Attachment june 29 2006 email

june 29 2006 email

OTHER submitted by Hughes

june 29 2006 email

2006-06-29

This document pretains to SAT-AMD-20060306-00025 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2006030600025_515815

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Andrea Kelly

From:    Joslyn Read @ead@hns.com]
Sent:    Thursday, June 29, 2006 8 : l l PM
To :     Andrea Kelly; John Martin; Kal Krautkramer; Robert
cc:      Steve Doiron
Subject: Re: Additional Information for SPACEWAY-3

TO: Robert Nelson, Andrea Kelley, John Martin, Kal Krautkramer

FROM: Joslyn Read, Hughes Network Systems, LLC

DATE: 29 June 2006

RE: Call Sign S2663 - Amendmentof M i n g Modification for SPACEWAY-3 [SAT-AMD-20060306-0025)

This is in response to your request for information on the amendment of the minor modification filed by Hughes
Communications Inc. ("Hughes"). You have asked us to explain the technical constraints obligating the
SPACEWAY-3 spacecraft to use spacecraft TT&C command frequencies which are not exactly on the edge of the
allocated band, as is required in §25.202(g). This communication provides additional detail to that provided
earlier today with regard to SPACEWAY's TT&C command frequencies.

As mentioned in our earlier correspondence, the SPACEWAY-3 ("SW3") spacecraft has been designed to receive
TT&C command signals on two specific frequencies in the range from 29,500 to 29,516 MHz. The use of a main
and a backup frequency is typical on geostationary orbit (GSO) satellites in order to provide an alternate
command path in the event of either interference or equipment malfunction on the primary command path.

Since the original design of the SPACEWAY system was to consist of a fleet of three adjacent Ka-band GSO
satellites operating at 99"W.L., 101"W.L. and 103"W.L., it was necessary to make sure that the TT&C carriers
from the three satellites would not interfere with each other. For this reason, Hughes and Boeing decided to place
the first command carrier for SPACEWAY-1 ("SWI") on band edge, with the primary command carrier for
SPACEWAY-2 ("SW2") adjacent to that of SWI, and the primary command carrier for SW3 adjacent to that of
SW2. The next adjacent carrier (fourth in line) is the secondary command carrier for SW1. The secondary
command carrier for SW2 follows in fifth position, and finally, the secondary command carrier for SW3 completes
the TT&C command frequency segment. These six contiguous blocks span approximately 16 MHz from band-
edge to 29,516 MHz (see Figure 1 below).

It further needs to be indicated that the design of the SPACEWAY satellites is based on E l data streams (2048
kbps) which typically have a bandwidth of approximately 2.7 MHz. While each actual command carrier is
approximately 1.6 MHz in width, each command carrier is assigned an entire E l channel since it is the next
largest bandwidth step that the satellite demodulator can process. As a result, the entire SPACEWAY fleet of
three satellites utilizes a total of 6 command carriers on 6 contiguous E l bandwidth slots extending from the band
edge to 25,516 MHz.

Being the third satellite in the fleet, SW3 was assigned the command carriers for the third and sixth E l bandwidth
slots from the band-edge. The design and construction of SW3 was well under way when the ownership of the
SPACEWAY satellites was divided between The DirecTV Group and Hughes Communications Inc. (and its
predecessors). A significant re-design of the spacecraft would have been required in order to change the TT&C
command frequencies from the previously established frequency plan.

Hughes confirms that the SPACEWAY-3 TT&C command frequencies will be transmitted so as to have an ElRP
density less than the levels specified in $25.1 38 of the FCC's rules for normal, on-station operations.

In sum, in its amendment application, Hughes has requested a waiver of §25.202(g) to maintain the present



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SPACEWAY-3 frequency plan. This waiver request, if granted, is consistent with the FCC's Ka-band emission
limits in s25.138. Furthermore, grant of this waiver request will enable Hughes to begin bringing state-of-the-art
high-speed broadband services by satellite to the U S . market in mid-2007.

Please do not hesitate to contact us with any further questions.

Sincerely,

Joslyn Read, AVP Regulatory
Hughes Network Systems, LLC
+ I 301 601 7226 direct
+ I 301 4282802 fax




                                    El bendwidth slot
                                                                                                       29 S I 6 GHz
          29.500 GHz


                                                   CMD carrier bandwidth (1 -6MHr)                          T

                                    Figure 1 - Command Carrier Freqeuncy Plen
                                       for SPACWAY 1 , 2 snd 3




 6/30/2006



Document Created: 2006-07-25 16:28:27
Document Modified: 2006-07-25 16:28:27

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