1.65 Letter Clarifyi

Section 1.65 Notification submitted by Gogo LLC

Gogo Update Letter Feb 4 2016

2016-02-04

This document pretains to SES-MFS-20151022-00735 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2015102200735_1125067

SatCom Law LLC 1317 F St. NW, Suite 400 Washington, D.C. 20004 T 202.599.0975 www.satcomlaw.com February 4, 2016 By Electronic Filing Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Gogo LLC Section 1.65 Letter File No. SES-MFS-20151022-00735, Call Sign E120106 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 above-referenced application to modify Gogo’s license for Earth Stations Aboard Aircraft (“ESAA”), which sought to add a number of satellites to the Gogo ESAA network (the “Gogo Modification”). Specifically, this letter provides corrections or clarifications regarding orbital debris mitigation matters for Yamal 300K and Yamal 401, technical parameters and market access issues relating to Yamal 300K, identification of satellites and administrations, and certain technical data. In addition, Gogo requests that the Commission hold in abeyance its request for authority to communicate with the AMC-1 satellite pending further developments. Yamal Spacecraft Orbital Debris Mitigation Statements The Gogo Modification sought authority to add the Yamal 300K and Yamal 401 satellites as authorized points of communication. In support of its requests, Gogo provided orbital debris 1 mitigation statements relating to both spacecraft. Subsequent to submitting the modification application, Gogo has had further discussions with Gazprom, the satellites’ operator, and provides corrections and clarifications regarding these statements. First, Gazprom has revised the tables regarding the residual propellant and pressurant that will be on board each spacecraft at its end of life. The updated tables are below and should replace the tables in Annexes 5.4.C and 5.4.D. In each table, the information that has changed from what was presented in the Gogo Modification is indicated by red, bold text. 1 See Gogo Modification, Annex 5.3.C, Yamal 300K Orbital Debris Mitigation Statement, and Annex 5.4.C, Yamal 401 Orbital Debris Mitigation Statement.

Ms. Marlene H. Dortch -2- February 4, 2016 Yamal 300K: Item Purpose Tank Number of Initial End of Tank End of life Volume Tanks / mass of life mass pressure pressure Interconnected item per / volume rating / tank units Hydrazine Attitude 26 liters Located in 25 kg 0.7 kg/ 8.1 atm NA (1) (liquid) control BOL common tank 0.7 l 0.7 liter and separated EOL by internal Nitrogen Pressurant 14 liters membrane. 0.1325 kg 0.1325 8.1 atm 2.9 atm BOL in each kg in 39.3 tank each liters tank/ EOL 39.3 l Xenon Orbit 38 liters 2 / Yes 71 kg in 0.54 kg 140 atm 2.6 atm (2) control each tank in each tank (1) – Not applicable, as after hydrazine depletion, membrane-separator of hydrazine and pressurant is completely folded and hydrazine pressure is not guaranteed (at the worst, it does not exceed Nitrogen pressure) (2) – Indicated value corresponds to the minimum operating pressure for plasma thrusters. Following the satellite orbit-raising, the xenon tank venting operation will be carried out, so the value listed in the table can be taken as the worst case. Yamal 401: Item Purpose Tank Number of Tanks / Initial End of Tank End of life Volume Interconnected mass of life pressure pressure item per mass / rating / tank volume units Hydrazine Attitude 26 liters 3 Tanks / 25 kg 0.7 kg/ 8.1 atm NA (1) (liquid) control BOL Interconnected 0.7 l 0.7 liter EOL Fuel and pressurant Nitrogen Pressurant 14 liters are located in 0.1325 0.1325 8.1 atm 2.9 atm BOL common tank and kg in kg in 39.3 separated by internal each each liters membrane. tank tank/ EOL 39.3 l Xenon Orbit 38 liters 4 / Yes 71 kg in 0.54 kg 140 atm 2.6 atm (2) control each in each tank tank (1) – Not applicable, as after hydrazine depletion, membrane-separator of hydrazine and pressurant is completely folded and hydrazine pressure is not guaranteed (at the worst, it does not exceed Nitrogen pressure) (2) – Indicated value corresponds to the minimum operating pressure for plasma thrusters. Following the satellite orbit-raising, the xenon tank venting operation will be carried out, so the value listed in the table can be taken as the worst case.

Ms. Marlene H. Dortch -3- February 4, 2016 In addition, Gazprom has confirmed that the residual pressure data presented for each spacecraft in the tables above assumes a temperature of 293K. Yamal 300K Market Access and Operational Information Gogo updates and corrects the information provided with respect to its proposed use of the Yamal 300K satellite as follows: • Gogo proposes to use the beam on Yamal 300K designated “Northern Beam 1.” That beam provides coverage over certain parts of U.S. territory and adjacent territorial waters, and accordingly Gogo seeks Commission authority to use the satellite in U.S. airspace. Furthermore, Gogo deletes its request to use the 12.5-12.75 GHz band for downlinks from Yamal 300K because this spectrum is not used by Northern Beam 1. A revised copy of Annex 2 to the Gogo Modification reflecting these changes is attached. • Subsequent to submission of the Gogo Modification, Panasonic filed a request for U.S. market access for the Yamal 300K satellite, including submission of a Schedule S and 2 detailed technical information. Gogo similarly requests U.S. market access for Yamal 300K and incorporates by reference the materials supplied in the Panasonic Amendment. Gogo also seeks any necessary waiver of Section 25.210(f) of the Commission’s Rules, 47 C.F.R. § 25.210(f). As discussed in the Panasonic Amendment, although the Yamal 300K satellite does not satisfy Commission requirements for full frequency reuse in the Ku-band spectrum that will be used for ESAA operations, Commission precedent supports grant of a waiver to permit U.S.- licensed earth stations to communicate with satellite capacity that would otherwise lay 3 dormant. Identification of Satellites and Administrations Gogo also provides the following information to correct certain data that was provided in items E21-E24 of the Schedule B filed with the Gogo Modification. 2 See Panasonic Avionics Corp., Call Sign E100089, File No. SES-AFS-20160107-00003 (the “Panasonic Amendment”). 3 See id., Attachment A at 6-7 & n.7 (citing cases).

Ms. Marlene H. Dortch -4- February 4, 2016 Satellite Name ITU-R Name ADMIN JCSAT-2B JCSAT-2R Japan (J) EUTELSAT MEXSAT-114.9 115 WB C-Ku Mexico( MEX) JCSAT-5A N-STAR-A Japan (J) Netherlands YAMAL 300K NSS-19 (HOL) YAMAL 401 EXPRESS-7C Russia (RUS) ASIASAT-7 ASIASAT-CK China (CHN) In addition, Gogo notes that the correct licensing administration for the Eutelsat 117 West A satellite is Mexico. Corrections to Form 312 and Schedule B Gogo has also completed a thorough review of the data submitted with the Gogo Modification and updates the Form 312 and Schedule B submitted with the application as follows: • In response to item 20 of the Form 312, Gogo specifies that the nature of service should be Fixed Satellite (box a), as ESAA is an application of the fixed-satellite service. • The response to item E38 of the Form 312 Schedule B was incorrect for the AES1 terminal and should be changed to 35.48 Watts. AMC-1 Satellite Finally, Gogo asks the Commission to defer action on the request in the Gogo Modification for authority to communicate with the AMC-1 satellite pursuant to the regulatory framework set forth in Section 25.227(a)(1) and (b)(1). In its application, Gogo noted that because AMC-1 had only recently been relocated to its position at 129.15° W.L., efforts to coordinate the satellite with operations of adjacent spacecraft had not yet been completed. As a result, Gogo was not in a position to provide a letter confirming that operation of the Gogo ESAA terminals using AMC-1 was consistent with coordination agreements with satellites operated within six degrees of the 4 AMC-1 orbital location. Pending completion of coordination efforts, Gogo proposed to operate its terminals with technical parameters that comply with the off-axis EIRP spectral density specified in 4 See Gogo Modification, Narrative at 3.

Ms. Marlene H. Dortch -5- February 4, 2016 5 Section 25.227(a)(1)(i)(A) in the plane of the geostationary satellite orbit (“GSO”). Gogo requested any necessary waiver of Section 25.227(a)(1)(i)(B) relating to the off-axis EIRP 6 spectral density of the Gogo antennas in directions other than along the GSO plane. Subsequent to filing of the Gogo Modification, efforts to coordinate Gogo ESAA operations using AMC-1 with adjacent satellites have continued. Once a coordination agreement has been finalized, Gogo expects to be able to update the Gogo Modification by supplying the coordination letter required pursuant to the regulatory framework set forth in Section 25.227(a)(2) and (b)(2). That will make the request in the Gogo Modification application for AMC-1 authority under the Section 25.227(a)(1) and (b)(1) framework moot. Accordingly, Gogo believes that the most efficient approach would be for the Commission to suspend processing of the AMC-1 request in the Gogo Modification and hold that request in abeyance. Gogo asks that the Commission proceed with processing of the remainder of the Gogo Modification, as the other satellites discussed in the application have all been coordinated and therefore do not present the same issues as AMC-1. ***** Gogo requests that the Commission update its records regarding the Gogo Modification to take the above information into account and seeks expeditious processing of the Gogo Modification with these updates. 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 cc: Jose Albuquerque Paul Blais Chip Fleming Cindy Spiers 5 Id., Narrative at 3 & Annex 3. 6 Id., Narrative at 3 & 14-15.

ANNEX 2: Updated Spacecraft and Teleport Tables Tx Use in US Satellite Satellite Location Beam Coverage Area Rx (GHz) (GHz) airspace? Operator AMC-1 129.15W North America 14-14.5 11.7-12.2 Yes SES-1 101W North America 14-14.5 11.7–12.2 Yes SES-4 22W Europe 14-14.5 12.5-12.75 No 10.95-11.2; SES East Atlantic Ocean 14-14.5 No 11.45-11.7 SES-6 40.5W 10.95-11.2; West Atlantic Ocean 14-14.5 Yes 11.45-11.7 Galaxy 17 91W North America 14-14.5 11.7-12.2 Yes IS-18 180E South Pacific 14-14.5 12.25-12.75 No North and South America IS-14 45W 14-14.5 11.7–12.2 Yes excludes Brazil Brazil 14-14.5 11.7–12.2 No IS-21 58W South Atlantic Ocean 14-14.5 11.45–11.7 No Mobility from Mideast to IS-22 72.1E 14-14.5 12.25–12.5 No Intelsat Japan and to Australia Northeast Pacific 14-14.5 12.25-12.75 Yes Northwest Pacific 14-14.5 12.25-12.75 No IS-19 166E Australia 14-14.5 12.25-12.75 No Southwest Pacific 14-14.5 12.25-12.75 No 10.95–11.2; IS-904 60E Spot 1 - Western Russia 14-14.5 No 11.45-11.7 Eutelsat 115WB 114.9W North America 14-14.5 11.7-12.2 Yes (Satmex 7) Eutelsat 117WA 116.8W Central and South America 14-14.5 11.7-12.2 Yes Eutelsat (Satmex 8) 10.95-11.2; North Pacific and E172A 1 172E 14-14.5 11.45-11.7; No Northeastern Russia 12.2-12.75 1 This satellite is only used for communications with the Aerosat antenna system.

Tx Rx Use in US Satellite Satellite Location Beam Coverage Area (GHz) (GHz) airspace? Operator 10.95-11.2; Africa 14-14.5 11.45-11.7; No T-11N 37.5W 12.5-12.75 Telesat Atlantic 14-14.5 11.45-11.7 No T-18 138E Asia 14-14.5 12.2–12.75 No JCSAT- 11.45-11.7; 154E South Pacific 14-14.5 No 2B 12.25-12.75 JSAT JCSAT- 132E Japan 14-14.5 12.25-12.75 No 5A 2 Yamal 183E 10.95-11.2; North Pacific Ocean 14-14.5 Yes 300K (177W) 11.45-11.7 Gazprom Space 10.95-11.2; Systems Yamal 401 90E Russia 14-14.5 11.45-11.7; No 12.5-12.75 Asiasat 7 105.5E China 14-14.5 12.25-12.75 No AsiaSat 2 This satellite is only used for communications with the Aerosat antenna system.


Document Created: 2016-02-04 17:24:49
Document Modified: 2016-02-04 17:24:49
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC