Panasonic-1 65 Lette

Section 1.65 Notification submitted by Panasonic Avionics Corporation

1.65 Letter

2012-09-14

This document pretains to SES-STA-20120913-00820 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2012091300820_966324

Squire Sanders (US) LLP 1200 19th Street, NW Suite 300 Washington, D.C. 20036 O +1 202 626 6600 F +1 202 626 6780 squiresanders.com Carlos M. Nalda T +1 202 626 6659 carlos.nalda@squiresanders.com September 13, 2012 VIA ELECTRONIC FILING Marlene Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Application of Panasonic Avionics Corporation for Special Temporary Authority, File No. SES-STA-INTR2012-02135, Call Sign E100089 Dear Ms. Dortch: Panasonic Avionics Corporation (“Panasonic”), pursuant to Section 1.65 of the Commission’s Rules, 47 C.F.R. § 1.65, hereby submits this letter to clarify certain information relating to the above-referenced application for special temporary authority (“STA”). Although filed concurrently with an application to modify Panasonic’s aeronautical mobile-satellite service (“AMSS”) license Call Sign E100089, the FCC Form 312 associated with the STA application does not include the file number of the modification application because it was not available at the time of the STA filing. For the record, the response to Question 3 on the Form 312 should read: “File No. SES-MFS-20120913-00818 (IBFS Submission No. IB2012002134)” so that the STA application can be associated with the modification application for license Call Sign E100089. In addition, in the context of an STA application, there is no opportunity to separately complete Schedule B of Form 312 and instead the Commission must refer to the technical information set forth in the STA application itself (narrative and attachments) and Schedule B of the associated modification application. In this case, the Schedule B of Form 312 of the modification application includes technical parameters – most importantly maximum transmit power spectral density levels -- associated with worldwide operation of Panasonic’s AMSS system, including in regions with greater than two-degree orbital spacing. 37 Offices in 18 Countries Squire Sanders (US) LLP is part of the international legal practice Squire Sanders which operates worldwide through a number of separate legal entities. Please visit squiresanders.com for more information.

Squire Sanders (US) LLP September 13, 2012 For avoidance of doubt, as indicated in the Technical Appendix filed with the STA application, the maximum EIRP spectral density associated with interim operations in the United States is 16.3 dBW/4 kHz (36.5 dBW EIRP) for the narrowest 500KG7D carrier (see STA Attachment 1, Technical Appendix at 7). This value is well below the power level coordinated for the Galaxy 17 satellite used for U.S. operations (see STA Attachment 3, Coordination Information) and is fully compliant with the Commission’s two-degree spacing policies and analogous off-axis EIRP spectral density levels for other mobile Ku-band services (see, e.g., 47 C.F.R. §§ 25.222, 25.226). Please feel free to contact the undersigned with any questions you may have or if Panasonic can provide any additional information to facilitate expeditious action on its STA application. Respectfully submitted, Squire Sanders (US) LLP /s/ Carlos M. Nalda ___________________________ Carlos M. Nalda Counsel to Panasonic Avionics Corporation cc: Paul Blais, FCC International Bureau 2


Document Created: 2012-09-14 07:02:35
Document Modified: 2012-09-14 07:02:35
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