20131223 Letter re I

SUPPLEMENT submitted by Row 44 Inc.

Supplemental Showing

2013-12-23

This document pretains to SES-MOD-20121023-00963 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2012102300963_1031234

DAVID S. KEIR 202.416.6742 DKEIR@LERMANSENTER.COM December 23, 2013 FILED VIA IBFS Mr. Jose Albuquerque Chief, Satellite Division International Bureau 445 Twelfth Street, S.W. Washington, D.C. 20554 Re: Row 44, Inc. – File Nos. SES-MOD-20121023-00963 and SES-AFS-20130920-00833 (Call Sign E080100) -- Supplemental Showing and Response to Comments Dear Mr. Albuquerque: This letter is submitted on behalf of Row 44, Inc. (“Row 44”) as a supplement to the information contained in its above-referenced application to modify its Ku-band Earth Stations Aboard Aircraft (“ESAA”) network license to add new points of communication, including the Intelsat 19 satellite at 166 E.L. (“IS-19”). As part of this implementation of service on IS-19, Row 44 requests use of space segment in the extended Ku-band downlink at 12.25-12.75 GHz, a non-conforming use under the International Telecommunication Union (“ITU”) Region 2 FSS spectrum plan covering the Americas.1 This additional space segment capacity will provide Pacific Region downlink coverage in the 12.25-12.75 GHz band within the satellite’s footprint, which includes substantial territory in ITU Region 3 (“Region 3”) as well as portions of the western U.S. and other parts of ITU Region 2 (“Region 2”). Within Region 2, this spectrum is allocated on a primary basis for the Broadcast Satellite Service (“BSS”) and terrestrial fixed services. Row 44 has requested a 1 See Row 44 License Modification Application, File No. SES-MOD-20121023-00963, Attachment at 4 (October 2012).

Mr. Jose Albuquerque December 23, 2013 Page 2 of 3 waiver of the U.S. Table of Allocations, consistent with prior grants of authority to other ESAA operators,2 to permit its remote service terminals to receive downlinks from IS-19 in this band. This submission also responds to Comments filed December 13, 2013 by EchoStar Satellite Operating Corporation (“EchoStar”) requesting that the Commission require Row 44 to provide a technical interference analysis demonstrating that its operations using the IS-19 downlink would not cause unacceptable interference to adjacent satellites operating in accordance with the Commission’s two-degree spacing policy.3 EchoStar and DirecTV previously made a similar request in connection with a prior grant of authority for comparable use of IS-19.4 Just prior to the filing of the EchoStar Comments, Row 44 proactively provided EchoStar with an analysis prepared by Intelsat that addresses EchoStar’s request for a demonstration that Row 44’s operations will not cause interference to the BSS. Further technical discussions between the parties resulted in minor clarifications of that analysis, a revised version of which is provided as Attachment A hereto.5 Intelsat’s calculations demonstrate that the maximum EIRP density of the IS-19 digital carriers that Row 44 will use is below the level that would trigger required coordination under the ITU Radio Regulations. This demonstration is further supported by well over a year of successful operation of IS-19 for provision of service using the 12.25- 12.75 GHz downlink band.6 Indeed, Intelsat 8 (“IS-8”), which operated at 166° E.L. prior to the launch of IS-19, was also authorized to provide Fixed Satellite Service (“FSS”) in the 12.25- 2 See Gogo LLC ESAA License, File No. SES-LIC-20120619-00574, at 2 & 4 (condition 90056) (granted May 1, 2013) (authorizing Intelsat 19 (Call Sign S2850) at 166.0 degrees E.L. as a point of communication). 3 See EchoStar Comments, File Nos. SES-MOD-20121023-00963 & SES-AFS-20130920- 00833 at 2 (filed December 13, 2013). 4 See Gogo LLC Response to Comments, File Nos. SES-LIC-20120619-00574, SES-AMD- 20120731-00709 and SES-AFS-20121008-00902 et al., Attachment A (filed November 27, 2013). 5 In the IS-19 application, Intelsat sought and obtained a waiver to permit use of the 12.25-12.75 GHz band for Region 2 downlinks. Intelsat explained that these operations would not harm BSS networks because there is sufficient orbital separation between IS-19 and both the nearest Region 2 BSS plan assignment (175.2° W.L.) and the nearest operational BSS satellite (129° W.L.). 6 See Intelsat 19 Authorizations, Call Sign S2850 and File Nos. SAT-RPL-20111222-00245, SAT-MOD-20120628-00107, SAT-STA-20120621-00102 and SAT-STA-20120613-00097 et al. (authorizing Intelsat to operate IS-19 in the 12.25-12.75 GHz downlink band with temporary authority commencing in August 2012).

Mr. Jose Albuquerque December 23, 2013 Page 3 of 3 12.75 GHz downlink frequency band in Region 2 pursuant to a waiver.7 There have been no reported incidences of harmful interference to BSS networks resulting from these operations on IS-19 and IS-8, use which dates back, in the aggregate, more than seven years. Row 44 notes, in addition, that it is seeking only to receive downlink signals from IS-19 in the 12.25-12.75 GHz band, and therefore these operations will have no interference impact upon BSS networks. Moreover, Row 44 does not seek interference protection for its ESAA downlinks with respect to existing or future BSS operations, and the waiver sought is geographically limited, including only the portion of Region 2 that is visible from IS-19. Finally, in the unlikely event that any interference is caused by Row 44’s operations to existing primary service users in the requested bands, Row 44 will cease the interfering operations. It is Row 44’s understanding, following discussions with EchoStar, that the attached showing fully addresses EchoStar’s concerns and satisfies its request for an interference analysis demonstrating that Row 44’s planned operations using IS-19 will not cause harmful interference to U.S. BSS networks, constrain future use of BSS spectrum, or otherwise impair access to the BSS downlink bands. Accordingly, grant of the requested modification will serve the public interest, and the Commission should proceed with processing and grant of its application on an expedited basis. Respectfully submitted, s/ David S. Keir David S. Keir Counsel to Row 44, Inc. cc: Jennifer A. Manner, EchoStar 7 See PanAmSat Licensee Corp., 21 FCC Rcd 36, 36 & 39-40 (¶¶ 1 & 9-12) (IB 2006) (granting PanAmSat’s request for waiver of the Table of Frequency Allocations to permit it to use the IS-8 downlink frequencies at 12.25-12.75 GHz for FSS in ITU Region 2).





Document Created: 2013-12-23 17:47:58
Document Modified: 2013-12-23 17:47:58
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