V11 C-band 1_65 May

Section 1.65 Notification submitted by KVH Industries, Inc.

Section 1.65 Letter

2012-05-07

This document pretains to SES-LIC-20120328-00307 for License on a Satellite Earth Station filing.

IBFS_SESLIC2012032800307_951096

Squire Sanders (US) LLP 1200 19th Street, NW Suite 300 Washington, D.C. 20036 O +1 202 626 6600 F +1 202 626 6780 squiresanders.com Carlos M. Nalda T +1 202 626 6659 carlos.nalda@squiresanders.com May 7, 2012 Marlene Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Application of KVH Industries, Inc.; File Nos. SES-LIC-20120328-00307 (Call Sign E120061) and SES-MOD-20120104-00005 (Call Sign E090001) Dear Ms. Dortch: KVH Industries, Inc. (“KVH”), pursuant to Section 1.65 of the Commission’s Rules, 47 C.F.R. § 1.65, hereby submits additional information of decisional significance for association with the above-captioned proceedings. In early January 2012, KVH commenced the licensing process for it latest maritime satellite communications innovation – the dual-band V11 ESV terminal. This “game changing” 1m C/Ku-band ESV terminal builds on KVH’s well-tested miniVSAT technology and has been extremely well-received by customers, with a significant number firm orders now under contract. KVH anticipates shipping V11 terminals to customers in Q2 2012 and commencing commercial operations at the beginning of Q3 2012. KVH believes this timing should not be an issue for the Ku-band authorization (File No. SES-MOD-20120104-00005; Call Sign E090001) since its application received no comment or opposition during the public notice period and involves no significant new licensing issues. KVH’s Ku-band network (including several smaller terminals) is fully authorized and has operated for years in compliance with the Commission’s ESV rules. Similarly, subject to potential comment by interested parties, KVH submits that it C-band application (File Nos. SES-LIC-20120328-00307, Call Sign E120061), which requests authority to operate beyond 200 km from the U.S. coast line and offshore terrestrial stations, may be processed rapidly since there is no potential for interference into C-band terrestrial stations. 37 Offices in 18 Countries Squire Sanders (US) LLP is part of the international legal practice Squire Sanders which operates worldwide through a number of separate legal entities. Please visit squiresanders.com for more information.

Squire Sanders (US) LLP May 7, 2012 Two unique aspects of the C-band application can be addressed through appropriate license conditions, which KVH hereby submits for the Commission’s consideration and with which it hereby agrees to comply. First, like the previously authorized Ku-band V3 terminal, the antenna aperture used on the V11 is smaller than that specified in ITU-R Resolution 902. The Commission should include a condition similar to Condition 300 (below) included in the V3 license to ensure that the V11 may operate internationally. 300 - With respect to antenna size and pointing accuracy, licensee is authorized to operate in accordance with Article 4.4 of the ITU Radio Regulations. The operations authorized herein shall not cause harmful interference to, and shall not claim protection from harmful interference caused by, a station operating in accordance with the provisions of the ITU Constitution, the ITU Convention, and the ITU Radio Regulations. The operations authorized herein are otherwise consistent with ITU provisions. Second, a waiver of the 300 gross ton vessel size limitation designed to protect C-band microwave links is appropriate because the V11 will not operate within 200 km of such links. Rather, the V11 will operate at Ku-band in this region to avoid any potential for interference into terrestrial operations. KVH suggests the following license condition to implement this operational restriction. XXXX - A waiver of 47 C.F.R. §25.221(a)(8) is GRANTED to permit operation in the 5925-6425 MHz (Earth-to-space) and 3700-4200 MHz (space-to-Earth) frequency bands on vessels smaller than 300 gross tons, subject to the limitation that the remote terminals shall not operate within 200 km of the U.S. coastline or offshore fixed service links operating in the 5925-6425 MHz band. Please feel free to contact the undersigned with any questions you may have or if KVH can provide any additional information to facilitate expeditious action on its applications. Sincerely, Squire Sanders (US) LLP /s/ Carlos M. Nalda Carlos M. Nalda Counsel for KVH Industries, Inc. 2


Document Created: 2012-05-07 16:08:15
Document Modified: 2012-05-07 16:08:15
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