS fully protects primary FSS operations rn Antenna characteristics and transmit power levels carefully designed to prevent harmful interference to adjacent satellites rn Automated satellite acquisition and closed-loop tracking ensure off-axis EIRP along the GSO remains within prescribed levels rn Cessation of emissions within 1OOms if tracking error exceeds 0.5' precludes any possibility of harmful interference RAS's operations have been fully coordinated by satellite operators rn Seven proposed satellite points of communication coordinated with twenty satellites within +/- 6" of their orbital locations No reported instances of interference in more than two years of demonstrations and testing 9

Protection of Adjacent Satellites (cont'd) Off-axis EIRP density levels ma not exceed the followin mask from maximum VSAl!input power density of ection into a Section 25.209(a) compliant antenna): 15 - 2510g(8)dBW/4kHz for 1.250I 8 5 7.00 * - GdBW/4kHz for 7.0 o e 8 5 9.20 18 - 2510g(@dBW/4kHz for 9.20 c 8 I 4 8 0 - 24dBW/4kHz for 480 e 8 1 1800 Off-Axis EIRP Spectral Density at 50" Skew - 14.25 GHz (+/- 0.5" Pointing Error Shown) RaySat antenna uses max. l5 I flange power density of - 18.1 dBW/4kHz - 3 Off-axis EIRP density f 3 g -5 levels at 500 skew angle 0 L confirm no possibility z of harmful interference -15 -25 -10 -a -6 4 -2 0 2 4 6 8 10 -hHwF4 10


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Document Modified: 2008-01-10 15:27:13
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