Attachment Narrative SAT-AMD-20110330-00065

Attachment Narrative

This document pretains to SAT-AMD-20110330-00065 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2011033000065_879667

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

)
)
In the Matter of )
)
ECHOSTAR CORPORATION ) File No. SAT-MOD-20101124-00244
) File No. SAT-AMD-2011____-_____
Amendment to Application for Modification ) Call Sign S2454
of Authority to Provide DBS Service at 86.5º )
W.L. Using the EchoStar 8 Satellite )
)

AMENDMENT

Pursuant to Section 25.116 of the Commission’s rules,1 EchoStar Corporation

(“EchoStar”)2 hereby amends its pending application for modification of its authority to provide

Direct Broadcast Satellite (“DBS”) service at the 86.5º W.L. orbital location using the EchoStar

8 satellite (“EchoStar 8 Application”).3 This amendment seeks to update the Technical Narrative

submitted in the original application to reflect the fact that command instructions will be

transmitted to the satellite over the 14003 MHz frequency while it is on-station and to request a

1
47 C.F.R. § 25.116.
2
On February 24, 2011, EchoStar Corporation filed an application requesting consent to
the pro forma assignment of its authorization to operate a Direct Broadcast Satellite service
satellite at 86.5 W.L. (Call Sign S2454) to EchoStar Satellite Operating Corporation. File No.
SAT-ASG-20110224-00033 (filed Feb. 24, 2011).
3
See File No. SAT-MOD-20101124-00244 (filed Nov. 24, 2011) (“EchoStar 8
Application”).

waiver of Section 25.202(g) of the Commission’s rules4 to allow EchoStar to provide such

command signals outside the edges of the allocated DBS bands.

I. AMENDMENT TO TECHNICAL REQUIREMENTS OF PART 25

As EchoStar has previously reported to the Commission, the EchoStar 8 satellite, which

is currently operating under Mexican authority at the 77.05 W.L. orbital location, experienced a

single event upset (“SEU”) in January 2011.5 Since that time, EchoStar has conducted testing to

determine whether and how the satellite was affected by the SEU.6 EchoStar has determined that

the SEU did not have a major effect on the health or the longevity of the satellite, and it has not

impaired the functionality of the payload. But the SEU did result in the partial disabling of the

satellite’s remaining 17 GHz receiver. While that receiver is capable of providing ranging

functions, it is not capable of receiving command instructions, which therefore have to be

conveyed over the 14003 MHz frequency.7

In the EchoStar 8 Application, EchoStar submitted a Technical Narrative describing the

satellite’s physical and operational characteristics, including EchoStar 8’s use of the 17799 MHz

frequency to provide both command and ranging functions. EchoStar hereby amends its pending

4
47 C.F.R. § 25.202(g).
5
See Letter from Petra A. Vorwig, Counsel for EchoStar Corporation, to Marlene H.
Dortch, Secretary, FCC, filed in File No. SAT-T/C-20090217-00026 (Feb. 1, 2011).
6
EchoStar is simultaneously filing an interim report of these test results under a request
for confidential treatment. See Letter from Petra A. Vorwig, Counsel for EchoStar Corporation,
to Marlene H. Dortch, Secretary, FCC, filed in File Nos. SAT-MOD-20101124-00244, SAT-
T/C-20090217-00026 (Mar. 30, 2011).
7
EchoStar is also adapting a flight software patch previously employed in other in-orbit
satellites to allow EchoStar to provide emergency command instructions over the 17 GHz feeder
link frequency in the event the 14 GHz receiver experiences a problem. EchoStar plans to
complete this adaptation prior to the proposed relocation of the satellite to 86.5 W.L.

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modification application to provide a revised Technical Narrative (Attachment A) reflecting the

fact that the satellite will use the 14003 MHz frequency for command signals and the 17799

MHz frequency only for ranging.8

As stated in the Commission’s rules with respect to applications for modification, “only

those items of information listed in § 25.114 that change need to be submitted, provided that the

applicant certifies that the remaining information has not changed.”9 The amended technical

information required pursuant to Part 25 of the Commission’s rules is set forth in the

accompanying Technical Narrative and FCC Form 312.10 EchoStar hereby certifies that, except

as described in this application, no information in its modification application has changed.11

II. PUBLIC INTEREST CONSIDERATIONS

EchoStar has previously described in its modification application, which is hereby

incorporated by reference, the public interest benefits that will result from a grant of authority to

8
See Attachment A, Technical Narrative, at 5.
9
47 C.F.R. § 25.117(d)(1).
10
The Schedule S submitted with the EchoStar 8 Application identified the 14003 MHz
frequency as one frequency over which EchoStar 8 is capable of operating; therefore, there are
no changes to the Schedule S.
11
The proposed change to the satellite’s command frequency does not implicate the
geographic service requirements of Section 25.148(c) of the Commission’s rules, 47 C.F.R.
§ 25.148(c), since service to Alaska and Hawaii is not technically feasible from the 86.5º W.L.
orbital location. 47 C.F.R. § 25.148(c); see also EchoStar Satellite L.L.C., Application to
Construct, Launch and Operate a Direct Broadcast Satellite at the 86.5º W.L. Orbital Location,
Order and Authorization, 21 FCC Rcd. 14045 ¶ 19 (2006) (“Given the very low elevation angles
to the 86.5º W.L. orbital location from Alaska and Hawaii, it is very unlikely that service to these
states from EchoStar-86.5W would be technically feasible. Therefore, we will not require
EchoStar-86.5W to provide service to Alaska and Hawaii from the 86.5º W.L. orbital location.”).

-3-

operate the EchoStar 8 satellite at 86.5° W.L.12 In short, U.S. consumers will have access to

additional DBS satellite capacity, thereby increasing the video programming options available to

them, years earlier than contemplated under EchoStar’s license. The proposed amendment to the

EchoStar 8 satellite’s command frequency is necessary to ensure that the satellite can be safely

maintained at the 86.5 W.L. orbital location, but it will not have any effect on the services that

EchoStar can provide over the satellite.

III. REQUEST TO WAIVE SECTION 25.202(g)

Section 25.202(g) of the Commission’s rules13 requires that telemetry, tracking and

control (“TT&C”) functions be conducted at the edges of a satellite’s allocated bands. EchoStar

requests a waiver of this rule in order to provide command signals to its DBS satellite, EchoStar

8, over the 14003 MHz frequency at the 86.5 W.L. orbital location.

Commission rules may be waived if there is good cause to do so.14 Good cause can be

shown by demonstrating that the waiver “would not undermine the policy objective of the rule or

order in question, special circumstances warrant a deviation from the general rule, and such a

deviation will serve the public interest.”15 In this case, there is good cause to waive the

requirements of Section 25.202(g) to allow the satellite to receive command signals over the

12
See EchoStar 8 Application, Narrative, at 7-8.
13
47 C.F.R. § 25.202(g).
14
See id. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969).
15
Telephone Number Portability; Sprint Local Telephone Companies Petition for
Waiver, Order, 19 FCC Rcd. 23962 ¶ 4 (2004); see also U.S. West Petition for Waiver of the
Tariff Review Plan Rules, Memorandum Opinion and Order, 12 FCC Rcd. 8343 ¶ 10 (1997);
WAIT Radio, 418 F.2d at 1159.

-4-

14003 MHz frequency. The recent SEU experienced by EchoStar 8 partially disabled the

satellite’s remaining 17 GHz receiver, necessitating this waiver request.

Allowing EchoStar to provide TT&C outside of the edges of its allocated bands would

not undermine the purpose of Section 25.202(g), which is to maximize efficient use of the radio

frequency spectrum and encourage competition.16 Specifically, EchoStar proposes to use a small

sliver of Fixed-Satellite Service (“FSS”) spectrum to provide command instructions to the

satellite. EchoStar has begun coordination discussions with SES World Skies with respect to its

AMC-3 satellite operating at 87.0 W.L. and will ensure EchoStar 8’s operations over the 14003

MHz frequency are coordinated prior to operation at 86.5 W.L.

The requested waiver also responds to special circumstances that are outside EchoStar’s

control. EchoStar could not foresee the effects of the SEU, but it has worked diligently to

mitigate those effects and ensure that the satellite can operate safely while it provides service

from 86.5 W.L to millions of U.S. subscribers. Both the continued safe operation of the satellite

and the service the satellite provides are in the public interest, further supporting grant of the

requested waiver.

IV. CONCLUSION

For the foregoing reasons, EchoStar amends its modification application to provide DBS

service from the 86.5º W.L. orbital location using the EchoStar 8 satellite and requests that the

Commission grant the requested modification and waiver as expeditiously as possible.

16
See Applications of Intelsat LLC; For Authority to Operate, and to Further Construct,
Launch, and Operate C-band and Ku-band Satellites that Form a Global Communications
System in Geostationary Orbit, Memorandum Opinion Order and Authorization, 15 FCC Rcd.
15460 ¶ 66 (2000).

-5-

Respectfully submitted,

EchoStar Corporation

________/s/___________
Pantelis Michalopoulos Alison Minea
Petra A. Vorwig Corporate Counsel
L. Lisa Sandoval EchoStar Corporation
Steptoe & Johnson LLP 1110 Vermont Avenue, NW, Suite 750
1330 Connecticut Avenue, NW Washington, D.C. 20005
Washington, D.C. 20036 (202) 293-0981
(202) 429-3000
Counsel for EchoStar Corporation

March 30, 2011

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ECHOSTAR-8 AT 86.5º W.L.

ATTACHMENT A
Technical Information to Supplement Schedule S

A.1 Scope

This attachment contains the information required by § 25.114(c) and other sections of the FCC
§ 25 rules that cannot be entered into the Schedule S software regarding the proposed operation
of the ECHOSTAR-8 satellite at 86.5º W.L.

A.2 General Description of Overall System Facilities, Operations and Services
(§ 25.114(d)(1))

The ECHOSTAR-8 satellite will operate at the 86.5° W.L. orbital location and will provide BSS
services to CONUS and Mexico. The satellite was designed to provide 32 channels in medium
power mode or 16 channels in high power mode.

The satellite will be biased such that the beams are steered towards the south in order to protect
the operations of Telesat Canada at the nominal 82° W.L. and 91° W.L. locations. The CONUS
beam will be operated in normal-mode only with a peak downlink EIRP of 54.6 dBW. The
Mexican beam can be operated either in normal-mode or high-powered-mode, the latter with a
peak downlink EIRP of 57.3 dBW.

EchoStar will use its two main feeder link earth station facilities with the ECHOSTAR-8
satellite. These are located in Cheyenne, WY and Gilbert, AZ. Spacecraft TT&C functions will
take place from EchoStar’s primary TT&C earth station and satellite control facility located in
Cheyenne, WY and the back-up facility located in Gilbert, AZ.

1

A.3 Predicted Space Station Antenna Gain Contours
(§ 25.114(d)(3))

The ECHOSTAR-8 antenna gain contours for the receive and transmit beams, as required by
§ 25.114(d)(3), are given in GXT format and embedded in the associated Schedule S submission.
These contours reflect the planned biasing of the satellite and adjustment of the reflectors.

A.4 Services to be Provided
(§ 25.114(d)(4))

The ECHOSTAR-8 satellite will provide a range of DBS services to millions of small and
inexpensive subscriber receive-only earth terminals. The proposed operation does not implicate
the geographic service requirements of Section 25.148(c) of the Commission’s rules, 47 C.F.R.
§ 25.148(c), since service to Alaska and Hawaii is not technically feasible from the 86.5º W.L.
orbital location. See 47 C.F.R. § 25.148(c); see also 86.5º W.L. Order ¶ 19 (“Given the very low
elevation angles to the 86.5º W.L. orbital location from Alaska and Hawaii, it is very unlikely
that service to these states from EchoStar-86.5W would be technically feasible. Therefore, we
will not require EchoStar-86.5W to provide service to Alaska and Hawaii from the 86.5º W.L.
orbital location.”).

Representative link budgets, which include details of the transmission characteristics,
performance objectives and earth station characteristics, are provided in the associated Schedule
S submission.

A.5 Satellite Transponder Frequency Responses
(§ 25.114(c)(4)(vii))

The typical receiver and transmitter frequency responses of each RF channel, as measured
between the receive antenna input and transmit antenna, fall within the limits shown in Table
A.5-1 below.

2

In addition, the frequency tolerances of § 25.202(e) and the out-of-band emission limits of
§ 25.202(f) (1), (2) and (3) will be met.

Table A.5-1: Typical Receiver and Transmitter Filter Responses

Offset from Channel Center Receiver Filter Response (dB) Transmitter Filter Response (dB)
Frequency (MHz)

±5 > -0.5 > -0.4

±7 > -0.7 > -0.5

±9 > -1.0 > -0.8

± 11 > -1.5 > -1.7

±12 > -2.0 > -3.6

±17.5 < -18 < -8

±20.2 < -38 < -18

±27.2 < -50 < -35

3

A.6 TT&C Characteristics
(§ 25.114(c)(4)(i) and § 25.114(c)(9))

A summary of the TT&C subsystem performance is given in Table A.6-1.

Table A.6-1: Summary of the on-station TT&C Subsystem Performance

Parameter Performance

On-Station Command Frequency 14003 MHz

On-Station Ranging Frequency 17799 MHz

Uplink Flux Density Between -72.6 and -82.6 dBW/m2

Uplink Polarization RHCP

12,206 MHz
On-Station Telemetry Frequencies
12,207 MHz

Maximum Downlink EIRP 21.1 dBW

Downlink Polarization LHCP

A.7 Interference Analyses
(§ 25.114(d)(13))

The ECHOSTAR-8 satellite network will operate on an unprotected, non-harmful interference
basis, until fully coordinated. Pending coordination, in the event operations of the ECHOSTAR-
8 satellite network cause harmful interference into another network, EchoStar will either cease
operations, or reduce transmission levels appropriately, immediately upon notification of such
interference.

4

The analyses of the proposed ECHOSTAR-8 satellite network with respect to the limits in
Annex 1 to Appendices 30 and 30A are provided in Appendices 1 and 2 to this document. The
results of these analyses are discussed below.

Appendix 1 shows that the proposed ECHOSTAR-8 satellite network meets the ITU criteria in
Annex 1 to Appendix 30, except for § 4.2.3 c) of Article 4 of Appendix 30/30A. There are a
number of adjacent Region 2 BSS networks that were deemed to be affected (see Annex 1 to
Appendix 1). The affected foreign administrations are Bahamas, Bolivia, Canada, Cuba,
Dominican Republic, Haiti, Holland, Jamaica, Mexico, Peru and the UK. Each of the affected
networks is discussed below:

 The affected networks of the Bahamas, Bolivia, Cuba, Dominican Republic, Haiti,
Jamaica and Peru are all original Plan networks. None of these networks are currently
operational, nor can we find any evidence that any of these networks are under
construction or scheduled for launch.

 The Canadian networks at the nominal 82° W.L. and 91° W.L. locations are deemed to be
affected. The Canadian networks are assigned to Telesat Canada. EchoStar and Telesat
Canada have executed a coordination agreement for EchoStar operations at 86.5° W.L.
Telesat Canada has informed EchoStar as to the maximum downlink EIRP levels that
EchoStar’s operations can cause over Canadian territory. The beams of the
ECHOSTAR-8 satellite will be biased towards the south specifically to protect the
Canadian networks to these protection levels.

 Mexico’s networks at the nominal 77° W.L. location are deemed to be affected. The
Mexican networks are assigned to QuetzSat. EchoStar will coordinate the operations of
the ECHOSTAR-8 satellite network with QuetzSat. Coordination should be
straightforward given the 9.5 degree orbital separation.

5

 Holland’s network at 58° W.L. is deemed to be affected. We can find no evidence that
this network is under construction or scheduled for launch. In the event the network were
to progress, it is expected that coordination could be achieved given the large orbital
separation and the small OEPM degradation caused to the network.

 The UK has five networks at 86.5° W.L. We can find no evidence that any of the
networks are under construction or scheduled for launch.

In addition, the USA’s USABSS-15 network at 110° W.L. was deemed to be affected. This
network receives a small OEPM degradation, and it is assigned to EchoStar’s affiliate, DISH
Network L.L.C.

Based on the preceding, EchoStar concludes that operation of the ECHOSTAR-8 satellite will
not cause harmful interference, or even unacceptable interference, into any adjacent operational
satellite network.

Appendix 2 shows that the proposed ECHOSTAR-8 satellite network meets all of the ITU
criteria in Annex 1 to Appendix 30A.

A.8 Orbital Debris Mitigation Plan
(§ 25.114(d)(14))

A.8.1 Spacecraft Hardware Design

The ECHOSTAR-8 satellite was designed and manufactured by Space Systems/Loral and was
launched in 2002. The satellite is not expected to undergo any planned release of debris during
its operation. EchoStar and the satellite manufacturer have assessed and limited the probability
of the satellite becoming a source of debris by collisions with small debris or meteoroids of less
than one centimeter in diameter that could cause loss of control and prevent post-mission

6

disposal. Such probability has been limited through component placement and the use of
redundant systems.

The ECHOSTAR-8 satellite has separate TT&C and propulsion subsystems that are necessary
for end-of-life disposal. The spacecraft TT&C system, vital for orbit raising, is extremely
rugged with regard to meteoroids smaller than 1 cm, by virtue of its redundancy, shielding,
separation of components and physical characteristics. An omni-directional antenna and wide
angle horn system are used principally during orbit raising. The command receivers, decoders,
telemetry encoders and transmitters are located within a shielded area, and are redundant and
physically separated. A single rugged thruster and shielded propellant tank provides the energy
for orbit raising. Otherwise, there are no single points of failure in the system.

A.8.2 Accidental Explosion Assessment
(§ 25.144(d)(14)(ii))

EchoStar has assessed and limited the probability of accidental explosions during and after
completion of mission operations. A Failure Mode Verification Analysis has also been
conducted, and the probability of accidental explosions has been limited through extensive
monitoring of ECHOSTAR-8 satellite’s batteries and fuel tanks for pressure and temperature.
Furthermore, bipropellant mixing is prevented by the use of valves that prevent backwards flow
in propellant lines and pressurization lines. Excessive battery charging or discharging is limited
by a monitoring and control system, which will automatically limit the possibility of
fragmentation. Corrective action, if not automatically undertaken, will be immediately
undertaken by the spacecraft operator to avoid destruction and fragmentation. Thruster
temperatures, impulse and thrust duration are carefully monitored, and any thruster may be
turned off via redundant valves. At the end of the satellite’s life, all energy sources will be
depleted. Specifically, the batteries will be left in a permanent state of discharge, chemical
propulsion systems will be depleted, and the electrical propulsion system will be disabled.

7

A.8.3 Safe Flight Profiles
(§ 25.144(d)(14)(iii))

In considering current and planned satellites that may have a station-keeping volume that
overlaps with the ECHOSTAR-8 satellite, EchoStar has reviewed the lists of FCC licensed
satellite networks, as well as those that are currently under consideration by the FCC. In
addition, networks for which a request for coordination has been submitted to the ITU within
±0.15 degrees of 86.5° W.L. have been reviewed.

There are no operational satellites in the immediate vicinity of 86.5° W.L.

With respect to ITU networks, Canada has two 17/24 GHz networks at 86.5° W.L. and the UK
has five BSS networks at 86.5° W.L. EchoStar can find no evidence that any of these networks
are under construction or scheduled for launch.

Based on the preceding, EchoStar concludes there is no requirement to physically coordinate the
ECHOSTAR-8 satellite with another satellite operator at the present time.

A.8.4 Post Mission Disposal Plan
(§ 25.144(d)(14)(iv))

At the end of the operational life of the ECHOSTAR-8 satellite, EchoStar will maneuver the
satellite to a disposal orbit with a minimum perigee of 360 km above the normal GSO
operational orbit. This proposed disposal orbit altitude exceeds the minimum required by
§ 25.283, which is calculated below.

The input data required for the calculation is as follows:

Total Solar Pressure Area “A” = 112 m2
“M” = Dry Mass of Satellite = 1807 kg
“CR” = Solar Pressure Radiation Coefficient (worst case) = 2

8

Using the formula given in § 25.283, the Minimum Disposal Orbit Perigee Altitude is calculated
as follows:

= 36,021 km + 1000 x CR x A/m
= 36,021 km + 1000 x 2 x 112/1807
= 36,145 km
= 359 km above GSO (35,786 km)

Thus, the designed disposal orbit of 360 km above GSO exceeds the required minimum by a
margin of 1 km. Maneuvering the satellite to the disposal orbit will require 6 kg of propellant,
and this quantity of fuel, taking account of all fuel measurement uncertainties, will be reserved to
perform the final orbit raising maneuvers. The fuel reserve was calculated using two methods.
The first method applied was the pressure-volume temperature method, which uses tank pressure
and temperature information to determine remaining propellant. The second method applied was
the bookkeeping method, which evaluates the flow rate at average pressure and total thruster on-
time of orbital maneuvers to determine the amount of propellant used. EchoStar has assessed
fuel gauging uncertainty and has provided an adequate margin of fuel to address such
uncertainty.

___________________________________

9

CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING
ENGINEERING INFORMATION

I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in this application, that I am familiar with Part 25 of the

Commission’s rules, that I have either prepared or reviewed the engineering information

submitted in this application and that it is complete and accurate to the best of my knowledge

and belief.

/s/
¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯
Stephen D. McNeil
Telecomm Strategies Canada, Inc.
Ottawa, Ontario, Canada
(613) 270-1177

10

APPENDIX 1 TO
ATTACHMENT A (TECHNICAL INFORMATION TO SUPPLEMENT
SCHEDULE S)

Analysis of ANNEX 1 of Appendix 30

1 Limits for the interference into frequency assignments in conformity with the
Regions 1 and 3 Plan or with the Regions 1 and 3 List or into new or modified
assignments in the Regions 1 and 3 List

Does not apply to the Region 2 Plan.

2 Limits to the change in the overall equivalent protection margin for frequency
assignments in conformity with the Region 2 plan

With respect to § 4.2.3 c) of Article 4, an administration in Region 2 is considered as being
affected if the overall equivalent protection margin28 corresponding to a test point of its entry in
the Region 2 Plan, including the cumulative effect of any previous modification to that Plan or
any previous agreement, falls more than 0.25 dB below 0 dB, or, if already negative, more
than 0.25 dB below the value resulting from:
– the Region 2 Plan as established by the 1983 Conference; or
– a modification of the assignment in accordance with this Appendix; or
– a new entry in the Region 2 Plan under Article 4; or
– any agreement reached in accordance with this Appendix. (WRC-03)

The MSPACE analysis was performed utilizing the Region 2 BSS Plan as contained in IFIC
2681. The CONUS beam was assumed to operate with a peak downlink EIRP of 54.6 dBW,
while the Mexican beam was assumed to transmit with a peak downlink EIRP of 57.3 dBW. The
results of the analysis are contained in Annex 1 to this Appendix. As shown, the affected foreign
administrations are Bahamas, Bolivia, Canada, Cuba, Dominican Republic, Haiti, Holland,
Jamaica, Mexico, Peru and the UK. The results are discussed below for each of these
administrations:

28
For the definition of the overall equivalent protection margin, see § 1.11 of Annex 5.

Page A1-1 of A1-6

 The affected networks of the Bahamas, Bolivia, Cuba, Dominican Republic, Haiti,
Jamaica and Peru are all original Plan networks. None of these networks is currently
operational. Until coordination, the ECHOSTAR-8 satellite network will operate on an
unprotected, non-harmful interference basis, and in the event operations of the
ECHOSTAR-8 satellite network cause harmful interference into these and any other
network, EchoStar will either cease operations, or reduce transmission levels
appropriately, immediately upon notification of such interference.
 The Canadian networks at the nominal 82° W.L. and 91° W.L. locations are deemed to be
affected. The Canadian networks are assigned to Telesat Canada. EchoStar and Telesat
Canada have executed a coordination agreement. The beams of the ECHOSTAR-8
satellite will be biased towards the south specifically to protect the Canadian networks to
the protection levels required by Telesat Canada.
 Mexico’s networks at the nominal 77° W.L. location are deemed to be affected. The
Mexican networks are assigned to QuetzSat. EchoStar will coordinate the operations of
the ECHOSTAR-8 satellite network with QuetzSat. Coordination should be
straightforward given the 9.5 degree orbital separation.
 Holland’s network at 58° W.L. is deemed to be affected. We can find no evidence that
this network is under construction or scheduled for launch.
 The UK has five networks at 86.5° W.L. We can find no evidence that any of the
networks are under construction or scheduled for launch.

3 Limits to the change in the power flux-density to protect the broadcasting-
satellite service in Regions 1 and 2 in the band 12.2-12.5 GHz and in Region 3 in
the band 12.5-12.7 GHz

With respect to § 4.2.3 a), 4.2.3 b) or 4.2.3 f) of Article 4, as appropriate, an administration in
Region 1 or 3 is considered as being affected if the proposed modification to the Region 2 Plan
would result in exceeding the following power flux-density values, at any test point in the service
area of its overlapping frequency assignments:

–147 dB(W/(m2 · 27 MHz)) for 0    0.23
–135.7  17.74 log  dB(W/(m · 27 MHz))
2
for 0.23    2.0
–136.7  1.66  2 2
dB(W/(m · 27 MHz)) for 2.0    3.59
–129.2  25 log  dB(W/(m2 · 27 MHz)) for 3.59   10.57
–103.6 dB(W/(m2 · 27 MHz)) for 10.57  

where  is the minimum geocentric orbital separation in degrees between the wanted and
interfering space stations, taking into account the respective East-West station-keeping
accuracies. (WRC-03)

Page A1-2 of A1-6

The closest Regions 1 or 3 BSS network is the Russian INTERSPUTNIK-47.5W-B network at
47.5°W, which is greater than 10.57 degrees from the 86.5° W.L. location, therefore the -103.6
dB(W/(m2 . 27 MHz)) PFD level applies for this network and all other Regions 1 and 3
networks. The GIMs Appendix 30 pfd tool was used to assess compliance with this Section.
Using the antenna gain contours and power levels of the beams the GIMS pfd tool showed that
no administrations are affected. Therefore, the ECHOSTAR-8 satellite network is compliant
with this Section.

4 Limits to the power flux-density to protect the terrestrial services of other
administrations29, 30, 31

With respect to § 4.2.3 d) of Article 4, an administration in Region 1, 2 or 3 is considered as
being affected if the consequence of the proposed modification to an existing assignment in the
Region 2 Plan is to increase the power flux-density arriving on any part of the territory of that
administration by more than 0.25 dB over that resulting from that frequency assignment in the
Region 2 Plan at the time of entry into force of the Final Acts of the 1985 Conference. The same
administration is considered as not being affected if the value of the power flux-density
anywhere in its territory does not exceed the limits expressed below.

With respect to § 4.1.1 d) or § 4.2.3 d) of Article 4, an administration in Region 1, 2 or 3 is
considered as being affected if the proposed new assignment in the Regions 1 and 3 List, or if the
proposed new frequency assignment in the Region 2 Plan, would result in exceeding a power
flux-density, for any angle of arrival, at any point on its territory, of:

–148 dB(W/(m2  4 kHz)) for   5°

–148 + 0.5 ( – 5) dB(W(m2  4 kHz) for 5° <   25°

–138 dB(W/(m2  4 kHz)) for 25° <   90°

where represents the angle of arrival. (WRC-03)

The GIMS pfd tool was used to determine the administrations whose terrestrial services may be
affected by the ECHOSTAR-8 satellite network. The GIMS pfd tool showed that no
Administrations are affected and therefore the ECHOSTAR-8 satellite is compliant with this
Section.

29
See § 3.18 of Annex 5.
30
In the band 12.5-12.7 GHz in Region 1, these limits are applicable only to the territory of administrations
mentioned in Nos. 5.494 and 5.496.
31
See Resolution 34.

Page A1-3 of A1-6

5 (Not used.)

6 Limits to the change in the power flux-density of assignments in the Regions 1
and 3 Plan or List to protect the fixed-satellite service (space-to-earth) in the
band 11.7-12.2 GHz32 in Region 2 or in the band 12.2-12.5 GHz in Region 3, and
of assignments in the Region 2 plan to protect the fixed-satellite service (space-
to-earth) in the band 12.5-12.7 GHz in Region 1 and in the band 12.2-12.7 GHz
in Region 3

With respect to § 4.2.3 e), an administration is considered as being affected if the proposed
modification to the Region 2 Plan would result in an increase in the power flux-density over any
portion of the service area of its overlapping frequency assignments in the fixed-satellite service
in Region 1 or 3 of 0.25 dB or more above that resulting from the frequency assignments in the
Region 2 Plan at the time of entry into force of the Final Acts of the 1985 Conference.

With respect to § 4.1.1 e) or 4.2.3 e) of Article 4, an administration is considered as not being
affected if the proposed new or modified assignment in the Regions 1 and 3 List, or if a proposed
modification to the Region 2 Plan, gives a power flux-density anywhere over any portion of the
service area of its overlapping frequency assignments in the fixed-satellite service in Region 1, 2
or 3 of less than:

–186.5 dB(W/(m2 · 40 kHz)) for 0    0.054°

–164.0  17.74 log  dB(W/(m2 · 40 kHz)) for 0.054°    2.0°

–165.0  1.66 2 dB(W/(m2 · 40 kHz)) for 2.0°    3.59°

–157.5  25 log  dB(W/(m2 · 40 kHz)) for 3.59°   10.57°

–131.9 dB(W/(m2 · 40 kHz)) for 10.57°  

where θ is the minimum geocentric orbital separation in degrees between the wanted and
interfering space stations, taking into account the respective East-West station-keeping
accuracies.

The GIMS pfd tool was used to verify compliance with this Section. All Regions 1 and 3 FSS
satellites are greater than 10.57° from the 86.5°W.L. location, therefore the -131.9 dB (W/(m2 .
40 kHz)) level applies. The results of the GIMS analysis shows that no administrations are
affected. Therefore the ECHOSTAR-8 satellite network is compliant with this Section.

32
Including assignments operating under No. 5.485.

Page A1-4 of A1-6

7 Limits to the change in equivalent noise temperature to protect the fixed-satellite
service (earth-to-space) in Region 1 from modifications to the Region 2 plan in the
band 12.5-12.7 GHz

With respect to § 4.2.3 e) of Article 4, an administration of Region 1 is considered as being
affected if the proposed modification to the Region 2 Plan would result in:
– the value of T / T resulting from the proposed modification is greater than the value of
T / T resulting from the assignment in the Region 2 Plan as of the date of entry into force of
the Final Acts of the 1985 Conference; and
– the value of T / T resulting from the proposed modification exceeds 6%,
using the method of Appendix 8 (Case II). (WRC-03)

From a review of the available ITU space network databases there are no assignments registered
in the Earth-to-space direction in the frequency band 12.5-12.7 GHz. Therefore, no Region 1
space stations can be affected, and the ECHOSTAR-8 satellite network is compliant with this
Section.

Page A1-5 of A1-6

Annex 1 to Appendix 1 to Technical Annex

ECHOSTAR-8

MSPACE Results

Orbital Max. OEPM
Admin Position Network Degradation
(degrees E) (dB)

BAH -87.20 BAHIFRB1 19.269
BOL -87.20 BOL00001 1.282
JMC -92.30 CRBBAH01 0.612
JMC -92.30 CRBBLZ01 3.691
JMC -92.30 CRBJMC01 0.927
JMC -92.70 JMC00002 0.829
CUB -89.20 CUB00001 5.504
DOM -83.30 DOMIFRB2 0.262
HTI -83.30 HTI00002 2.158
PRU -85.80 PRU00004 1.617
CAN -82.00 CAN-BSS1 1.255
CAN -91.10 CAN-BSS2 1.752
MEX -77.00 MEX-TDH1 1.366
MEX -76.80 MEX-TVD1 0.937
MEX -77.20 MEX-TVD2 0.591
MEX -77.00 QUETZSAT-77 1.997
USA -110.00 USABSS-15 0.306
G -86.50 USAT-S3 31.369
G -86.50 USAT-S3 MOD-A 29.846
G -86.50 USAT-S3 MOD-B 30.086
G -86.50 USAT-S3 MOD-C 30.215
G -86.50 USAT-S3 MOD-D 29.846
HOL -58.00 NSS-BSS 58W 0.361

Page A1-6 of A1-6

APPENDIX 2 TO
ATTACHMENT A (TECHNICAL INFORMATION TO SUPPLEMENT
SCHEDULE S)

Analysis of ANNEX 1 of Appendix 30A

1 (SUP - WRC-2000)

2 (SUP - WRC-2000)

3 Limits to the change in the overall equivalent protection margin with respect to
frequency assignments in conformity with the Region 2 feeder-link
plan33 (WRC-2000)

With respect to the modification to the Region 2 feeder-link Plan and when it is necessary under
this Appendix to seek the agreement of any other administration of Region 2, except in cases
covered by Resolution 42 (Rev.WRC-03), an administration is considered as being affected if the
overall equivalent protection margin34 corresponding to a test point of its entry in that Plan,
including the cumulative effect of any previous modification to that Plan or any previous
agreement, falls more than 0.25 dB below 0 dB, or, if already negative, more than 0.25 dB below
the value resulting from:
– the feeder-link Plan as established by the 1983 Conference; or
– a modification of the assignment in accordance with this Appendix; or
– a new entry in the feeder-link Plan under Article 4; or
– any agreement reached in accordance with this Appendix except for Resolution 42
(Rev.WRC-03). (WRC-03)

See the results described under Section 2 of Appendix 30 Annex 1 Analysis.

33
With respect to § 3 the limit specified relates to the overall equivalent protection margin calculated in
accordance with § 1.12 of Annex 3.
34
For the definition of the overall equivalent protection margin, see § 1.11 of Annex 5 to Appendix 30.

Page A2-1 of A2-3

4 Limits to the interference into frequency assignments in conformity with the
Regions 1 and 3 feeder-link Plan or with the Regions 1 and 3 feeder-link List or
proposed new or modified assignments in the Regions 1 and 3 feeder-link
list (WRC-03)

Does not apply to the Region 2 Plan.

5 Limits applicable to protect a frequency assignment in the bands 17.3-18.1 GHz
(Regions 1 and 3) and 17.3-17.8 GHz (Region 2) to a receiving space station in
the fixed-satellite service (earth-to-space)

An administration in Region 1 or 3 is considered as being affected by a proposed modification in
Region 2, with respect to § 4.2.2 a) or 4.2.2 b) of Article 4, or an administration in Region 2 is
considered as being affected by a proposed new or modified assignment in the Regions 1 and 3
feeder-link List, with respect to § 4.1.1 c) of Article 4, when the power flux-density arriving at
the receiving space station of a broadcasting-satellite feeder-link would cause an increase in the
noise temperature of the feeder-link space station which exceeds the threshold value of  T / T
corresponding to 6%, where  T / T is calculated in accordance with the method given in
Appendix 8, except that the maximum power densities per hertz averaged over the worst 1 MHz
are replaced by power densities per hertz averaged over the necessary bandwidth of the feeder-
link carriers. (WRC-03)

The following table shows the results of  T / T calculations for the closest Regions 1 and 3
feeder link space stations, based on the Region 1 and 3 Plan and List. As shown, the  T / T’s
are well below the allowed 6% level. Therefore, the ECHOSTAR-8 satellite network is in
conformity with this Section.

Page A2-2 of A2-3

Closest Region 1 or 3 Feeder Link Space E/S E/S Range E/S Victim Calculated
Station Lat Long (km) Gain Satellite Rx T/T
(°N) (°E) towards System Noise (%)
Network Name Orbital Peak Victim Temp
Position Receive Satellite (K)
Antenna (dBi)
Gain
(dBi)

INTERSPUTNIK-
-47.5 37 33.3 -111.8 40296 -10 600 0.01%
47.5W-B

MCO-BSS-40.5W -40.5 35.9 33.3 -111.8 40921 -10 600 0.01%

IRL21100 -37.2 48.08 33.3 -111.8 41222 -10 600 0.15%

NGR11500 -37.2 38.47 33.3 -111.8 41222 -10 600 0.02%

DBL-G4-37.2W -37.2 35 33.3 -111.8 41222 -10 300 0.01%

AND34100 -37 48.88 33.3 -111.8 41241 -10 600 0.18%

GMB30200 -37 47.69 33.3 -111.8 41241 -10 600 0.14%

GUI19200 -37 42.29 33.3 -111.8 41241 -10 600 0.04%

POR__100 -37 47.17 33.3 -111.8 41241 -10 600 0.12%

MTN__100 -36.8 37.55 33.3 -111.8 41259 -10 600 0.01%

SMR31100 -36.8 48.88 33.3 -111.8 41259 -10 600 0.18%

6 Limits applicable to protect a frequency assignment in the band 17.8-18.1 GHz
(Region 2) to a receiving feeder-link space station in the fixed-satellite service
(earth-to-space) (WRC-03)

Does not apply to Region 2 Plan.

Page A2-3 of A2-3

Document Created: 2011-03-30 18:04:19
Document Modified: 2011-03-30 18:04:19

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