PAC 11-30 165 Letter

Section 1.65 Notification submitted by Panasonic Avionics Corporation

1.65 Notification

2012-11-30

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

IBFS_SESSTA2012091300820_976776

                                                                                                Squire Sanders (US) LLP
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                                                                                                Suite 300
                                                                                                Washington, D.C. 20036

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                                                                                                squiresanders.com



                                                                                                Carlos M. Nalda
                                                                                                T +1 202 626 6659
                                                                                                carlos.nalda@squiresanders.com



November 30, 2012

VIA ELECTRONIC FILING
Marlene H. 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-20120913-00820 (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 supplemental information for association
with the above-captioned application for special temporary authority (“STA”). Specifically,
Panasonic seeks to clarify that the scope of the STA request is limited to U.S.-registered aircraft,
as well as provide information regarding the downlink frequencies and coverage areas of the
satellite points of communication to be utilized for eXConnect operations.

       Please feel free to contact the undersigned if Panasonic can provide any additional
information to facilitate expeditious action on its pending STA application.

                                                                    Respectfully submitted,

                                                                    Squire Sanders (US) LLP


                                                                    /s/ Carlos M. Nalda
                                                                    ______________________________________
                                                                    Carlos M. Nalda

Attachment                                                          Counsel to Panasonic Avionics Corporation

cc:        Paul Blais, FCC International Bureau
           Stephen Duall, FCC International Bureau
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
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                                                  Application for Special Temporary Authority
                                                        FCC File No. SES-STA-20120913-00820
                                                                 Panasonic Avionics Corporation


                             SUPPLEMENTAL INFORMATION

       Further to its submission of November 15, 20121 and pursuant to Section 1.65 of the

Commission’s Rules, 47 C.F.R. § 1.65, Panasonic Avionics Corporation (“Panasonic”) hereby

clarifies certain information associated with the above-referenced request for special temporary

authority (“STA”). Specifically, Panasonic seeks to clarify that the scope of the STA request is

limited to U.S.-registered aircraft, as well as provide information regarding the downlink

frequencies and coverage areas of the satellite points of communication to be utilized for

eXConnect operations.

I.     SCOPE OF STA REQUEST

       Panasonic’s STA request, as supplemented via this and prior submissions, is prompted by

the strong public interest benefits associated with commencement of commercial operations

onboard its U.S. launch customer, United Airlines. Thus, Panasonic confirms that this STA

request seeks Commission authority to operate the next-generation Aura LE antenna only on

U.S.-registered aircraft operating within the United States and outside of U.S. airspace in the

regions served by the requested satellite points of communication.

II.    DOWNLINK (RECEIVE) FREQUENCIES

       Panasonic seeks to utilize the following satellite points of communication and downlink

frequencies to operate the “eXConnect” aeronautical mobile-satellite service (“AMSS”) system:




1
 See Letter from Carlos M. Nalda to Marlene H. Dortch dated November 15, 2012 (File No.
SES-STA-20120913-00820).


                                               -1-


                                                  Application for Special Temporary Authority
                                                        FCC File No. SES-STA-20120913-00820
                                                                 Panasonic Avionics Corporation



 Satellite          Orbital      Downlink              Coverage Areas/            STA Operations
                    Location     Frequencies           ITU Regions (R)            in the U.S.?
 GE-23              172° E       11.45-11.7 GHz        North Pacific (R2, R3)     Yes (AK, HI)

                                 10.95-11.2 GHz        Southwest Pacific (R3)     No
                                 11.45-11.7 GHz        (Oceania, SE Asia)

                                 12.2-12.75 GHz        South Pacific (R3)         No
                                                       (Australia/NZ)
 G-17               91° W        11.7-12.2 GHz         North America (R2)         Yes (CONUS)
 Estrela do Sul 2   63 ° W       11.45-12.2 GHz        N. Atlantic Ocean          No
 (T-14R)                                               (R1, 2)
                                                       (Canada and Atlantic)
 Telstar 11N        37.5° W      11.45-12.2 GHz        Atlantic Ocean (R1, 2)     No

                                 11.7-12.2 GHz         United States (R2)         Yes (CONUS)

       As the Commission is aware, AMSS receive operations in Ku-band FSS downlink

spectrum are on a non-conforming unprotected, non-interference basis only. In its original STA

application, Panasonic requested a waiver of the U.S. Table of Allocations, 47 C.F.R. §2.106,

with respect to the 11.7-12.2 GHz band. Given the additional satellites and downlink bands

currently associated with the STA request, Panasonic extends its waiver request to the additional

receive bands identified above. In this connection, Panasonic will only utilize receive spectrum

allocated for FSS downlinks, will not claim protection from conforming uses of the spectrum and

will cease operations upon notification that its receive operations are causing interference to any

conforming use of the band.

       III.    COVERAGE AREAS

       Three of the four satellites Panasonic will utilize for eXConnect AMSS operations are

U.S. licensed: GE-23, G-17, and T-11N. The fourth, EDS 2/T-14R, is on the Permitted Space

Station List. The relevant service areas for each of these satellites are included below:


                                                -2-


         Application for Special Temporary Authority
               FCC File No. SES-STA-20120913-00820
                        Panasonic Avionics Corporation


       GE-23
  (NORTH PACIFIC)




       GE-23
(SOUTHWEST PACIFIC)




        -3-


       Application for Special Temporary Authority
             FCC File No. SES-STA-20120913-00820
                      Panasonic Avionics Corporation

     GE-23
(SOUTH PACIFIC)




      G-17
(NORTH AMERICA)




      -4-


        Application for Special Temporary Authority
              FCC File No. SES-STA-20120913-00820
                       Panasonic Avionics Corporation

      T-11N
(ATLANTIC OCEAN)




(UNITED STATES)




      -5-


           Application for Special Temporary Authority
                 FCC File No. SES-STA-20120913-00820
                          Panasonic Avionics Corporation

      EDS 2/T-14R
(NORTH ATLANTIC OCEAN)




         -6-



Document Created: 2012-11-30 17:33:07
Document Modified: 2012-11-30 17:33:07

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