Attachment Narrative Statement

This document pretains to SES-STA-20111128-01387 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011112801387_928054

FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) Panasonic Avionics Corporation ) File No. ) Authority to Operate Up to 50 Technically ) Identical Aeronautical Mobile-Satellite ) Call Sign: E100089 Service Aircraft Earth Stations in the 14.0- ) 14.4 GHz and 11.7-12.2 GHz Frequency ) ) Bands REQUEST FOR SPECIAL TEMPORARY AUTHORIZATION Panasonic Avionics Corporation (“Panasonic”), pursuant to Section 25.120(b)(3) of the Commission’s rules, 47 C.F.R. § 25.120(b)(3), hereby seeks a 60-day special temporary authority (“STA”) to continue operating its “eXConnect” aeronautical mobile-satellite service (“AMSS”) system on a commercial basis. The Commission recently authorized Panasonic to operate the eXConnect AMSS system onboard Lufthansa Airlines aircraft using the previously authorized MELCO antenna.1 Concurrent with the filing of the instant STA request, Panasonic has filed with the Commission a Modification Application to modify the pointing offset threshold for increasing data logging frequency (i.e., decreasing the interval between individual log entries) included in the Panasonic AMSS Authorization from 0.2º to 0.25º to reflect the actual 1 Order and Authorization, Panasonic Avionics Corporation, Application for Authority to Operate Up to 50 Technically Identical Aeronautical Mobile-Satellite Services Aircraft Earth Stations in the 14.0-14.4 GHz and 11.7-12.2 GHz Frequency Band, File Nos. SES-LIC- 20100805-00992, SES-AMD-20100914-01163, SES-AMD-20101115-01432, SES-AMD- 20110325-00358, SES-AFS-20110405-00402, SES-STA-20110104-00005, Call Sign E100089, DA 11-1480 (Aug. 31, 2011) (“Panasonic AMSS Authorization”).

technical characteristics of the MELCO aircraft earth station (“AES”) antenna and data logging protocol being implemented by Panasonic.2 I. DISCUSSION On August 31, 2011, the Commission authorized Panasonic to operate the eXConnect AMSS system onboard Lufthansa Airlines aircraft using the previously authorized MELCO antenna.3 In so doing, the Commission concluded that grant of the authorization would serve the public interest by allowing Panasonic “to provide two-way, in-flight broadband services, including Internet access, to passengers and flight crews aboard commercial airliners, thereby enhancing competition in an important sector of the mobile telecommunications market in the United States.”4 On September 30, 2011, Panasonic filed an application for a 30-day Special Temporary Authority (“STA”) to afford sufficient time to complete the ongoing software program necessary to fully implement the data logging protocol designed by Panasonic in anticipation of receiving its AMSS license. Included with the STA application was a Request for Clarification and/or Limited Waiver to confirm that the data logging approach embodied in its data logging protocol complies with the Panasonic AMSS Authorization. On November 22, 2011, the Commission granted the STA until December 21, 2011,5 but for procedural reasons no action was taken on the Request for Clarification and/or Limited Waiver. Given the current procedural posture, Panasonic now understands that the 2 Panasonic Aeronautics Corporation, Modification Application, Call Sign E100089, SES- MOD-INTR2011-04985, SES-LIC-20100805-00992, SES-AMD-20100914-01163, SES- AMD-20101115-01432, SES-AMD-20110325-00358, SES-AFS-20110405-00402, SES- STA-20110104-00005, Call Sign E100089 (filed Nov. 28, 2011). 3 See generally id. 4 See id. at ¶ 1. 5 See SES-STA-20110930-01161 (Nov. 22, 2011). ‐2‐

appropriate mechanism to ensure that the data logging condition in its license reflects the technical characteristics of the MELCO antenna and data logging protocol designed by Panasonic is to request modification of the relevant license condition. A. Data Logging Condition and Current Protocol The stated pointing accuracy of the MELCO AES antenna is 0.25°. The Panasonic AMSS Authorization includes Condition 26(k) as one of several operating requirements for the eXConnect system: Panasonic shall maintain records of the following data for each operating AES: location (latitude, longitude, altitude); aircraft attitude (pitch, yaw, roll); transmit frequency and occupied bandwidth; data rate; EIRP; and target satellite. This data shall be recorded at intervals of no more than two minutes while an AES is transmitting and every 30 seconds when aircraft roll angle is greater than 10 degrees. Panasonic shall also record instances when AES pointing error angle is greater than 0.2 degrees. Panasonic shall make this data available upon request to an FSS system operator or the Commission within 24 hours after receiving the request.6 Consistent with the stated pointing accuracy of the MELCO antenna, however, Panasonic’s data logging protocol decreases the time between log entries from every two minutes to every 30 seconds if an aircraft roll angle exceeds 10° or the pointing offset angle exceeds 0.25° rather than 0.2° as set forth in Condition 26(k). B. Grant of 60-Day Special Temporary Authority Will Serve the Public Interest Panasonic is seeking a further 60-day STA to continue operating its eXConnect system on a commercial basis during the pendency of the companion Modification Application. A further 60-day STA will also enable Panasonic to continue to operation of its eXConnect system in the manner authorized in the AMSS Authorization while Panasonic continues to implement the data logging software update and continue to provide service to 6 See Panasonic AMSS Authorization at ¶ 26(k) (emphasis added). ‐3‐

MELCO-equipped Lufthansa Airlines aircraft that intermittently transit U.S. airspace, which have operated without interference since the commencement of experimental trials in 2010. The requested modification is in the public interest because it will enable Panasonic to implement its data logging protocol based on prior Commission precedent to support provision of its innovative two-way, in-flight broadband services to passengers and crew onboard aircraft in flight. Grant of the STA request will also afford the Commission time to consider the Modification Application, which is akin to a minor modification under Section 25.118 (47 C.F.R. § 25.118) of the Commission’s Rules because it will in no way increase the potential for interference from eXConnect system operations. This, in turn, will enhance competition in the mobile telecommunications market in the United States.7 Grant of the request STA will also ensure that the increase in consumer demand for in-flight broadband services will be met by affordable and reliable broadband communications services while strengthening U.S. leadership in these advanced communications services. 7 Panasonic AMSS Authorization at ¶ 1. ‐4‐

II. CONCLUSION In view of the foregoing, and in the absence of any objection or public interest harm and the significant public benefits associated with the requested relief, Panasonic respectfully requests that the Commission grant Panasonic a 60-day STA to permit continued operation of the eXConnect system on a commercial basis. Sincerely, PANASONIC AVIONICS CORPORATION /s/ Carlos M. Nalda _________________________ Carlos M. Nalda Squire, Sanders & Dempsey (US) LLP 1200 19th Street, N.W. Suite 300 Washington, D.C. 20036 Its Attorney November 28, 2011 ‐5‐

CERTIFICATE OF SERVICE I, Mark D. Johnson, do hereby certify that on this 28th day of November, 2011, I caused to be sent via First Class, postage prepaid US mail, a copy of the foregoing “Request for Special Temporary Authority” to the following persons: David S. Keir, Esq. Lerman Senter PLLC 2000 K Street, NW Suite 600 Washington, DC 20006 Counsel for Row 44, Inc. ‐6‐


Document Created: 2011-11-28 16:16:55
Document Modified: 2011-11-28 16:16:55
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC