Row 44 Ex Parte Noti

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Row 44 Inc.

Row 44 Ex Parte Notice (3-22-2013)

2013-03-22

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

IBFS_SESLIC2012042700404_991245

                                                                                             DAVID S. KEIR
                                                                                                 202.416.6742
                                                                                      DKEIR@LERMANSENTER.COM




                                         March 22, 2013



VIA IBFS

Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 Twelfth Street, SW
Washington, DC 20554

       Re: Notice of Ex Parte Presentation - Application of ViaSat, Inc.; FCC File Nos.
           SES-LIC-20120427-00404 and SES-STA-20120815-00751 (Call Sign E120075)

Dear Ms. Dortch:

        Row 44, Inc. (“Row 44”), by its counsel, hereby provides notice, pursuant to Section
1.1206 of the Commission’s Rules, that John Guidon, Chief Technology Officer of Row 44, and
James Costello, Vice President, Engineering, of Row 44, along with the undersigned counsel,
met with the following International Bureau staff members on March 20, 2013: Paul Blais,
Stephen Duall, Andrea Kelly, Alyssa Roberts, and Cindy Spiers. Joseph Hill and Kathyrn
Medley of the FCC participated in the meeting by telephone. Byung K. Yi also joined the
meeting near its conclusion. The meeting was requested to discuss the above-referenced ViaSat,
Inc. applications, which are designated as permit-but-disclose proceedings.

         At the outset of the meeting, counsel noted that Row 44 has had two principal concerns
regarding the ViaSat applications from the time they were filed. First, Row 44 has been troubled
that ViaSat has sought to ignore the novelty of its sui generis proposal to provide aeronautical
mobile-satellite service (“AMSS”) in the Ka-band, and has proceeded as if the existing fixed-
satellite service (“FSS”) rules were applicable to it without the requirement of further technical
showings and evaluation of discrete public interest considerations. Second, and even more
significantly, Row 44 is concerned that the design deficiencies of ViaSat’s Mantarray antenna
have the potential to disrupt both existing and future FSS and MSS applications in the Ka-band.

       Counsel also noted that Row 44 is aware of ViaSat’s March 14, 2013 ex parte meeting
with the Bureau staff, and that Row 44’s previously-scheduled meeting was not intended to


         Ms. Marlene H. Dortch
         March 22, 2013
         Page 2


address the arguments raised therein, but to elaborate on the technical issues that it has
previously advanced in its comments and ex parte letters concerning these applications. Mr.
Guidon and Mr. Costello noted preliminarily, however, that to the extent that ViaSat’s March
14th ex parte presentation seeks to rely on the recent decision within the European Union by
CEPT’s Electronic Communications Committee, which advanced Ka-band AMSS as an
application of the FSS, this decision offers no persuasive evidence in support of ViaSat’s
applications. The ViaSat Mantarray antenna does not comply with requirement stated in the
ECC decision that mobile antennas meet the standard set forth in ETSI 303 978 for Earth stations
on board mobile platforms at 17.3-20.2 GHz and 27.5-30.0 GHz. Row 44’s principals also
emphasized that the technical issues concerning ViaSat’s Ka-band equipment are of substantial
importance to Row 44 as it continues to work with its antenna supplier toward developing a
state-of-the-art Ka-band AMSS antenna that does not suffer from the deficiencies exhibited by
the Mantarray antenna.

        The remainder of the discussion was driven by the figures and illustrations contained on
the attached slides, which were reviewed with the Bureau staff. Row 44 made the following
points:

              ViaSat’s use of 2-lambda horn spacing in its antenna is a design flaw that
               produces the variable grating lobes evidenced in ViaSat’s own off-axis EIRP plots
               (1-lambda horn spacing is recognized as necessary to avoid generating grating
               lobes, and Ka-band antennas can meet this standard);

              In the Mantarray design, ViaSat seeks to suppress the grating lobes by off-setting
               each row of horns by one-half the width compared to the adjacent rows, but based
               on ViaSat’s plots, the grating lobes are not fully suppressed even at zero degrees
               of antenna skew;

              Because of these flaws, the grating lobes cause asymmetrical exceedances of the
               Section 25.138 mask at different frequencies and skew values which range up to
               20 dB in excess of the benchmark standard provided in the FCC Rule;

              The inconsistent grating lobe levels are further indicative of design and
               manufacturing deficiencies that make interference impact more difficult to assess,
               and may be further exacerbated by factors unaccounted for in the antenna plots
               such as installation variances and equipment aging;

              ViaSat’s technical analyses have consistently ignored the additive impact of mis-
               pointing/mis-orientation in both azimuth and elevation, considering only the
               former, but not the latter, in assessing the potential interference impact of its
               proposed network; and


         Ms. Marlene H. Dortch
         March 22, 2013
         Page 3


              Analysis that takes into account mis-pointing/mis-orientation in both the azimuth
               and elevation planes shows that at 40 degrees of skew, the ViaSat antenna would
               be in violation of the 0.5 degree mis-pointing limit almost 10% of the time, and
               would exceed this pointing error threshold approximately 20% of the time at 60
               degrees skew.

       Row 44 urged the Bureau to carefully evaluate each of these issues as it proceeds with its
consideration of ViaSat’s pending applications, and to withhold action on the applications until
these deficiencies are addressed and resolved.

                                                    Respectfully submitted,

                                                        s/ David S. Keir
                                                    David S. Keir
                                                      Counsel to Row 44, Inc.


cc: Paul Blais, FCC (via email)
    Stephen Duall, FCC (via email)
    Joseph Hill, FCC (via email)
    Andrea Kelly, FCC (via email)
    Kathyrn Medley, FCC (via email)
    Alyssa Roberts, FCC (via email)
    Cindy Spiers, FCC (via email)
    Byung K. Yi, FCC (via email)

    William Bell, FCC (via email)
    Howard Griboff, FCC (via email)
    Fern Jarmulnek, FCC (via email)
    Kal Krautkramer, FCC (via email)
    Hsing Liu, FCC (via email)
    Robert Nelson, FCC (via email)

    John Janka, Counsel to ViaSat (via email & U.S. mail)


Presentation Concerning ViaSat
   Ka-band AMSS Proposal




          20 March 2013


Concerns with ViaSat Ka-band Proposal

• Row 44 Has Had Two Principal Concerns:
  1)   ViaSat’s Effort to Ignore the Lack of Ka-Band Spectrum
       Allocations and Service Rules Covering Mobile Operations,
       and to Shoehorn its Proposal into Existing Fixed-Satellite
       Service Rules in Order to Seek Fast-Track Approval; and
  2)   The Evident Design Deficiencies in ViaSat’s Mantarray
       Antenna, Which Raise Harmful Interference Concerns.


• This Presentation Focuses Primarily on the Second
  of These Issues


ViaSat Antenna Deficiencies




     (Figure extracted from ViaSat’s
     application)




                                (enlargement of Figure
                                from ViaSat’s application)


ViaSat Antenna Deficiencies


                          These first-order grating lobes should have
                          been eliminated by shifting the horns .5-
                          width between rows.

                          Instead, the lobes are present, violating the
                          25.138 EIRP limits by 5 dB.


ViaSat Antenna Deficiencies

             Grating lobe levels
             vary ~7 dB between
             frequencies. Levels
             should be similar.




                               ~15 dB




                                   ~15 dB level variation exists
                                   between grating lobe levels for
                                   the same TX frequency. These
                                   levels should be similar.


     CALCULATING ANTENNA POINTING ERROR
                                                  Pointing error is the projection of both azimuth
                      Antenna pattern and
                      Clarke Belt with 0          and elevation error along the Clarke Belt
                      deg. skew
                                                                                                                          Skew Angle
                                    Clarke
                                    Belt
                                                    1 = Elevation Error * Sine(skew angle)
                                                                                            1
                     Skew Angle




                                     Clarke                                                                                   Ellipse representing
                                     Belt                               Elevation Error                                       main antenna lobe
                     Antenna pattern                                                                                          (wider in elevation
                     across Clarke Belt in                                                                                    than azimuth)
                     presence of skew



                                                                                                                                 Clarke Belt




                                     Clarke
                                     Belt

                     Antenna pattern in                                       Azimuth
                     presence of skew and                                     Error
                     mispointing


                                                                                              2      2 = Azimuth Error * Cosine(skew angle)



1 = Elevation Error * Sine(skew angle) 2 = Azimuth Error * Cosine(skew angle)                   2       1

             Total pointing error along Clarke Belt = 1 + 2                               Net pointing error


                                                                    Pointing Error Exceedance Rate while Transmitting due to ViaSat Antenna‘s Deficiencies
                                                      100.00%
                                                                                                                                          =—=60 degree skew

                                                      90.00%
                                                                                                                                          ===50 degree skew
Probability of Pointing Error Exceeding Given Value




                                                      80.00%                                                                              ——40 Degree

                                                                                                                                          =——30 Degree Skew
                                                      70.00%
                                                                                                                                          ==20 Degree Skew

                                                      60.00%                                                                                      10 Degree Skew

                                                                                                                                          =—=0 Degree Skew
                                                      50.00%
                                                                                                     60 deg. skew
                                                                                                     violates .5 deg                       —— .5 Degree Pointing Error Limit
                                                                                                     error ~20%of
                                                      40.00%                                                              40 deg. skew    —— .2 Degree Pointing Error Limit
                                                                       \\     \                                           violates .5
                                                                                                                          degree error
                                                      30.00%
                                                                                                                          ~9% of time
                                                                         \\                                                              30 deg. skew
                                                                                                                                         vialates .5
                                                      20.00%
                                                                                                                                         degree error
                                                                                                                                         3%of time
                                                       10.00%


                                                       0.00%
                                                            0.000                                   0400          0.500         0.500     0.700         0.800      0.200       1.000
                                                                                                Magnitude of Pointing Error (deg.)



Document Created: 2013-03-22 18:43:15
Document Modified: 2013-03-22 18:43:15

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