Attachment Response

Response

REPLY TO COMMENTS submitted by L3 Communications Titan Corp.

Response to ViaSat, Inc. comments

2007-05-15

This document pretains to SES-LIC-20070322-00396 for License on a Satellite Earth Station filing.

IBFS_SESLIC2007032200396_567105

20070504M01V07_Response_to_Viasat_Comments.doc


                                                                               iNTELLICOM

May 15, 2007


Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
9300 East Hampton Drive
Capitol Heights, MD 20743

Attention: Satellite Division, International Bureau


SUBJECT:          Response to ViaSat Comments
                  File No.: SES—LIC—20070322—00396
                  Call Sign: E060390
                  Comments of ViaSat, Inc., May 4, 2007


The referenced filing was accepted for Public Notice on April 4, 2007. We will address the ViaSat
comment herein. It is our position that the comment does not provide sufficient justification to halt
the license grant. We request that the liscense be granted based on the substantial information
already filed with the FCC.


Background

L3 has developed methods to protect adjacent satellite operations. These methods have taken
several years to develop and refine and have been verified in laboratory and operational
conditions. A conservative analysis has been performed and will continue to be used to protect
adjacent satellite operations. Power Spectral Density (PSD) into the antenna shall be managed
within the required FCC limits by limiting transmit power and/or utilizing spread spectrum
modulation.

 "SES, Intelsat, and ITC acknowledge that the use of the L3 non—conforming
antennas will not cause unacceptable interference into adjacent satellites
in accordance with the FCC‘s 2—degree spacing policy"

L3‘s development of this product has been incremental, conservative, and thorough. L3‘s license
application with the FCC follows this incremental approach and includes the following steps:

     1.   Experimental License — L3‘s first experimental license was granted June 3, 2005. L3
          have been performing development and verification testing of the earth station for almost
          two years. The development and verification activities have improved the product and
          have helped to achieve customer and satellite operator confidence.

     2.   Single Station License — This is the current license application. Since the use of small
          aperture, "non—compliant" antennae is not routine for the FCC, we chose to seek FCC
          confirmation of the EIRP spectral density, antenna performance attributes, and spread
          spectrum modulation techniques through a single station license.      L3 has applications
          which involve from one to several earth stations and as such single station licenses are
          appropriate.
                            iNTELLICOM Technologies, Inc.
                                    PO Box 27056, San Diego, CA 92198
                               Tel: (858) 486—1115, Email: info@itccom.net
                                              www.itccom.net


20070504M01V07_Response_to_Viasat_Comments.doc


                                                                                  iNTELLICOM

    3.    Blanket VSAT License — With FCC confirmation of the "non—compliant" antenna, L3
          intends to file for the Blanket VSAT license at a later date. VSAT networks have been
          routinely licensed by the FCC and the attributes of the L3 network will be shown to
          comply with FCC rules. In this license application, we plan to address the network
          provisions which ensure that positive control of all VSAT earth stations can be maintained
          from the Hub (or Network Controller).


Publice Notice Comment

We have reviewed the comments filed by ViaSat and provide the following in response:

     1.    "ViaSat is concerned about the potential for interference if this terminal were operated
          within an Network"

              a.    The license application is for operation of a single earth station and not a Blanket
                   VSAT network. It is not appropriate to dismiss this application for something that
                   has not been requested.

              b.   We are more than happy to deal with the networking aspects in the planned
                   Blanket VSAT license application.

    2.    "I The Application Does Not Provide A Technical Basis For Assessing The Interference
          Potential Of The Terminal If Operated Within A Network."

              a.   The license application is for operation of a single earth station and not a Blanket
                   VSAT network. It is not justified to dismiss this application for something that has
                   not been requested.

              b.   The application provides extensive technical information regarding antenna
                   patterns, pointing angle analysis, modulation, maximum power spectral density
                   relative to FCC 25.209, and corrections for relative rotation to the geostationary
                   arc. This information is substantial for a single earth station. In fact Intelsat and
                   SES have provided a signed affidavit stating that they are in agreement
                   with the operational practices. Whether for a single earth station or a network,
                   the maximum power spectral density will not be exceeded.                  Additional
                   technical information on the network management techniques will not change the
                   key performance metric which is the maximum EIRP spectral density.

              c.   Per the filed document 20060920M01V10pm_TECH_BRIEF.doc: "While spread
                   spectrum is used as a method to reduce transmit power spectral density, it is
                   NOT USED as a multiple access scheme".             Since CDMA is not used, the
                   management of the EIRP spectral density of each station is sufficient.

                         e    A CDMA based network, such as ViaSat‘s, requires additional
                              reduction of 10*Log(N) below a single carrier or station EIRP density,
                              where N is the number of accesses. Our system does not require a
                              reduction of this type.




                             iNTELLICOM Technologies, Inc.
                                   PO Box 27056, San Diego, CA 92198
                               Tel: (858) 486—1115, Email: info@itccom.net
                                                 www.itccom.net


20070504M01VO7_Response_to_Viasat_Comments.doc


                                                                                    iNTELLICOM

             d.     "L3 Titan accounts for the relative rotation of the antenna, but does not appear to
                   allocate any excess gain for multiple access methods"
                         e       L3‘s correction for relative rotation of the antenna demonstrates the
                                 attention to detail and the use of conservative engineering methods.
                         e       Margins for multiple access methods are appropriate for a CDMA
                                 network but are not relevant to our application.

             e.      "ViaSat has used and tested the L—3 Datron antenna and raises no issue with
                   respect to the antenna‘s performance" and "ViaSat‘s operations using this
                   antenna employed a modem that had a spread spectrum waveform with a very
                   low power density, which greatly reduces the potential for interference due to
                   antenna mispointing".
                             e     This is the approach that L3 has proposed. The Direct Sequence
                                   spreading factor is adjusted to ensure that the maximum EIRP
                                   density is not exceeded.

             f{.   We are more than happy to deal with the networki‘ng aspects in the planned
                   Blanket VSAT license application.


    3.    "II. The Commission Should Apply The Same Locational Record Keeping Requiremenis
          That Apply To Earth Station On Vessels."

              a.   We are aware that the FCC is currently reviewing a requirement for network
                   operators of mobile or "non—compliant‘ antennas to maintain records of the
                   location. Should the FCC rule to require records for VSAT networks and/or for
                   single earth stations, then the mechanisms specified by the FCC will be added to
                   the system to ensure compliance.

              b.    The license application is for operation of a single earth station and not a blanket
                   VSAT network. The location and activities of a single earth station are not
                   typically required by the FCC.

     4.   The potential victim of interference is not represented by ViaSat but instead by the
          satellite operators. L3 has filed an affidavit with the license application signed by the
          satellite operators, Intelsat and SES Americom, stating that they are satisfied with the
          technology and operational methods planned. In addition, L3 has been registered for
          operation on SES New Skies Satellites. A signed affidavit of satellite operators provides
          credibility that operation of this earth station is acceptable with regards to interference.




                                 iNTELLICOM Technologies, Inc.
                                      PO Box 27056, San Diego, CA 92198
                                  Tel: (858) 486—1115, Email: info@itccom.net
                                                 www.itccom.net


20070504M0IVO7_Response_to_Viasat_Comments.doc


                                                                               iNTELLICOM

Conclusions and Recommendations

L3 has been developing and verifying operation of this earth station for well over two years and
has been developing satellite earth station antennas and modem equipment for over 20 years.
The L3 earth station technology has been favorably critiqued by SES Americom, Intelsat, SES
New Skies, FCC‘s Engineering and Technology branch, FCC‘s International branch, and
numerous customers. An affidavit was provided by satellite operators supporting the operation of
the earth station.

ViaSat‘s comments are not applicable to a single earth station. Comments regarding CDMA
multiple access margins are not applicable since CDMA is not used. ViaSat‘s comments
regarding testing of the earth station antenna confirm the use of the antenna and a spread
spectrum waveform with a low power density, "which greatly reduces the potential for
interference".

L3‘s product development has been incremental, conservative, and thorough. L3‘s license
applications with the FCC follow this incremental approach. The single earth station license is
requested by L3 for its continued verification and customer training and trials. L3 intends to file
for a subsequent Blanket VSAT license. Technical information on the antenna performance and
maximum EIRP density, which has already been filed with the FCC, should be ample to evaluate
the interference impact on adjacent systems and has been confirmed by satellite operators.

We respectfully request that the FCC grant a license for a single earth station.


 Regard
               /

 Paul Molier
_ VP, Intellicom Technologies
480—993—2220
PMoller@1TCcom.net
www.IntelicomTech.com




 co:
 Elizabeth Park
 LATHAM & WATKINS LLP
 555 Eleventh Street, NW
 Suite 1000
Washington, DC 20004—1 304




                            iNTELLICOM Technologies, Inc.
                                    PO Box 27056, San Diego, CA 92198
                               Tel: (858) 486—1115, Email: info@itccom.net
                                                 www.itccom.net


20070504M01V07_Response_to_Viasat_Comments.doc


                                                                               iNTELLICOM




                                     Certificate of Service

|. Paul E. Moller, herby certify that on this 15 day of May, 2007, 1 served a true copy of the
foregoing Response to ViaSat comments by commercial courier upon the following:


         Elizabeth Park
         LATHAM & WATKINS LLP
         555 Eleventh Street, NW
         Suite 1000
         Washington, DC 20004—1304
         Direct Dial: (202) 637—1056
         Fax: (202) 637—2201
         Email: elizabeth.park@lw.com
         www.lw.com




—
Paul E. Moller




                            iNTELLICOM Technologies, Inc.
                                   PO Box 27056, San Diego, CA 92198
                               Tel: (858) 486—1115, Email: info@itccom.net
                                                 www.itccom.net



Document Created: 2007-05-15 14:06:47
Document Modified: 2007-05-15 14:06:47

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