FCC 1.65 Ltr with NA

LETTER submitted by Gogo LLC

1.65 Letter with NASA Coordination Agreement

2013-02-01

This document pretains to SES-LIC-20120619-00574 for License on a Satellite Earth Station filing.

IBFS_SESLIC2012061900574_984454

SatCom Law LLC 1317 F St. NW, Suite 400 Washington, D.C. 20004 T 202.599.0975 www.satcomlaw.com February 1, 2013 By Electronic Filing Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Gogo LLC ESAA License Application and STA Requests, Call Sign E120106 File Nos. SES-LIC-20120619-00574; SES-AMD-20120731-00709; SES-AFS-20121008-00902; SES-STA-20121009-00907; & SES-STA-20130107-00018 Dear Ms. Dortch: Gogo LLC (“Gogo”), by its attorney and pursuant to Section 1.65 of the Commission’s rules, 47 C.F.R. § 1.65, hereby updates the record regarding Gogo’s above-referenced application for a blanket license to operate earth stations aboard aircraft (“ESAAs”) and related requests for special temporary authority (“STA”). Specifically, Gogo advises the Commission that it has finalized a coordination agreement with the National Aeronautics and Space Administration, and an executed copy of the agreement is attached. Please let me know if you have any questions regarding this matter. Respectfully submitted, /s/ Karis A. Hastings Karis A. Hastings Counsel for Gogo LLC karis@satcomlaw.com Attachment cc: Andrea Kelly Paul Blais Eleanor Lott Trang Nguyen

~2013—01—08 NASA—Gogo Coor Agreement General HQ A Coordination Agreement Between the National Aeronautics and Space Administration (hereinafter "NASA") and Gogo, LLC (hereinafter "Gogo") for Operation of the AMSS in the 14.0 —14.5 GHz—Band Gogo seeks to license and operate aeronautical mobile—satellite stations (AMSS) over the Continental United States (CONUS) on a secondary basis in the 14.0 to 14.5 GHz FSS band. The AMSS terminals are part of the Gogo communications system aboard general aviation and commercial aircraft using transponders in the Geostationary Satellite Orbit (GSO) arc. This Coordination Agreement has been prepared in compliance with the rules of the Federal Communications Commission (FCC) and the recommendations of the member states of the International Telecommunication Union (ITU) following the World Radio Communication Conference WRC—03. 1. Overview The 14.0 — 14.5 GHz—band has been allocated to the mobile—satellite service, now including aeronautical mobile—satellite service, on a secondary basis, provided that Airborne Earth Stations (AES) include specific protection to the Space Research Services (SRS) earth stations and to the Tracking and Data Relay Satellite System (TDRSS) within the 13.40 — 14.4 GHz—band Gogo has filed an application for license authorization to operate up to 1000 technically identical AES units in the 14.05 — 14.47 GHz—band. The Gogo AESs receive from, and transmit to, the same GSO satellite transponder under control of a Ground Earth Station (GES) and Network Operations Center (NOC). They, and the terrestrial network to which they are connected, comprise the Gogo system. This Coordination Agreement has been prepared to ensure that operation of the Gogo AESs conform to FCC requirements for protection of the SRS Network. Gogo has the authority to negotiate and sign this Coordination Agreement for their AMSS system and NASA has the authority to negotiate and sign this agreement for the TDRSS and SRS Network sites listed in Section 3.1. NASA and Gogo Coordination Agreement 1 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ 2. AUTHORITY NASA concludes this agreement pursuant to 42 USC §2473 © (5) and (6) and section 203 © (5) of the National Aeronautics and Space Act of 1958 as amended, in addition to the Manual of Regulations and Procedures for Federal Radio Frequency Management (National Telecommunications & Information Administration Redbook), May 2008 Edition, May 2011 Revision. 3. Space Research Services Earth Stations TDRSS Earth Station Sites: Table 1 provides a list of TDRSS earth stations sites requiring interference protection. The White Sands and Guam sites are currently operational,. The Blossom Point, MD site is planned for operation within the year 2013. Also provided are the TDRSS satellite orbital locations currently supported by each earth station site. Earth Station Site Latitude (deg) Longitude (deg) ?ril;fese SEzt;Hthgng.) Continental United States 1734 4171 White Sands, —167.5 New Mexico —164.2 Antenna Size— 18.3 meter 32.5434N 106.6121W —79 Antenna Gain — 66.4 dBi —62 Elevation —1456 m —49 —47 ~41 Continental United States —12 Blossom Point, MD ~41 Antenna Size — 20 meter s omeatdtin—a72 ap 38.4289N 77.0839W _j; Elevation —4 m , —62 —19 United States Territory Guam 85 Antenna Size—11 meter 13.5881N 144.$410E ]8393 Antenna Gain —— 61.9 dBi —171 Elevation — 129 m —174 Table 1. Existing TDRSS Earth Station Sites NASA and Gogo Coordination Agreement 2 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ * Ephemeris data on existing TDRSS spacecraft indicated in Table 1 may be found at the following Web site: http://celestrak.com/NORAD/elements/ . Choose Tracking and Data Relay Satellite System (TDRSS) Additional TDRSS Earth Station Sites: NASA shall provide Gogo at least two months written notice of when the Blossom Point, MD earth station is about to become operational. Protection of this site must be provided by its planned operational date of use. NASA may unilaterally add additional TDRSS earth station sites to the list in Table 1 above. NASA will notify Gogo as soon as it knows that a new earth station is being planned and has the coordinates of the newly planned site. Earth Site Protection Limits: The TDRSS protection limits are listed in the Table 2 below. Frequency Band Interference Threshold Limit Reference Percentage Measured at Antenna Output of Time 13.40 —14.00 GHz —176 dBW/ kHz Never to be Exceeded 14.00 —14.05 GHz —146 dBW/ MHz Never to be Exceeded 14.05 — 14.40 GHz —100 dBW (WSC, Guam), —85 Never to be Exceeded dBW (BP) Table 2. TDRSS Protection Limits For interference calculations, the TDRSS spacecraft can have an inclination angle up to 15 degrees. In calculating the interference threshold levels in Table 2, the antenna patterns in Figure 1 below should be used. NASA and Gogo Coordination Agreement 3 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ Antenna Gain (dBi) 10 Antenna off—axis angles (degrees) ‘ Figflre 1. 'fDRSS Earth Statriiol;»z;;tenna Gain i;aflérfis Note: This antenna pattern for WSC and Guam sites is calculated using Annex III of Appendix 8 of the ITU Radio Regulations, with the following modifications: Gi= 5+ 15log(D) » »1202(D/ 13°* where Gmax and D are given in Table 1. In the case of the BP site, the antenna pattern in ITU F.1245 is used which has side lobes up to 3 dB less than those obtained with Annex 3 of Appendix 8 for large off—axis angles. For this pattern, G;= 2 + 15log(D/A) and 9 =12.02 (D/ay* 4. Operational Coordination Agreement NASA and Gogo agree to the following: a. The purpose of this Coordination Agreement is to provide protection to the TDRSS earthstation sites listed in Table 1 and any future TDRSS earth station sites. b. The level of protection afforded to the sites in Table 1, and any future TDRSS earth station sites which NASA adds to Table 1 pursuant to Section 3.2 of this Agreement, shall be equal to or greater than the Interference Threshold Limits shown in Table 2. 4.1 This Coordination Agreement may be reviewed periodically by the signatories to the agreement following commencement of service by Gogo under an operational license from the NASA and Gogo Coordination Agreement 4 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ FCC. The purpose of the review is to assess the effectiveness of this agreement and update this, or subordinate operational agreements, as appropriate. 4.2 Each party shall inform the other party in a timely manner of changes in the points of contact as defined in Section 5. 4.3 FINANCIAL OBLIGATIONS: Each party shall be responsible for funding its own responsibilities under this Agreement. No provision of this Agreement shall be interpreted to require obligation of funds in violation of the Anti—Deficiency Act 31 U.S.C § 1341. Gogo agrees to: 4.4 Monitor, control and cease transmissions from any AES that would exceed the thresholds given in Table 2 within line—of—sight of the sites listed in Table 1. 4.5 Monitor, control and cease transmissions from any AES that would exceed the thresholds given in the Table 2 within line—of—sight of such additional sites as NASA may require. 4.6 Respond expeditiously to a NASA request for protection of the sites listed in Section 3.1, or additions thereto as provided for in Section 3.2, in accordance with the threshold limits of Section 3.3. 4.7 Respond expeditiously to a NASA request to isolate a source of interference to a TDRSS earth station suspected to be from an AES. 4.8 Provide a central point of contact (on a 24 hour, 7 day basis) for interference resolution and other contact. NASA agrees to: 4.9 Maintain an open dialog with Gogo concerning any perceived breach of interference thresholds that may be attributable to an AES that is not in compliance with this Coordination Agreement. 4.10 Provide timely notification to Gogo of changes or additions to TDRSS earth station sites, TDRSS spacecraft orbital positions or interference thresholds listed in this Coordination Agreement. 5. Assignment and Termination 5.1 This Coordination Agreement shall be binding upon the parties hereto and their respective successors and assigns. NASA and Gogo Coordination Agreement 5 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ 5.2 This Coordination Agreement may be terminated by either party upon 6 months written notice to the other. 5.3 CONTINUING OBLIGATIONS: The obligation of Gogo to protect the NASA TDRSS earth stations from interference as described in this agreement will survive termination or expiration of this Agreement. 6. Points of Contact 6.1 Points of contact concerning this Coordination Agreement: Name: Victor Sparrow Name: William J. Gordon Organization: NASA HQ Organization: Gogo, LLC Title: Director, NASA Spectrum Policy Title: VP, Regulatory Affairs Address: Address: NASA Headquarters Gogo, LLC 300 E Street SW 5614 Connecticut Ave, NW #288 Washington D.C. 20546—0001 Washington, DC 20015 Phone: (202) 358—4808 Phone: 202—680—0576 Fax: (202) 358—2865 Fax: E—mail: Victor.D.Sparrow@nasa.gov E—mail: bgordon@gogoair.com 6.2 Points of contact for technical concerns related to this Coordination Agreement: Name: Vincent Scott Galbraith Name: Tim Joyce Organization: NASA GSFC Organization: Gogo, LLC Title: Goddard Spectrum Manager Title: VP, RF Engineering Address: Address: Goddard Space Flight Center Gogo, LLC Mission Services Program Office 1250 N. Arlington Heights Rd. Greenbelt, MD 20771 Itasca, IL 60153 Phone: (301) 286—5089 Phone: 630—647—1427 Fax: (301) 286—1724 Fax: 630—647—1627 E—mail: vincent.s.galbraith@nasa.gov E—mail: tioyee@gogoair.com NASA and Gogo Coordination Agreement 6 of 7

2013—01—08 NASA—Gogo Coor Agreement General HQ 7. Signatures This Coordination Agreement is being made in good faith by both parties and is effective on the date on of final signature. For: The National Aeronauties and Space For: Gogo Administration By: 4 / By: P lpr Name: Victor Sparrow Name: William J. Gordon Title: Director, NASA Spectrum Policy Title: VP, Regulatory Affairs and Planning Date: t”?{ /[ Z3 Date: /[ 5/[2()/3 NASA and Gogo Coordination Agreement 7 of 7


Document Created: 2013-02-01 14:22:30
Document Modified: 2013-02-01 14:22:30
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