1 65 Cover Letter (S

Section 1.65 Notification submitted by Panasonic Avionics Corporation

1.65 Letter and Certification Letter

2013-02-05

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

IBFS_SESSTA2012091300820_984744

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 February 5, 2013 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 provides confirmation from Eutelsat America Corp., the current licensee of the E172A satellite (formerly GE-23), that the proposed operations are consistent with the coordinated parameters of the satellite. 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 Andrea Kelly, 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 entities. Please visit squiresanders.com for more information.

).• 11 1111PW' euteisatam erica communicationsvia satellite February 4, 2013 Mark DeFazio Manager, GCS Regulatory and Business Operations Panasonic Avionics Corporation 26200 Enterprise Way Lake Forest, CA 92630 Re: Application of Panasonic Avionics Corporation Call Sign E100089, File No. SES- MFS-20120913-00818 Dear Mr. DeFazio: In connection with Panasonic Avionics Corporation's ("PAC's") above-captioned application ("Application") to the Federal Communications Commission;' you have requested that Eutelsat confirm it has reviewed the technical characteristics of PAC's Ku- band aeronautical mobile-satellite service ("AMSS") operations with the Eutelsat 172A satellite ("E172A," formerly GE-23). You would like Eutelsat to certify that such operations are consistent with Eutelsat's coordination agreements for the satellite and that, when operated in the prescribed manner, such operations do not result in unacceptable interference. As set forth in the Application, the basic characteristics of the PAC phased-array ("PPA") aircraft earth station ("AES") terminal (referred to in the Application as the "Aura LE" terminal) for operation with the E172A satellite at 172°E.L. include:2 Antenna Dimensions 34.7 inches (0.88 m) 6.6 inches height (0.17 m) Type of Antenna Dual panel waveguide fed phased array SSPA Rated Output Power 16 watts Bandwidth 10.70 GHz to 12.75 GHz 14.0 GHz to 14.5 GHz 1 Application of Panasonic Avionics Corporation To Modify AMSS License To Permit Operation of Up to 2000 Technically Identical Aeronautical Mobile-Satellite Service ("AMSS") Aircraft Earth Stations ("AES5") in the 14.0-14.5 GHz and 10.7-12.75 GHz Frequency Bands, Call Sign E100089, File No. SES-MFS-20120913-00818 ("Application"). 2 See id at 4. 1776 I Street, N.W. - Suite 810 Washington, DC 20006 +1.202.559.4330 (tel) + 1.646.349.1636 (fax) www.eutelsatamerica.com

eutelsatamerica communications via satellite Transmit Gain 38 dBi EIRP 48 dBW Transmit Polarization Horizontal or Vertical Receive GIT 10 to 14 dB/K Transmit Azimuth Beamwidth 1.5 degrees Transmit Elevation Beamwidth 4 degrees We understand that the terminal is designed to comply with the FCC's rules and policies governing Ku-band earth stations onboard aircraft ("ESAAs") adopted in new Section 25.227 of the rules.3 You have advised Eutelsat that the PPA AES avoids interference to other satellite operations by limiting off-axis EIRP spectral density to no more than the levels specified in the contract between Eutelsat and Panasonic, through various means, including: (i) limiting transmit power spectral density by controlling the transmit power of the terminal and using spread spectrum technology (selecting appropriate carrier bandwidths and spread factors); (ii) controlling the off-axis gain of the antenna along the GSO by inhibiting transmissions when the skew angle exceeds a specified threshold; and (iii) controlling pointing error to less than 0.2° (3-sigma) and inhibiting transmissions when the pointing offset exceeds a threshold of 0.35 degrees.4 When operating as described in the Application and with the off-axis EIRP density envelope as defined in the contract between Eutelsat and Panasonic, PAC's proposed operations are compliant with the off-axis EIRP density levels coordinated with neighboring satellites up to and including 6° separation in the geostationary orbit from the E172A satellite, and therefore will not cause unacceptable interference into these satellites. Eutelsat confirms that the maximum downlink satellite EIRP density of 13 dBW/4KHz, which you have stated is the operational level of the Ku-band AMSS network operated by PAC, is consistent with Eutelsat's existing coordination agreements with adjacent satellite operators. Based on the foregoing representations and affirmations by PAC, additional consultations between Eutelsat engineering staff and PAC, and more than a year of operation on the El 72A satellite, Eutelsat hereby confirms the following: 3 See Revisions to Parts 2 and 25 of the Commission's Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary- Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14.0-14.5 GHz Frequency Bands; Service Rules and Procedures to Govern the Use of Aeronautical Mobile Satellite Service Earth Stations in Frequency Bands Allocated to the Fixed Satellite Service, IB Docket Nos. 12-376 & 05-20, Notice of Proposed Rulemaking and Report and Order, FCC 12- 161 (rel. Dec. 28, 2012) ("ESAA Order"). 4 See Application at 5, 8-11 and Technical Appendix at 4-12. -2-

• eutelsatamenca communications via satellite 1. Eutelsat is familiar with the represented technical characteristics of the PPA AES terminal. 2. Eutelsat has incorporated the power density levels contractually agreed between Eutelsat and Panasonic, for both uplink and downlink, into its current operational planning and coordination agreements with adjacent satellite operators for the E172A satellite at 172° E.L. 3. Eutelsat further advises that it is not aware of any cases of unacceptable interference relating to PAC's operation of the PPA AES from other customers operating on the E172A satellite or from adjacent satellite operators. In sum, Eutelsat confirms that, if operated as described in the Application, as supplemented by PAC's representations and affirmations set forth above, operation of the PPA AES terminal will not cause unacceptable interference into other operations on E172A or adjacent satellites. Please let me know if you require any further support from Eutelsat relative to PAC's operation of the PPA AES terminal on the El 72A satellite. Sincerely, 7:-)1 ezA16(-?7 Ronald Samuel Chief Executive Officer -3-


Document Created: 2013-02-05 14:20:45
Document Modified: 2013-02-05 14:20:45
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