Attachment Narrative

This document pretains to SES-MOD-20180720-02562 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2018072002562_1468324

                                    Description of Modification

        Viasat, Inc. (“Viasat”) requests authority to modify the coordinates of its Ka-band
gateway-type earth station located in Detroit, Michigan (Call Sign E160100). Due to conditions
on the leased property for the earth station, the exact location of the earth station was required to
be moved approximately 150 feet. The address of the modified location remains 1965 Porter
Street, Detroit, MI 489216. Grant of this modification is in the public interest because it will
allow the deployment of the earth station, which will serve as an aggregation and interconnection
point for the ViaSat-2 network. The Schedule B to the Form 312 provides the modified site
information. All other technical parameters remain unchanged.

         The earth station is authorized to communicate with the ViaSat-2 satellite at 69.9º W.L.
and to operate in the 17.7-19.3 GHz and 19.7-20.2 GHz downlink frequencies and the 27.5-29.1
GHz and 29.5-30.0 GHz uplink frequencies. Viasat is authorized to operate the earth station (i)
in the 18.3-18.8 GHz, 19.7-20.2 GHz, 28.35-28.6 GHz and 29.5-30.0 GHz frequencies on a
primary basis; (ii) in the 18.8-19.3 GHz and 28.6-29.1 GHz frequencies on a secondary basis to
NGSO FSS systems; (iii) in the 17.8-18.3 GHz band on a secondary basis to fixed terrestrial
services; (iv) in the 27.5-28.35 GHz frequencies on a secondary basis to Upper Microwave
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Flexible Use (“UMFU”) services with the rights and protections afforded by Section 25.136; and
(v) in the 17.7-17.8 GHz on an unprotected, non-interference basis pursuant to a waiver.

        Since the original license was granted, the Commission has adopted Section 25.136,
which provides that earth stations in the 27.5-28.35 GHz band segment requested prior to July
14, 2016 that were subsequently granted may be operated without providing interference
protection to stations in the UMFU service. The original application for this earth station was
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filed on June 7, 2016 and was granted on January 19, 2017, and meets these criteria.

        Because the modified earth station is in substantially the same location identified in the
current license, the -77.6 dBm/m2/MHz contour does not change materially, and Viasat requests
that the Commission grant this modification and treat the earth station as grandfathered under
Section 25.136(a)(3). UMFU licensees would be protected to the same extent before and after
the proposed modification. As detailed in the attached Exhibit A Technical Analysis, the
coverage contours at the licensed location and the modified location cover the same census
blocks (covering a total population of 2 in each case), as well as the same roadways, structures
and land uses. Therefore, the earth station should continue to be qualified to operate under
grandfathered status.

        Out of an abundance of caution, Viasat has initiated coordination with existing terrestrial
licensees in the vicinity of the modified earth station site, and Comsearch has sent a prior


1
 After Viasat sought to operate in the 18.8-19.3 GHz and 17.8-18.3 GHz band segments on a
non-interference basis pursuant to waivers of the U.S. Table of Frequency Allocations, the
Commission adopted secondary allocations for GSO FSS operations in these bands. See Update
to Parts 2 and 25 Concerning Non-Geostationary, Fixed-Satellite Service Systems and Related
Matters, Report and Order, 32 FCC Rcd 7809 ¶¶ 7, 15 (2017).
2
    See 47 C.F.R. § 25.136(a)(3).


coordination notice (“PCN”) on Viasat’s behalf to all such licensees. No objections were
received in response to the PCNs.




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Document Created: 0330-04-12 00:00:00
Document Modified: 0330-04-12 00:00:00

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