Attachment Narrative SES-LIC-20110429-00528

Attachment Narrative

This document pretains to SES-LIC-20110429-00528 for License on a Satellite Earth Station filing.

IBFS_SESLIC2011042900528_886872

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of )
)
)
Application of KVH Industries, Inc. for ) File No. _______________
License to Operate a Network of Vehicle- )
Mounted Earth Stations (“VMESs”) in the ) Call Sign ______________
14.0-14.5 GHz (Transmit) and 10.95–11.2 )
GHz, 11.45–11.7 GHz and 11.7-12.2 GHz )
(Receive) Frequency Bands )
)

APPLICATION FOR VMES NETWORK LICENSE

Felise Feingold Carlos M. Nalda
Vice President and General Counsel Joshua T. Guyan
KVH Industries, Inc. Squire Sanders & Dempsey (US) LLP
50 Enterprise Center 1201 Pennsylvania Avenue, NW
Middleton, RI 02842 Suite 500
Washington, DC 20004
(202) 626-6600

Counsel for KVH Industries, Inc.

April 29, 2011

SUMMARY

KVH Industries, Inc. (“KVH”) hereby submits this application for a vehicle-mounted

earth station (“VMES”) network license to operate up to 250 Ku-band TracPhone V7 Land and

TracPhone V3 Land terminals (125 of each type) in the land mobile context throughout the

United States. The land-based terminals will operate with ALSAT (and specifically the AMC-15,

AMC-21 and GE-23 satellites) in the 14.0-14.5 GHz (transmit) and 11.7-12.2 GHz (receive)

bands, as well as with GE-23 in the 10.95-11.2 and 11.45-11.7 receive bands. Network

operations will be controlled by KVH from its headquarters via a single network operations

center located in Carlsbad, California.

The V7 terminal employs a 0.6m antenna and is authorized by the Commission to operate

in the maritime context as a Ku-band earth station onboard vessel (“ESV”). In addition, KVH

received a special temporary authorization (“STA”) to operate the V7 in the land mobile context

and has confirmed that the V7 is appropriate for use as a VMES terminal. As demonstrated

herein, the V7 terminal complies fully with the Commission’s VMES rules and policies,

including off-axis EIRP spectral density limits and other provisions designed to protect co-

frequency operations from harmful interference. The V3 terminal employs a 0.37m antenna,

similarly complies with the Commission’s rules and policies and is also authorized by the

Commission to operate in the maritime context as a Ku-band ESV.

The KVH terminals are highly efficient and affordable, and grant of KVH’s application

for a VMES network license will serve the public interest by extending the reach of vehicular

broadband communications to more first responders, newsgathering vehicles, public

transportation (e.g., trains), leisure travelers and other users throughout the United States.

TABLE OF CONTENTS

Page

SUMMARY.................................................................................................................................... i
I. INTRODUCTION ............................................................................................................. 2
II. THE V7 AND V3 TERMINALS SATISFY THE COMMISSION’S VMES
REQUIREMENTS............................................................................................................. 3
A. Description of the V7 Terminal ............................................................................. 4
B. Description of the V3 Terminal ............................................................................. 6
C. Satellite Points of Communication, Hubs and Network Control Center ............... 8
D. Emissions Designators ........................................................................................... 9
E. Compliance with the Ku-band VMES Rules ....................................................... 10
1. Off-Axis EIRP Spectral Density Limits .................................................. 10
a. The KVH VMES Antennas Comply with the VMES Off-
Axis EIRP Spectral Density Limits ............................................. 10
b. Request for Waiver ...................................................................... 17
2. VMES Terminal Antenna Pointing Control ............................................ 19
3. Compliance With Additional VMES Requirements................................ 26
4. Protection of Other Users in the 14.0-14.5 GHz Band ............................ 28
III. CONCLUSION................................................................................................................ 29

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of )
)
Application of KVH Industries, Inc. to ) File No.
Operate a Network of Vehicle-Mounted )
Earth Stations (“VMESs”) in the 14.0-14.5 ) Call Sign
GHz (Transmit) and 10.95–11.2 GHz, )
11.45–11.7 GHz and 11.7-12.2 GHz )
(Receive) Frequency Bands )

APPLICATION FOR VMES NETWORK LICENSE

KVH Industries, Inc. (“KVH”), by its attorneys and pursuant to Section 25.226 of the

Commission’s rules, 47 C.F.R. § 25.226, hereby submits this application to operate a network of

250 V7 and V3 Ku-band miniVSAT terminals as Vehicle-Mounted Earth Stations (“VMESs”)

communicating with ALSAT (and specifically the AMC-15, AMC-21 and GE-23 satellites) in

the 14.0-14.5 GHz (transmit) and 11.7-12.2 GHz (receive) bands, as well as with GE-23 in

10.95-11.2 and 11.45-11.7 receive bands. Network operations will be controlled by KVH from

its headquarters via a single network operations center located in Carlsbad, California.

The TracPhone V7 Land and TracPhone V3 Land terminals have been previously

authorized by the Commission to provide maritime broadband services as earth stations onboard

vessels (“ESVs”). As demonstrated herein and in prior applications, and confirmed by

operations in both the land mobile and maritime contexts, the V7 and V3 comply fully with the

Commission’s two-degree spacing requirements. Because the terminals will extend high-speed

Internet access to first responder, satellite newsgathering vehicles, public transportation (e.g.,

trains), leisure travelers and other mobile broadband users, grant of this application would

strongly serve the public interest.

I. INTRODUCTION

The Commission has authorized KVH to operate the V7 terminals on a temporary basis

for land mobile communications and on a long-term commercial basis as part of KVH’s Ku-band

ESV network. Such operations have resulted in no complaints of harmful interference. In this

application, KVH requests long-term authority for V7 and similar V3 VMES operations, and

demonstrates that the terminals comply with the Commission’s VMES licensing rules.

KVH holds special temporary authorization to operate the V7 terminal in the land mobile

satellite-service (“LMSS”) to communicate with the AMC-15 satellite in the 14.0-14.5 GHz and

11.7-12.2 GHz frequency bands.1 KVH has received no complaints of interference based on its

operation of those terminals. In addition, KVH currently holds a Ku-band ESV network license

to operate up to 3,500 V7 and 1,000 V3 terminals to communicate with ALSAT and GE-23 in

extended Ku-band downlink frequencies.2 These terminals have operated in the maritime

context without any report of interference.

The Commission’s ESV rules are virtually identical to its VMES rules with respect to

protection of adjacent satellites and other co-frequency services from potential interference, and

1
See IBFS File No. SES-STA-20091019-01338, Call Sign E030131 (granted Nov. 9, 2010).
KVH filed its application for such authority before the Commission’s new VMES rules were
effective.
2
See IBFS File No. SES-MOD-20110126-00062 (Call Sign E090001). KVH previously held
three separate ESV network licenses for the V7 terminal to communicate with three specific
satellite points of communication. Call Sign E060335 authorized KVH’s ESV network to
communicate with the AMC-21 satellite at 125º degrees W.L. using a hub earth station located in
Miami, Florida. See IBFS File No. SES-LIC-20060824-01502. The separately licensed hub
earth station’s Call Sign is E040267. Call Sign E070085 authorized communication with the
AMC-15 satellite at 105º W.L. using a hub earth station located in Carlsbad, California. See
IBFS File No. SES-LIC-20070504-00563. The separately licensed hub earth station’s Call Sign
is E030131. Call Sign E090001 authorized KVH’s ESVs to communicate with the GE-23
satellite at 172º E.L. using a hub earth station located in Kapolei, Hawaii. See IBFS File No.
SES-LIC-20081104-01450. The separately licensed hub earth station’s Call Sign is E010236.

2

KVH has established the V7’s compliance with these requirements in multiple ESV applications

and years of interference-free operation. KVH has also established the V3’s compliance with

these requirements in the recently granted ESV application. Moreover, the operational

environment in the maritime context (including vessel pitch, yaw and roll as well as jarring

effects of waves in various sea states) is significantly harsher than on land (with smooth road

surfaces and truly stationary temporary fixed operations). Thus, the range of dynamic motion

affecting antenna pointing is far easier to address in the land mobile context.

KVH has verified the ability of the V7 to operate on land pursuant to LMSS STA

authority. This real-world operating experience, as well as the extensive technical demonstration

included herein, confirm the V7 complies with the Commission’s Ku-band VMES rules. The

recently authorized V3 terminal will operate in much the same manner as the V7 and will also

meet the Commission’s Ku-band VMES rules.

II. THE V7 AND V3 TERMINALS SATISFY THE COMMISSION’S VMES
REQUIREMENTS

As demonstrated below, the V7 and V3 terminals operate in compliance with the

Commission’s rules and policies governing Ku-band VMES operations.3

3
KVH has included regulatory compliance matrices in Section 4 of the Technical Exhibits for
the V7 and V3. In the context of preparing the cross-polarization spectral density tables required
by the Commission’s VMES rules, KVH discovered a minor, theoretical exceedance of the mask
for the V7 terminal in a 1.1 degree range at 14.0 GHz (only) when the network operates at its
maximum number of simultaneously-transmitting terminals (N=7 using an 18 MHz channel;
other transmit frequencies do not show a similar exceedance). KVH does not believe a waiver of
the VMES rules is necessary to address this theoretical exceedance, but identifies the issue out of
an abundance of caution. To the extent the Commission concludes that a waiver may be
necessary, KVH has requested a waiver of the Commission’s rules with respect to the minor
cross-polarization exceedance in Section II.E.1.b., infra.

3

also spread over the 18 MHz to 36 MHz channel and is overlaid onto the same transponder

spectrum using a technique called PCMA.4

A summary of the V7 terminals operating characteristics are set forth in Tables 1 and 2,

below. Additional information regarding the uplink transmission parameters for the 18 and 36

MHz bandwidth channels are included in the Technical Exhibit.5

Antenna diameter 0.6m
Type of Antenna Parabolic rear-fed
Peak Power (SSPA) 4 watts
Transmit Bandwidths 18, 27, 36 MHz
Transmit Gain 36.8 dBi at 14 GHz
EIRP 42.4 dBW
Transmit Data Rate 32 kbps to 512 kbps
Transmit Polarization Horizontal or Vertical
Transmit Max PSD <10 dBW/4kHz
Transmit Azimuth, 2.36°
Elevation Beamwidth
Receive G/T 13 dB/K minimum
Receive Bandwidth 500 MHz
Receive Polarization Dual Vertical and Horizontal

Table 1. V7 Terminal Operating Parameters

4
Paired Carrier Multiple Access (“PCMA”) is a proprietary technique developed by ViaSat for
its spread spectrum ArcLight service.
5
See Technical Exhibit 1, Section 3.

5

Antenna diameter 0.37 m
Type of Antenna Parabolic rear-fed
Peak Power (SSPA) 3 watts
Transmit Bandwidth 18, 36 MHz
Transmit Gain 33 dBi at 14 GHz
EIRP 38 dBW
Transmit Data Rate 32 kbps to 512 Mbps
Transmit Polarization Horizontal or Vertical
Transmit Max PSD <10 dBW/4kHz
Transmit Azimuth, 3.5° (symmetrical antenna)
Elevation Beamwidth
Receive G/T 10 dB/K minimum
Receive Bandwidth 500 MHz
Receive Polarization Dual Vertical and Horizontal

Table 3. V3 Terminal Operating Parameters

Azimuth Continuous coverage over full
360º
Elevation 10 to 80º antenna elevation

Position accuracy Conscan 0.6º RMS;
(AZ) 0.8º RMS in-motion accuracy;
Declared Maximum Pointing
Error: 1.5º
Dynamic Tracking Roll: +/-25° at 8 second period
capability Pitch: +/-15° at 5 second period
Yaw: +/-8° at 50 second period
Azimuth Turn rate: 12°/s and
15°/s2 acceleration

Table 4. V3 Terminal Antenna Control Parameters

C. Satellite Points of Communication, Hubs and Network Control Center

In the instant application, KVH requests authority to operate a network of up to 125 V7

and 125 V3 VMES terminals in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14.0-

8

14.5 GHz bands.6 KVH requests authority for its VMES terminals to communicate in the

extended Ku-band receive frequencies (10.95-11.2 GHz and 11.45-11.7 GHz bands) only with

the GE-23 satellite. The Commission authorized VMES receive operations in these bands in its

VMES Order.7 The terminals will communicate in conventional Ku-band frequencies with

ALSAT (including specifically AMC-15, AMC-21 and the GE-23), previously authorized for V7

and V3 ESV operations. Like KVH’s ESV network, the VMES network will be controlled by

the network control center in Carlsbad, California.8

D. Emissions Designators

KVH’s granted V7 LMSS authorization requested authority to operate the terminals over

channel bandwidths of 14 MHz and 27 MHz.9 The V7 ESV terminal was authorized to operate

over channel bandwidths of 22 MHz (transmit) and 30 MHz (receive).10 KVH seeks in the

instant application to operate over the bandwidths of 18 MHz and 36 MHz. The requested

emissions designators are as follows:

6
In the 10.95–11.2 GHz and 11.45–11.7 GHz frequency bands, KVH will not claim protection
from interference from any authorized terrestrial stations to which frequencies are either already
assigned, or may be assigned in the future. See 47 C.F.R. § 25.226(a)(7).
7
See Amendment of Parts 2 and 25 of the Commission’s Rules to Allocate Spectrum and Adopt
Service Rules and Procedures to Govern the Use of Vehicle-Mounted Earth Stations in Certain
Frequency Bands Allocated to the Fixed-Satellite Service, IB Docket No. 07-101, Report and
Order, FCC 09-64, n.1 (2009) (“VMES Order”). See also 47 C.F.R. §§ 25.202(a)(10); 25.226(a).
8
KVH maintains ultimate direction and control of its Ku-band VMES operations via a network
management agreement with ViaSat, Inc.
9
See IBFS File No. SES-STA-20091019-01338, Call Sign E030131, Exhibit A at 8. Only
communications with the GE-23 satellite will use a 27 MHz bandwidth channel.
10
See IBFS File No. SES-LIC-20081104-01450, Call Sign E090001. The authorized emissions
designators were 22M0G7D and 30M0G7D.

9

Satellite(s) Frequencies Emissions Designators
ALSAT 11.7-12.2 Receive 18M0G7D, 36M0G7D
14.0-14.5 Transmit 18M0G7D, 36M0G7D
GE-23 at 172° EL
(additional designator 18M0G7D, 27M0G7D,
and bands) 11.7-12.2 Receive 36M0G7D
18M0G7D, 27M0G7D,
14.0-14.5 Transmit 36M0G7D
10.95-11.2 Receive 27M0G7D
11.45-11.7 Receive 27M0G7D

E. Compliance with the Ku-band VMES Rules

The V7 and V3 terminals comply with Commission rules and policies designed to protect

other users of the Ku-band from harmful interference from VMES transmit operations.

1. Off-Axis EIRP Spectral Density Limits

The KVH VMES terminals will operate in accordance with the off-axis EIRP spectral

density limits for Ku-band VMES terminals in the Commission’s rules.11

a. The KVH VMES Antennas Comply with the VMES Off-Axis
EIRP Spectral Density Limits

The KHV VMESs will transmit using CRMA spreading12 over 18, 27 or 36 MHz channel

bandwidths. The small diameter KVH antennas do not meet the Commission’s Section 25.209

antenna pattern.13 However, the aggregate EIRP levels of the terminals do not exceed the limits

11
KVH notes a minor, theoretical exceedance of the cross-polarization limits in Section
25.226(a)(1)(i)(C) for the V7 when operating with the theoretical maximum number of
simultaneously transmitting antennas at 14 GHz (only). The V7 terminal complies with co-
polarization off-axis EIRP spectral density limits in both the azimuth and elevation plane. See
Section II.E.1.b., infra.
12
CRMA, or Code Reuse Multiple Access, is a ViaSat proprietary spread spectrum technique,
similar to CDMA, used in the ArcLight satellite system.
13
See V7 and V3 antenna gain plots in their respective Technical Exhibits, Section 6.

10

KVH has provided in the V7 and V3 Technical Appendices measured antenna gain data

required by Section 25.132 of the Commission’s rules and, pursuant to Section 25.226(a)(1)(i)

and (b)(1), the required tables.16 Table 1 contains the co-polarized E and H plane antenna

patterns for the parabolic antenna, the E and H plane EIRP charts and the Commission’s GSO

and Elevation masks. Table 2 provides the cross-polarized E and H plane antenna gain and EIRP

charts versus the Commission’s VMES off-axis EIRP spectral density limits.

The off-axis EIRP spectral density plots, and the antenna gain plots and tables provided

in the Technical Appendices, demonstrate that the V7 and V3 terminals comply with the

Commission’s two-degree spacing policies and the spectral density levels set forth in Section

25.226 of the rules with a minor, theoretical exception for the V7 (discussed in Section II.E.1.b.,

infra). Because the V7 otherwise complies with the off-axis EIRP spectral density limits

contained in Section 25.226(a)(1) of the rules and has been fully coordinated in the ESV context

and in the context of its prior land mobile STA, no further coordination is required for VMES

authorization.

b. Request for Waiver

In the context of preparing the cross-polarization spectral density tables required by the

Commission’s VMES rules, KVH discovered a minor, theoretical exceedance of the mask for the

V7 terminal in a 1.1 degree range at 14.0 GHz (only) when the network operates at its maximum

number of simultaneously-transmitting terminals (N=7 using an 18 MHz channel; other transmit

frequencies do not show a similar exceedance).17 KVH does not believe a waiver of the VMES

16
See Technical Exhibit 1, Section 1 and Technical Exhibit 2, Section 4.
17
KVH did not previously discover this theoretical anomaly because its V7 applications were not
prepared with the degree of granularity currently required of VMES and ESV applications.
KVH believes that this minor, theoretical exceedance would not require a waiver but, if the

17

rules is necessary, but identifies this issue out of an abundance of caution. To the extent the

Commission concludes that a waiver may be necessary, KVH has respectfully requests a waiver

of the Commission’s rules with respect to the minor cross-polarization exceedance.

The theoretical 1.6 dB exceedance could occur only if all seven V7 terminals were

transmitting simultaneously and in perfect conscan synchronization (i.e., pointed at their

maximum declared pointing error in exactly the same direction along the GSO arc towards a

victim satellite). As the Commission is aware, the V7 terminals operate using unsynchronized

circular conscans and thus the possibility of multiple terminals being in perfect alignment is so

remote as to be non-existent. Indeed, each V7 terminal is more likely to be pointed away from

the GSO arc than along it. Furthermore, the spectral density is reduced by 1.5 dB in the

extremely unlikely event that there are five terminals in perfect alignment and by 2.3 dB in the

similarly unlikely event that there are four terminals in such alignment.

Table 2 in Technical Exhibit 1 shows that between 6.8° and 7.9° (and -6.8° and -7.9° for

the circular antenna), the KVH aggregate emissions exceed the mask for cross-polarization by

1.6 dB or less and only at 14.0 GHz. The potential exceedance is limited to a 1.1 degree range

that peaks in a gap between neighboring satellites at two-degree spacing. Further, the minor

exceedance would be permitted for co-polarized emissions, but Section 25.226(a)(1)(i)(C) of the

Commission’s VMES rules does not contain the same 10 percent exceedance allowance at the

sidelobes for cross-polarization emissions.

KVH has been operating the V7 terminal for years without incidents of interference and

the V7 terminal individually operates in full compliance with the off-axis EIRP spectral density

Commission concludes otherwise, the V7’s multi-year record of interference-free operation
strongly supports such a waiver.

18

limits (including the cross-pol limit). Therefore, to the extent necessary and for the reasons

described above, good cause exists for waiver of Section 25.226(a)(1)(i)(C) of the Commission’s

rules.

2. VMES Terminal Antenna Pointing Control

The V7 and V3 terminals will meet the VMES off-axis EIRP spectral density limits with

a declared maximum antenna mispointing of 1.0° and 1.5°, respectively.18 Upon reaching their

declared maximum pointing errors, the terminals will inhibit transmission within 100

milliseconds and, out of an abundance of caution, will not resume until the pointing error value is

back to within the average pointing offset of each terminal (see below, 0.6º and 0.8º,

respectively).19

The antenna systems utilize a conical scanning function and rate gyros to stabilize the

antenna and keep it pointed properly at the desired satellite. The conscans are currently set to

worst case 0.4º and 0.6º from boresight, respectively. The additional dynamic pointing error for

the antenna accelerations during in-motion operation is expected to be approximately 0.2º. Thus

the total expected mean pointing error for each vehicle in motion, including both conscan and

dynamic error, is 0.6º and 0.8º, respectively.

The VMES V7 and V3 terminals utilize a motion-stabilized tracking antenna and a direct

sequence spread spectrum (“DSSS”) burst modem manufactured by ViaSat to access the satellite.

Each terminal will use the CRMA common spreading code and a random access method to

18
See 47 C.F.R. § 25.226(b)(1)(iv)(A).
19
See 47 C.F.R. § 25.226(b)(1)(iv)(B). Although KVH could resume transmission upon
bringing pointing offset within the declared maximum pointing errors of 1.0° and 1.5° (for the
V7 and V3, respectively), its system is conservatively designed to recommence transmissions
when the pointing offset reaches the mean pointing offsets of 0.6° and 0.8°, respectively.

19

access the satellite. CRMA is closely analogous to the more generally understood code division

multiple access (“CDMA”) multiple access method, but differs in that all terminals use a

common spreading code rather than a number of individual codes for each transmitter.

Individual bursts are distinguished by time difference of arrival. The use of this spreading

technique allows the EIRP spectral density for each VMES terminal to be significantly lower

than typical TDMA systems operating in Ku-band.

The KVH VMES network uses a spread spectrum multiple access technique whereby the

individual off-axis EIRP density of each VMES terminal is well below the maximum aggregate

network limit. Therefore, each antenna individually will not generate harmful levels of

interference even if the antenna were pointed directly at an adjacent satellite. Random pointing

errors across the KVH VMES fleet will not cause objectionable levels of adjacent satellite

interference because the antenna on each VMES will be pointing in a different direction with a

different error component. There is an extremely low probability that multiple antennas will be

mispointed at an adjacent satellite at the same time in such a way that results in harmful

interference. Because the pointing error is random and momentary, each VMES antenna actually

has a higher likelihood of being pointed away from the geostationary satellite arc than at an

adjacent satellite in the arc.

The following plots show how random pointing error adds up for the V7 terminal in

several cases. In the first plot, Figure 13, a number of different standard deviations of pointing

error are plotted: 1.666°, 1.0°, 0.6660, 0.5°, 0.333° and 0.166°. Each plot represents a long term

statistical sampling of 1,000,000 random errors for the specified standard deviation. The off-axis

EIRP spectral density mask is shown as adjusted to account for the spreading used by each

terminal. The ±12.1° of topocentric angle used for theta represent ±10° of geostationary satellite

20

arc. The reference dBi plot on the charts is representative of the average of the antenna pattern

for the topocentric angles to the geostationary arc from various locations in the coverage area.

The second plot, Figure 14, shows the same reference dBi plot representing the aggregate

population of terminals with no pointing error. A single terminal with 2° of pointing error is

shown. It can be seen that even when the terminal is pointed directly at an adjacent satellite, the

power density is well below the VMES off-axis EIRP density mask. In this case, the terminal’s

input power density has been reduced by an additional 11.8 dB from the network aggregate –

equivalent to a population of 15 co-frequency terminals transmitting simultaneously (using the

36 MHz emission).

Pointing Error Effects Across GEO Arc
(includes 0.4º Conscan)

40

35

30
Ref dBi
25 FCC Mask
1.666
1.000
dBi

20
0.666
0.500
15 0.333
0.166
10

5

0
12.1

10.9

9.7

8.4

7.2

6.0

4.8

3.6

2.4

1.2

0.0

1.2

2.4

3.6

4.8

6.0

7.2

8.4

9.7

10.9

12.1

Topocentric Theta (+/- 10 deg GEO)

Figure 13 - Aggregate Pointing Error for Several Standard Deviations

21

Pointing Error Effects Across GEO Arc for a
single ES mispointed by 2º in Azimuth

40

30

20

Ref dBi
dBi

10 FCC Mask
Single ES

0

-10

-20
12.1

10.9

9.7

8.4

7.2

6.0

4.8

3.6

2.4

1.2

0.0

1.2

2.4

3.6

4.8

6.0

7.2

8.4

9.7

10.9

12.1
Topocentric Theta (+/- 10 deg GEO)

Figure 14. Impact of a Single Terminal with 2° of Pointing Error

Figure 15 shows 15 co-frequency terminals transmitting simultaneously, each with random error

fitting the 0.2° standard deviation and with conscan active. The aggregate power summation of

all 15 terminals is also plotted along with the reference dBi and adjusted FCC mask.

22

Effect of Aggregate Pointing Error For 15 ES
(0.2º Stdev Pointing Error and 0.4º Conscan)

40
Ref dBi
FCC Mask
30 Series1
Series2
dBi or dBi Minus PSD Reduction

Series3
Series4
20
Series5
Series6
Series7
10
Series8
Series9
Series10
0
Series11
Series12
Series13
-10
Series14
Series15
Sum of ES
-20
12.1

10.9

9.7

8.4

7.2

6.0

4.8

3.6

2.4

1.2

0.0

1.2

2.4

3.6

4.8

6.0

7.2

8.4

9.7

10.9

12.1
Topcentric Theta

Figure 15 - Aggregate Pointing Error for 15
Co-Frequency Terminals with 0.2° Std Dev Error

The following plots show how random pointing error adds up similarly for the V3

terminal in several cases. In the first plot, Figure 16, the same standard deviations of pointing

error are plotted: 1.666º, 1.0º, 0.666º, 0.5º, 0.333º and 0.166º. The VMES mask is shown again

as adjusted to account for the spreading used by each terminal. The ±12.8º of topocentric angle

used for theta represent ±10º of geostationary satellite arc. The reference dBi plot on the charts

is representative of the average of the antenna pattern for the topocentric angles to the

geostationary arc from various locations across CONUS.

The second plot, Figure 17, again shows the reference dBi plot representing the aggregate

population of terminals with no pointing error. A single V3 with 2º of pointing error is

shown. It can be seen that even when the V3 is pointed directly at an adjacent satellite, the

power density is well below the Commission’s off-axis EIRP density mask. In this case the V3’s

23

This extremely conservative analysis firmly establishes that V7 and V3 will operate

consistent with the Commission’s two-degree spacing policies and will not cause harmful

interference to other Ku-band operations.

3. Compliance With Additional VMES Requirements

KVH will comply with the additional requirements for VMES applicants.

Section 25.226(a)(5), (b)(6) Points of Contact. The KVH points of contact for the

proposed VMES operations, available 24 hours, 7 days a week, with authority to cease all

emissions from the VMESs are:

Robert Bourget
KVH Industries, Inc.
Phone: 401.851.3830
Mobile: 401.864.8458
Email: rbourget@kvh.com

The KVH contact information for its network control station in Carlsbad, California is:

6155 El Camino Real
Carlsbad, San Diego County, CA 92009
Tel: 760-476-2583

For filing issues involving this authorization request please contact:

Carlos Nalda
Squire, Sanders & Dempsey (US) LLP
1201 Pennsylvania Ave, NW
Suite 500
Washington, DC 20004
Office: (202) 626-6659
Fax: (202) 626-6780
Cell: (571) 332-5626
Email: carlos.nalda@ssd.com

For technical issues involving this authorization request:

Kenneth G. Ryan, P.E., Skjei Telecom, Inc.
Regulatory Engineering Consultant
Office: (703) 917-4020
Fax: (703) 917-0098
Cell: (703) 919-0361

26

Email: ken@skjeitelecom.com

Section 25.226(a)(6), (b)(7) Recordkeeping. KVH will maintain, for each VMES

transmitter, a time-annotated record of the vehicle location, transmit frequency, channel

bandwidth and satellite used for at least one year. The location and time of all transmissions, at

time intervals no greater than every 5 minutes while the VMES is transmitting, will be stored on

a server at the hub. This information will be sent to the network control facility in Carlsbad, CA.

It will be available, as required by the Commission rules, to a coordinator, fixed system operator,

FSS operator, the NTIA or the Commission within 24 hours of the request.

Section 25.226(a)(7) Protection Claims. KVH will not claim protection from

interference from any authorized terrestrial stations to which frequencies are already assigned or

may be assigned in the future, in the 10.95-11.2 GHz and 11.45-11.7 GHz frequency bands.

Section 25.226(a)(8) Protection Limitation. KVH VMES terminals receiving in the

10.95-11.2 GHz, 11.45-11.7 GHz and 11.7-12.2 GHz bands shall receive protection from

interference caused by space stations other than the target space station only to the degree to

which harmful interference would not be expected to be caused to a 25.209-compliant antenna

and stationary at the location at which any interference occurred.

Section 25.226(a)(9) Loss of Reception. The KVH VMES terminals will automatically

cease transmitting within 100 milliseconds upon loss of reception of the satellite downlink signal.

Section 25.226(b)(4) Geographic Area of Service. KVH seeking authority to operate

its VMES network within the continental United States (CONUS), Alaska, Hawaii and the U.S.

territories and possessions.

Section 25.226(b)(8) Radiation Hazard. KVH has included radiation hazard analyses

for the V7 and V3 terminals with this application as Exhibits 3 and 4.

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4. Protection of Other Users in the 14.0-14.5 GHz Band

KVH’s operation of the V7 and V3 antennas will protect other users in the 14.0-14.5

GHz band consistent with the requirements of the Commission’s VMES rules.

Protection of Fixed-Satellite Service. As discussed above, KVH’s terminals will

operate in compliance with the VMES off-axis EIRP spectral density limits, even taking the

declared pointing accuracy values into consideration. The VMES limits are consistent with those

for routinely licensed VSAT earth stations and are consistent with the Commission’s two-degree

spacing policies.

Protection of Potential NGSO FSS Systems. KVH acknowledges that non-

geostationary orbit (“NGSO”) systems are also permitted to operate in the Ku-band. However,

no such systems are currently authorized. KVH will undertake adequate protection measures if

such systems are authorized in the future. In any event, the V7 and V3 terminals meet the

Commission’s required off-axis EIRP mask in directions other than the GSO arc.

Protection of Terrestrial Radio Services. KVH has examined current spectrum use in

the 14.0-14.5 GHz band and has determined that there are no active FCC-licensed terrestrial

services in this band in North America with which its proposed operations would potentially

conflict.

Protection of the Radio Astronomy Service. VMES applicants must coordinate

through the National Science Foundation (“NSF”) any operations in the 14.47-14.5 GHz band

within specified distances from an expanded number of radio observatory sites. The KVH

VMES terminals will not enter a coordination area (i.e., within the specified distances from any

current or future radio astronomy sites) absent completion of coordination and associated

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notification under Section 25.226(d) of the Commission’s VMES rules. KVH will use Global

Positioning Satellite (“GPS”) location technology to ensure compliance with this requirement.20

Protection of Space Research Service. KVH recognizes the utilization of the frequency

band from 14.0-14.05 GHz and the possible use of the band from 14.05-14.2 GHz allocated to

the National Aeronautics and Space Administration (“NASA”) Tracking and Data Relay Satellite

System (“TDRSS”) for space research conducted at White Sands, New Mexico and Blossom

Point, Maryland. For purposes of this application, KVH will avoid VMES operation within 125

km of these earth stations until a coordination agreement is executed with NASA.21 KVH will

use GPS location technology to ensure compliance with this requirement.22

III. CONCLUSION

The V7 and V3 terminals are highly efficient and affordable, and have proven their

ability to operate consistent with the Commission’s rules and policies in the ESV and land

mobile context. Indeed, the V7 and V3 terminals have been fully licensed by the Commission as

ESVs in the analogous maritime context. Grant of a long-term VMES network license will serve

the public interest by extending the reach of affordable and reliable vehicular broadband

communications to first responders, newsgathering vehicles, public transportation (e.g., trains),

leisure travelers and other users throughout the United States. Accordingly, the Commission

should grant the instant VMES application at the earliest practicable time.

20
See 47 C.F.R. § 25.226(e).
21
See 47 C.F.R. § 25.226(c).
22
See 47 C.F.R. § 25.226(e).

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Document Created: 2011-04-29 10:43:19
Document Modified: 2011-04-29 10:43:19

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