Attachment Supplement to Earth

Supplement to Earth

SUPPLEMENT submitted by Latham & Watkins LLP

Supplement

2010-05-25

This document pretains to SES-MFS-20090624-00789 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2009062400789_819740

555 Eleventh Street, NW., Suite 1000 Washington, D.C. 20004—1304 Tel: +1.202.637.2200 Fax: +1.202.637.2201 www.lw.com FIRM / AFFILIATE OFFICES LATHAM&WATKl NSLLP Abu Dhabi Moscow Barcelona Munich Beijing New Jersey Brussels New York Chicago Orange County May 25, 2010 Doha Paris Dubai Riyadh Frankfurt Rome BY HAND DELIVERY Hamburg San Diego Hong Kong San Francisco Houston Shanghai Ms. Marlene H. Dortch London Silicon Valley Los Angeles Singapore Secretary 2oL 20 Madrid Tokyo Federal Communications Commission Milan Washington, D.C. 445 12th Street, S.W. Washington, D.C. 20554 Re: Supplement to ViaSat, Inc. Earth Station Application File Nos. SES—MFS— 20090624—00789; SES—AFS—20091117—01463 (Call Sign EO50318) Dear Ms. Dortch: ViaSat, Inc. ("ViaSat") submits the enclosed satellite coordination letter to supplement the above—referenced earth station application. The coordination letter is for the GE International Holdings satellite, GE—23 at 172° E.L. and covers the VR—12 antenna that ViaSat proposes to add in the pending application. The application already includes a coordination for the GE—23 satellite covering the currently authorized antenna. If you should have any questions regarding this submission, please contact the undersigned. Respectfully submitted, Elizabeth R. Park Enclosure ce: Kathyrn Medley (electronic copy) Trang Nguyen (electronic copy) Jeanette Spriggs (electronic copy)

GE Satellite 2 Bethesda Metro Center Suite 600 Bethesda, MD 20814 T +1 301 634 3838 F +1 301 634 3936 27 April 2007 Federal Communications Commission — {nternational Bureou 445 12® Street, SW. washington, D.C. 20554 Subject: Enginegering Certification of GE Internotional Hotdings. To Whorm it May Concern: . This letter certifies that GE International Holdings ["SAT—GE") is aware that ViaSat, Inc. ["ViaSat") has been granted authority to operate a transmit/receive steerable antenna for asronautical mobile— satellite services [AMSS}, under Federal Communications Commission {"FCC"} Grant Call Sign E050318 {FCC File No. SES—LC—20051028—01494, as amended (FCC File No. SES—AMD—20060314— 00440, and SES—AMO—20070309—00325}, for using fixed—satellite service frequencies pursuant to ITU RR 5.504A, on a non—conforming., non—interference basis. ViaSat is seeking FCC authorization to utilize the SAT—GE satellite GE—23 at 1727 degrees EL. licensed by the FCC and also seeks to add a new antenna type. SAT—GE understands that, as described in ViaSat‘s application, ViaSat proposes to add a new antenna type that is very similar to the currently authorized antenna. The transmit/receive reflector antenna is an aircraft earth station steerable antenno manufactured by ViaSat. The aperture dimensions of the reflector antenna are 29.2 cm by 29.2 ocm witha transmit gain of 31.83 dBi ot 14.25 GHz and a receive gain of 29.62 dBi at 11.95 GHz,. These antennas will actively point to the intended sotellite using a method resistant to capturing and tracking adjacent satellites per 1TU— R M.1643. When communicating with the GE—23 satellite, ViaSat will operate its reflector antenna within the 14.2 ~14.5 GHz FSS uplink band, 11.4 — 11.7 GHz FSS downlink band with a masimum ei.rp. of 39. 5 dBw, and a corresponding maximurn power spectrol density at the antenna flonge of —31.87 dBW/4 kHz. The sub—meter antenna is a non—conforming antenna becouse the off—axis gain exceeds the §25.209 antenna performance standard by 10.25 dB in the main—lobe region. ViaSat will reduce the effective power spectral density into each individual antenna flonge such that the aggregoate reduction in power density will equal 10.25 dB. Thus, the network aggregate antenna flonge density will be —24.25 dBW/4 kHz, which is 10.25 dB below the limit of —14.0 dBW/4 kHz provided in the FCC‘s rules. The nominal individual antenna flonge density will be —34.64 dBW/4 kHz. ViaSat will operate using direct sequence spread spectrum so that the aggregaote off—oxis eirp. transmissions, from all co—frequency AES terminals within the footprint of the satellite, are always equal to or less than that of routinely authorized VSAT transmissions. Specifically, ViaSat will 66 neemasiondl Motdngs, bw.

operate its system so that the co—frequency aggregate off axis ei.cp from all AES antenno transmissions towards the intended geostationary satellite shall not exceed: Angle off—axis Maximum e.Lrp. in any 4 kHz band L25t s 0s 7.0° 15— 25 log 0 dBw — 70 <0s92° 6 dBgw $.2°<0< 48° 18 — 25 log © dBgw 48° <Os 180° —24 dBW The forword downlink (hub to AES} maximurm EIRP will be compliant with the levels coordinated with udjacent satellites. . ViaSat will maintain the forward downlink EIRP density and the aggregate off—axis EIRP values, by maintaining tight control of the system operation, which includes: 1} Maintaining antenna pointing to the intended satellite in a manor consistent with ITU_R M.1643; 2) network management that inhibits transmission within 1 second of receive link loss from same transponder; 3 fauk detection system that terminates transmissions when out of tolerance conditions fincluding the antenna pointing error) are detected; 4) continuous monitoring/oversight by ground network operations center; and 5) the continuous monitoring of the number of simultaneous co—frequency tronsmissions made by the remote terminals, and thereby the resulting aggregate return—uplink EIRP. The congestion control algorithm manages and controls both the aggregote EIRP and the COMA multiple access to maintain the aggregate off—oxis EIRP density to within prescribed limits. SAT—GE acknowledges that the use of the above referenced transmit/receive reflector antenna by ViaSat, installed and operated in accordance with the above conditions, is within the levels coordinated with the adjacent satellite operators and should not cause unacceptable interference into adjacent satellites operating in accordance with FCC‘s 2—degree spacing policy. if the FCC quthorizes the operations proposed by ViaSct in the Application, SAT—GEwill include the antenna, as described above. in all future satellite network coordinations. ViaSat shall comply with all such coordinetion agreements reached by the satellite operators, in order to prevent unacceptable interference into odjocent satellites, SAT—GE has been informed and ViaSat acknowledges that the aontennos will be installed and operated in occordance with the above conditions and/or any other operational requirements specified in the FCC cuthority granted to ViaSat. Furthermore, ViaSat agrees that it will accept interference from adjacent sateilites to the degree to which harmful interference would not be expected to be caused to an earth station employing an antenna conforming to the reference

patterns defined in Section 25.209 of FCC rules. If the use of this ontenna should cause unacceptable interference into other systems, ViaSat has agreed thatit will terminate transmissions immediately upon notice from the affected parties. Sincerely, M@j@&/ w 29fhord200 VP, Engineering SAT—GE

Acceptance by ViaSat: ViaSattestiffes that the information provided to Intelsat and reflected in this affidavit letter is true and accurate to the best of ViaSat‘s knowledge. 4 Regulatory Affairs ViaSat, Inc. Acceptance by Intelsot: INTELSAT agrees to operation of the above—described AMSS terminals by ViaSat, with the technical parameters described herein, with respect to its satellites currently operational or to be operated in the future within +6° of the orbital location 172° E.L. ' Jose Alburquerque Senior Director, Spectrum Engineering Intelsat


Document Created: 2010-05-25 13:52:08
Document Modified: 2010-05-25 13:52:08
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