Attachment 25.222 Compliance

This document pretains to SES-MOD-20110321-00320 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2011032100320_871888

Exhibit 1 - Showing of Compliance with Section 25.222


                                        Vizada, Inc.

                            Application to Modify License to
   Update the Particulars of Operation and Antenna Facilities Specifications for the
      Sea Tel Model 4003A and 4006 1.0 Meter Ku-band Remote ESV Antennas;
   Update the Particulars of Operation and Antenna Facilities Specifications for the
            Sea Tel Model 5009 1.2 Meter Ku-band Remote ESV Antennas;
   Update the Particulars of Operation and Antenna Facilities Specifications for the
            Sea Tel Model 6006 1.5 Meter Ku-band Remote ESV Antennas;
  Add up to 500 Sea Tel Model 4009/4010 1.0 Meter Ku-band Remote ESV Antennas;
    Add up to 500 Sea Tel Model 5010 1.2 Meter Ku-band Remote ESV Antennas;
  Add up to 500 Sea Tel Model 6009 1.5 Meter Ku-band Remote ESV Antennas; and
 Add up to 500 Intellian 1.05 Meter Ku-band Model V110 Remote ESV Antennas to the
           Authorization to Provide ESV Service via Southbury, CT Teleport

                                      Call Sign WB36

                               SES-MOD-20100517-00615


         By this application applicant Vizada, Inc. (Vizada) requests that the Particulars of
Operation (Section B of the license) and the Antenna Facilities Specifications (Section E
of the license) listed in its authorization to provide Earth Station on Vessel (ESV) service
via its Southbury, CT teleport, call sign WB36 be updated for the Sea Tel model 4003A
and 4006 1.0 meter Ku-band remote ESV antennas; the Sea Tel model 5009 1.2 meter
Ku-band remote ESV antennas; and the Sea Tel model 6006 1.5 meter Ku-band remote
ESV antennas. It is requested that this update of the Particulars of Operation information
and the Antenna Facilities Specifications for the 4003A, 4006, 5009 and 6006 antennas
be accomplished by replacing the Particulars of Operation and the Antenna Facilities
Specifications currently listed in the authorization for the model 4003A, 4006, 5009 and
6006 Sea Tel Antennas with the Particulars of Operation information and the Antenna
Facilities Specifications set forth for the 4003A, 4006, 5009 and 6006 antennas in the
responses for E38 through E50 of the Schedule B Section of the Application.

        Vizada also requests that up to 500 Sea Tel model 4009/4010 1.0 meter Ku-band
remote ESV antennas; up to 500 Sea Tel model 5010 1.2 meter Ku-band remote ESV
antennas; up to 500 Sea Tel model 6009 1.5 meter Ku-band remote ESV antennas; and up
to 500 Intellian model V110 1.05 Meter Ku-band remote ESV antennas be added to its
authorization to provide ESV service via its Southbury, CT teleport, call sign WB36.
These remote ESVs will be located on vessels traveling in U.S. and international waters.
They will operate with hub antennas that have already been licensed and will be utilized
to provide ESV service in the same manner as the other remote ESV antennas previously
authorized by the Commission.


Exhibit 1 - Showing of Compliance with Section 25.222

        Vizada’s current WB36 Ku-band ESV authorization is set forth in the license
dated August 16, 2010 pursuant to File Number SES-MOD-20100517-00615. The
license authorizes Vizada to operate up to 250 Sea Tel model 4003A, 250 model 4006, 50
model 4996T, 500 Sea Tel model 5009 and 400 model 6006 antennas to communicate via
any satellite on the Permitted Space Station List (ALSAT) to provide ESV service.

        Vizada by this application now requests that the license be modified to update the
Particulars of Operation (Section B of the license) and the Antenna Facilities
Specifications (Section E of the license) listed in the current authorization for the Sea Tel
model 4003A, 4006, 5009 and 6006 antennas by replacing the Particulars of Operation
and Antenna Facilities Specifications listed for these antennas in the current authorization
with the Particulars of Operation information and the Antenna Facilities Specifications
set forth for the 4003A, 4006, 5009 and 6006 antennas in the responses for E38 through
E50 of the Schedule B Section of the Application.

        Vizada also seeks to add up to 500 Sea Tel model 4009/4010 1.0 meter Ku-band
remote ESV antennas; up to 500 Sea Tel model 5010 1.2 meter Ku-band remote ESV
antennas; up to 500 Sea Tel model 6009 1.5 meter Ku-band remote ESV antennas; and up
to 500 Intellian model V110 1.05 Meter Ku-band ESV remote antennas to its
authorization for the ESV remotes to communicate via any ALSAT satellite to provide
ESV service. It is noted that the manufacturer of the 4009/4010, 5010 and 6009 states
that these antennas share identical RF transmit and receive electrical components with the
respective earlier models of each for which Vizada currently has ESV authorization. Sea
Tel states that the Reflector, Feed, OMT, BUC, LNB, waveguides, rotary joint and power
supplies are all identical between the various models of the 4006, 4009 and 4010.
Likewise, the Reflector, Feed, OMT, BUC, LNB, waveguides, rotary joint and power
supplies are all identical between the various models of the 6006 and 6009 and between
the 5009 and 5010. As with the other antennas currently authorized for ESV service,
operation of the Sea Tel model 4009/4010, 5010 and 6009 antennas and the Intellian
model V110 antennas will be in full compliance with the requirements of the
Commission’s ESV regulations as set forth in part 25 of the Rules.

        Vizada’s Showing of Compliance with Part 25 of the Commission’s Rules
follows herewith and the exhibits required by Section 25.222 are included as attachments
to the modification application.


            Showing of Compliance with Part 25 of the Commission’s Rules

Section 25.222

   (a) (1) Comply. See Blaney and Varan declarations regarding operation of Sea Tel
       antennas and Exhibits 2, 3 and 4 for the model 4003/4006/4009/4010 antenna;
       Exhibits 5, 6 and 7 for the model 5009/5010 antenna; and Exhibits 8, 9 and 10 for
       the model 6006/6009 antenna See Intellian and Varan declarations regarding
       operation of Intellian antennas and Exhibits 11, 12 and 13 for the model V110


Exhibit 1 - Showing of Compliance with Section 25.222

     antenna. The transmitters of all have off-axis EIRP spectral densities less than or
     equal to the levels in paragraph 25.222(a)(1)(i)(A) and meet the requirements of
     25.222 (a)(1)(i)(A-C) with an N value of 1. All are circular ESV antennas so
     25.222 (a)(1)(i)(D) is not applicable. Exhibits 2, 3 and 4 for the model
     4003/4006/4009/4010 antenna; Exhibits 5, 6 and 7 for the model 5009/5010
     antenna; Exhibits 8, 9 and 10 for the model 6006/6009 antenna; and Exhibits 11,
     12 and 13 for the model V110 antenna provide the detailed demonstration
     described in paragraph 25.222 (b)(1). The Blaney and Intellian declarations also
     contain certifications that the antennas comply with the pointing requirement in
     paragraph 25.222 (a)(1)(ii)(A) and the cessation of emission requirement in
     paragraph 25.222 (a)(1)(iii)(A).

  (a) (2) Not Applicable.

  (a) (3) Comply. The Vizada Security Officer has authority and ability to cease all
      emissions from ESVs through the facilities of Vizada’s Southbury Teleport. This
      point of contact is available 24 hours a day, seven days a week by calling +1-301-
      838-7700.

  (a) (4) Comply. These records are being collected and maintained as specified.
      Requests to make this data available may be directed to the Vizada Security
      Officer by calling +1-301-838-7700.

  (a) (5) Comply.

  (a) (6) Comply. The ESVs are controlled by the Hub earth station located at
      Vizada’s Southbury Teleport.

  (a) (7) Comply.

  (b) (1) Comply. The tables described in 25.222(b)(1)(i) are attached with the
      application as Exhibits 2, 3 and 4 for the model 4003/4006/4009/4010 antenna;
      Exhibits 5, 6 and 7 for the model 5009/5010 antenna; Exhibits 8, 9 and 10 for the
      model 6006/6009 antenna; and Exhibits 11, 12 and 13 for the model V110
      antenna. Exhibits 2, 5, 8 and 11 provide the detailed demonstration described in
      paragraph 25.222(b)(1)(i)(A). Exhibits 3, 6, 9 and 12 provide the detailed
      demonstration described in paragraph 25.222(b)(1)(i)(B). Exhibits 4, 7, 10 and 13
      provide the detailed demonstration described in paragraph 25.222(b)(1)(i)(C).
      The value N described in 25.222(a)(1)(i)(A) is 1 for all. The certifications from
      the equipment manufacturer stating that the tracking system meets the pointing
      and cessation of emission requirements of 25.222(b)(1)(iii) are contained in the
      Blaney and Intellian declarations.

  (b) (2) Not Applicable.

  (b) (3) Comply. See Exhibit 14.


Exhibit 1 - Showing of Compliance with Section 25.222

   (b) (4) Comply. The Vizada Security Officer has authority and ability to cease all
      emissions from ESVs through the facilities of Vizada’s Southbury Teleport. This
      point of contact is available 24 hours a day, seven days a week by calling +1-301-
      838-7700.

  (b) (5) Comply. See the Radiation Hazard Report Exhibits.

  (c) Comply.

  (d) Comply.



Document Created: 2011-02-27 15:59:23
Document Modified: 2011-02-27 15:59:23

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