Attachment Narrative

This document pretains to SAT-AMD-20110427-00080 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2011042700080_886614

                                     Before the
                        FEDERAL COMMUNICATIONS COMMISSION
                                Washington, D.C. 20554


                                                 )
                                                 )
In the Matter of                                 )   File No. SAT-LOA-20070105-00003
                                                 )   File No. SAT-AMD-20080114-00022
ECHOSTAR CORPORATION                             )   File No. SAT-AMD-20080213-00045
                                                 )   File No. SAT-MOD-20110330-00064
Amendment to Application for Modification        )   File No. SAT-AMD-2011____-_____
of Authority to Construct, Launch, and           )   Call Sign S2725
Operate a Satellite at 75º W.L. in the 17/24     )
BSS GHz Band                                     )


                                          AMENDMENT

       Pursuant to Sections 308 and 309 of the Communications Act of 1934, as amended,1 and

Section 25.116 of the Commission’s rules,2 EchoStar Corporation (“EchoStar”)3 hereby amends

its pending application to modify its authority to construct, launch, and operate a 17/24 GHz

Broadcast-Satellite Service (“BSS”) satellite at the 75º W.L. orbital location. This amendment

requests authority to locate the satellite at a slight offset of 0.15 degrees from the 75° W.L.

orbital location at 75.15° W.L. to avoid station keeping overlap with the Brasilsat B3 satellite,

consistent with Commission rules. This amendment also updates the Technical Narrative and




       1
           47 U.S.C. §§ 308, 309.
       2
           47 C.F.R. § 25.116.
       3
          On April 21, 2011, the Commission consented to the pro forma assignment of EchoStar
Corporation’s authorization to launch and operate the above-referenced space station to EchoStar
Satellite Operating Corporation. File No. SAT-ASG-20110224-00034 (granted Apr. 21, 2011).
The pro forma assignment has not yet been consummated.


Schedule S submitted in the original application4 to reflect satellite design changes described in

the recently completed Critical Design Review (“CDR”).5

I.     AMENDMENT TO TECHNICAL REQUIREMENTS OF PART 25

       A.       Revised Orbital Location

       On March 18, 2009, the Commission authorized EchoStar to construct, launch and

operate a 17/24 GHz BSS satellite at 75° W.L.6 EchoStar requests authority to operate the

satellite at 75.15° W.L. -- an offset of 0.15 degrees from its authorized orbital location -- in order

to ensure the satellite’s station keeping volume does not overlap with that of the Brasilsat B3

satellite operated by Star One at the nominal 75° W.L. orbital location. EchoStar requests

authority to operate at this offset location on a full-power, full interference protection basis

pursuant to Section 25.262(b) of the Commission’s rules.7 As discussed in the attached

Technical Narrative, other than EchoStar, no other operator has received Commission

authorization to operate a 17/24 GHz BSS satellite within four degrees of 75.15° W.L. EchoStar

currently has Commission authority to operate a 17/24 GHz BSS satellite at 79° W.L.8 EchoStar

       4
         See File Nos. SAT-LOA-20070105-00003 (filed Jan. 5, 2007), SAT-AMD-20080114-
00022 (filed Jan. 14, 2008), SAT-AMD-20080213-00045 (filed Feb. 13, 2008) (“75° W.L.
Application”).
       5
          See Confidential Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation
to Marlene H. Dortch, Secretary, FCC, filed in File Nos. SAT-LOA-20070105-00003, SAT-
AMD-20080114-00022, SAT-AMD-20080213-00045 (Mar. 17, 2011), revised by Confidential
Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation to Marlene H. Dortch,
Secretary, FCC, filed in File Nos. File Nos. SAT-LOA-20070105-00003, SAT-AMD-20080114-
00022, SAT-AMD-20080213-00045 (Apr. 13, 2011).
       6
      Stamp Grant, File Nos. SAT-LOA-20070105-00003, SAT-AMD-20080114-00022,
SAT-AMD-20080213-00045 (granted Mar. 18, 2009).
       7
           47 C.F.R. § 25.262(b).
       8
      Stamp Grant, File Nos. SAT-LOA-20020328-00050, SAT-AMD-20050118-00247,
SAT-AMD-20080114-00018, SAT-AMD-20080213-00044 (granted Apr. 20, 2009).



                                                 -2-


will shortly seek Commission authorization to operate that satellite at 79.15° W.L. for a similar

reason in order to avoid the station-keeping volume of the AMC-5 satellite that operates

nominally at 79.05° W.L. If the requested revision is granted, EchoStar will operate both of its

satellites with four degree spacing, ensuring no harmful interference into either.

       B.       Revised Technical Information

       This amendment also reflects revised physical and operational characteristics for

EchoStar’s 17/24 GHz BSS satellite, including its beam configuration; telemetry, tracking and

control (“TT&C”) frequencies; and power flux density (“PFD”) levels. Since EchoStar filed its

original application, improvements in satellite design have allowed the satellite manufacturer to

revise the satellite’s beam configuration to provide additional flexibility between CONUS and

spot beam coverage. Specifically, the current design includes three large area coverage beams

and an array of 30 small spot beams, which can be steered as a single group. The satellite design

has also been revised to allow for TT&C operations at the edge of the satellite’s authorized

bands, bringing it into conformance with Section 25.202(g) of the Commission’s rules.9 These

changes, in turn, have necessitated certain minor revisions to the original PFD analysis.

Additionally, EchoStar is providing a revised orbital debris mitigation plan, which was

developed based on the concrete satellite design presented during the CDR.

           As stated in the Commission’s rules with respect to an application for modification,

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




       9
         47 C.F.R. §25.202(g). EchoStar notes that because the TT&C frequencies have been
revised to conform to Section 25.202(g), the waiver granted in the original authorization is no
longer required. See Stamp Grant, File Nos. SAT-LOA-20070105-00003, SAT-AMD-
20080114-00022, SAT-AMD-20080213-00045, at ¶4 (granted Mar. 18, 2009)



                                                -3-


that the applicant certifies that the remaining information has not changed.”10 The amended

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

accompanying Technical Narrative, Schedule S, and FCC Form 312. 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 application, which is hereby incorporated by

reference, the public interest benefits from the construction, launch and operation of a 17/24 GHz

BSS satellite at 75° W.L.12 This amendment to its modification application is in the public

interest for the same reasons. The slight change in orbital location will allow EchoStar to insure

adequate separation with the Brasilsat B3 satellite without affecting the services that may be

provided from the satellite.13 Additionally, the technical changes described in this amendment

are the result of design improvements and technical developments that have occurred since the

Technical Narrative was submitted. These developments will allow EchoStar to use spectrum

more efficiently, resulting in better service to its customers.

       10
            47 C.F.R. § 25.117(d)(1).
       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 75º W.L.
orbital location.
       12
            See 75° W.L. Application.
       13
           As noted in the Technical Narrative, EchoStar has entered into a tentative physical
coordination agreement with Star One, which operates Brasilsat B3. EchoStar also will monitor
the orbital elements and longitude of the GOES 13 satellite operating at the nominal 75° W.L.
orbital location with a maximum east-west station-keeping of ±0.5 degrees, and will coordinate
with NOAA to the extent GOES 13’s station keeping box overlaps with that of EchoStar’s
satellite. See Attachment A at 13.



                                                 -4-


       These changes also will not result in additional interference to any authorized user in the

spectrum. Of course, EchoStar will coordinate its operations as required under the

Commission’s rules.

III.   CONCLUSION

       For the foregoing reasons, EchoStar amends its modification application to construct,

launch, and operate a 17/24 GHz BSS satellite at the 75º W.L. orbital location to request

authority to operate the satellite 0.15 degrees offset from its authorized orbital location with full-

power and full interference protection and to provide an updated and revised Technical Narrative

and Schedule S.

                                               Respectfully submitted,

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



April 27, 2011




                                                 -5-


                                    ECHOSTAR EX-4


                                     ATTACHMENT A
              Technical Information to Supplement Schedule S



A.1    SCOPE


This attachment contains the information required by 47 C.F.R. §25.114(c) and other sections of
the FCC’s Part 25 rules that cannot be entered into the Schedule S submission. Together with
the associated Schedule S this information provides a complete description of the ECHOSTAR
EX-4 satellite, as amended.


A.2    ORBITAL LOCATION
       (§25.114(c)(5))


The Commission has previously authorized EchoStar to operate a 17/24 GHz satellite at 75°
W.L. As explained in section A.13.3, EchoStar proposes to offset the satellite by 0.15° and to
center the station-keeping box at 75.15° W.L. in order to avoid an overlap of the station-keeping
volume with the BRASILSAT B3 satellite that operates nominally at 75° W.L.


A.3    GENERAL DESCRIPTION OF OVERALL SYSTEM FACILITIES,
       OPERATIONS AND SERVICES
       (§25.114(d)(1))


The ECHOSTAR EX-4 satellite will operate at the 75.15° W.L. orbital location and will provide
BSS services primarily to CONUS and Puerto Rico. The satellite also has a steerable downlink
spot beam that is currently intended to serve southern Mexico, subject to receipt of appropriate
authorizations. The satellite will provide service to U.S. territories using the 17.3-17.7 GHz

                                               1


downlink band, while the Mexico downlink spot beam will operate in the 17.7-17.8 GHz
downlink band.


The satellite will employ four types of downlink beams, three with a fixed large coverage area
and one with a steerable spot beam pattern coverage. The four beam types are:


   1) A CONUS large area coverage beam which serves all of the continental US;


   2) A Northern CONUS large area coverage beam which serves the northern and south-
       eastern parts of CONUS;


   3) A Southern CONUS large area coverage beam that serves the southern parts of CONUS,
       Mexico and Central America;


   4) An array of 30 small spot beams which can be steered as a single group, but which in the
       baseline configuration are pointed to provide service to CONUS, Puerto Rico and
       Southern Mexico.


The satellite can be operated in one of two primary modes. In the first mode, the three CONUS-
type beams are operated, providing twenty-four 26 MHz wide channels and using the lower 400
MHz of the 24.75-25.25 GHz / 17.3-17.8 GHz bands. Additionally, the Mexico spot beam can
be operated using the upper 100 MHz. In this mode, full frequency reuse is achieved through the
use of dual orthogonal circular polarizations. In the second mode, the CONUS North and
CONUS South beams and the 30 spot beams are simultaneously operated. The two CONUS
beams each use six 26 MHz channels in opposite polarizations. The thirty spot beams use 88
MHz wide channels. For the spot beams, full frequency reuse is achieved through a combination
of dual orthogonal circular polarizations and spatial isolation. In the second mode, all downlink
beams serving U.S. territory utilize the lower 400 MHz of the 17 GHz band, while the Mexico
spot beam utilizes the upper 100 MHz. There are variations of the second mode, which allow
varying numbers of CONUS beam channels to be used, with a proportionate reduction in the

                                               2


number of spot beams that can be used. The frequency plan details are provided in the updated
Schedule S that is being submitted as part of this amendment application.


The feeder uplink transmissions to all the transponders in the large area coverage beams and
some of the spot beams will occur from EchoStar’s existing feeder link station facilities in
Cheyenne, WY. Additional uplinks for the remaining spot beams are from Gilbert, AZ, Mt.
Jackson, VA, New Braunfels, TX, and optionally from Puerto Rico and Mexico City.


All active communications transponders will use either a single, a dual combined, or a triple
combined 135W travelling wave tube amplifier (“TWTA”) arrangement giving a total saturated
RF power per transponder of 405 Watts (i.e., up to 3 x 135 Watts). This produces peak EIRP
levels of between 59.4 dBW and 59.9 dBW in the large area coverage CONUS beams. For the
spot beams the peak EIRP levels vary between 60.5 dBW to 66.5 dBW. The peak EIRP for the
individual downlink spot beams vary to account for different rain attenuation characteristics of
the relevant service areas.


Spacecraft TT&C functions will take place in the 24/17 GHz frequency bands for on-station
operations, and orbit raising. The TT&C earth stations for on-station operations will be located
at EchoStar’s existing satellite control facilities in Cheyenne, WY and Gilbert, AZ.


A.4    PREDICTED SPACE STATION ANTENNA GAIN CONTOURS
       (§25.114(d)(3))


The ECHOSTAR EX-4 antenna gain contours for the receive and transmit beams, as required by
§25.114(d)(3), are given in GXT format. However, because of the large number of beams
involved and the known problems of the Schedule S software in handling a large number of
beams, the GXT files have not been embedded in the Schedule S software file and are being
provided separately to the Commission.       For the steerable spot beams, the gain contours
provided in the GXT files are representative of the baseline configuration pointing of the beams.



                                                3


A.5      SERVICES TO BE PROVIDED
         (§25.114(d)(4))


The ECHOSTAR EX-4 satellite will provide a range of DBS services to millions of small and
inexpensive subscriber receive-only earth terminals. The spot beams may be used for local-into-
local broadcasting and for video-on-demand services.


There will be one wideband digitally modulated signal transmitted in each of the active
transponders, supporting a range of information data rates depending on the order of the
modulation (e.g., QPSK, 8PSK) and the type and degree of FEC coding used.


Representative link budgets, which include details of the transmission characteristics,
performance objectives and earth station characteristics, are provided in the associated Schedule
S form. The representative modulation/coding schemes provided in the associated Schedule S
submission are as follows:

      a) QPSK, Turbo rate 5/6 inner coding (27 MHz1 and 88 MHz bandwidths);

      b) 8PSK, Turbo rate 2/3 inner coding (25.8 MHz and 88 MHz bandwidths).

A.5.1     Earth Stations


For most geographic locations within the service areas of each of the DBS beams, the standard
receive dish size will have a 45 cm equivalent reflector diameter, although larger dish sizes
(typically up to 90 cm in diameter) may be used in some geographic areas subject to high rain
attenuation. There will be millions of these types of terminals across the service areas.




1
      The 27 MHz carriers will be transmitted in the 26 MHz channels. These emissions can be
      accommodated within the useful bandwidth of the channel filters.

                                                 4


The feeder uplink earth stations (main and back-up) will typically use a 12 meter antenna.2 In
addition, all feeder link transmissions will comply with §25.223(b)(1), (2) and (4).


A.6      TT&C CHARACTERISTICS
         (§25.114(c)(4)(1) AND §25.114(c)(9))


The information provided in this section complements that provided in the associated Schedule S
submission.

The ECHOSTAR EX-4 TT&C sub-system provides for communications during pre-launch,
transfer orbit and on-station operations, as well as during spacecraft emergencies. The TT&C
sub-system will operate at the edges of the 17/24 GHz BSS frequency bands during the launch
and early operations phases of the mission as well as on-station.

During transfer orbit and on-station emergencies, the TT&C signals will be received and
transmitted by the satellite using a combination of antennas on the satellite that create a near
omni-directional gain pattern. During normal on-station operation, the TT&C signals will be
received via a high gain communications receive antenna and transmitted via the CONUS
transmit antenna. A summary of the TT&C subsystem characteristics is given in Table A.6-1.




2
      EchoStar will apply for all necessary earth station licenses for U.S. feeder link earth stations
      in due course.

                                                    5


                          Table A.6-1: TT&C Performance Characteristics
   Command Modulation                                                  PCM/FSK



   Command/Ranging Frequencies                                       24,753.0 MHz
   (On-Station)                                                      24,755.0 MHz

   Uplink Flux Density                                       Between -110 and -82 dBW/m2

                                                     Pseudo-omni antenna during transfer orbit and on-
   Satellite Receive Antenna Types                   station emergencies;
                                                     Communications spot antenna during on-normal
                                                     on-station mode.
   Polarization of Satellite Receive Antennas        RHCP for all antennas
   Peak Deviation (Command/Ranging)                                    ± 400 kHz

   Telemetry/Ranging Frequencies
   (Launch and Early Operations Phase                                17,301.0 MHz
                                                                     17,302.0 MHz
   and On-Station)

                                                     Pseudo-omni antenna during transfer orbit and on-
   Satellite Transmit Antenna Types                  station emergencies;
                                                     CONUS coverage antenna during on-normal on-
                                                     station operations.
   Polarization of Satellite Transmit Antennas       LHCP for all antennas

   Maximum Downlink EIRP                             10 dBW (pseudo-omni antenna);
                                                     21 dBW (CONUS coverage antenna).
   Telemetry/Ranging Modulation Index:
         1 sub-carrier                                                       1.0
         2 sub-carriers                                                      0.7
         3 sub-carriers                                                      0.6




A.7    SATELLITE TRANSPONDER FREQUENCY RESPONSES
       (§25.114(c)(4)(vii))


The predicted worst case receive and transmit channel filter response performance is given in
Table A.7-1 below. The receive response is measured from the satellite receive antenna up to
the input of the TWTA. The transmit response is measured from the input of the TWTA to the
satellite transmit antenna.

                                                 6


               Table A.7-1: Typical Receiver and Transmitter Filter Responses

       Frequency offset   Gain relative to channel center                   Comments
         from channel                 frequency
            center                      (dB)
                            Receive            Transmit

          CF±6 MHz           0.35                 0.43
         CF±7.7 MHz          0.45                 0.56
                                                                             In-Band
         CF±9.6 MHz          0.61                 0.90
                                                              Value does not exceed these p-p values
         CF±12 MHz           1.52                 2.55
         CF±13 MHz           2.93                 4.12
        CF±16.5 MHz           -3.0
        CF±20.0 MHz                               -3.0                     Out-of-Band
        CF±27.0 MHz                               -25.0       Attenuation is not less than these values

        CF±29.1 MHz          -30.0




A.8     CESSATION OF EMISSIONS
        (§25.207)


Each active satellite transmission chain (channel amplifiers and associated TWTA) can be
individually turned on and off by ground telecommand, thereby causing cessation of emissions
from the satellite, as required.


A.9     FOUR-DEGREE COMPATIBILITY

        (§25.140)


The demonstration of four-degree compatibility is contained in the link budgets embedded in the
associated Schedule S form. The link budgets show the end-to-end link performance taking into
account the assumed interference environment, which is described below.


Other than EchoStar, no other operator has received Commission authorization to operate a
17/24 GHz satellite within four degrees of 75.15° W.L. EchoStar currently has Commission
                                                          7


authorization to operate the 17/24 GHz ECHOSTAR EX-3 satellite at 79° W.L. EchoStar will
shortly seek Commission authorization to operate the ECHOSTAR EX-3 satellite at 79.15° W.L.
for the same reason it seeks an offset to 75.15° W.L. Operation of the satellite at 79.15° W.L.
avoids the station-keeping volume of the AMC-5 satellite that operates nominally at 79.05° W.L.
and it has the additional benefit of creating a four-degree separation from the 75.15° W.L.
location.


For purposes of this amendment application, it has been assumed that future 17/24 GHz satellites
will be located at four-degree increments from the 75.15° W.L. location.        All link budgets
assume pairs of interfering adjacent satellites nominally located at 4° and 8° from the requested
orbital location3 and transmitting digital carriers. All adjacent networks were assumed to be
transmitting with an uplink input power density of -56.5 dBW/Hz. The interfering downlink
EIRP density assumed was dependent on the victim receive antenna’s location. That is, a
receive location located within the regions defined by §25.208(w)(1) and §25.208(w)(4) is
assumed to experience interference levels caused by adjacent satellites transmitting with a PFD
level of -115 dBW/m2/MHz.           Receive locations located within the regions defined by
§25.208(w)(2) and §25.208(w)(3) are assumed to experience interference levels caused by
adjacent satellites transmitting with a PFD level of -118 dBW/m2/MHz and -121 dBW/m2/MHz,
respectively. All victim and interfering earth station antennas were assumed to have a sidelobe
pattern of 29-25 log().


The link budgets demonstrate that the proposed services can successfully operate given the
assumed interference environment and with reasonably high link availabilities.         With the
assumption that future adjacent satellites located four degrees from 75.15° W.L. have similar
technical characteristics to the ECHOSTAR EX-4 satellite, which is the case for the planned
ECHOSTAR EX-3 satellite, the link budgets then also serve to show that the interference into
future adjacent satellite networks is acceptable.




                                                    8


A.10   OFF-AXIS EIRP DENSITY LEVELS

       (§25.223)


The off-axis EIRP spectral density levels of the feeder link earth station antennas transmitting to
the ECHOSTAR EX-4 satellite will not exceed the limits of §25.223.


A.11   PFD ANALYSIS

       (§25.208)


The power flux density (“PFD”) analysis of the ECHOSTAR EX-4 satellite is included in Annex
1 to this Attachment. The analysis demonstrates that all beams of the ECHOSTAR EX-4
satellite that transmit in the 17.3-17.7 GHz band are compliant with the PFD levels of
§25.208(w) and in all four regions defined by §25.208(w). In addition, the analysis demonstrates
that the Mexico spot beam, which transmits in the 17.7-17.8 GHz band, is compliant with the
PFD levels of §25.208(c).


A.12   GEOGRAPHIC SERVICE REQUIREMENTS
       (§25.225)


The 75.15° W.L. location is not suitable for the provision of BSS service to either Alaska or
Hawaii due to the extremely low elevation angles toward these geographic areas as shown in
Figure A.12-1. The elevation angles towards the majority of Alaska are less than 5° and most of
Alaska is not visible. The elevation angles towards Hawaii are less than 1° and most of Hawaii
is not visible. For those geographic areas that are visible, the extremely low elevation angles
would not permit a viable BSS service due to the difficulty in locating user receive dishes such




3
    To account for station-keeping tolerances, the actual geocentric orbital separations used in
    the interference calculations were 3.9° and 7.9°.

                                                 9


that they would have line-of-sight to the satellite because of blockage from buildings, terrain and
foliage.




       Figure A.12-1: Elevation Angles from 75.15° W.L. towards Alaska and Hawaii




                                                                                                                                SATSOFT
                                      70.00




                                      60.00




                                      50.00
           North Latitude (Degrees)




                                      40.00




                                      30.00


                                                                                  10°
                                                                0°
                                      20.00
                                                                     5°
                                          -1 70 .00   -160.00        -150.00              -140.00         -130.00   -1 20 .00
                                                                               East Longitude (Degrees)




A.13   ORBITAL DEBRIS MITIGATION PLAN
       (§25.114(d)(14))


A.13.1 Spacecraft Hardware Design


Space Systems/Loral (“Loral”) is the manufacturer of the ECHOSTAR EX-4 satellite. Loral has
assessed the launch, orbit raising, deployment and normal operations portions of the mission and
determined that no debris will be released by the spacecraft except for the following case during
                                                                                     10


deployment. The only portion of the mission in which portions of the spacecraft are separated
from the main spacecraft body is during deployment. Separation and deployment mechanisms
are intended to contain the debris generated when activated.         There are several reflector
deployment hold-down electro-explosive devices (“EED”s) that have the potential to expel a
small amount of debris — up to 3mg of titanium debris from the hold-down and 2mg of “soot”
per firing. These EEDs have flown on over 35 spacecraft and had no failures. The assessment
found no other sources for debris throughout the mission.


To protect the spacecraft from small body collisions, including debris less than one centimeter in
diameter, the design of the ECHOSTAR EX-4 spacecraft allows for individual faults without
losing the entire spacecraft. All critical components (i.e. computers and control devices) are
built within the structure and shielded from external influences. Items that cannot be built within
the spacecraft nor shielded (like antennas) are redundant and/or are able to withstand impact.
The ECHOSTAR EX-4 spacecraft can be controlled through both the normal payload antennas
and wide angle antennas. The likelihood of both being damaged during a small body collision is
minimal. The wide angle antennas on this spacecraft are similar to open waveguides that point
towards the Earth (there is one set on each side of the spacecraft; either set could be used to
successfully de-orbit the spacecraft). These wide angle antennas would continue to operate even
if struck and bent.


A.13.2 Accidental Explosion Assessment
       (§25.144(d)(14)(ii))

Loral has reviewed failure modes for all equipment to assess the possibility of an accidental
explosion onboard the spacecraft. In order to ensure that the spacecraft does not explode on
orbit, the satellite controller will take specific precautions. All batteries and fuel tanks are
monitored for pressure or temperature variations.       Alarms in the Satellite Control Center
(“SCC”) inform controllers of any variations. Additionally, long term trending analysis will be
performed to monitor for any unexpected trends.




                                                11


Operationally, batteries will be operated utilizing the manufacturer’s automatic recharging
scheme. Doing so will ensure that charging terminates normally without building up additional
heat and pressure. As this process occurs wholly within the spacecraft, it also affords protection
from command link failures (on the ground).


In order to protect the propulsion system, fuel tanks will all be operated in a blow down mode.
At the completion of orbit raising, the pressurant will be isolated from the fuel system. This will
cause the pressure in the tanks to decrease over the life of the spacecraft. This will also protect
against a pressure valve failure causing the fuel tanks to become over pressurized.


In order to ensure that the spacecraft has no explosive risk after it has been successfully de-
orbited, all stored energy onboard the spacecraft will be removed. Upon successful de-orbit of
the spacecraft, all propulsion lines and latch valves will be vented and left open. All battery
chargers will be turned off and batteries will be left in a permanent discharge state. These steps
will ensure that no buildup of energy can occur resulting in an explosion in the years after the
spacecraft is de-orbited.


A.13.3 Safe Flight Profiles


In considering current and planned satellites that may have a station-keeping volume that
overlaps the ECHOSTAR EX-4 satellite, EchoStar has reviewed the lists of FCC licensed
satellite networks, as well as those that are currently under consideration by the FCC (i.e., those
filed with the FCC before this application). In addition, networks for which a request for
coordination has been published by the ITU within ±0.15° of 75.15° W.L. have also been
reviewed.


Based on these reviews, there are two satellites operating nominally at 75° W.L.: the
BRASILSAT B3 satellite operated by Star One; and the GOES 13 satellite operated by NOAA.
There are no pending applications before the Commission to use a location within ±0.15° of
75.15° W.L. With respect to published ITU filings, other than the Brazilian and USA networks

                                                12


that are filed at 75° W.L. on behalf of the aforementioned operational satellites, there is also a
Luxembourg filing and Papua New Guinea filing, both at 75° W.L. EchoStar can find no
evidence that the Luxembourg and Papua New Guinea networks are being progressed towards
launch.


The BRASILSAT B3 satellite operates nominally at 75° W.L. with a maximum east-west
station-keeping of ±0.1°.     The GOES 13 satellite operates nominally at 75° W.L. with a
maximum east-west station-keeping of ±0.5°. Star One and NOAA utilize the inclination-
eccentricity separation technique to avoid collision when the two satellites are in proximity of
each other.


EchoStar and Star One have reached a tentative physical coordination agreement, whereby
EchoStar will operate the ECHOSTAR EX-4 satellite at 75.15° W.L. The ECHOSTAR EX-4
satellite will be operated with an east-west station-keeping tolerance of 0.05°, thereby avoiding
any overlap with the station-keeping volume of the BRASILSAT B3 satellite. EchoStar will
continue to coordinate its operations with Star One to the extent necessary to avoid any such
overlap.


EchoStar also has confirmed with the National Telecommunications and Information
Administration (“NTIA”) that the GOES 13 satellite is located at the nominal 75° W.L. orbital
location with a maximum east-west station-keeping tolerance of ±0.5°. EchoStar will monitor
NOAA’s website4 to track GOES 13’s orbital elements and longitude on a regular basis.
EchoStar will utilize this data and the inclination-eccentricity separation technique to insure
adequate separation with the GOES 13 satellite when it occasionally traverses through the
station-keeping volume of the ECHOSTAR EX-4 satellite. For those cases where the GOES 13




4
    GOES 13’s orbital elements are available at http://www.oso.noaa.gov/goes/index.htm, and its
    longitude is available at http://noaasis.noaa.gov/cemscs/navsum.txt

                                               13


satellite’s path will overlap ECHOSTAR EX-4’s station keeping box, EchoStar will coordinate
its satellite operations with NOAA.


EchoStar will continue to monitor Commission and ITU resources to identify satellites that
reasonably can be expected to operate at, or near, 75.15° W.L. In the event that concrete plans
are made by another party to operate a satellite near 75.15° W.L. such that there is a possibility
of physical collision with the ECHOSTAR EX-4 satellite, EchoStar will engage in coordination
discussions to establish any necessary operational procedures to ensure that a physical collision
will not take place.


A.13.4 Post-Mission Disposal


At the end of the operational life of the ECHOSTAR EX-4 satellite, EchoStar will maneuver the
satellite to a disposal orbit with a minimum perigee of 300 km above the normal GSO
operational orbit. This proposed disposal orbit altitude exceeds the minimum required by 47
C.F.R § 25.283, which is calculated below.


The input data required for the calculation are as follows:


Total Solar Pressure Area “A” = 110.5 m2
“M” = Dry Mass of Satellite = 2491 kg
“CR” = Solar Pressure Radiation Coefficient (worst case) = 1.24


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 1.24 x 110.5/2491
       =       36,076 km
       =       290 km above GSO (35,786 km)

                                                14


While the minimum disposal orbit altitude required by § 25.283 is 290 km, EchoStar will reserve
enough fuel to meet or exceed a minimum perigee disposal orbit of 300 km out of an abundance
of caution. Thus, the designed disposal orbit of 300 km above GSO exceeds the required
minimum by a margin of 10 km. Taking account of all fuel measurement uncertainties,
performing the final orbit raising maneuvers will require approximately 11.6 kg of propellant,
which will be reserved.




A.14     SPACECRAFT CHARACTERISTICS

         (§25.114(c)(10))


Spacecraft physical and electrical characteristics are included in the associated Schedule S form.


The spacecraft reliability is consistent with current manufacturing standards in place for the
major suppliers of space hardware. Payload and bus design reliability are both greater than 0.8
with an overall spacecraft reliability to EOL of greater than 0.7.        Transponder sparing is
consistent with documented failure rates which allow attaining the overall reliability stated
above.




                            ___________________________________




                                                15


              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


                                 ANNEX 1 to ATTACHMENT A

1.0      PFD ANALYSIS


EchoStar calculates the power flux density/MHz on the Earth’s surface from these emissions as:
EIRP minus spreading loss in direction of interest minus bandwidth correction factor.1 For the
CONUS beams, the bandwidth correction factor is 25.8, which corresponds to the narrower 25.8
MHz carrier. For the spot beams, the bandwidth correction factor is 88, which corresponds to
the 88 MHz channel bandwidth.


1.1      17.3-17.7 GHz Band


All downlink beams of the ECHOSTAR EX-4 satellite operate in the 17.3-17.7 GHz band except
for the Mexico spot beam. The allowable PFD levels in the 17.3-17.7 GHz band are defined by
§25.208(w) as:


      (1) In the region of the contiguous United States, located south of 38° North Latitude and
          east of 100 West Longitude: -115 dBW/m2 /MHz.


      (2) In the region of the contiguous United States, located north of 38° North Latitude and
          east of 100° West Longitude: -118 dBW/m2 /MHz.


      (3) In the region of the contiguous United States, located west of 100° West Longitude: -121
          dBW/m2 /MHz.


      (4) For all regions outside of the contiguous United States including Alaska and Hawaii:
          -115 dBW/m2 /MHz.




1
      Note that this is a conservative estimate of maximum PFD since the calculation does not take
      into account clear sky atmospheric losses.


CONUS Beam:


The maximum downlink EIRP of the CONUS beam is 59.5 dBW. The maximum PFD level that
the beam is capable of producing is -117.0 dBW/m2/MHz. This occurs in the southeast portion
of CONUS.                           Figure 1 shows the geographic location of the maximum PFD and the -118
dBW/m /MHz and -121 dBW/m2/MHz contours. The diagram demonstrates that the PFD levels
                              2


produced by the CONUS beam are compliant in all regions defined by §25.208(w).

Figure 1. PFD contours of the CONUS beam.




                                                                                                               SATSOFT
                                                                                                        -121
 North Latitude (Degrees)




                                                                 -121
                            40.00


                                                                                     -118     -117.00




                            30.00


                                                                                       -121




                                                      -100.00                                 -80.00
                                                          East Longitude (Degrees)


CONUS North Beam:


The maximum downlink EIRP of the CONUS North beam is 59.9 dBW. The maximum PFD
level that the beam is capable of producing is -116.53 dBW/m2/MHz. This occurs in the
southeast portion of CONUS. Figure 2 shows the geographic location of the maximum PFD and
the -118 dBW/m2/MHz and -121 dBW/m2/MHz contours. The diagram demonstrates that the
PFD levels produced by the CONUS North beam are compliant in all regions defined by
§25.208(w).


Figure 2. PFD contours of the CONUS North beam.




                                                                                                              SATSOFT
                            40.00                         -121



                                                                 -118
 North Latitude (Degrees)




                            35.00




                            30.00
                                                                                  -116.53




                                                                                            -118
                            25.00
                                                                                              -121



                                    -100.00   -95.00        -90.00      -85.00          -80.00       -75.00
                                                       East Longitude (Degrees)




CONUS South Beam:


The maximum downlink EIRP of the CONUS South beam is 59.4 dBW. The maximum PFD
level that the CONUS beam is capable of producing is -116.96 dBW/m2/MHz. This occurs in
the southeast portion of CONUS. Figure 3 shows the geographic location of the maximum PFD
and the -118 dBW/m2/MHz and -121 dBW/m2/MHz contours. The diagram demonstrates that
the PFD levels produced by the CONUS South beam are compliant in all regions defined by
§25.208(w).


Figure 3. PFD contours of the CONUS South beam.




                                                                                                    SATSOFT
                            40.00
 North Latitude (Degrees)




                                                          -121
                            35.00

                                                                          -118


                                                                                 -118
                            30.00


                                                                                         -116.96


                            25.00                                                 -121




                                    -100.00   -95.00       -90.00       -85.00             -80.00
                                                   East Longitude (Degrees)


Spot Beams:


Table 1 shows the maximum PFD levels that can occur at the boresight of each of the spot beams
and compares these levels to the applicable regional PFD level of §25.208(w). Table 1 shows
that the peak PFD is less than the applicable PFD level of §25.208(w) for all beams.

Table 1. Peak PFD levels of the spot beams.
                                              Applicable
                          Beam Peak                            ECHOSTAR EX-4
Beam      Beam Peak                       §25.208(w) PFD                               PFD Margin
                          Longitude                                Peak PFD
 ID      Latitude (°N)                         Limit                                      (dB)
                             (°W)                               (dBW/m2/MHz)
                                          (dBW/m2/MHz)
SP01          46.93         127.16             -121                  -122.0               1.0
SP02          45.66         114.19             -121                  -121.8               0.8
SP03          45.82         105.28             -121                  -121.7               0.7
SP04          45.34          97.87             -118                  -121.6               3.6
SP05          45.86          90.63             -118                  -118.6               0.6
SP06          46.55          84.41             -118                  -118.6               0.6
SP07          47.40          69.44             -118                  -118.6               0.6
SP08          39.77         121.59             -121                  -121.8               0.8
SP09          39.85         113.22             -121                  -121.7               0.7
SP10          39.26         104.78             -121                  -121.6               0.6
SP11          39.66          98.55             -118                  -121.5               3.5
SP12          39.35          91.70             -118                  -119.9               1.9
SP13          39.92          85.41             -118                  -119.5               1.5
SP14          40.59          79.88             -118                  -118.4               0.4
SP15          40.56          73.61             -118                  -118.4               0.4
SP16          33.84         120.39             -121                  -121.7               0.7
SP17          34.00         112.82             -121                  -121.6               0.6
SP18          33.53         105.13             -121                  -121.5               0.5
SP19          33.88          98.59             -115                  -121.4               6.4
SP20          34.35          93.15             -115                  -118.7               3.7
SP21          34.16          87.12             -115                  -117.6               2.6
SP22          34.75          82.02             -115                  -116.6               1.6
SP23          34.70          76.27             -115                  -116.7               1.7
SP24          28.68          99.71             -115                  -121.4               6.4
SP25          29.12          94.52             -115                  -118.3               3.3
SP26          29.59          88.90             -115                  -117.3               2.3
SP27          29.48          83.37             -115                  -115.3               0.3
SP28          25.16          80.70             -115                  -115.2               0.2
SP29          19.72         98.84        N/A (Mexico beam)           -116.5               N/A
SP30          18.32          66.36             -115                  -115.3               0.3


All beams conform to the applicable PFD level of §25.208(w) at each beam’s boresight.
However, since a beam centered in one region defined by §25.208(w) can overlap into a region
with a lower allowable PFD level, it is necessary to examine those beams that are near regional
boundaries to determine whether they conform to all the PFD levels of §25.208(w). Such an
examination was performed for all beams located near regional boundaries and it was found that
all such beams comply with the PFD levels of §25.208(w) in all four regions.


1.2      17.7-17.8 GHz Band


§25.208(c) contains PFD limits that apply in the 17.7-17.8 GHz band. The PFD limits of
§25.208(c) are as follows:


      (1) -115 dB(W/m2) in any 1 MHz band for angles of arrival between 0 and 5 degrees above the
         horizontal plane;


      (2) -115+(-5)/2 dB(W/m2) in any 1 MHz band for angles of arrival  (in degrees) between 5
         and 25 degrees above the horizontal plane; and


      (3) -105 dB(W/m2) in any 1 MHz band for angles of arrival between 25 and 90 degrees above
         the horizontal plane.


Only the ECHOSTAR EX-4 satellite’s Mexico spot beam has the capability of transmitting in
the 17.7-17.8 GHz band. The beam’s peak downlink EIRP is 65.3 dBW. The maximum PFD
can be calculated to be -116.5 dBW/m2/MHz. This PFD level is lower than all PFD levels of
§25.208(c) (i.e. at all elevation angles), therefore the Mexico spot beam is compliant with
§25.208(c).




                                 ________________________________



Document Created: 2011-04-27 19:45:53
Document Modified: 2011-04-27 19:45:53

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