Attachment Exhibit C

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

IBFS_SESMOD2012102300963_972570

Exhibit C Coordination Letters 1

October 3, 2012 Federal Communications Commission International Bureau 445 12th Street, SW. Washington, D.C. 20554 Re: Engineering Certification Concerning Intelsat 19 (IS—19) at 166° E.L. To Whom It May Concern: This letter certifies that Intelsat LLC ("Intelsat") understands that Row 44, Inc. {"Row 44") is seeking to modify its existing Federal Communications Commission ("FCC") blanket authorization (FCC Call Sign E080100) for operation of aeronautical mobile—satellite service ("AMSS") transmit/receive Earth stations, on a non—conforming, non—harmful—interference basis, using fixed—satellite service {"FSS") frequencies pursuant to [TU RR 5.504A. Row 44 is seeking to modify its FCC authorization to add several satellites as additional points of communication, including Intelsat 19 ("1S—19") at 166° East Longitude. Intelsat further understands that Row 44‘s primary transmit/receive antenna is an AMSS steerable antenna manufactured by TECOM designed to provide bi—directional broadband services to aircraft in flight. The antenna is identified by the model number Ku—Stream 1000. it supports reception and transmission in the 11.45—12.75 GHz 714.05—14.47 GHz bands with incependent linear polarized array antennas to and from a geostationary satellite in space. The antenna is an independent linear polarized array that is 0.62 meters in size with a transmit gain of 28.8 dBi at 14.25 GHz and a receive gain of 31.1 dBi at 11.75 GHz. The antenna operates under gimbaled motor control to orient the antenna in azimuth, elevation and polarization and achieves a + 0.2 degree pointing accuracy during active tracking of the intended satellite. The antenna complies with Section 25.209 of the FCC‘s Rules with respect to the off—axis co—polarization gain in the plane of the geostationary satellite orbit and to the off—axis cross polarization gain using the parameters of Row 44‘s existing FCC license, under which it will continue to operate for all flights within U.S. airspace, Outside the continental United States, Row 44 will operate at higher skew angles to maximize coverage, operating in conformity with European Telecommunications Standards Institute European Standard (EN) 302 186, Satellite Earth Stations and Systems (SES); Harmonized EN for satellite mobile Aircraft Earth Stations (AESs) operating in the 11/12/14 GHz frequency bands covering essential requirements under article 3.2 of the Radio & Telecommunications Terminal Equipment Directive. The actual skew angle is constantly monitored by the antenna control system and, during transoceanic flights, the aircraft transmitter will be muted in the event that a skew angle of 65° is exceeded. When communicating with IS—19, Row 44 will operate its antenna within the 14.05—14.47 GHz FSS uplink band and the 12.25—12.75 GHz FSS downlink band with a maximum equivalent isotropically radiated power (EIRP) of 42.8 dBW. Intelsat Corporation 3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F41 202—944—7898

intelsat further accepts that the forward downlink (hub‘ to AES} maximum EIRP density for communications with is 11.8 dBW/4 kHz, which is above the 10 dBW/4 kHz specified in Section 25.134(g)(2) of the FCC‘s rules. Row 44 will maintain the forward downlink EIRP density and the off—axis EIRP spectral density by tight control of system operation that includes: 1) maintaining the pointing error to be < 0.2 degrees, relative to the intended satellite; 2) fault detection that terminates transmissions when out of tolerance conditions (including the antenna pointing error} are detected; and 3) continuous monitoring/oversight by ground network operations center (NOC). intelsat acknowledges that the use of the above referenced transmit/receive antennia by Row 44, 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 two—degree spacing policy. Intelsat has a coordination agreement in effect with Optus, JSAT and GE, the only other operators of satellites operational within +/—6° of IS—19 in the bands that are used by the Row44 system, which is consistent with the operations Row 44 proposes. If the FCC authorizes the operations proposed by Row 44 in its application, Intelsat will include the antenna, as described above, in all future satellite network coordinations with other adjacent satellite operators. Row 44 shall comply with all such coordination agreements reached by the satellite operators. In order to prevent unacceptable interference into adjacent satellites, Intelsat has been informed, and Row 44 acknowledges, that the antennas will be installed and operated in accordance with the above conditions and the terms of its FCC License. In particular, the proposed antenna will operate in compliance with the Commission‘s two—degree spacing requirements, including the pointing accuracy and shutdown requirements of Section 25.222(a) of the Commission‘s Rules that apply to mobile Earth stations on vessels, See 47 C.LR. § 25.222(a). Moreover, Row 44 agrees that it will accept interference from adjacent satellites to the degree to which harmful interference would not be expected to be caused to an earth station employing an antenna conforming in all respects to the reference patterns defined in Section 25.209 of the FCC‘s rules. If the use of this antenna should cause unacceptable interference into other systems, Row 44 has agreed that it will terminate transmissions immediately upon notice from the affected parties. ‘ The hub station being used for this service is licensed to HNS License Sub LLC under Call Sign E940460.

Based on Row 44‘s commitment to the operating conditions stated above, satellites operating at two—degree spacing or more should not experience unacceptable interference as a result of the modification of Row 44‘s AMSS blanket FCC License as outlined here to include (5—19 as an additional point of communication. Sincerely, 11. /| {/(/[ Alan Yates Senior Technical Advisor, Spectrum Engineering Intelsat LLC Acceptance by Row 44, Inc.: Row 44 affirms that the information provided to Intelsat and reflected in this coordination letter is true and accurate to the best of Row 44‘s knowledge, information and belief, and that it shall comply with all refevant coordination agreements, as provided herein. [ Qidon Chief Technical Officer Row 44, Inc.

October 3, 2012 Federal Communications Commission International Bureau 445 12th Street, S.W. Washington, D.C. 20554 Re: Engineering Certification Concerning Intelsat 27 (IS—27) at 55.5° W.L. To Whom It May Concern: This lettercertifies that Intelsat LLC ("Intelsat") understands that Row 44, Inc. ("Row 44") is seeking to modify its existing Federal Communications Commission ("FCC") blanket authorization (FCC Call Sign EO80100) for operation of acronautical mobile—satellite service ("AMSS") transmit/receive Earth stations, on a non—conforming, non—harmful—interference basis, using fixed—satellite service ("FSS") frequencies pursuant to ITU RR 5.504A. Row 44 is seeking to modify its FCC authorization to add several satellites as additional points of communication, including Intelsat 27 ("IS—27") at 55.5° West Longitude. Intelsat further understands that Row 44‘s primary transmit/receive antenna is an AMSS steerable antenna manufactured by TECOM designed to provide bi—directional broadband services to aircraft in flight. The anterna is identified by the model number Ku—Stream 1000. It supports reception and transmission in the 11.45—12.75 GHz /14.05—14.47 GHz bands covered by Row 44‘s existing FCC License with independent linear polarized array antennas to and from a geostationary satellite in space. The antenna is an inclependent linear polarized array that is 0.62 meters in size with a transmit gain of 28.8 dBi at 14.25 GHz and a receive gain of 31.1 dBi at 11.75 GHz. The antenna operates under gimbaled motor control to orient the antenna in azimuth, elevation and polarization and achieves a + 0.2 degree pointing accuracy during active tracking ofthe intended satellite. The antenna complies with Section 25.209 of the FCC‘s Rules with respect to the off—axis co—polarization gain in the plane of the geostationary satellite orbit and to the off—axis cross polarization gain using the parameters of Row 44‘s existing FCC license, under which it will continue to operate for all flights within U.S. airspace. Outside the continental United States, Row 44 will operate at higher skew angles to maximize coverage, operating in conformity with European Telecommunications Standards Institute European Standard (EN) 302 186, Satellite Earth Stations and Systems (SES); Harmonized EN for satellite mobile Aircraft Earth Stations (AESs) operating in the 11/12/14 GHz frequency bands covering essential requirements under article 3.2 of the Radio & Telecommunications Terminal Equipment Directive. Intelsat Corporation 3400 International Drive NW, Washington DC 20008—3006 USA wwwintelsat.com T+1 202—944—6800 F +1 202—944—7898

The actual skew angle is constantly monitored by the antenna control system and, during transoceanic flights, the aircraft transmitter will be muted in the event that a skew angle of 55° is exceeded. When communicating with IS— 27, Row 44 will operate its antenna within the 14.05—14.47 GHz FSS uplink band and the 11.45—12.75 GHz FSS downlink band with a maximum equivalent isotropically radiated power (EIRP) of 42.8 dBW. Row 44 will maintain the forward downlink EIRP density and the off—axis EIRP spectral density by tight control of system operation that includes: 1) maintaining pointing error to be < 0.2 degrees, relative to the intended satellite; 2) fault detection that terminates transmissions when out of tolerance conditions (including the antenna pointing error) are detected; and 3) continuous monitoring/oversight by ground network operations center (NOC). Intelsat acknowledges that the use of the above referenced transmit/receive antenna by Row 44, 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 two—degree spacing policy. Intelsat will operate the IS—21 satellite at 58°W, which is 2.5° away from IS—29. Intelsat has a coordination agreement in effect with Hispamar, the only other operator of satellites operational within +/—6° of IS—27 in the bands that are used by the Row44 system, which is consistent with the operations Row 44 proposes. If the FCC authorizes the operations proposed by Row 44 in its application, Intelsat will include the antenna, as described above, in all future satellite network coordinations with other adjacent satellite operators. Row 44 shall comply with all such coordination agreements reached by the satellite operators. In order to prevent unacceptable interference into adjacent satellites, Intelsat has been informed, and Row 44 acknowledges, that the antennas will be installed and operated in accordance with the above conditions and the terms of its FCC License. In particular, the proposed antenna will operate in compliance with the Commission‘s two—degree spacing requirements, including the pointing accuracy and shutdown requirements of Section 25.222(a) of the Commission‘s Rules that apply to mobile Earth stations on vessels. See 47 C.F.R. § 25.222(a). Moreover, Row 44 agrees that it will accept interference from adjacent satellites to the degree to which harmfulinterference would not be expected to be caused to an earth station employing an antenna conforming in all respects to the reference patterns defined in Section 25.209 of the FCC‘s rules. Ifthe use of this antenna should cause unacceptable interference into other systems, Row 44

has agreed that it will terminate transmissions immediately upon notice from the affected parties. Based on Row 44‘s commitment to the operating conditions stated above, satellites operating at two—degree spacing or more should not experience unacceptable interference as a result of the modification of Row 44‘s AMSS blanket FCC License as outlined here to include IS—27 as an additional point of communication. Alan Yates Senior Spectrum Advisor, Spectrum Strategy Intelsat LLC Acceptance by Row 44, Inc.: Row 44 affirms that the information provided to Intelsat and reflected in this coordination letteris true and accurate to the best of Row 44‘s knowledge, information and belief, and that it shall comply with all relevant coordination agreements, as provided herein. .-/ Wdon hief Technical Officer Row 44, Inc.


Document Created: 2012-10-22 11:57:09
Document Modified: 2012-10-22 11:57:09
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