Attachment Narrative

This document pretains to SES-MOD-20180314-00221 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2018031400221_1354216

                                 Before the
                   FEDERAL COMMUNICATIONS COMMISSION
                            Washington, DC 20554

In the Matter of

Application of KVH Industries, Inc. to       )   Call Sign E090001
Modify its Ku-band Earth Stations            )
Onboard Vessels (“ESV”) Blanket License      )   File No. SES-MOD-____________



               APPLICATION TO MODIFY ESV BLANKET LICENSE

         By this application, KVH Industries, Inc. (“KVH”) seeks to modify its existing

Ku-band earth station onboard vessel (“ESV”) blanket license, Call Sign E090001, 1 by

adding additional emission designators for its previously licensed Tracphone Model V3

(“V3”) ESV terminal. KVH will continue to operate the V3 ESV terminal below the off-

axis ESD levels specified in Sections 25.222(a)(1)(i) of the Commission’s rules and will

otherwise operate consistent with Commission policies governing ESVs.2

         Currently in the ESV Blanket License, KVH is authorized to operate the V3 ESV

terminal using various emission designators to communicate with satellites on the

Commission’s Permitted Space Station List (“Permitted List”) in the 14.0-14.5 GHz

(Earth-to-space), 10.95-11.2 GHz (space-to-Earth), 11.45-11.7 GHz (space-to-Earth) and

11.7-12.2 GHz (space-to-Earth) bands. Here, KVH seeks to add narrower bandwidth

carriers capable of supporting high-throughput satellite (“HTS”) beams on various U.S.-

licensed Permitted List satellites, thereby improving KVH’s operational efficiency and

enhancing the provisioning of satellite-based communications services to private,


1See KVH Industries, Inc., File No. SES-LIC-20081104-01450 and subsequent filings
and modifications, Call Sign E090001 (“ESV Blanket License”).
2   See generally 47 C.F.R. § 25.222.


commercial and government vessels operating in U.S. waters and beyond.

          As noted, KVH will continue to operate the V3 terminal within the off-axis EIRP

spectral density limits specified in Section 25.222(a)(1) of the Commission’s rules and, to

the extent applicable, incorporates by reference the V3 terminal technical information

previously submitted in support of the ESV Blanket License. 3 Pursuant to Section

25.117(c) of the Commission’s rules,4 KVH provides the FCC Form 312 Schedule B and

updated radiation hazard study for information that is changing as a result of the

requested modification. KVH confirms that V3 terminal operations will be consistent

with the terms, conditions and operational parameters that are currently authorized in the

ESV Blanket License.

          The public interest would be served by grant of this modification because it will

allow KVH to deliver improved commercial services by utilizing HTS beams on multiple

satellites, thereby providing enhanced high-speed satellite broadband connectivity to

various U.S. maritime customers. Additionally, because the new emission complies with

the Commission’s two-degree spacing values and other ESV rules and policies, grant is

fully consistent with the public interest.

          Based on the foregoing, KVH respectfully request that the Commission grant its

request to modify its existing Ku-band ESV blanket license, Call Sign E090001, by

adding additional emission designators for its previously licensed V3 ESV terminal.




3   Supra n. 1.
4   47 C.F.R. § 25.117(c).



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Document Created: 2018-03-14 21:23:16
Document Modified: 2018-03-14 21:23:16

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