Attachment Exhibit A

This document pretains to SES-MOD-20180206-00088 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2018020600088_1335044

                                   Description of Modification

With this application, Viasat, Inc. (“Viasat”) requests modification of its earth station located in
Pendergrass, Georgia (call sign E160161, File No. SES-MOD-20170718-00770) to add new
narrowband emissions that will be used to communicate with the General Atomics Orbital Test
Bed (“OTB”) Earth Exploration Satellite Service (“EESS”) non-geostationary orbit (“NGSO”)
satellite. The Viasat ground station will be used with the OTB satellite for telemetry, tracking
and control (“TT&C”) in both Launch and Early Operation (LEOP) and ongoing operations.
The technical parameters will be identical for both the LEOP and ongoing operations.

The OTB satellite is expected to be launched in the second quarter of 2018 and will be used for
remote sensing applications. It will operate in a circular, inclined orbit of 24 degrees at an
altitude of 720 km. General Atomics has not yet filed an application for authority to operate the
OTB satellite with the Commission. However, General Atomics has discussed the proposed
satellite operations with Commission staff and other interested agencies. Viasat expects General
Atomics to file shortly an application for authority with the Commission containing the technical
parameters of the satellite. This request to modify the Pendergrass earth station is being
submitted at this time due to the short time until satellite launch and the need to provide critical
LEOP support.

The emission designators that will be used with the OTB satellite will be narrower than the
existing emissions on the license, and thus, the earth station may be operated at power spectral
density levels that are higher than currently authorized. Viasat originally coordinated the earth
station operations with TV broadcast auxiliary service (“BAS”) licensees in the vicinity. In that
coordination, Viasat confirmed to potentially impacted BAS licensees that Viasat would
undertake certain measures to mitigate potential interference. Namely, Viasat indicated that it
would construct a shielding berm to protect a particular antenna tower location that does not
have sufficient naturally occurring terrain shielding in the direction of Viasat’s earth station.
Viasat intends to conduct testing to confirm that the berm sufficiently protects the potentially
impacted BAS stations. In addition, in connection with the original license application, Viasat
prepared an analysis of the potential impact of the earth station operations on certain
communications links with helicopters used in electronic news gathering by one particular BAS
licensee. Viasat indicated that it would undertake coordination with that BAS licensee for the
periodic helicopter operations.

The higher power operations proposed in this application are still within the scope of the
coordination Viasat undertook in connection with the currently authorized earth station
parameters. Attached here is a supplement to the original coordination study that Viasat
provided in the original license application. The supplement confirms that the berm
contemplated in the original coordination report would be sufficient to shield the BAS stations at
the antenna tower location at issue, even with the narrower bandwidth emissions proposed in this
application. Viasat will also coordinate testing of the berm and the above-mentioned helicopter
operations, as it originally committed to doing. Therefore, the proposed modifications are within
the scope of the original coordination.


                                                                                           WILLIAM F. HAMMETT, P.E.
                                                                                             RAJAT MATHUR, P.E.
                                                                                             ROBERT P. SMITH, JR.
                                                                                               NEIL J. OLIJ, P.E.
                                                                                                AMELIA NGAI
                                                                                                MANAS REDDY
                                                                                               ___________
                                                                                           ROBERT L. HAMMETT, P.E.
                                                                                                   1920-2002
                                                                                             EDWARD EDISON, P.E.
                                                                                                  1920-2009
                                                                                               ___________
                                                                                            DANE E. ERICKSEN, P.E.
              BY E-MAIL DARYL.HUNTER@VIASAT.COM                                             ANDREA L. BRIGHT, P.E.
              AND BY FIRST CLASS MAIL                                                            CONSULTANTS


              November 10, 2017

              Daryl Hunter, P.E.
              Senior Director, Regulatory Affairs
              ViaSat, Inc.
              6155 El Camino Real
              Carlsbad, California 92009

              Dear Mr. Hunter:

              This is a supplement to our July 22, 2016, report, Frequency Coordination Study for Proposed
              EESS Uplink near Pendergrass, Georgia. That study was based on a 2 GHz Earth Exploration
              Satellite Service (EESS) uplink on 2,056 MHz with 1M31F1D emission and a main beam
              equivalent isotropic radiated power (EIRP) of 83.2 dBm. The uplink signal would therefore be
              co-channel with TV Broadcast Auxiliary Service (BAS) Channel A3, 2,049.5–2,061.5 MHz.

              The power flux density, expressed in the standard International Bureau units of dBW/4 kHz,
              would be 28.0 dBW/4 kHz. Mr. Gerry Einig of ViaSat’s System Engineering department asked
              whether a shielding berm with at least 37 dB of isolation, the amount of shielding we found
              necessary to protect a nearby electronic news gathering receive-only (ENG-RO) with no terrain
              obstruction to the proposed uplink antenna, would remain sufficient to ensure no interference if
              uplink signals with narrower emission (but no increase in main beam EIRP) were to be used.
              These narrower signals could increase the power spectral density by up to 25 dB (but again, not
              increase the main beam EIRP).

              The protection criteria used for our study was a very stringent – no more than a 0.5 dB
              degradation of the protected ENG signal – and the protected received signal level (RSL) was not
              a predicted, rain or Raleigh-faded signal but rather the noise floor of a highly-sensitive central
              ENG receiver itself. The receiver’s noise floor was used because the location of an originating
              ENG truck could be at the furthest extent of the useful service distance for an ENG receive site.
              Because of this stringent interference criteria, which is a frequency re-use criteria, not a
              frequency-sharing criteria, the interference from a below-threshold uplink signal should be quite
              insensitive to the modulation density. That is, if a co-channel potentially interfering signal is at
              least 9 dB below the -105 dBm RSL noise threshold assumed for a 6 MHz wide split-channel
              digital ENG signal, it should no longer matter what the bandwidth of the interfering signal
              is. This might not be true for an extreme case of a continuous wave (CW) interfering signal, but


    e-mail:   dericksen@h-e.com
 Delivery:    470 Third Street West • Sonoma, California 95476
Telephone:    707/996-5200 San Francisco • 707/996-5280 Facsimile • 202/396-5200 D.C.


Daryl Hunter, P.E., page 2
November 10, 2017



that is not what you have proposed; rather, the uplink signal would still have digital modulation,
but it would be a narrower emission than the 1M31F1W emission that our 2016 report studied.

Thus, it is our opinion that a shielding berm with at least 37 dB of attenuation towards the
nearby and line-of-sight “Fox Tower” ENG-RO site would continue to be adequate even for
narrower bandwidth uplink signals. Note that the 252.4°T±3° EESS transmitting antenna
preclusion azimuth called for in our 2016 study would still be required.

We appreciate the opportunity to be of service and would welcome any questions on this matter.
Please let us know if we can be of further assistance.

Sincerely,




Dane E. Ericksen
rb

cc:   Mr. Gerry Einig - BY E-MAIL GERRY.EINIG@VIASAT.COM



Document Created: 2018-02-06 13:29:17
Document Modified: 2018-02-06 13:29:17

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