Aero Ex Parte Submis

SUPPLEMENT submitted by ViaSat, Inc.

Supplement 11-5-2012

2012-11-05

This document pretains to SES-LIC-20120427-00404 for License on a Satellite Earth Station filing.

IBFS_SESLIC2012042700404_973742

555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004-1304 Tel: +1.202.637.2200 Fax: +1.202.637.2201 www.lw.com FIRM / AFFILIATE OFFICES Abu Dhabi Moscow Barcelona Munich Beijing New Jersey Boston New York Brussels Orange County November 5, 2012 Chicago Paris Doha Riyadh Dubai Rome Frankfurt San Diego VIA ELECTRONIC FILING Hamburg San Francisco Hong Kong Shanghai Houston Silicon Valley Ms. Marlene H. Dortch London Singapore Secretary Los Angeles Tokyo Federal Communications Commission Madrid Washington, D.C. 445 Twelfth Street, S.W. Milan Washington, D.C. 20554 Re: Submission of Ex Parte Presentation; IBFS File Nos. SES-LIC-20120427- 00404; SES-STA-20120815-00751, Call Sign E120075 Dear Ms. Dortch: ViaSat, Inc. (“ViaSat”) files this ex parte submission to supplement the record in these proceedings. As explained in ViaSat’s Supplemental Submission in this proceeding on July 20, 2012, ViaSat believes that the operation of the aeronautical terminals in the Ka band should be treated as an application of the FSS across the entire portion of the Ka band that has been authorized for use by GSO FSS spacecraft.1 In this respect, it is important to recognize that the existing primary allocations for the MSS in the Ka band are quite limited, and cover only 100 MHz in Regions 1 and 3 (29.9-30.0 GHz and 20.1-20.2 GHz), and only 500 MHz in Region 2 (29.5-30.0 GHz and 19.7-20.2 GHz). In contrast, high-capacity spacecraft such as ViaSat-1 rely on access to a full 1500 MHz of spectrum in order to serve its coverage area. In particular, ViaSat-1 achieves its unprecedented capacity throughout its coverage area by employing many small spot beams and a frequency reuse plan that requires geographic separation among co-channel spot beams. As a result, the band segments allocated for MSS are not used in adjacent spot beams. This means that the connection for an aircraft that is flying across the United States will have to be handed off from one spot beam to another, and in the case on many flights, will require use of a portion of the Ka band that is allocated only for FSS. Stated another way, operation in the 28.35-29.1 GHz and 18.3-19.3 GHz band segments on ViaSat-1, which are allocated only for FSS, is essential to avoid gaps in coverage. This 1 ViaSat, Inc. Supplemental Submission, File No. SES-LIC-20120427-00404, Call Sign E120075 (filed July 20, 2012) (“Supplemental Submission”). DC\2338865.1

Ms. Marlene H. Dortch November 5, 2012 Page 2 concept is illustrated in the attached map, which shows the spot beams2 on ViaSat-1 that do not utilize the 19.7-20.2 GHz and 29.5-30.0 GHz band segments. Please contact the undersigned if you have any questions regarding this submission. Respectfully yours, /s/ John P. Janka Elizabeth R. Park Enclosures cc: Robert Nelson Andrea Kelly Stephen Duall William Bell Howard Griboff Paul Blais Joseph Hill Byung K. Yi David Keir, Counsel to Row 44, Inc. 2 Coverage for -4 dB contour depicted for each beam. DC\2338865.1



Document Created: 2012-11-05 10:23:14
Document Modified: 2012-11-05 10:23:14
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