Attachment Georgia Reply - 2071

Georgia Reply - 2071

REPLY submitted by Dow Lohnes PLLC

Reply to Opposition of ViaSat, Inc.

2012-01-31

This document pretains to SES-LIC-20111027-01267 for License on a Satellite Earth Station filing.

IBFS_SESLIC2011102701267_938781

Before the OR‘G‘NAL FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Application by ViaSat, Inc. ) SES-LI%I: — To Operate Earth Station Y E11015 %)6}.&%%68&‘5[7‘:0 In Duluth, Georgia ) in the 2085.0 —2086.5 MHz band ) JAN 3 1 2017 To: Office of the Secretary Federal g%’gg‘(;‘ffigg“;’;‘;;‘;?ymissmn Attn: Chief, International Bureau REPLY OF GEORGIA TELEVISION COMPANY AND MEREDITH CORPORATION TO OPPOSITION OF VIASAT, INC. Pursuant to Section 25.154(d) of the Commission‘s rules, Georgia Television Company and Meredith Corporation (together, the "Television Broadcasters") hereby submit this Reply to the Opposition of ViaSat, Inc. ("ViaSat").‘ In their Petition to Deny, the Television Broadcasters demonstrated that ViaSat‘s proposed earth station (the "Earth Station") would cause harmful interference to the electronic news gathering ("ENG") operations of both WSB—TV and WGCL— TV. Rather than eliminate this interference, ViaSat‘s Opposition faults the Television Broadcasters for being "categorical[ly]" opposed to receiving interference and then offers several flawed mitigation strategies that offer little real—world protections to the Television Broadcasters‘ ENG operations." The Television Broadcasters are willing to coordinate for any realistic, noninterfering proposal, but the burden is on ViaSat to present the Television Broadcasters with such a proposal. To date, it has not. 1 47 C.F.R. § 25.154(d). 2 ViaSat, Inc., Opposition, at 3, 8 (filed Jan. 19, 2012).

1. THE BURDEN IS ON VIASAT TO PRESENT THE TELEVISION BROADCASTERS WITH A WORKABLE, NONINTERFERING PROPOSAL FOR ITS EARTH STATION. ViaSat spends much of its Opposition criticizing the Television Broadcasters for being unwilling to engage in frequency coordination. ViaSat‘s claims, however, simply are not true. The Television Broadcasters are willing (and have always been willing) to coordinate any proposal that properly accounts for the day—to—day realities in the ENG 2 GHz band. The burden, however, falls on ViaSat to present the Television Broadcasters with such a proposal that will not interfere with existing 0perations.3 The Commission‘s coordination rules do not require incumbent licensees to accept whatever proposal may be thrown in front of them. Rather, at a minimum, any proposal must protect the Television Broadcasters ENG receive sites.* This is particularly true here because, as ViaSat acknowledges, its Earth Station will operate on a secondary, non—interfering basis. To date, however, the proposals that ViaSat has put forth all are likely to cause interference to the Television Broadcaster‘s ENG facilities. IL. THE EARTH STATION WILL CAUSE HARMFUL INTERFERENCE TO THE TELEVISION BROADCASTERS‘ ENG RECEIVE SITES. In their Petition, the Television Broadcasters demonstrated that the Earth Station was likely to cause interference to the Television Broadcasters‘ ENG operations. To alleviate these interference concerns, ViaSat announced in its Opposition that it would reduce its power by 10 dB. ViaSat‘s revised engineering analysis, however, falls well short of the requirements in the Commission‘s rules and is fundamentally flawed. 3 AstroVision Int‘l, Inc., 15 FCC Red 22299, 22304 (IB 2000) ("AstroVision will need to demonstrate in its Earth station application how it plans to operate in order to protect users in the primary and secondary services, operating on these proposed TT&C uplink frequencies."). * Amendment ofPart 2 ofthe Commission‘s Rules to Allocate Spectrum Below 3 GHzfor Mobile and Fixed Services to Support the Introduction ofNew Advanced Wireless Services, Including Third Generation Wireless Systems, 21 FCC Red 4441, 4452 (2006) ("[T}he protection of BAS TVPU ENG RO sites . . . must be demonstrated."). L2 .

ViaSat‘s engineering analysis dramatically understates the potential for interference to the Television Broadcasters‘ ENG operations. To prove that it will not cause interference, ViaSat analyzes the hypothetical desired and undesired signal strength from just five potential transmit locations in the Atlanta market. ViaSat acknowledges that in several of the cases the undesired signal was above the receiver noise floor, but claims this is acceptable because the desired signal strength from these five locations was sufficiently strong to overcome the undesired interference. ViaSat, however, does not address the millions of other potential transmit locations within the Atlanta market and the desired and undesired ratios from those locations. ViaSat‘s interference analysis is woefully lacking and unconvincing. Using desired and undesired signal strength is inappropriate for mobile transmitters. It is impossible to predict in advance the desired signal strength for a mobile ENG truck. An ENG truck can transmit from an infinite number of locations in the heart of or on the fringes of the Atlanta market. At times, the desired signal strength will be strong because the path to the ENG receive site is a few miles and unobstructed. At other times, it will be weak. Trees, buildings, or other obstructions may block the path to the receive site. Breaking news may occur thirty or more miles from the nearest ENG receive site, or it may occur in downtown Atlanta where an ENG truck would be surrounded by tall buildings. In these very common instances, the desired signal strength will be substantially lower than the minimum assumed by ViaSat‘s rudimentary analysis. In those cases, the ViaSat Earth Station would cause harmful interference and prevent the Television Broadcasters from delivering live breaking news coverage of an important event in the local community. Because of the inherent mobile nature of ENG facilities, the Commission‘s interference rules do not rely on desired and undesired interference ratios for ENG facilities. Instead, Section 101.105 of the Commission‘s rules sets the interference criteria for microwave facilities by 13 .L

referring to the Telecommunications Industry Association Telecommunications Bulletin TWB 10, "Interference Criteria," which specifies a maximum interference threshold of 1 dB of degradation to an ENG receive site." As the attached Engineering Statement demonstrates, even with its reduced power level, ViaSat‘s Earth Station substantially exceeds the maximum interference degradation standard required by the Commission‘s rules." In practice, when performing local coordination, the broadcast industry and other 2 GHz earth station applicants have settled on an even more stringent interference criteria than that set forth in the Commission‘s rules. When the Commission ordered the Department of Defense to relocate its tracking, telemetry, and commanding earth stations to the 2 GHz band, the Society of Broadcasting Engineers and the Department of Defense negotiated a mutually beneficial frequency coordination Memorandum of Understanding.‘ The DoD MOU settled on a maximum interference degradation standard of 0.5 dB for ENG receive only sites." The Commission has subsequently acknowledged that 0.5 dB is an appropriate standard for measuring ENG interference." Regardless of whether the Earth Station must satisfy the 1 dB standard in Section 101.105 or the industry standard of 0.5 dB, the attached Engineering Statement demonstrates that the Earth Station fails to properly protect the Television Broadcasters‘ ENG operations. * 47 C.F.R. § 101.105(a)—(c). 6 See Exhibit A. 7 See SBE/DoD Memorandum of Understanding: 2025—2110 MHz Spectrum Sharing (Apt. 30, 2009) ("DOD MOU"). 8 iSee id. ° Amendment ofPart 101 ofthe Commission‘s Rules to Facilitate Use ofMicrowave for Wireless Backhaul & Other Uses and to Provide Additional Flexibility to Broad. Auxiliary Serv. & Operational Fixed Microwave Licensees.26, FCC Red 11614, €25, n. 91 (2011). —4_

III. VIASAT‘S PROPOSED MITIGATHON TECHNIQUES WILL NOT PROTECT THE TELEVISION BROADCASTERS FROM INTERFERENCE,. ViaSat offers four potential mitigation techniques to protect the Television Broadcasters from harmful interference, but each technique is inadequate and unlikely to offer the necessary protections to the primary ENG facilities in the 2 GHz band. First, ViaSat has offered to reduce its power by 10 dB, but as noted above, even with the new reduced power, the Earth Station still exceeds the maximum interference degradation standards for ENG receive sites. Second, ViaSat suggests it might be willing to restrict the elevation angles and azimuths for the Earth Station to protect the Television Broadcasters‘ receive sites. It is extremely unlikely, however, that this proposal would reduce the interference sufficiently to fall below the minimum degradation standards. The attached Engineering Statement already assumes 30 dB of suppression from antenna pointing, yet even with this assumption the Earth Station still fails the interference threshold at the Richland tower receive site by almost 50 dB."" ViaSat‘s third mitigation technique — limiting use of the Earth Station to noon and midnight — does not realistically account for how and when the Television Broadcasters use their ENG facilities. WSB—TV broadcasts local news at noon and is very likely to be using one or more ENG trucks at that time. Moreover, both WSB—TV and WGCL—TV must cover breaking news when it happens. The Television Broadcasters cannot predict when the next breaking news event will oécur, but it is very likely that they will need to use their ENG facilities at the same time ViaSat proposes to operate the Earth Station. ViaSat‘s fourth and final mitigation technique — offering to cease operations upon notice from the Television Broadcasters — provides little real world protection. As an initial matter, given the Earth Station‘s secondary status in the 2 GHz band, ViaSat‘s proposed mitigation 10 See Exhibit A.

technique is actually a requirement of operating in the 2 GHz band. Regardless, in the fast paced local news business, ViaSat‘s concession to immediately cease operations provides little comfort. When covering breaking news, a broadcaster must know that its ENG operations will work. By the time a local reporter discovers that interference has interrupted live coverage and the local engineer is able to uncover the cause, it often is too late. The shot is lost and the newscast must move to the next story. Even assuming ViaSat immediately cooperates with any request to cease operations, under the best of cirecumstances, it will take several minutes for the local engineers to discover the source of the problem, call ViaSat, and convince ViaSat to cease operations. By then, it may be too late and the interference will have prevented timely reporting of breaking news.

CONCLUSION ViaSat‘s Earth Station presents a substantial risk of harmful interference to the Television Broadcasters‘ ENG facilities. Although ViaSat has suggested that it is willing to mitigate the interference by reducing power or limiting its operations, none of ViaSat‘s proposals would provide the Television Broadcasters with sufficient protections to ensure continued, reliable use of their primary ENG facilities. ViaSat cannot demonstrate that its Earth Station complies with the Commission‘s interference rules. The Commission, therefore, must deny the application. Respectfully submitted, GEORGIA TELEVISION COMPANY AND MEREDITH ORPORATION Mlchael Béslle Robert]. Folliard, III Their Attorneys DOW LOHNES PLLC 1200 New Hampshire Avenue, NW Suite 800 Washington, D.C. 20036 (202) 776—2000 January 31, 2012

EXHIBIT A Engineering Statement

du Treil, Lundin & Rackley, Inc. Consulting Engineers ENGINEERING STATEMENT IN SUPPORT OF REPLY GEORGIA TELEVISION COMPANY AND MEREDITH CORPORATION ATLANTA, GEORGIA This Engineering Statement was prepared on behalf of Georgia Television Company and Meredith Corporation, licensees of television broadcast stations WSB—TV and WGCL—TV, respectively, both in Atlanta, Georgia. This statement was prepared in Reply to the Opposition of ViaSat, Inc. to the Petition to Deny filed by Georgia Television Company and Meredith Corporation to the ViaSat, Inc. application operate a satellite earth station in the 2 GHz broadcast auxiliary band. Background Georgia Television Company and Meredith Corporation are the licensees of broadcast auxiliary stations KR9903 and KC62919, which are authorized for operation in the broadcast auxiliary band allocated from 2025 to 2100 MHz. These broadcast auxiliary stations are employed for electronic news gathering (‘ENG®) by mobile vehicles. These stations utilize multiple receive locations throughout the region to ensure reception capability from even the most remote or difficult mobile transmission locations in the market. The receive locations for these stations are summarized as follows in the table below:

du Treil, Lundin & Rackley, Inc. Consulting Engineers Page 2 Location Name Latitude Longitude Antenna Height (dd—mm—ss)(NAD83) (dd—mm—ss)(NAD®83) (m AGL) Westin Plaza Hotel 33—45—34.0 84—23—18.1 220.4 Richland Tower 33—48—27.0 84—20—27.0 304.8 Fox Tower 34—07—32.0 83—51—32.0 271.3 Blackjack Tower 33—58—19.2 84—30—08.3 76.2 Newnan Tower 33—24—41.0 84—49—47.8 304.8 The ENG operators depend on the sensitivity of the receivers at each of these locations to complete their mobile ENG transmissions, which unlike normal fixed link situations may not have proper path clearances and/or may involve partial obstructions from trees and buildings. The sensitivity of the receiver will depend on the digital mode of operation, which also affects the carrier—to—noise required; and thus, the potential for interference into the receiver. For purposes of this analysis, the digital mode of operation that results in the highest level ofinterference vulnerability has been assumed, which is the 64QAM mode. Threshold to Interference of ENG Receivers Based on the TIA/EIA Telecommunications Systems Bulletin, TSB10—F, Interference Criteriafor Microwave Systems, Annex B, the determination of allowable interference is generally based on the Threshold—to—Interference (T/) ratio that results is a threshold degradation of 1 dB. In this case the ENG receivers have a given sensitivity

du Treil, Lundin & Rackley, Inc. Consulting Engineers Page 3 level of —87 dBm" in a 64QAM modulation density mode. Based on data provided by the equipment manufacturer, the required carrier—to—noise ratio in this mode is 21.0 dB. For this case, the T/I ratio would then be calculated to be 27 dB for a 1 dB degradation level." The threshold signal level for interference into the ENG receivers is thus calculated to be as follows: I = —87 dBm — 27 dB = —114 dBm This means that in order to meet the threshold 1 dB degradation to the ENG receiver, the incoming interfering signal level should not exceed —114 dBm. This is irrespective of what level might be received from the ENG transmitter, other than it must be assumed that the signal received from the ENG transmitter is at the minimum threshold level of —87 dBm. Evaluation of Interference from the Proposed ViaSat, Inc. Transmitter ViaSat, Inc. proposes operation of its earth station at its facility in Duluth, GA. The parameters of the proposed operation are summarized as follows: Geographic coordinates (NAD83) 33—57—47.5 N.L. / §4—05—45.5 W.L. Site Elevation 284.0 m AMSL Antenna type 7.3 meter dish Antenna gain 41.5 dBi Antenna radiation center height 5.9 m AGL / 289.9 m AMSL Transmitter power input to antenna 1.7 W (+32.3 dBm) * The term dBm references decibels relative to 1 milliwatt of power. * See Annex B of TIA/EIA TSB10—F for details on the calculation of the T/ ratio figure. * It is noted that a 0.5 dB degradation protection level would require a T/I ratio of 30 dB and a threshold for interference into the ENG receivers of —117 dBm.

du Treil, Lundin & Rackley, Inc. Consulting Engineers Page 4 Emission designator 128KGID Emission bandwidth 128 kHz The first step in evaluating the interference from the ViaSat, Inc. earth station is a study of the terrain from the transmitting antenna location to each of the victim ENG receive locations. Terrain profiles from the ViaSat, Inc. earth station location to each of the ENG receive locations were prepared using the high resolution U.S.G.S. 1—second terrain database. These profiles are included herein as Figures 1 through 5. Inspection of the terrain profiles indicates that there is a line—of—sight path from the ViaSat, Inc. earth station antenna to the Richland receiving antenna of the ENG system. This means that for this location free—space propagation losses should be considered for the evaluation of interference. Diffraction losses due to terrain obstructions would not be considered. It is noted that the Technical Analysis included with the ViaSat, Inc. Opposition indicates that there is 30 to 50 dB of diffraction loss on all of the radials from the earth station to the receiving antennas." This seems to be based on a 3.7—meter ‘obstruction‘ occurring at a distance of 0.00 km on all of the paths. There is no justification for this obstruction and there appears to be no basis for this. In fact, given that the ‘obstruction‘ occurs at distance of 0.00 km at the same approximate height listed — . — — — — ** for the receive antenna suggests that the obstruction indication is erroneous. A topographic map showing the ViaSat, Inc. earth station transmitter site location and the radial directions to each of the ENG receive antennas was prepared by $ See Exhibit B of Opposition of ViaSat, Inc., with specific reference to the *Pathloss Calculation‘ sheet included for each ENG receive location. ‘ ** It is noted that the geographic coordinates of the Fox tower location shown in the Technical Analysis included with the ViaSat, Inc. Opposition are in error. The latitude for the Fox tower site shown therein is 33—07—32. However, the correct latitude is 34—07—32. While this completely changes the orientation and distance from the earth station site, using the correct coordinate data to the Fox tower site still shows a terrain obstruction from the earth station. See Figure 3 herein.

du Treil, Lundin & Rackley, Inc. Consulting Engineers Page 5 the undersigned and is shown at Figure 6 herein. The topographic map data confirms the close—in terrain profile results shown in Figures 1 through 5. In addition, the topographic map clearly shows the absence of any terrain elevations that would cause a 3.7—meter terrain obstruction from the earth station to any of the ENG receive antennas. For the ENG receive site location with a line—of—sight path from the ViaSat, Inc. earth station antenna, a free—space interference analysis was conducted. The results of the analysis for this ENG receive location are summarized as follows: Interference Evaluation into the Richland Site Azimuth from earth station 232.7°True Distance to ENG receive location 28.5 km Antenna gain toward ENG receiver‘" 11.5 dBi Transmitter power at antenna 32.3 dBm EIRP toward ENG receive antenna 43.8 dBm Free—space path loss 127.9 dB Receive antenna gain 20 dBi Received interfering signal level —64.1 dBm Threshold level for interference to ENG —114.0 dBm Interference result Fail threshold by 49.9 dB As indicated above, the Richland receive site is subject to interference exceeding the permissible level by 49.9 dB. This means that this receive location could be subject to *‘ A transmitting antenna discrimination factor of 30 dB was estimated under the assumption that the earth station would transmit at an elevation at low as 5° above the horizon. The attached Figure 7 is a copy of the earth station antenna pattern submitted with the ViaSat, Inc. earth station application, which is included for reference.

du Treil, Lundin & Rackley, Inc. Consulting Engineers Page 6 significant levels of interference from the ViaSat, Inc. earth station operation, which + . . ++ could render this receive site unusable.** Conclusion In conclusion, a careful analysis of the terrain and interference potential from the proposed ViaSat, Inc. earth station facility at Duluth, Georgia indicates that there will be line—of—sight to at least one of the five subject ENG receive locations employed by WSB—TV and WGCL—TV; and that this particular receive location could be subject to significant levels of interference from the earth station operations. Louis R. du Treil, Jr., P.E. du Treil, Lundin & Rackley, Inc. 201 Fletcher Ave. Sarasota, Florida 34237—6019 Phone: 941—329—6004 January 30, 2012 4 The Technical Analysis included with the ViaSat, Inc. opposition concedes that even its calculations show cases where the undesired signal from its earth station would be above the calculated noise floor. This alone is sufficient to determine that the earth station emissions would fail the T/I ratio for the interference degradation criteria of 1 dB and cause objectionable interference.

Figure 1 Path Distance: 35.25 km. Tx LOS Path Inclination: 0.4126 deg. Tx LOS Path Inclination: —0.0648 deg. 100— poortt—tg—T——T—T—T—TaorT—T—T|TT—TGT—T—Tg—T—TGT—TfoGTOTT—T—TT—T—GTGTGTTfaT—GTT—TT—q—G—TtTt—T—Tf—T—T—T—T 3———L—ne wo—}——#’—"‘f |—so0 M 500— |—500 0 t _ |— 0 r 400—) |—400 8 300— —300 ~% *———————AT1 ; e TT T TT ; F4A 7 t t & TT g+T T T T 4 4+ C oC 5 kt t T C T &T 5 TT T T44 TT T T &oh +T +411 —® ViaSat 33°57 47.50" N Kilometers 33°45¢ 34.00" N 084° 05‘ 45.50" W 084°23‘ 18. 10" W Elevation 284.0 m. Elevation 323.9m. Ant. AGL — TRx/Div 5.9/0.0/0.0 m. Ant. AGL — Tx/Rx/Div 0.0/220.4/0.0 m. Frequency — Tx 0.00000 MHz Frequency — Tx 0.00000 MHz Azimuth 230.211 deg T Azimuth 050.048 deg T KEY: Profile ¥—# K=48,.F=08F1 TERRAIN PROFILE FROM VIASAT EARTH STATION TO WESTIN PLAZA HOTEL SITE.

Figure 2 Path Distance: 28.48 km. Tx LOS Path Inclination: 0.5672 deg. Tx LOS Path Inclination: 0.0343 deg. re—C————G=—P__I~ J 1t T |T—7 TT —TOT—T—Ot—Tt—t—q—t—t—Tt ToA TtAAA —t—t—t y +t ——t T —+~ I—700 so0 |—s00 \ J soo— —500 400—| |—400 300—}~ |—300 200 t—rt—po—t—rt poTo—rot gouo—rot—for—r—tgor—t—t <goro—r—Tfor To T TT T —TO—TgTo—r—tg—T—T T L4 T T g T T T £ 200 vissat Richland 2293 33°5747.50" N Kilometers 33°48 27.00" N 084° 05‘ 45.50" W 084° 20‘ 27.01" W Elevation 284.0 m. Elevation 267.0 m. Ant. AGL — Tx/Rx/Div 5.9/0.0/0.0 m. Ant. AGL — Tx/Rx/Div 0.0/304.8/0.0 m. Frequency — Tx 0.00000 MHz Frequency — Tx 0.00000 MHz Azimuth 232.748 deg T Azimuth 052.612 deg T KEY: Profile K=413 K=48, F=0.6°F1 TERRAIN PROFILE FROM THE VIASAT EARTH STATION TO THE RICHLAND TOWER SITE.

Fiqgure 3 Path Distance: 28.35 km. Tx LOS Path Inclination: 0.4931 deg. Tx LOS Path Inclination: 0.0425 deg. TOT—T—T T—T—T—|T TT T TT [ T—TOT—|T TOTOT—|T T —TOT—|OTOT TT TOTOT T T OTOT [ OTTOTOT TTOT—TOTATO—T q TOt—T— 300— \—ano 800— |—800 100— |—700 600— |—soo 500— |—s00 400— |—400 300— |—300 200 T T 4 * T T U l T T T & T & T T 4 40 I T U 1{2 T T U 4‘ T T U JG £ K d JG T T T i T T04 JI T To U JA I _T T JG T T U J% 200 a OX kevs ViaSat 33°5747.50° N Kilometers 34°0732.00° N 084° 05 45.50" W 083°51° 32.00° W Elevation 284.0 m. Elevation 263.0 m. Ant. AGL — Tx/R/Div 5.9/0.0/0.0 m. Ant. AGL — Tx/Rx/Div 0.0/271.3/0.0 m. Frequency — Tx 0.00000 MHz Frequency — Tx 0.00000 MHz Azimuth 050.492 deg T Azimuth 230.625 deg T KEY: Profile K=40 K=48, F=0.6°F1 TERRAIN PROFILE FROM THE VIASAT EARTH STATION LOCATION TO THE FOX TOWER SITE.

Figure 4 Path Distance: 37.57 km. Tx LOS Path Inclination: 0.269 deg. Tx LOS Path Inclination: —0.1623 deg. Tt ————gj———i—tg———t—t—tj———tTt—G—ttttT—ti—ttg—T—T—TtTttTT—TT—T—tj—Tt——t—t t 1 700— |—700 sa0— |—600 500— |—500 400—I |—400 300— |—s00 200 T T TT 5 TT TT t TTE T OTAI 5 TT TTA 7 TT TTA i TT T T To TOR TT TTA 4 T TTA & TT TTA 4 1 F913 & T T T TT $ 1 for 109 * misoase: T T U 200 ¥iatat 33°5747.50° N Kilometers 33°58 19.20" N 084° 05‘ 45.50" W 084°30‘ 08.30" W Elevation 284.0 m. Elevation 390.4 m. Ant. AGL — Tx/R/Div 5.9/0.0/0.0 m. Ant. AGL — Tx/Rx/Div 0.0/76.2/0.0 m. Frequency — TX 0.00000 MHz Frequency — Tx 0.00000 MHz Azimuth 271.603 deg T Azimuth 091.376 deg T KEY: Profile K=4B K=4B.F=06F TERRAIN PROFILE FROM THE VIASAT EARTH STATION LOCATION TO THE BLACKJACK TOWER SITE.

Figure 5 Path Distance: 91.53 km. Tx LOS Path Inclination: 0.1679 deg. Tx LOS Path Inclination: 0.0193 deg. T mo—/H TJTTTT7 I T I TTTT|TTTTTITTTTT|T I I I TT TTTTJTTTTTTTTTTITTTTT]TT I I I l CTJTTTT I T I TTTT|ITTTT|TTTTTITTT I I I \'\L\—sm 700— I—700 600— t—600 M I— 0 7 t 500— |—soo e r _ (— $ 400— |—400 2t s L t] [3 " |—300 206 Illlk{lllhwllk\\HioHHiHH*III\Jsl\IIAOIIIIJSIIH*\H1J5|1H*I\\IJSIH\%HH#HH*HIIJSIIHI*\ 200 ewnan ViaSat 33°57 47.50° N Kilometers 33°24‘ 41.00" N 084° 05 45.50" W 084°49‘ 47.80" W Elevation 284.0 m. Elevation 253.2 m. Ant. AGL — TR/Div 5.9/0.0/0.0 m. Ant. AGL — Tx/Rx/Div 0.0/304.8/0.0 m. Frequency — TX 0.00000 MHz Frequency — Tx 0.00000 MHz Azimuth 228,239 deg T Azimuth 047.832 deg T KEY: Profile K=453 K=43,F=06F1 TERRAIN PROFILE FROM THE VIASAT EARTH STATION LOCATION TO THE NEWNAN TOWER SITE.

| Proposed ViaSat, Inc. Earth station (2086 MHz) 33—57—47.5N/84—05—45.5W f } 4A L. fTo Blackjack\\‘gee——_ A 1 km circle for reference 24 _ fA | | }B(m}vng USGS Topographic Map Luxomni, GA (1992) Contour interval: 20 ft Meters TOPOGRAPHIC MAP OF THE PROPOSED VIASAT, INC. EARTH STATION TRANSMITTER LOCATION AND THE RADIAL DIRECTIONS TO THE PROTECTED ENG RECEIVERS duTreil, Lundin & Rackley, Inc. Sarasota, Florida

©001407KSAT7.3M AntennaS/N28344XEfor P/N 1103739 111756 Tested per ATP1112257 Test No.:PM :\ Radiation Patterns 2.073.0Hz. Xmit.Pol:: RHC,Rev.Pol.:RHC El Plane,+ 45%,80dB scale, @ LNA input Jackson CountyRangeFacility ElevatedRangew8 ft. Xmit. Engineer: AZuevski Assoc.: M.Lipham July,2010 ‘Meas. No.: 9 DATE ENGR 18714 NC El o REMARKS PROJECT & E+ 3 1 jatiqf t r[le (oet il_n_ L eanbt4

CERTIFICATE OF SERVICE I, Rayya Khalaf, hereby certify that on this 3 1st day of January 2012, I caused a copy of the foregoing Reply to Opposition to Petition to Deny to be served on the following by first class mail: John P. Janka Elizabeth R. Park Jarrett Taubman Latham & Watkins, LLP 555 11"" Street, NW Suite 1000 Washington, DC 20004 Rayy ala


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