Attachment Narrative SES-MFS-20170312-00255

Attachment Narrative

This document pretains to SES-MFS-20170312-00255 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2017031200255_1200365

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of

Application of Panasonic Avionics ) Call Sign E100089
Corporation to Modify its Earth Stations )
Aboard Aircraft (“ESAA”) Blanket License ) File No. ___________________
)

APPLICATION TO MODIFY ESAA BLANKET LICENSE

By this application, Panasonic Avionics Corporation (“Panasonic”) seeks modification of

its existing earth stations aboard aircraft (“ESAA”) blanket license, Call Sign E100089, 1 by

adding authority to operate its previously authorized Single-Panel Antenna (“SPA”) and

Panasonic Phased Array (“PPA”) terminals with satellites on the Commission’s Permitted Space

Station List (“Permitted List”) and certain additional satellite points of communication.

Panasonic also seeks authority to add 1,000 new ESAA terminals – the TECOM Ku-Stream

1000 (“TECOM”), which has been previously authorized by the Commission – for operation

with Permitted List satellites and other U.S.-serving satellites currently authorized in Panasonic’s

ESAA Blanket License. Finally, Panasonic requests removal of certain satellite points of

communication from its ESAA Blanket License and updates the frequency coordination, power

level and emission designator information associated with its ESAA terminal operations.

The modifications sought herein will enhance Panasonic’s operational flexibility and

improve the in-flight broadband connectivity services available to U.S. passengers. Grant of the

1
See Panasonic Avionics Corporation, File No. SES-LIC-20100805-00992 (Call Sign E100089)
and subsequent filings and modifications (“ESAA Blanket License”); Panasonic Avionics
Corporation Application for Authority to Operate Up to 50 Technically Identical Aeronautical
Mobile-Satellite Service Aircraft Earth Stations in the 14.0-14.4 GHz and 11.7-12.2 GHz
Frequency Bands, Order and Authorization, DA 11-1480 (rel. Aug. 31, 2011).

requested modifications also will extend the coverage and increase the capacity of the global

eXConnect network. Additionally, grant will facilitate access to the eXConnect network by

aircraft equipped with the previously licensed TECOM ESAA terminal.

Pursuant to Section 25.117(c) of the Commission’s rules, 47 C.F.R. § 25.117(c),

Panasonic provides information that is changing as a result of the requested modification in the

FCC Form 312 Schedule B and Technical Appendix, including updating certain ESAA

operational parameters. The remaining information in support of its ESAA Blanket License has

not changed. The proposed operations are consistent with the Commission’s rules and policies

governing Ku-band ESAAs 2 and, for the reasons described herein, grant of the proposed

modification would serve the public interest.

I. BACKGROUND

Panasonic’s ESAA Blanket License was the subject of a recent authorization to add

satellite points of communication for its previously licensed PPA terminal and add the SPA

terminal for long-term commercial operations. 3 The Panasonic ESAA terminals are fully

certified for operation on the subject commercial aircraft and operate in accordance with the

terms of the Panasonic Order, the ESAA Blanket License, and Section 25.227 of the

Commission’s rules, 47 C.F.R. § 25.227, governing ESAA operations.

2
See 47 C.F.R. § 25.227; see also Revisions to Parts 2 and 25 of the Commission’s Rules to
Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service
Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-
12.2 GHz and 14.0-14.5 GHz Frequency Bands; Service Rules and Procedures to Govern the
Use of Aeronautical Mobile Satellite Service Earth Stations in Frequency Bands Allocated to the
Fixed-Satellite Service, IB Docket Nos. 12-376 & 05-20, Notice of Proposed Rulemaking and
Report and Order, FCC 12- 161 (rel. Dec. 28, 2012) (“ESAA Order”).
3
See Panasonic Avionics Corporation, File No. SES-MFS-20160819-00730 (Call Sign E100089)
(granted on Oct. 19, 2016).

2

Panasonic has fully described the eXConnect System in prior submissions and hereby

incorporates by reference the technical showing regarding the control functionality and other

operational characteristics submitted in connection with prior applications. 4 The additional

operations proposed herein, including operation of the TECOM antenna and ESAA operations

with new individual satellite points of communication and Permitted List satellites, will be

consistent with the terms, conditions and operational parameters that are currently authorized

under Panasonic’s ESAA Blanket License and with the Commission’s ESAA rules.

II. DISCUSSION

A. Satellite Points of Communication

1. Permitted List Operations

Panasonic is requesting authority to operate its ESAA terminals, as well as the TECOM

terminal, with any satellite on the Commission’s Permitted List pursuant to Section

25.227(a)(12) of the Commission’s rules, which permits an ESAA system that complies with the

off-axis EIRP spectral density (“ESD”) limits in Section 25.227(a)(1)(i) to request such authority.

Panasonic will operate the ESAA terminals with Permitted List satellites in permissible portions

of the 14.0-14.5 GHz band consistent with these uplink off-axis ESD limits, and in the 10.95-

11.2 GHz and 11.45-12.2 GHz downlink bands.

Panasonic’s existing ESAA Blanket License generally authorizes operations pursuant to

Section 25.227(a)(2) of the Commission’s rules because, out of an abundance of caution,

Panasonic sought satellite operator certification for all ESAA operations. In some cases, the

ESAA terminals operate with off-axis ESD levels in excess of those specified in Section

25.227(a)(1), and in other cases operate consistent with the Commission’s two-degree spacing

4
See, e.g., Panasonic Avionics Corporation, File No. SES-LIC-20100805-00992 (granted August
31, 2011) (Call Sign E100089) and subsequent amendment and modification applications.

3

policies embodied in those levels. The application dockets for all of the subject ESAA terminals

include antenna performance information demonstrating compliance with applicable off-axis

ESD levels and they are currently operating with two-degree spaced satellites without

interference.5 Of course, the general performance characteristics of these previously licensed

ESAA terminals are well-understood and will not change.6

2. Additional Satellite Points of Communication

Panasonic seeks to add three individual satellites (AsiaSat-7, IS-33E and JCSAT-2B)

as authorized points of communication for the PPA and SPA terminals and one (Galaxy 16) as

an authorized point of communication for the SPA terminal only.

The following table provides an overview of the basic parameters of ESAA operations

with each individual satellite point of communication. 7 A complete table reflecting all

satellites in the eXConnect network is included in the Technical Appendix.

5
See Panasonic Avionics Corporation, File No. SES-MFS-20120913-00818, Call Sign E100089
at Technical Appendix (providing off-axis ESD plots for the PPA terminal) and File No. SES-
MFS-20160819-00730, Call Sign E100089 at Technical Appendix (providing off-axis ESD plots
for the SPA terminal); see also Row44 Inc., File No. SES-MFS-20150928-00635, Call Sign
E080100 (“Row 44 ESAA Blanket License”).
6
As the Commission is aware, Panasonic controls off-axis ESD emissions from the ESAA
terminals through limitations on the transmit power spectral density and control of pointing error.
At all times, Panasonic will operate the subject ESAA terminals with Permitted List satellites at
two-degree compliant levels.
7
The SPA and PPA terminals will operate in the uplink direction within the 14.0-14.5 GHz band
consistent with satellite operator coordination agreements, the Commission’s rules and
applicable international requirements.

4

Table 1. Proposed Satellite Points of Communication

Satellite Licensing Orbital Downlink ITU Satellite ITU Service
Admin.8 Location Freq. (GHz) Network9 Region To U.S.10
AsiaSat 7 China 105.5° E 12.25-12.75 ASIASAT-CKX 3 No
Galaxy 16 U.S. 99° W 11.7-12.2 U.S.-licensed 2 Yes
IS-33E U.S. 60° E 10.95-11.2; INTELSAT9-60E 1, 3 No
11.45-12.2;
12.5-12.6
JCSAT- Japan 154° E 11.45-11.7 N-SAT-154E 3 No
2B

Each of these proposed satellites has been previously authorized as points of

communication for similar ESAA operations11 or is a U.S.-licensed satellite.12 Accordingly, the

technical and operational parameters of each satellite are well known to the Commission,

including each satellite’s orbital debris mitigation and end-of-life plans, and no new showing

regarding these issues is required. In the attached Technical Appendix and Form 312 Schedule

8
Each foreign licensing administration is a member of the World Trade Organization for
services covered under the World Trade Organization Basic Telecommunications Agreement.
See FCC Form 312 at Item 42; 47 CFR § 25.137(a).
9
Panasonic provides the ITU satellite network filing name for each non-U.S. licensed satellite.
10
“Yes” indicates that the relevant satellite will be used for ESAA operations in U.S. territory.
“No” indicates that ESAA operations will be conducted outside U.S. territory, even if the
satellite may have some coverage of the United States.
11
See, e.g., Gogo LLC, File No. SES-MFS-20151022-00735 (Call Sign E120106) (granted
authority to add AsiaSat-7 and JCSAT-2B as authorized points of communication under its
ESAA blanket license).
12
Galaxy 16 is a U.S.-licensed satellite and currently an authorized point of communication for
the PPA terminal. IS-33E is a U.S.-licensed satellite that was recently authorized by the
Commission (see Intelsat License LLC, File No. SAT-LOA-20150327-00016 (Call Sign S2939)
(granted on Feb. 25, 2016)).

5

B, Panasonic provides information regarding the operational characteristics of the ESAA

terminals with each satellite identified in Table 1.

Out of an abundance of caution, Panasonic requests a waiver of the U.S. Table of

Allocation in Section II.A.3 to the extent necessary to permit its receive ESAA operations with

IS-33E in the 12.5-12.6 GHz downlink band and AsiaSat-7 in the 12.25-12.75 GHz downlink

band. In addition, although Panasonic has included satellite operator certifications for most

individual satellite points of communication proposed herein confirming that ESAA operations

are consistent with their coordination agreements and will not result in unacceptable interference

to other satellites within +/- 6 degrees, it has not done so for JCSAT-2B. The absence of such a

certification does not affect the request to communicate with this satellite because at all times

Panasonic will operate the PPA and SPA terminals consistent with the off-axis ESD levels in

Section 25.227(a)(1).13 Depictions of the geographic areas in which its ESAA terminals will

operate with each proposed satellite point of communication are also included.14

a. Ground Segment

The gateway earth stations for Panasonic’s ESAA network are located in various

countries around the world to provide global coverage and vary by satellite. Table 2, below,

reflects the gateway earth stations for the satellite points of communication proposed herein. A

complete table reflecting all satellites and gateways in the eXConnect network is included in the

Technical Appendix.

13
Although no satellite operator certification is necessary when an ESAA operates in accordance
with the Section 25.227(a)(1) mask, Panasonic reserves the right to supplement the record with a
certification for JCSAT-2B should it be deemed necessary or appropriate.
14
See Technical Appendix, I.; see also 47 C.F.R. § 25.227(b)(4).

6

Table 2. Gateway Earth Stations Table

Satellite Satellite Gateway Country Gateway FCC Call
Operator Earth Operator Sign
Station
Location

AsiaSat-7 AsiaSat Beijing China China Telecom N/A
Satellite

Galaxy 16 Intelsat Brewster, U.S. U.S. E120043
WA Electrodynamics

IS-33E Intelsat Cologne Germany Stellar N/A

IS-33E15 Intelsat Moscow Russia Gazprom N/A

JCSAT-2B SKY Kapolei, HI U.S. Hawaii Pacific E010016
Perfect Teleport LP
JSAT

Network control and monitoring of the earth stations and the eXConnect System will

continue to be provided by a Panasonic Mission Control Center (“MCC”) in Lake Forest,

California on a 24/7 basis. The MCC makes use of the Network Management System (“NMS”)

to provide complete control and visibility to all components the eXConnect network. The NMS

system has the capability of shutting down any component in the system that is malfunctioning.

The primary points of contact at Panasonic’s MCC facility has been previously provided to the

Commission by Panasonic.16

15
Effective November 2017, the gateway earth station in Moscow, Russia will no longer support
IS-33E satellite operations. Panasonic includes representative link budgets for IS-33E with both
gateway earth station locations.
16
See Panasonic Avionics Corporation, File No. SES-MFS-20160819-00730 (Call Sign
E100089), Technical Appendix.

7

3. Waiver Request

Although Panasonic has previously been granted a waiver of Section 2.106 of the

Commission’s rules, 47 C.F.R. § 2.106, to operate ESAA terminals in the 12.25-12.75 GHz

downlink band, out of an abundance of caution, Panasonic respectfully requests a similar waiver

here. Specifically, Panasonic’s ESAA terminals will communicate with IS-33E in the 12.5-12.6

GHz downlink band and with AsiaSat-7 in the 12.25-12.75 GHz downlink band.

The FCC’s Table of Allocations permits use of the 10.95-11.2 GHz and 11.45-11.7 GHz

bands (on an unprotected basis) and the 11.7-12.2 GHz and 14.0-14.5 GHz bands (on a primary

basis) for ESAA operations.17 Panasonic seeks to utilize FSS satellite capacity available in the

12.25-12.75 GHz band for ESAA receive operations on an unprotected, non-harmful interference

basis outside the United States (principally in Regions 1 and 3).18 The Commission previously

waived Section 2.106 with respect to operation of Panasonic’s eXConnect System and other in-

flight connectivity providers in this additional Ku-band downlink spectrum. 19 The requested

waiver would serve the public interest because use of this downlink (receive) spectrum is

essential to offering in-flight broadband connectivity in Ku-band spectrum and presents a

negligible risk of interference to other spectrum users.20

17
See 47 C.F.R. § 2.106 and n. NG52 and NG55; 47 C.F.R. § 25.227.
18
The 12.5-12.75 GHz band is allocated for FSS downlinks in Region 1 and the 12.2-12.75 is
allocated for FSS downlinks in Region 3.
19
See, e.g., Panasonic Avionics Corporation, SES-MFS-20150609-00349 (Call Sign E100089).
20
See id.

8

B. TECOM ESAA Terminal

1. Addition of TECOM ESAA Terminal

Panasonic seeks to add the TECOM ESAA terminal to is ESAA Blanket License for

operations on aircraft equipped with this terminal, including those installed on Southwest

Airlines aircraft. The TECOM ESAA terminal is designed for aeronautical applications and has

been previously licensed by the Commission for similar operations.21

As previously demonstrated to the Commission, the TECOM terminal complies with the

requirements set forth in Section 25.227 of the Commission’s rules, 47 C.F.R. § 25.227, to

facilitate Ku-band ESAA operations in a two-degree spacing environment.22 In the interest of

administrative convenient and to avoid providing substantial amounts of duplicative information,

Panasonic incorporates by reference the technical demonstration, including off-axis ESD plots

and related operational characteristics of the TECOM ESAA terminal, into the record of this

proceeding.

Panasonic will operate the TECOM in accordance with the off-axis ESD masks in

Section 25.227(a)(1)(i) of the Commission’s rules designed to protect co-frequency operations

from harmful interference, as well as all other applicable ESAA requirements. To the extent that

the Commission wishes to review additional technical information for the TECOM terminal,

Panasonic will provide such information in due course.

21
See Row 44 ESAA Blanket License.
22
Id. Technical Annex (Panasonic will operate the TECOM at the same maximum EIRP level
authorized in the Row 44 ESAA Blanket License (43.8 dBW). Row44 requested a cautionary
waiver of 25.227(a)(1)(i)(B) because it exceeded the off-axis ESD mask in the plane
perpendicular to the GSO arc and, out of an abundance of caution, Panasonic requests a similar
waiver here.

9

The TECOM ESAA terminal has operated in the United States pursuant to Commission

authority without any reported interference and in compliance with the ESAA rules embodied in

Section 25.227. In addition to being two-degree spacing compliant, the TECOM terminal has a

pointing accuracy of 0.2º or greater and will automatically cease transmissions if point offset

exceeds 0.5º or greater, and otherwise will operate in compliance with the Commission’s ESAA

rules and policies. Panasonic will also ensure that the terminal is operated consistent with

existing coordination agreements with the National Science Foundation and NASA, or impose an

exclusion zone around radio astronomy and TDRSS sites (as contemplated in Section 25.227)

until such agreements can be appropriately modified. Thus, addition of this terminal to the

Panasonic’s ESAA Blanket License will not increase the potential for interference from the

eXConnect System operations in the United States.

2. Permitted List Operations

Panasonic proposes to operate the TECOM in permissible portions of the 14.0-14.5 GHz

band (Earth-to-space), the 10.95-11.2 GHz band (space-to-Earth) and the 11.45-12.2 GHz band

(space-to-Earth) with Permitted List satellites pursuant to Section 25.227(a)(12) of the

Commission’s rules. As discussed above, Panasonic has incorporated by reference the extensive

technical showing upon which the Commission granted authority for the TECOM terminal to

operate in the U.S. two-degree spacing environment. In addition, Panasonic will operate the

terminal at the same power levels at which it operates with two-degree spaced satellites today,

which are necessarily compliant with the off-axis ESD limits in Section 25.227(a)(1)(i).

Accordingly, Panasonic respectfully requests that the Commission included Permitted List

authority for the TECOM antenna in its ESAA Blanket License.

10

3. Additional Satellite Points of Communication

In addition to requesting Permitted List authority, Panasonic also seeks authority for

the TECOM terminal to communicate with certain individual U.S. and non-U.S.-licensed

satellites. Table 3, below, provides an overview of the basic parameters of TECOM terminal

operations with each such satellite.23

Table 3. Proposed Satellite Points of Communication (TECOM)

Satellite Licensing Orbital Downlink ITU Satellite ITU
Admin.24 Location Freq. (GHz) Network25 Region
Anik G1 Canada 107.3° W 11.7-12.2 CANSAT-34 2
Galaxy U.S. 99° W 11.7-12.2 U.S.-licensed 2
16
Eutelsat U.S. 172° E 10.95-11.2; U.S.-licensed 2
172A 11.45-11.7
IS-29E U.S. 50° W 10.95-11.2; U.S.-licensed 1, 2
11.45-11.7
Telstar U.S. 37.5° W 11.45-12.2 U.S.-licensed 1, 2
11N

Yamal Netherlands 183° E 10.95-11.2; NSS-19 1, 2
300K 11.45-11.7

These proposed satellites have been previously authorized in Panasonic’s ESAA Blanket

License. Accordingly, the technical and operational parameters of the satellites are well known

to the Commission and no new showing regarding these issues is required. In addition,

Panasonic will operate the TECOM terminal with each satellite at power levels below levels

23
The TECOM terminal will operate in the uplink direction within the 14.0-14.5 GHz band
consistent with satellite operator coordination agreements, the Commission’s rules and
applicable international requirements.
24
Each foreign licensing administration is a member of the World Trade Organization for
services covered under the World Trade Organization Basic Telecommunications Agreement.
See FCC Form 312 at Item 42; 47 CFR § 25.137(a).
25
Panasonic provides the ITU satellite network filing name for each non-U.S. licensed satellite.

11

Because Panasonic will operate the TECOM terminal in the same manner at the same

power levels at which it is authorized to operate today, the same public interest considerations

that supported prior grant of ESAA operating authority apply here. To the extent any rule waiver

may be necessary, grant of such a waiver would serve the public interest by enhancing

competition, expanding use of a currently authorized ESAA terminal and not otherwise

undermining the policies underlying the rule.

C. Revisions to ESAA Blanket License

Panasonic seeks the removal of certain currently authorized satellite points of

communication from its ESAA Blanket License. Specifically, Panasonics seeks to remove the

following PPA satellite points of communications from its license: AMC-16, Anik-F1,

Amazonas-2, Galaxy 17 and SES-6. Panasonic also seeks to remove the following MELCO

satellite points of communication from its license: Galaxy 16, Galaxy 17, SES-6, AMC-16,

Eutelsat 115WB and IS-29E. Due to changes in Panasonic’s satellite network configuration,

these satellites no longer support MELCO or PPA terminal operators or are no longer part of the

eXConnect network. Accordingly, Panasonic respectfully requests the removal of the identified

satellites from the ESAA Blanket License as authorized points of communication to accurately

reflects its existing ESAA operations.

Additionally, Panasonic seeks to revise certain emission designators associated with

various frequency bands authorized for the MELCO, PPA and SPA ESAA terminals.

Specifically, Panasonic inadvertently included an extra character (“K”) in several emission

designators. Panasonic has provided an updated emission designator exhibit in the Technical

Appendix which accuracy reflects its ESAA terminal operations under its ESAA Blanket

13

License.28 In addition, FCC Form 312 Schedule B associated with this application reflects the

correct emissions designators.

The ESAA Blanket License also includes ESAA terminal frequency coordination limits

over identified satellite arc ranges rather than individual locations of satellite points of

communication. Given the different operational characteristics associated with each satellite,

however, Panasonic updates the frequency coordination information to show orbital location-

specific information for ESAA terminal operations. The updated information will harmonize

Panasonic’s ESAA Blanket License with other ESAA licensees, and effectively replaces the

information currently set forth in Section C of the license. The ESAA terminals will continue to

operate in accordance with the terms of the Panasonic Order, the ESAA Blanket License, and

Section 25.227 of the Commission’s rules governing ESAA operations.

Finally, Panasonic seeks to correct the power levels for the MELCO terminal to reflect

those proposed in a prior modification application. It appears that Panasonic’s prior request to

increase the maximum EIRP value for the MELCO antenna, which was included in the Form 312

Schedule B and accompanied by an appropriate satellite operator certification, 29 was neither

reflected in the license grant nor a decision denying that portion of the prior application. In the

absence of such a denial, Panasonic believes the omission to be a minor administrative oversight

and respectfully requests that the Commission address this issue in the context of the present

application. The updated information regarding MELCO operations set forth in this

modification application effectively replace currently authorized MELCO parameters in the

ESAA Blanket License.

28
See Technical Appendix, IV.
29
See File No. SES-MFS-20130930-00845 (Call Sign E100089) at FCC Form 312, Schedule B
and Technical Appendix (Telesat certification letter).

14

Document Created: 2017-03-12 20:20:21
Document Modified: 2017-03-12 20:20:21

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