Attachment Attachment A

This document pretains to SAT-LOA-20051221-00267 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2005122100267_473545

                                           ECHOSTAR-10

                                          ATTACHMENT A
                      Technical Information to Supplement Schedule S



A.1           Scope


This attachment contains the following information:

      (i)       Information required by §25.114(d) that is not expected to be included in the
                associated Schedule S submission (See Sections A.2, A.3, A.4, A.8, A.9 and A.10
                below);

      (ii)      Information required by §25.114(c) and other sections of the FCC §25 rules that
                cannot be entered into the Schedule S software used to prepare the associated
                Schedule S submission (See Sections A.5, A.6 and A.7);

      (iii)     Technical waiver requests, including necessary justification (See Section A.11);

      (iv)      Additional comments relating to the data provided in the associated Schedule S
                submission (see Section A.12).


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


The ECHOSTAR-10 satellite will operate at the 110°W.L. orbital location and has the capability
to provide BSS services to the USA, including Alaska and Hawaii, as well as to Puerto Rico and
Cuba. The satellite operates in the 17.3-17.8 GHz BSS feeder uplink band (ITU Appendix 30A)
and the 12.2-12.7 GHz BSS downlink band (ITU Appendix 30), using a subset of the channels
licensed by the Commission to EchoStar at this orbital location.


Spot beams are used on both uplink and downlink to provide a high level of frequency reuse and
satellite power efficiency, and to permit broadcasting of specific programming into restricted
                                                     1


geographic areas.       There are six separate uplink spot beams pointed towards six separate
locations within CONUS, as well as four uplink spot beams pointed to geographic areas outside
of CONUS (Alaska, Hawaii, Puerto Rico and Cuba).1 There are 49 distinct downlink beams,
consisting of 45 spot beams covering different parts of CONUS, and individual beams covering
Alaska, Hawaii, Puerto Rico and Cuba. The assignment of uplink channels to the different
uplink beams has been made in order to permit the ECHOSTAR-10 satellite to be collocated in
the future at the 110°W.L. nominal orbital position with other existing EchoStar satellites that
operate uplinks only from the Cheyenne and Gilbert feeder link earth stations.


Ten downlink channels and 27 uplink channels are used by the ECHOSTAR-10 satellite. Using
42 active TWTAs, each of 140 Watts saturated power capability, the satellite supports the
simultaneous transmission of 123 independent signal transmission chains, each of nominally 24
MHz bandwidth.2,3,4 Based on this, the satellite achieves an average spatial frequency reuse
factor of 12.3 for the downlink frequencies and 4.55 for the uplink frequencies. This is in
addition to the two-fold frequency reuse factor inherent in the use of dual orthogonal circular
polarization as prescribed by the ITU Region 2 BSS Plan.


EchoStar will add four feeder link earth station facilities in CONUS to complement its existing
uplink facilities in Cheyenne, WY and Gilbert, AZ. These will be located in the following U.S.
cities: Mount Jackson (VA), Monee (IL), Spokane (WA) and New Braunfels (TX). These
locations have been selected to achieve the spatial isolation necessary to permit the uplink




1
    EchoStar is not requesting authority to operate the beam covering Cuba, and will not do so until and unless all
    required approvals for such operation by the U.S. Government, including the Commission, have been requested
    and obtained.
2
    Each channel is nominally 24 MHz bandwidth, with 29.16 MHz channel center frequency spacing, consistent
    with the ITU Appendix 30 and 30 A BSS Plans. However, note that the transponder useful bandwidth is
    actually greater than 24 MHz (approximately 26 MHz) which permits the transmission of signals with occupied
    bandwidth slightly in excess of 24 MHz. See also Section A.4.2.
3
    Nine of these signal transmission chains downlink the same signals into two separate spot beams, making a total
    of 132 beam-channel signal paths.
4
    The associated Schedule S shows 137 possible transponders, which includes five alternate signal connectivities
    for certain channels downlinking into the non-CONUS beams (see Section A.12.2).

                                                         2


frequency reuse. In addition there may be uplink earth stations outside of CONUS, in each of the
other four uplink beams that serve Alaska, Hawaii, Puerto Rico and Cuba. 5,6


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.


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


The ECHOSTAR-10 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.7
Note that this consists of the following:

      •   Specific co-polar gain contours for all ten receive beams;

      •   Specific co-polar gain contours for all 49 transmit beams, including 45 that serve CONUS
          and the four non-CONUS beams (i.e., Alaska, Hawaii, Puerto Rico and Cuba).

The GXT data files that form part of the ITU submission for ECHOSTAR-10 are provided as a
separate attachment to this application.


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


The ECHOSTAR-10 high powered spot-beam satellite will provide a range of DBS services to
millions of small and inexpensive subscriber receive-only earth terminals.




5
      EchoStar will apply for all necessary earth station licenses for U.S. feeder link earth stations in due course.
6
      EchoStar’s primary feeder link earth stations will be located in CONUS. However, the ECHOSTAR-10 satellite
      design also permits programming to be uplinked from the non-CONUS beams, rather than back-hauling the
      signals to the CONUS feeder link sites. Therefore, uplinks from outside CONUS may also be utilized in the
      future. In the case of the Cuba spot beam, this will not occur unless EchoStar requests and receives prior
      Commission and other approval.
7
      All beams operate in both LHC and RHC polarization. Only one GXT file is provided for each beam and this
      applies to both senses of polarization.

                                                             3


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 submission, and further described in Section A.4.2 below.


A.4.1   Earth Stations


The subscriber receive-only earth stations to be used with the ECHOSTAR-10 satellite will have
effective antenna diameters in the range 45 to 90 cm, depending on a variety of factors such as
rain zone, availability requirements, location in CONUS, and the number of EchoStar satellites
simultaneously being received. There will be millions of these types of terminals across the
service areas. The feeder uplink earth stations (main and back-up) will typically use a 13 meter
antenna, although possible future uplinks from the non-CONUS beams may use antennas as
small as 6 meters.


A.4.2   Link Budgets


Three representative modulation/coding schemes are provided in the associated Schedule S
submission, as follows:

   a) QPSK, DVB-S rate 3/4 inner coding

   b) QPSK, DVB-S rate 5/6 inner coding

   c) 8PSK, Turbo rate 2/3 inner coding

Each of these schemes has its associated bandwidth and power efficiencies as given in the
Schedule S.


Representative link budgets for all of the above schemes are provided as attachments embedded
in the Schedule S. The following notes provide additional explanation of these link budgets:


                                               4


    •   Each link budget table is for one of the three modulation/coding schemes listed above.8

    •   There are multiple columns in each table showing different example link budgets in the
        various downlink beams (three for CONUS and one for each of the four non-CONUS
        beams).

    •   Each column shows the link performance under both clear sky and rain-faded downlink
        conditions.

    •   The uplink is operated with both UPC (Uplink Power Control) at the feeder link earth
        station and satellite ALC (Automatic Level Control), so the effects of any uplink rain fade
        are minimized. Also, the link budgets are all shown for the case of an uplink from the
        Cheyenne feeder link earth station, as the results for the other possible uplink beams and
        uplink sites are approximately the same. The reason for this is that the satellite G/T is
        designed to be approximately 8 dB/K and the operating flux density (for the same
        transponder gain setting) is designed to be approximately -86 dBW/m2 towards all the
        candidate uplink sites in the different satellite receive beams.

    •   Each satellite TWTA transmits several distinct RF channels and therefore always operates
        in a multi-carrier, linear, backed-off mode, and never at saturation. This allows some
        adjustment of beam downlink EIRP by varying the uplink drive level on a channel,
        although the maximum EIRP level for each downlink beam given in the associated
        Schedule S submission will not be exceeded.                   The link budgets therefore show
        representative EIRP levels as currently foreseen for the operation of the satellite in the
        various downlink beams operating in different rain climatic zones in CONUS, with
        examples of downlinks in the states of Florida, New York and California within CONUS.
        Similar examples are given for the non-CONUS downlink spot beams.

    •   The link budgets include a significant intra-system C/I allowance of between 11 and 14
        dB for the CONUS downlinks, which reflects the relatively high levels of intra-system




8
    The QPSK emissions have an occupied bandwidth of 24.0 MHz. The 8PSK emission has an occupied
    bandwidth of 25.8 MHz, which can be accommodated within the useful bandwidth of the channel filters.

                                                       5


          interference arising from the spatial frequency reuse as well as interference from other
          sources, including other adjacent DBS satellite networks.     The exact C/I value varies
          from beam to beam and for the different locations within the service area of a beam.

      •   Subscriber earth terminals with effective antenna diameters in the range 45 cm (~18
          inches) to 60 cm (~24 inches) are shown in the representative link budgets. In practice,
          terminals anywhere within this range, or larger (up to 90 cm effective antenna diameter),
          may be used.


A.5       TT&C Characteristics
          (§25.114(c)(4)(i) and §25.114(c)(9))


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


The ECHOSTAR-10 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 uplink and downlink frequency ranges during all phases of the
mission.


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 and transmitted via an Earth-coverage horn antenna on the Earth (+Z) face of the
spacecraft.


A summary of the TT&C subsystem characteristics is given in Table A5-1.


                         Table A5-1: TT&C Performance Characteristics
   Command Modulation                                                 PCM/FSK

                                                                    17,304.0 MHz
   Command/Ranging Frequencies
                                                                    17,306.0 MHz


                                                  6


   Uplink Flux Density                                                Between -80 and -60 dBW/m2

                                                              Pseudo-omni antenna during transfer orbit and on-
   Satellite Receive Antenna Types                            station emergencies;
                                                              Earth coverage horn antenna during on-normal on-
                                                              station mode.

   Polarization of Satellite Receive Antennas                 HP for pseudo-omni antenna;
                                                              VP for Earth-coverage horn antenna.
   Peak Deviation (Command/Ranging)                                             ± 400 kHz

                                                                              12,201.0 MHz
   Telemetry/Ranging Frequencies                                              12,696.5 MHz
                                                                              12,699.5 MHz
                                                              Pseudo-omni antenna during transfer orbit and on-
   Satellite Transmit Antenna Types                           station emergencies;
                                                              Earth coverage horn antenna during on-normal on-
                                                              station operations.
   Polarization of Satellite Transmit Antennas                              VP for all antennas

   Maximum Downlink EIRP                                      13 dBW (pseudo-omni antenna);
                                                              27 dBW (Earth-coverage horn antenna).
   Telemetry/Ranging Modulation Index:
         1 sub-carrier                                                              1.0
         2 sub-carriers                                                             0.7
         3 sub-carriers                                                             0.6

A.6     Satellite Transponder Frequency Responses
        (§25.114(c)(4)(vii))


The predicted worst case receive and transmit channel filter response performance is given in
Table A6-1 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.


               Table A.6-1 - Typical Receiver and Transmitter Filter Responses

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

                              Receive            Transmit

          CF±5 MHz              0.55               0.73                          In-Band

                                                          7


           CF±7 MHz          0.80          0.94        Value does not exceed these p-p values

           CF±9 MHz          1.11          1.35

           CF±11 MHz                       2.73

           CF±12 MHz         1.84          3.56

           CF±13 MHz         2.47

           CF±18 MHz         -12.00         0.0
                                                                     Out-of-Band
           CF±21 MHz         -33.00        -1.0
                                                       Attenuation is not less than these values
           CF±27 MHz         -38.00        -10.0




A.7       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.8       Interference Analyses
          (§25.114(d)(13))


The analyses of the proposed ECHOSTAR-10 satellite network with respect to the limits in
Annex 1 to Appendices 30 and 30A are given in Appendices 1 and 2 to this document. The
results of these analyses are discussed below.


Appendix 1 shows that the proposed ECHOSTAR-10 satellite network meets the ITU criteria in
Annex 1 to Appendix 30, and so no coordination is required, except for the following cases:


      •   The MSPACE analysis results with respect to non-U.S. networks are given in Section 2
          and Annex 1 of Appendix 1. The only affected foreign administrations are Argentina,
          Canada, France, the United Kingdom, the Netherlands and Mexico. None of the OEPM

                                                   8


          degradations are more than 1.0 dB greater than the allowed 0.25 dB except for the United
          Kingdom and the Netherlands filings at 105.5°W and 114°W respectively.          These two
          filings would be expected to produce such results due to their close orbital separation
          from the U.S. 110°W orbital location. Regarding the cases where the OEPM exceedence
          is less than 1 dB it is likely that the agreement of the affected Administrations can be
          achieved, if necessary, through coordination.


      •   Section 4 of Appendix 1 indicates a minor pfd exceedence of the Alaska beam over a
          small part of Russian territory. This is often a problem with U.S. DBS satellites due to
          the geometry of the look angles to Alaska. It is likely that the agreement of Russia can be
          obtained if necessary through coordination.


Appendix 2 shows that the proposed ECHOSTAR-10 satellite network meets all of the ITU
criteria in Annex 1 to Appendix 30A.


The closest adjacent U.S. licensed DBS satellites to the 110°W.L. orbital position are 9° away at
119°W.L. and 101°W.L.. This wide orbital spacing ensures that interference into these networks
will not be a problem. In this regard it should be noted that the highest spot beam peak EIRP of
the ECHOSTAR-10 satellite is 63.9 dB, which is only 1.7 dB higher than the ECHOSTAR-8
satellite that is currently operational at the 110°W.L. orbital position.


A.9       ITU Filing for ECHOSTAR-10
          (§25.114(d)(13))


All materials related to the ITU filing for ECHOSTAR-10 (to be filed as “USABSS-26” network
name) are attached to this application. These consist of the following:

      •   SpaceCap database file (USABSS-26.mdb) containing the data required by the ITU as
          stated in Appendix 4 of the Radio Regulations.

      •   Contour data files in .gxt format for all transmit and receive beams to be filed, including
          both co-polar and cross-polar.      These are combined into a single database file
          (BSS26GXT.mdb) that can be read by ITU software (e.g., GIMS and MSPACE).
                                                   9


   •   Diagrams of the gain towards the geostationary orbit in .gxt format for receive beams to be
       filed. These are combined into a single database file (BSS26GSO.mdb) that can be read by
       ITU software (e.g., GIMS).

   •   Description in WORD document format of the various service areas (BSS26_SA.doc).

A.10    Orbital Debris Mitigation Plan
        (§25.114(d)(14))


EchoStar has assessed and limited the amount of debris released during normal operations. The
satellite was designed to minimize debris generated after separation from the launch vehicle and
to cause no debris during normal on-station operations. All pyrotechnic devices onboard the
satellite have been designed to retain all physical debris. With its satellite contractor, EchoStar
assessed and limited the probability of the space station becoming a source of debris by collisions
with small debris or meteoroids smaller than one centimeter in diameter that could cause loss of
control and prevent post-mission disposal. The possibility of collisions with small debris and
meteoroids was taken into account as part of the satellite design. EchoStar has taken steps to
limit the effects of such collisions through the use of shielding, the placement of components,
and the use of redundant systems. In addition, all sources of stored energy are located within the
body of the spacecraft, thereby providing protection from small orbital debris.


EchoStar has assessed and limited the probability of accidental explosions during and after
completion of mission operations. The satellite was designed to ensure that debris generation
does not result from the conversion of energy sources on board the satellite into energy that
fragments the satellite.   The propulsion subsystem pressure vessels have been designed to
provide high safety margins. EchoStar and its satellite manufacturer, Lockheed Martin, have
limited the probability of accidental explosions during mission operations by means of a failure
mode verification analysis. All pressures, including those of the batteries, will be monitored by
telemetry. At end-of-life and once the satellite has been placed into its final disposal orbit, all
on-board sources of stored energy will be depleted, the batteries will be discharged and all fuel
line valves will be left opened.



                                                10


In considering current and planned satellites that may have a station-keeping volume that
overlaps the ECHOSTAR-10 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, non-
USA networks for which a request for coordination has been submitted to the ITU in the vicinity
of 110°W.L. have also been reviewed. Only those networks that either operate, or are planned to
operate, and have an overlapping station-keeping volume with the ECHOSTAR-10 satellite, have
been taken into account in the analysis. For purposes of calculating potential station-keeping
volume overlap, US satellites have been assumed to have a maximum east-west excursion of
±0.05° from their nominal location, while non-US satellite networks have been assumed to have
a maximum excursion of ±0.1° from their nominal location.


Currently there are four operational US licensed satellites within ±0.5° of 110°W.L. These are as
follows:


   •   DIRECTV 6 satellite at 109.5°W.L., launched in 1997.

   •   ECHOSTAR 6 satellite at 110.2°W.L., launched in 2000.

   •   ECHOSTAR 8 satellite at 110.0°W.L., launched in 2002.

   •   DIRECTV 5 satellite at 109.8°W.L., launched in 2002.

None of these satellites in their current locations have overlapping station-keeping volumes with
respect to the 110.0°W.L. orbital position.


When the ECHOSTAR-10 satellite is launched it will be located at 110.0°W.L.


The only non-US ITU filing with a station-keeping volume that would overlap that of
ECHOSTAR-10 is a UK filed network on behalf of Intelsat (INTELSAT V-B 250E) at 110°W.L.
We can find no evidence that this satellite is under construction or scheduled to be launched.
EchoStar will continue to monitor this situation and contact Intelsat if plans for the INTELSAT
V-B 250E satellite are progressed. EchoStar will ensure that all necessary physical coordination
with Intelsat takes place to ensure there is no risk of collision between the proposed
ECHOSTAR-10 and INTELSAT V-B 250E satellites.

                                               11


EchoStar therefore concludes that physical coordination of the ECHOSTAR-10 satellite is
currently required only with respect to the current operations of EchoStar and DIRECTV in the
close proximity of the 110°W.L. orbital position. EchoStar already coordinates in this way with
DIRECTV for the current fleets of satellites and will continue to do so with respect to the
introduction of ECHOSTAR-10.


At the end of the operational life of the EchoStar-10 satellite, EchoStar will maneuver the
satellite to a disposal orbit with a minimum perigee of 330 km above the normal GSO
operational orbit, which is higher than the minimum derived from the calculation required in
§25.283:

       Solar array area = 74 m2
       Satellite body area (oriented for max antenna exposure) = 6 m2
       Uplink/Downlink antenna area = 20 m2
       Total Solar Pressure Area “A” = 100 m2
       “M” = Dry Mass of Satellite = 2165 kg
       “CR” = Solar Pressure Radiation Coefficient (worst case) = 2


Therefore the Minimum Disposal Orbit Perigee Altitude:

               =       36,021 km + 1000 x CR x A/m
               =       36,021 km + 1000 x 2 x 100/2165
               =       36,113.38 km
               =       327 km above GSO (35,786 km)

Adequate margin has already been accounted for in the calculation of the designed disposal orbit
of 330 km, which includes margin relative to the above calculation.          This will require
approximately 14 kg of propellant that will be reserved, taking account of all fuel measurement
uncertainties, to perform the final orbit raising maneuvers.




                                                 12


A.11        Waivers Requested


A.11.1 Cross-Polar Isolation of the Satellite Antennas
            (§25.210(i) and §25.215)


Section S7 of the associated Schedule S submission states that the minimum cross-polar isolation
is in the range 24.6 to 29.7 dB for the satellite receive antennas and in the range 28.3 to 30.0 dB
for the satellite transmit antennas.9 This is less than the 30 dB requirement stated in §25.210(i)
(for the FSS) and §25.215 (for the BSS). However, this is not a problem for the following
reasons:

    (i)       For the ECHOSTAR-10 receive antennas the non-compliance in cross-polar isolation
              only impacts the levels of potential interference from other feeder uplinks into the
              ECHOSTAR-10 uplinks.                The non-compliance results in negligible levels of
              additional interference into ECHOSTAR-10 compared to the other link degradations,
              and this effect has already been factored into the link budgets given in the associated
              Schedule S submission.

    (ii)      The 1.7 dB shortfall in cross-polar isolation of the ECHOSTAR-10 transmit antennas
              creates an insignificant amount of additional self-interference into the ECHOSTAR-
              10 network, which has already been factored into the link budgets given in the
              associated Schedule S submission.

    (iii)     The 1.7 dB shortfall in cross-polar isolation of the ECHOSTAR-10 transmit antennas
              creates an insignificant amount of additional downlink interference to adjacent co-
              frequency DBS satellites operating 9° away in the geostationary orbit. This is because
              the overall interference isolation of adjacent satellites is dominated by the receive
              earth station antenna off-axis discrimination for co-polar signals, and the contribution
              from the cross-polar component is negligible. 28.3 dB cross-polar isolation will




9
    Note that the worst-case cross-polar isolation for the any of the transmit antennas serving U.S. territory is 28.8
    dB which is 0.5 dB higher than the minimum stated above.

                                                          13


            increase the adjacent satellite interference by approximately 0.002 dB compared to the
            case where the cross-polar isolation is 30 dB.

   (iv)     At the 110°W.L. orbital position channels 28, 30 and 32 are licensed to DIRECTV.
            These operate cross-polar to the EchoStar channels (27, 29 and 31). Therefore the 1.7
            dB shortfall in the cross-polar isolation of the ECHOSTAR-10 transmit antennas does
            have a minor impact on the cross-polar interference into these DIRECTV channels,
            but this is negligible as shown below.

            The cross-polar interference from the same or collocated satellite is dependent on the
            combined cross-polar isolation factors of the satellite transmit and the earth station
            receive antennas. The latter is likely to be in the region of 25 dB (see ITU-R Rec.
            BO.1213). This factor therefore dominates the cross-polar interference. The 1.7 dB
            shortfall in the cross-polar isolation of the ECHOSTAR-10 transmit antennas will
            therefore result in a 0.47 dB reduction in the cross-polar interference received by
            DIRECTV, and still give a C/I level in excess of 23.3 dB. This is significantly higher
            than other likely link degradation effects, including other interference sources.
            Therefore we can conclude that the 1.7 dB shortfall has negligible effect in terms of
            additional interference into channels 28, 30 and 32 of the DIRECTV satellite at the
            110°W.L. orbital position.


A.12      Additional Information Concerning Certain Data in the Associated Schedule S


A.12.1 Space Station Antenna Beam Characteristics (S7)


For all the communications downlink beams a value of 2.1 dB is assigned to parameter S7.k
(Xmit Input Losses). This value, combined with the actual Peak Gain (S7.c) and the stated Xmit
Effective Output Power (S7.l), gives the actual Xmit Max EIRP (S7.m). However, in practice
the value of the S7k parameter will vary (typically over the range 1.6 to 2.6 dB) depending on the
redundancy switching and beam configuration, and the value of 2.1 dB has been used as a mid-
range value. This simplification by using a constant value of 2.1 dB does not in any way affect
the accuracy of the important data, which is the maximum downlink EIRP per beam (S7.m).


                                                 14


This approach is further justified by the fact that each TWTA is shared between several
transponders, and operates in a multi-carrier backed-off mode, so that the individual power that
can be delivered to each spot beam (S7.l) is adjustable within certain bounds by means of varying
the uplink drive level per carrier.


A.12.2 Space Station Transponders (S10)


137 separate communications transponders are shown in the Schedule S. All of these can be
simultaneously operated with the following exceptions:

   •   Transponder ID 133 is an alternate configuration to transponder ID 011. They both use
       channel 26 to downlink in beam 46 (Alaska);

   •   Transponder IDs 134 and 135 are alternate configurations to transponder IDs 016 and
       017. They both use channels 23 and 25, respectively, to downlink in beam 47 (Hawaii);

   •   Transponder ID 136 is an alternate configuration to transponder ID 013. They both use
       channel 29 to downlink in beam 48 (Puerto Rico);

   •   Transponder ID 137 is an alternate configuration to transponder ID 012. They both use
       channel 27 to downlink in beam 48 (Cuba).


Note that this results in a maximum of 132 simultaneously active transponders. Of these, nine
transponders are transmitting the same signal to two downlink spot beams, leaving a total of 123
independent signal transmission chains.


                             ___________________________________




                                               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/_________

                                                                    Richard J. Barnett, PhD, BSc
                                                                    Telecomm Strategies Inc.
                                                                    6404 Highland Drive
                                                                    Chevy Chase, MD 20815
                                                                    (301) 656-8969




                                                  16



Document Created: 2005-12-27 15:05:08
Document Modified: 2005-12-27 15:05:08

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