Attachment Modification adendum

This document pretains to SES-MOD-20171003-01092 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017100301092_1284367

                            APPLICATION FOR MODIFICATION
         The Boeing Company (“Boeing”) requests modification of its existing license (E140097)

for Earth Stations Aboard Aircraft (“ESAA”)1 to add satellite Eutelsat E172B as an authorized

point of communication.2

         The Boeing Broadband Satellite Network (“BBSN”) currently operates with multiple

satellite points of communications, including satellite E172A at orbital location 172° E.L.

E172A provides high-capacity coverage over the Pacific Ocean necessary to support

Boeing’s operations on behalf of the United States Government. The E172A satellite is

scheduled to be replaced during the 4th quarter of 2017. Boeing has identified the E172B

satellite as a suitable replacement to support Boeing’s operations on behalf of the United States

Government. Boeing therefore seeks authority to begin operating using the E172B satellite by 15

November 2017. Concurrently with this application, Boeing is filing a request for Special

Temporary Authority to permit testing to begin with the new satellites during the pendency of

this application.




________________________________
1
 Application of The Boeing Company for Authority to Operate Up to 100 Earth Stations
Aboard Aircraft, Call Sign E140097, File Not. SES-LIC-20140922-00748 (Granted Mar. 18,
2015) (“Boeing ESAA Application”).
2
    Call Sign S3021.


         I. SATELLITE POINTS OF COMMUNICATION AND NETWORK CONTROL

         E172B is the replacement satellite for E172A and will be licensed in the U.S. and

subsequently listed on the Commission’s Approved Space Station List.3 Thus, all of the

information normally required under Section 25.114, 47 C.F.R. § 25.114, has already

been provided to the Commission in a prior application. To the extent necessary, Boeing

incorporates that information by reference.4

         The Boeing ESAA network uses variable power-density control of individual

simultaneously transmitting co-frequency ESAA terminals in the same satellite receiving beam.

Sections 25.227(a)(3)(ii) and 25.227(b)(3)(ii) of the Commission’s rules require variable power

systems to either operate 1 dB below the off-axis EIRP spectral density (“ESD”) envelope

defined in the Commission’s rules, or to secure certificates from the target satellite operator

indicating that such higher power levels have been coordinated with adjacent satellite operators

within six degrees in each direction. Accordingly, Boeing provides the attached statements

from Intelsat certifying to the information required by the Commission’s rules, including that the

aggregate ESD limits that the Boeing ESAA system adheres to have been coordinated with

adjacent satellite operators. The network control and measures for ensuring the protection of

other spectrum users will be the same as described in Sections II.D and V of Boeing’s ESAA

application.5




___________________________________
3
 https://www.fcc.gov/approved-space-station-list.
4
    Application of ES 172 LLC, SAT-RPL-20170927-00136 (Filed 27 September 2017)
5
    Boeing ESAA Application at 7, 15.


                                       II. PUBLIC INTEREST

        Boeing’s BBSN network exclusively serves the needs of the United States Air Force Air

Mobility Command in support of critically-important air transport operations. BBSN is used by

the Air Force to enable broadband capabilities on more than a dozen Very Important

Personnel/Special Air Mission aircraft operated by the U.S. Air Force to transport senior

leadership of the U.S. Government and the Department of Defense.

        It is crucial that BBSN maintain the coverage and capacity capabilities required by Air

Force Mobility Command missions. Therefore, authority to communicate with E172B

will strongly serve the public interest, and Boeing requests that the Commission grant this

application at the earliest practical time.


‘)3 eutelsat
       communications via satellite




                                                                                                           September 1st, 2017


  To whom it may concern


    Re: Engineering Certification of Eutelsat




  Eutelsat confirms and hereby certifies the following with respect to the operations proposed in
  the above reference application:

       a) The proposed Ku—band operation of BOEING‘s ESAA terminal has the potential to
            create harmful interference to adjacent satellite networks that may be unacceptable;
       b) BOEING will use Eutelsat capacity on the Eutelsat 10A and Eutelsat 172B
          satellites for other ESAA operations
       c) The proposed operation of the ESAA transmit/receive terminals at the power
          density levels defined between BOEING and Eutelsat is consistent with existing
          satellite coordination agreements with the adjacent satellites of the Eutelsat 10A
          and Eutelsat 172B satellites within 6 degrees of orbital separation from the
          satellite.

  If the FCC authorizes the operation proposed by BOEING, Eutelsat will include the power
  density levels specified by BOEING, defined within the satellite coordination agreements, in all
  future satellite network coordination with operators of satellite that are adjacent to those
  satellites addressed by this letter.



                                                                                  Sincerely,           |


                                                                                g;-or;E‘uteét
                                                                                  Filipe De Oliveira
                                                                                  Director of Resources Engineering




                                                                                                               ———www.eutelsat.com

  Eutelsat S.A. — société anonyme & Conseil d‘Administration au capital de 987 459 990 € — RCS n° 422 551 176 Paris
  Siege social — 70 rue Balard — F—75502 Paris Cedex 15 — France : tel. +33 1 53 98 47 47 — fax +33 1 53 98 37 00



Document Created: 2017-10-02 10:14:02
Document Modified: 2017-10-02 10:14:02

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