Attachment attachment A

attachment A

SUBMISSION FOR THE RECORD submitted by EchoStar

Attachment A

2005-08-05

This document pretains to SAT-LOA-19980702-00066 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1998070200066_449486

STEPTOE &JOHNSON«= atrorners at caw Pancels Mictalopootos Received Philp L Mater 1310 Comnecteut Aenve. NY 202423000 AUG 1 1 2005 Washingon. DC 200361795 prichalogsteptoecom proler@iteptoccom Rilles Bransh Ter2024293000 m ac2024293002 Bwege * mepoecom RECEIVED August 5, 2005 AUG ~ 5 2005 BY HAND DELIVERY Faden Communcaton Commsn Marlene H. Dortch Ofteot Secray Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Mobile Satellite Ventures Subsidiary LLC File Nos. SAT—LOA—19980702—00066, SAT—AMD—20001214—00171, SAT—AMD—20010302— 00019, SAT—AMD—20031118—00335, SAT—AMD—20040209—00014 and SAT—AMD—20040928—00192 Call Sign $2358 Dear Ms. Dortch: On June 22, 2005, EchoStar Satelite L.L.C. ("EchoStar")filed a Petition for Clariication and/or Reconsideration (*EchoStar Petition®) ofthe International Bureau‘s decision to grant Mobile Satellite Ventures Subsidiary LLC‘s (°MSV‘s") above—referenced application and associated amendments to operate an L—band Mobile Satelite Service("MSS®) satellite with extended Ku—band feeder links at the 101° W.L. orbit location.‘ In EchoStar‘s Reply to MSV‘s Opposition to EchoStar‘sPetition, EchoStar indicated that it would soon be filing an Application for Review of the Intemational Bureau‘s recent decision denying an EchoStar application to operate atthe 101° W.L. orbital location.®. EchoStar stated that ‘ See In the Matter ofMobile Sarellte Ventures Subsidiary LLC, DA 05—1492 (rel. May 23, 2005) ("MSY Order"). * See In the Matter ofEchoStar Satellte LLC, DA 05—1955 (rel. Tly 6, 2005) (*EchoStar Order®). See EchoStar Reply, filed in File No. SAT—LOA—19980702—00066 er al. (July 21, 2005). This Reply is the subject of a pending Motion to Strike filed by MSV, and Opposition filed by EchoStar. See (Continued...) washinctow +. wew york +/ rwotnix + tos anorits +/ tonpon +. srusstis

Marlene H. Dortch August 5, 2005 Page 2 accompanying that forthcoming Application for Review would also be a preliminary sharing analysis between EchoStar and MSV that the International Bureau may also find relevant i its consideration of the EchoStar Petition. EchoStar indicated that it would provide a copy of this sharing analysis for the record in the above—captioned proceedings when the analysis was completed and submitted with EchoStar‘s Application for Review." Accordingly, enclosed as Attachment A to this leter,please find a copy of the following sharing analysis for inclusion in the record of this proceeding: "MSV—EchoStar Sharing Analysis," prepared by Dr. Richard J. Barnett, Telecomm Strategies Inc. Please let us know if you have any questions or would like to discuss this issue further. Sinccrcly, io L. Malat use Pamchs :chaloponlos Philip L. Malet Counsel to EchoStar Satellite LLC ee:—— Donald Abelson, International Bureau Cassandra Thomas, International Bureau Fem Jarmulnck, International Burcau Robert Nelson, International Bureau Jennifer Manner, Vice President, Regulatory Affairs, MSV (by first class mail, postage prepaid) Bruce D. Jacobs and David S. Konezal, Counsel to MSV (by first class mail, postage prepaid) David Bair, Vice President, Project Operations, EchoStar (by first class mail, postage prepaid) MSV Motion to Strike Reply of EchoStar SatellteL.L.C., filed in SAT—LOA—19980702—00066 er al. (Aug. 1. 2003); see EchoStar Opposition to Motion to Strike, filed in SAT—LOA—19980702—00066 er al (Aug. 5, 2003) * EchoStar Reply at 4. While EchoStar in its Reply indicated that it would be filing this sharing analysis with ts forthcoming Application for Review, it ultimately decided to file a Petition for Reconsideration ofthe EchoStar Order instead of an Application for Review. Accordingly, the shoring analysis was attached to this Petition for Reconsideration. See Petition for Reconsideration, fled in File No. SAT—LOA—20040210—00015 eral. (Aug. 5, 2005).

ATTACHMENT A MSV—EchoStar Sharing Analysis A.1 Introduction MSV‘s planned use of the extended Ku—band at 101°W.L. for its MSS feeder links is compatible with EchoStar‘s FSS use of the same frequencies and same orbital location for spot beam DTH services." Sharing of the frequencies would be based on geographic separation of the spot beams in both systems. Such an arrangement would constitute efficient use of the Ku—band FSS spectrum. The analysis presented below is intended to demonstrate the feasibility of this shoring arrangement between MSV and EchoStar. It is not intended to derive the final sharting conditions, which are best established through bilateral coordination between the parties. A.2 MSV‘s Ku—Band Feeder Links In the November 2003, February 2004 and September 2004 Amendments to its FCC application for a next generation MSS satellite, MSV has provided scant information conceming its Ku—band feeder links:® MSV showed an illustrative Ku—band feeder link beam with broad North American coverage, but also stated that ®... Ku—band feeder link spot beams may also be formed by the satellite in the event spatial frequency reuse of the available feeder link spectrum ‘The Ku—hand frequency ranges under considetion hee are thosein the U Appondix 30 B Plan,which are 10.7—10.95 GHHeand 11.2—11.45 GHte downlink, and 12.75—12.25 GHte uplink * See Applications of Mobile Satllte Ventures Subsidhry LLC, ile No. SAT—AMD—20081118:00895 (Nov. 18, 2003 Fie No. SAT—AMD2004020900014 (Reb.9, 2005);File No. SATAMD2004092800192 (Gepu 28, 2000

becomes necessary ...."".. More recently MSV has stated that it intends to use an ATC self— interference cancellation systemin its next generation satellite in order to protect its MSS operations from its own ATC operations.‘ MSV has stated that its interference cancellation scheme will *... require MSV to employ greater re—use of its feeder link frequencies than it would otherwise . MSV will accomplish this by deploying additional gateway earth stations at a relatively modest additional cost...."" To date MSV has not clarified the details of ts feeder link design, such as the design of the spot beam coverage or the number and location of feeder link earth. stations. Its authorization, however, expressly is conditioned on operating up to two feeder link earth stations with its new satellite. Currently MSV is authorized bythe FCC to operate onl two feeder link earth stations located in Reston, VA and Alexandria, VA. However, these two locations are too close to each other to allow for spatial re—use of the feeder link frequencies using satellite spot beams. Therefore, in the sharing analysis below it is assumed that one of the feeder link spot beams will point towards the Washington DC area (and hence be used with the Reston and/or Alexandria earth stations), and a second spot beamwill be pointed towards a distant location, which was arbitrarily selected as being Houston, TX. Candidate spot beam coverage to implement this scheme is shown in Figure 2—1 below.* * See Appliations of Mobil Satlite Venturs Subsidiry LLC, File No SATE—AMD200811800335 (Nov. 18, 2003); File No SAT—AMD—20040209—00014 (Feb.9, 2009 * See Consoliated Oppositon t and Comments on PettionsforReconsideration a1.C p7—8 (August20, 2003); Replyof Mobile Stelite VenuresSubsidiry LLC a technicl Appendix 1.2 (eptember2 2003); Applications of Mobile Satelfte Ventures Subsidlry LLC, File No. SAT—AMD—20031 11800335 at Technical Appendixp.11 (Nov. 18, 2003); MSV ex—parte Janvary 22, 2006); Response of Mobile Satelite Ventures Subsidiary LLC to Opposition o Inmarsat Ventures Lt at 17—18 (Apri14, 2004) * See Respanse of Mobile Satelfte Ventures Subsidhry LLC to Oppositon of Inmarsat Ventures Lid. at Sction 11.2, Aprl14,2004 Not thatthe contourshown e —2,—3,—4,—6,—4,—10,—14 and —20 dB relative to beam peak. The —14 dB contour is usd in he analysi in ltersections ofts document

Figure 2—1 — Candidate MSV Feeder Link Spot Beam Coverage A satellite reflector of 2 meters in diameter is assumed, which results in a peak gain of approximately 45 dBi at the downlink frequencies. This gain is significantly higher than the broad North American beam originally shown in MSV‘s Amendment, which was 29 dBi, allowing for a reduction in satellite transmit power on the feeder downlink. There is an inconsistency in the MSV Amendments (common to both the November 2003 and February 2004 Amendments) regarding the actual feeder downlink EIRP and PFD levels. In Table 1—6 of the MSV Amendment, the maximum feeder downlink PFD at the Earth‘s surface is stated to be in the range —167.3 to —168.7 dBW/m°/4kHz, depending on elevation angle, although no back—up analysis is shown to support this.. This is inconsistent with the MSV link budget given in Table 1—12 ofthe MSV Amendment, which shows a feeder downlink EIRP of 20.5 dBW per carer (50 kHz bandwidih). Such an EIRP level corresponds to a PFD of 152. dBW/m‘/4kHz which is at least 14.8 dB higher than the PFD values stated by MSV in its Table 1—6. This analysis assumes that the MSV link budget is correct and that the proposed feeder downlink EIRP densityis 20.5 dBW/SOkHz.

Regarding the MSV feeder uplink, Table 1—13 of the MSV Amendment shows a feeder uplink EIRP of 61 dBW per carrier (200 kHz bandwidth). This will be assumed in the sharing analysis below. A.3 EchoStar‘s Spot Beam Downlinks In its FCC Amendment for 101°W, EchoStar proposes downlink spot beams with a peak EIRP of 57 dBW (in 27 MHz). Typically, service could be provided down to EIRP levels of 50 dBW in the dryer rain regions. These parameters will be used in the sharing analysis below. AA EchoStar‘s Feeder Uplinks EchoStar‘s planned satelite at 101°W will have reconfigurable uplink beam capability, including both fixed and steerable satellte receive beams. ‘The spot beams are steerable such that uplinks can be received from any part of the visible Earth, subject to appropriate regulatory constraints. These spot beams are relatively large (39.5 dBi}, but they could be made smaller to further facilitate sharing with MSV. In the sharing analysis belowit will be assumed that these beams have 45 dBi peak gain, and operate with an earth station EIRP level of 80.6 dBW (in 27 MHz), as given in the link budgets of the EchoStar 101 W° FCC application, as amended. A.5— Downlink Sharing Analysis Table 5—1 below shows the analysis of downlink interference from MSV into EchoStar. The MSV downlink EIRP is assumed to be as given in Section A.2 above, and the minimum

EchoStar downlink EIRP as given in Section A.3 above. The results show that a C/l of 16.2 dB is achieved outside of the —14 dB gain contour of the candidate MSV downlink spot beam." Table 5—1 — Downlink Interference Analysis (MSV > EchoStar) Parameter Unite Value MSV downink EIRP por carrer {r 50 kiiz) 205 dewisoitte MSV downink EIRP density (por Ho) 265 doWhie N: EchoStar downlnk EIRP (per 27 Miiz) soo dawreriiie Min. EchoStar downink EIRP densty (por He) 4s coWhie Resuling Ginto EchoStar at MSV beam poak 22| o Resuling GMinto EchoSiar at MSV —14 dB contour 162 «o Table 5—2 below shows the analysis of downlink interference from EchoStar into MSV. The maximum EchoStar downlink EIRP is assumed to be as given in Section A.3 above, and the minimum MSV downlink EIRP as given in Section A.2 above. The results showthat a C/I of 16.8 dB is achieved outside of the —26 dB gain contour of the EchoStar downlink spot beam.® Table 5:2 — Downlink Interference Analysis (EchoStar > MSV) Parameter Unite Value Mex. EchoStr downink EIRP (por 27 Miiz) sro dawromitte Max EchoStar downink EIRP (per Hz) —i7a doWhte MSV downlnk EIRP (per 50ko 2os aewisoitie MSV downink EIRP (por Ho) 265 dBWhiz Resuling Ginto MSV at EchoStar beam peak <2| sn Resuling GLinto MSV at EchoStar—26 d8 contour 168 c EEchoSaris ot necessail proposingtat 162 d be the crieionfordownlinkineference fromMSV into EEchoStar, although operation at ts C leveli learly a possibiliy, pariculaly fonewly stablished EchoStar services Similary, EchoStar is not necessarily proposing that 168 B be th crierion for downlink interfrence from EEchaar into MSV,although opertionatthis / leveis clealy a possblit. paicularly for MSV‘s nouly establshed linkso ts next peneration satelit, T is noted that this evel of adicent stelitinterference is Jowerthanthe MSV—1 sitelitinrasystem intecfrence (C/ of 127 dB).

Figure 5—1 below shows some example EchoStar downlink spot beams superimposed on the assumed MSV spot beams. The four EchoStar beams to the center and west of CONUS are all well isolated from the MSV spot beams, showing the significant amounts of territory that can be served by EchoStar that are well removed from the MSV feeder link beams and earth stations. The EchoStar beam to the south—east has deliberately been located relatively close to one ofthe MSV beams. Note, however, that even in this case the MSV receiving earth station is outside of the —26 dB gain contour of the EchoStar spot beam and so a C/Iof greater than 16.8 dB would be achieved for the MSV feeder downlink. For this EchoStar spot beam the —14 dB gain contour of the MSV beam intersects approximately one third of the main service area of the EchoStar beam, but useful EchoStar service could be achieved over a significant area of the beam due to the fact that the EchoStar EIRP is well above the assumed minimum of 50 dBW over the main part ofthe EchoStar beam. Figure 5—1 — Example EchoStar Spot Beams and Assumed MSV Spot Beams Blue=EchoSur; Red=MSV

A.6— Uplink Sharing Analysis Table 6—1 below shows the analysis of uplink interference from MSV into EchoStar. The MSV uplink EIRP is assumed to be as given in Section A.2 above, and the EchoStar uplink EIRP as given in Section A.4 above. The results show that a C/I of greater than 18.3 dB is achieved provided the MSV feeder link earth stations are located outside ofthe —20 dB gain contour of the EchoStar uplink spot beam." Table 6—1 — Uplink Interference Analysis (MSV > EchoStar) Parameter Ynite Yalze MSV upink EIR_ (par200 kitz) 6110 dewraookie MSV upink EIRP densiy (per Hz) 20 dowhte Echotar upink EIRP (por 27 NHe) sos cowrerme EchoStar upink EIRP density (per H2) 63 ownie Resuling C1 into EchoStar t MSV Eis located at EchoStar beam poak EHIE3 Resuling C1 into EchoStaif MSV Eis located at EchoStar—20 dB contour 2s o Table 6—2 below shows the analysis of uplink interference from EchoStar into MSV using the same assumptions as for Table 6—1 above. The results show that a C/I of 21.7 dB is achieved provided the EchoStar feeder link earth stations are located outside ofthe —20 dB gain contour of the MSV uplink spot beam." EEchaar is not necessrily proposing that 18.3 d be the criterion to e usedfor uplik inerfrencefom MSV into EchoStr,although operationatthis C/ leveis lealy a possblt. paticulaly for newly esuablished EchaStarservices °: EchaSar is not necessaril proposing that 217 dB be the criteionto e used foruplnk intrferencefrom EchaSa into MSV,althoush opertionatthis C/ leveis clealy a possblit, panicularly for MSV‘s newly establishedlinks o ts nextpenertion satelit, 1 is noted that hi evel o adjcent seitinterfrence is ystem inerference (CH of 147 dB),

Table 6—2 — Uplink Interference Analysis (EchoStar > MSV) Parameter Unite Yalue EchoStar uplink EIRP {per 27 NHa) so6 dawrzmuke EchoStar uplink EIRP densiy (por Hz) 63 dowhte MGV uplink EIRP (por 200 kiz 610 dewrodkiz MGV uplink EIAP density (per Hz) a0 doWhte Resuting GM ito EchoStar it MSV ES is located at EchoStar beam poak 17 s Resuling GLinto EchoStar it MSV ES is located at EchoStar—20 dB contour 217 as Two uplink sharing scenarios are addressed below in terms of the location of the EchoStar uplinks.. The first is shown in Figure 6—1 where the EchoStar uplinks are located outside of the USA, as illustrated in the EchoStar 10W FCC application, as amended..In this case there is ample geographic separation of the beams between MSV and EchoStar to meet the levels computed in Tables 6—1 and 6—2 above.In fact the isolation is likely to be much greater than 30 dB, rather than the 20 dB assumed in these tables, resulting in C/I levels of the order of 30 dB. Note also that the 20 dB contour of the EchoStar beam only enters a very small area of CONUS in southem Texas along the Mexican border, thereby placing negligible constraints on the possible location ofthe MSV feeder link earth stations.

Figure 6—1 — Scenario of EchoStar Uplinks Outside of the USA B — © revsoninre? The second scenario is shown in Figure 6—2 where the EchoStar uplinks are located inside the USA at Cheyenne, WY and Gilbert, AZ." . In this case there is also more than sufficient geographic separation of the beams between MSV and EchoStar and likely isolation and hence C/1 levels would be in the region of 30 dB or more.. Note that with this scenario there would be considerable flexibility for MSV to locate ts 2"" feeder link earth station anywhere within large 5* ‘These two sites arealeady esablshed EchoStar uplink ies used withother EchoStar satlites

parts of CONUS provided it maintains a certain geographic distance from Cheyenne, WY and Gilbert, AZ. Figure 6—2 — Scenario of EchoStar Uplinks in the USA A7 Possible Use of Additional MSV Feeder Link Earth Stations MSV has indicated that it might choose to use up to three or four additional feeder link earth station sites in order to obtain higher levels of frequency re—use.". Although this would restrict the fexibility for EchoStars use of the band, sharing would still be visble as demonstrated in Figures 7—1 below, which shows the downlink situation (similar results apply in the case of the uplink). Two additional feeder link sites have been arbitrarily located at Chicago ©*— See MSV Oppostion to Peitionfor Clarifcationandor Reconsideatonat 4—5 uy 7, 2008). EchoStardoes not conced thatthe FCC should modifythe two feeder nk conditin n the MSV authorization; wthout possibleretitions onthefiurelocation ofadditonal earth stations.. Similar restrictions were placed on MSS feeder linksin the 29 GHz band o accommedate LMDS sations. Rulemaking to Amend Pars 1 2, 21 and 25 othe Commision‘ Ruleto Redesignate the 27.5—29.5 GHiz Frequency Band.to Rellocae the 295300 GHHz Frequency Band, to Establsh Rales and PolicesforLocal Mulipoint Distibution Sevice andfor Fised Sarelte Sevices11 FCC Red. 19005, 19083 (1996) 10

and San Diego, which ensure adequate isolation from the other two assumed MSV feeder link sites at Washington DC and Houston. Many example EchoStar beams are shown in Figure 7—1, all of which achieve the 26 dB isolation from the MSV feeder link earth station sites.. This illustrates well that EchoStar and MSV would be able to share the band even with a higher level of frequency reuse in the MSV system. Figure 7—1 — Downlink Example with Four MSV Feeder Link Earth Stations Blue= EchoStar Red =MSV A.8 Conclusions In this sharing analysis it has been demonstrated that, with EchoStar and MSV‘s particular requirements for use of the Appendix 30B Ku—band, shoring is possible using co— frequency collocated satellites, without placing undue constraints on either party. Such sharing is feasible because of the use of spot beams by both MSV and EchoStar. Spot beams in the MSV system apparently are necessary in order to permit MSV to implement the ATC interference 11

cancellation system that it intends to deploy. In the EchoStar system spot beams are an important means for efficiently transmitting its programming to restricted geographic areas. Although the analysis presented here clearly shows the feasibity of sharing. coordination between the partis is necessary to arrive at the optimum arrangements for both parties. 12

CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING INFORMATION 1 hereby certify that I am the technically qualified person responsible for preparation of the engineering information contained in this pleading, that 1 am familiar with Part 25 of the Commission‘s Rules, that 1 have either prepared or reviewed the enginecting information submitted in this pleading, and thatit is complete and accurate to the best of my knowledge and belief. Pubad Aom Richard J. Bamett, PhD, BS Telecomm Strategies Inc. 6404 Highland Drive Chevy Chase, Maryland 20815 (s01) 656—8960 Dated:. August 5, 2005 13


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Document Modified: 2005-08-11 17:35:21
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