VS Amendment Attachm

SUPPLEMENT submitted by ViaSat, Inc.

Amended Attachment A

2011-09-27

This document pretains to SES-STA-20110526-00633 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011052600633_918808

                                                                        Amended Attachment A



                                 Amended and Restated
         Request for Special Temporary Authority to Communicate with VIASAT-1

                ViaSat, Inc. (“ViaSat”) requests Special Temporary Authority (“STA”) to use
certain earth station facilities to communicate with its Ka-band VIASAT-1 satellite to enable in-
orbit testing and short-term operations at 109.2º W.L. and also while VIASAT-1 is drifted to its
ultimate location at 115.1º W.L. The 109.2º W.L. location is not occupied at Ka band and thus is
available for these operations. As summarized in the table below, ViaSat has pending
applications for full authority for each of these facilities: the TT&C and Gateway facilities are
the subject of individual applications; the user terminals are the subject of a single blanket
license application.

                STA is requested for a period not to exceed ninety (90) days from the date of
launch, which is expected to occur on or about October 19, 2011. 1 ViaSat anticipates being able
to notify the Commission about the precise scheduled launch date of VIASAT-1 prior to actual
grant of this STA.

               ViaSat is filing concurrently the following requests for STA to operate earth
stations to communicate with VIASAT-1 at 109.2º W.L. The Commission currently has before it
the pending applications referenced below, which contain the salient technical parameters that
are not contained in this STA request:

Antenna Type            Antenna Location              Pending Application
TT&C and Gateway        Rapid City, SD                E110015
                                                      SES-LIC-20101217-01585
                                                      SES-AMD-20110128-00074
TT&C and Gateway        Milford, UT                   E110026
                                                      SES-LIC-20110228-00212
                                                      SES-AMD-20110502-00541
Gateway                 Denver, CO                    E110048
                                                      SES-LIC-20110328-00379
                                                      SES-AMD-20110502-00537
User Terminal           Vicinity of Green Bay, WI     E100143
                                                      SES-LIC-20101217-01585
                                                      SES-AMD-20110128-00074
User Terminal           Vicinity of Phoenix, AZ       E100143
                                                      SES-LIC-20101217-01585
                                                      SES-AMD-20110128-00074
User Terminal           Vicinity of San Diego, CA     E100143
                                                      SES-LIC-20101217-01585
                                                      SES-AMD-20110128-00074

1
        The proposed STA operations would commence after the satellite is located at 109.2º
        W.L. by ViaSat’s satellite manufacturer, which is expected to occur approximately 12-14
        days after launch.


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User Terminal            Vicinity of Portland, OR       E100143
                                                        SES-LIC-20101217-01585
                                                        SES-AMD-20110128-00074

                These STAs will allow ViaSat to conduct in-orbit testing of VIASAT-1
immediately after its launch, perform TT&C at 109.2º W.L., and drift the spacecraft from
109.2º W.L. to 115.1º W.L. They also will enable short-term operations at 109.2º W.L. with less
than full two-degree spacing from other existing Ka band satellite operations—namely, ViaSat’s
WildBlue service on WildBlue-1 and Anik F2 at 111.1º W.L. Such short-term operations
generally will be consistent with the parameters specified in the pending applications cited above
or in the VIASAT-1 authorization, and will allow ViaSat to gather valuable technical data that
could assist in the development, coordination and/or operation of broadband satellite systems at
locations where the “offsets” required by the Commission’s safe flight policies do not allow full
two-degree spacing. Thus, the proposed operations at 109.2º W.L. present a unique opportunity
to create a controlled environment for evaluating actual Ka-band broadband operations at less
than two-degree spacing.

               ViaSat is coordinating the proposed operations with operators of commercial
Ka-band satellites within six degrees of 109.2º W.L. In the unlikely event that harmful
interference nonetheless occurs, ViaSat will take all appropriate steps to eliminate the
interference. In addition, ViaSat has initiated the US334 coordination process for the proposed
operations.

              ViaSat has evaluated the potential for an overlapping station-keeping volume with
another spacecraft near 109.2º W.L. No satellite system is currently located at 109.2º W.L., and
ViaSat is unaware of any other system that will be located in the immediate vicinity during these
proposed operations.

               In-orbit testing will consist of performance verification testing of each beam on
VIASAT-1. The Rapid City and Milford gateways will provide TT&C and backup TT&C
functionality during the testing and will operate at power levels consistent with regular
operations. The Denver gateway will be used to transmit and receive test signals, and, consistent
with industry practices and as detailed below, that gateway will temporarily need to transmit to
the spacecraft at higher-than-normal power levels during certain tests.

                In order to allow the Denver gateway to test each beam in each direction (both
uplink and downlink), the spacecraft will be oriented at various times to position a given beam
over Denver for the appropriate test. In closed-loop tests, the satellite will be oriented such that
both the uplink and downlink beams being tested are positioned over the Denver gateway. In
open-loop uplink tests, each uplink beam will be positioned over the Denver gateway, which will
result in the corresponding downlink beam illuminating a different geographic area than under
regular operations (with that signal not intended to be received by any earth station). Open-loop
downlink tests will be performed on a “noise loaded” basis (there will be no uplink
transmission), with each downlink beam under test being positioned over the Denver gateway.




                                                 2
DC\1542120.2


                 Tests that involve uplink transmissions will be performed using unmodulated CW
carriers transmitted from the Denver site. In certain cases, this will involve a maximum uplink
power level of 85 dBW, which exceeds the level specified in the pending applications and the
VIASAT-1 authorization. Operations at these higher-than-normal power levels will be short-
term (i.e., typically several minutes) and limited to two specific frequencies that, consistent with
Section 25.138, are being coordinated with adjacent satellites. Those frequencies currently are
planned to be at 28.61 GHz and 29.75 GHz, but could be anywhere within the 28.1-29.06 GHz
and 29.5-30.0 GHz ranges, depending on coordination. The corresponding downlink power level
of 73 dBW is higher than the level authorized for VIASAT-1, and the resulting pfd will be
-89 dBW/m2/MHz, which exceeds the limit in Section 25.208(e). Those frequencies currently
are planned to be 18.81 GHz and 19.95 GHz, but could be anywhere within the 18.81-19.26 GHz
and 19.7-20.2 GHz ranges, depending on coordination of the corresponding uplink band. While
ViaSat does not believe that the brief duration of the testing at these power levels will result in
harmful interference to terrestrial users, it bears emphasis that all remaining terrestrial users in
these frequency ranges operate on a secondary basis, and are not entitled to interference
protection in any event. 2 To the extent necessary, ViaSat seeks a waiver of Section 25.208(e) to
allow the testing operations described above.

                ViaSat has filed an application for Commission authority to launch VIASAT-1
and operate it at 115.1º W.L. 3 The Commission already has granted U.S. market access for the
Isle of Man/United Kingdom-authorized VIASAT-1 satellite at 115.1º W.L., and has passed on
the technical specifications of this spacecraft. 4 While at 109.2º W.L., VIASAT-1 will operate
pursuant to Commission authority pursuant to STA, a request for which is currently pending.

               ViaSat will make available a 24/7 point of contact in the event that any issues
arise in connection with the operations under the requested STAs. Personnel will be on duty at
all times during the STA period and can be contacted at (720) 493-7300.

               The proposed operations are a critical step in ensuring that VIASAT-1 will be
fully operational after its upcoming launch and upon arrival at 115.1º W.L. Furthermore, the
proposed operations will allow ViaSat to gather valuable technical data that could assist in the
development, coordination and/or operation of broadband satellite systems in a less-than-full-
two-degree-spaced environment. Moreover, all appropriate arrangements are in place with
ViaSat’s manufacturer and launch provider to enable the launch into and testing of VIASAT-1 at
109.2º W.L. Thus, grant of the requested STAs would serve the public interest, convenience and
necessity.




2
        See 47 C.F.R. § 101.147(r) (stations operating in the 18.8-19.3 GHz band are no longer
        co-primary with Part 25 services after June 8, 2010).
3
        See SAT-LOA-20110722-00132; as amended (Call Sign 2830).
4
        See SAT-LOI-20080107-00006; SAT-AMD-20080623-00131; SAT-AMD-20090213-
        00023 (Call Sign S2747), grant stamped Aug. 18, 2009.

                                                 3
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Document Created: 2011-09-27 15:27:47
Document Modified: 2011-09-27 15:27:47

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