Attachment reply comments

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REPLY TO COMMENTS submitted by EchoStar

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2006-02-03

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

IBFS_SATLOA2005122100267_482182

S T E P T O~EJ O H N S O N L L P ATTORNEYS AT LAW Pantelis Michalopoulos 1330 Connecticut Avenue. NW 202.429.6494 Washington, DC 20036-1795 prnichalo@steptoe.com Tel 202.429.3000 Fax 202.429.3902 steptoe.com FEE3 - 3 2006 February 3,2006 Federal Communications Commissbrr Omce of Secretary Via HAND DELIVERY Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street S.W. Washington, D.C. 20554 Re: EchoStar Satellite Operating Corporation File No. SAT-LOA-20051221-00267 (formerly SAT-MOD-20051221-00267) Dear Ms. Dortch, EchoStar Satellite Operating Corporation (“EchoStar”) hereby reports that, while the parties are still working towards an agreement, as of 1.OO pm today, there is still no agreement between EchoStar and DIRECTV Enterprises, LLC (“DIRECTV”) with respect to the operation of EchoStar 10 at 110.2” W.L. Attached is a copy of the submission made to the Commission by EchoStar yesterday. That submission sets forth certain EIRP reductions that would provide ample protection for DIRECTV- 5. Respectfidly submitted, I - - Pantelis Michalopoulos Counselfor EchoStar Satellite Operating Corporation Attachment cc: Andrea Kelly, International Bureau Robert Nelson, International Bureau Chip Fleming, International Bureau William Wiltshire, Counselfor DIRECTV Enterprises, LLC WASHINGTON NEW Y O R K PHOENIX LOS ANCELES LONDON BRUSSELS - * . 7 I - I --*r f * - -_ - -x I _ - x 1 . - .L I-I **e- I

STEPTO E &JoH v S O N tIp A T T O R N E Y S AT LAW Pantelis Mjchalopoulos 1330 Connecticut Avenue, NW 202.429.6494 Washington. DC 20036-1795 pmic halot3steptoe.com Tel 202.429.3000 Fax 202.429.3902 steptoe.com February 2,2006 Marlene H. Donch Secretary Federal Communications Commission 445 12th Street NW Washington, DC 20554 Re: EchoStar Satellite Operating Corporation, Reply to Comments Filed by DIRECTV - Enterprises, LLC File No. SAT-LOA-20051221-00267 (formerly SAT-MOD-20051221- 00267) Dear Ms.Dortch: On January 30,2006, Echostar Satellite Operating Corporation (“EchoStar”) filed a response to comments fiIed by DIRECTV Enterprises, LLC with respect to the above referenced file number.’ At the time of the filing, EchoStar refrained from including a full technical analysis of DIRECTV’s interference concerns in the hope that negotiations between EchoStar and DTRECTV would obviate the need for such an analysis. To date, those negotiations have not borne fruit, however. Accordingly, EchoStar hereby submits a more complete analysis of DIRECTV’s claims of potential interference. Moreover, while EchoStar remains hopeful that agreement will be reached by tomorrow, failure to reach agreement cannot be entirely foreclosed at this point. For that event, EchoStar also submits a reasonable proposal to limit the power of the EchoStar 10 satellite’s frequencies 27,29, and 3 1 on certain beams. That proposal would amply protect DIRECTV’s operations at 110” W.L. ’Reply Comments of EchoStar Satellite Operating Corporation,filed in SAT-MOD-20051221- 00267 (filed Jan. 30,2006) (“Reply Comments”).

Marlene H. Dortch February 2,2006 Page 2 In its response, EchoStar argued that, in the absence of a standard to determine acceptable cross-polar C/I levels for DIRECTV, one important criterion is what each of the DBS providers has determined it can accept for its own operations. The attached Technical Annex confirms that, “[i]n the absence o f . . . a rule it is useful to consider the typical levels of cross-polar interference that operators accept when that interference occurs within their own systems and use this as a measure of what could and should be accepted in the 110”W situation.’72Specifically, the Technical Annex concludes that: DIRECTV appears to tolerate cross-polar C/I levels as low as 16.5 dB in its CONUS downlinks at the 101”W.L orbital position; 0 EchoStar tolerates C/I levels as low as 16.3 dB from operation of the EchoStar 8 satellite, and 13.2 dB from operation of the EchoStar 10 satellite; 0 DlRECTV’s own data show that DIRECTV has allowed for C/I levels of 18.2 dB or less for the DIRECTV 5 satellite that is the subject of DIRECTV’s asserted concerns. The Technical Annex also examines another important criterion -- effect on availability. It concludes that, even taking at face value DIRECTV’s own availability objective -- 99.75%,only 5 out of 18 “offending” EchoStar 10 beams result in link availabilities for DIRECTV 5 below that objective.3 In two of those five cases, the availability for DIRECTV 5 is already below DIRECTV’s 99.75% objective without taking into account any effect from EchoStar 10 whatsoever. Finally, the Technical Annex points out that DIRECTV’s stated EbNo requirement of 7 dB is unduly conservative, and could be improved by between 1 and 2 dB for a typical QPSK rate 6/7 transmission as currently used by DIRECTVe4 This improvement would result in availability percentages that are significantly higher still, even taking into account the effect of all of EchoStar 10’s beams. In any event, to advance a reasonable resolution of these issues, EchoStar proposes certain power reduction measures that would further ameliorate DIRECTV’s already tenuous interference concerns. In particular, the proposed ElRP reductions would ensure that the resulting availability for DIRECTV 5 is above 99.75% (except, of course, in those cases where it was below that percentage already) even accepting DIRECTV’s overly conservative EbMo requirement of 7dB. Technical Annex at 2. Id. at 2-3. 4 Id. at 16.

Marlene H. Dortch February 2,2006 Page 3 Please contact me if you have any questions. Respectfully yours, Pantelis Michalopoulos Counselfor EchoStar Satellite Operating Corporation Enclosures cc: Andrea Kelly, International Bureau Robert Nelson, International Bureau Chip Fleming, International Bureau William M. W iltshire, Counsel for DIRECTV Enterprises, LLC

Technical Annex 1. Introduction and Backwound This Technical Annex has been prepared on behalf of EchoStar Satellite L.L.C. (“EchoStar”) in response to the Comments of DIRECTV Enterprises L.L.C. (“DIRECTV”) concerning the levels of cross-polar interference that will be caused by the EchoStar 10 satellite into DIRECTV’s closely spaced satellites in the vicinity of 1 1O”W. The EchoStar 10 satellite is a high power, high spectral efficiency spot beam satellite that provides a massive amount of local-into-local broadcasting capacity to the US consumer, as explained in the FCC application. Spot beam satellites of this type must operate at relatively high downlink ElRP levels in order to overcome the high levels of intra-system interference generated by the large number of geographically separated co-frequency spot bcam downlinks. However, spot beam satellites of this type only operate on a subsct of the DBS channels at a particular orbital location, and typically the remaining DBS channels at the same orbital location are used with CONUS coverage beams. Therefore, inevitably, there is a high level of intra-system interference caused by the spot beam downlink transmissions into the collocated cross-polar CONUS transmissions. Normally, the channels in both polarizations in this scenario are under the control of the same operator, who will elect to tolerate the relativety high self-interference levels. However, there is a unique situation at the 1 lOoW orbital position, where EchoStar and DIRECTV are each licenscd to use tkequencies on three channels that are partly co-fiequency but crosspolar with each other, leaving only the polarization discrimination to provide the necessary interference isolation. In this case, the normal trade-off between the performance of the spot beam satellite and the interference into the CONUS downlinks does not come under the control of a single entity. So, in this case, DIRECTV is objecting to a level of cross-polar interference that would normally be accepted if it wcre “intra-systcm” interference, but because the interference arises from an EchoStar satellite, DIRECTV claims that it is not acceptable. 1

Because of the unique licensing situation at 110"W there is no FCC rule regarding the appropriate level of cross-polar interference from collocated satellite downlinks. In the absence of such a rule it is useful to consider the typical levels of cross-polar interference that operators accept when that interference occurs within their own systems and use this as a measure of what could and should be accepted in the 1 1 OoW situation. In this technical annex we explore several examples of this, as follows: At the 101OW orbital position, DIRECTV operates the D4S spot beam satellite on channels that are cross-polar with CONUS downlink transmissions from its D8 satellite. In sum, DlRECW appears to tolerate cross-polar C/I levels as low as 16.5 dB in its CONUS downlinks at the 101OW orbital position. This is addressed in Section 2 below. 0 At the 110"W orbital position, EchoStar operates both spot beam satellites (including EchoStar 10 in the future) on channels that are cross-polar with CONUS downlink transmissions from its EchoStar 8 satellite. In sum, EchoStar tolerates C/I levels as low as 16.3 dB from operation of the EchoStar 8 satellite, and 13.2 dB from operation of the EchoStar 10 satellite. This is addressed in Section 3 below. 0 The DIRECTV satellite that would be affected by EchoStar 10 at the 1 1 OoW orbital position is D5. Although actually designed for use at the 110"W orbital position, this satellite was originally deployed by DIRECTV at the 119OW orbital position in 2000, and subsequently was relocited to llOoWin 2005. In its May 2000 FCC application for this satellite, DIRECTV provides specific data concerning the cross-polar C/I allowance. DIRECTV's own data show that DIRECTV has allowed for C/I levels of 18.2 dB or less. This is addressed in Section 4 below. Another approach to assessing the acceptable interference levels is to consider the resulting availability of the affected DIRECTV satellite downlinks. The conclusions 2

From this analysis are stark. Even taking at face value DIRECTV’s own availability objective, only five out of I8 potentially interfering EchoStar 10 beams result in link avajlabiljties for D5 below that objective. In two of the five cases, the results for D5 are already below that objective using the baseline assumption in DIRECTV’s link budgets and without any additional effect fiom EchoStar 10. This is explored in Section 5 of this technical annex. Section 6 includes proposals for reductions in certain EchoStar 10 spot beam EIRP levels to mitigate the interference into DIRECTV’s D5 satellite. Thcse reductions in EIRP are based on the dual considerations of the DIRECTV link performance and the impact on the Echostar-I 0 service capability. 2. DIRECTV’s Self-Interference from its Spot Beam Satellite at 10loW The analysis of the cross-polar self-interference that DIRECTV experiences at the 101OW orbital position is summarized in Table 2-1 below, bascd on DIRECTV’s FCC and ITU filings at this orbital location. The victim channels are assumed to be operating in a D8 CONUS downlink beam. The cross-polar interference sources consist of a spot beam downlink on the D4S satellite in approximately half the channel and a CONUS downlink on the D8 satellite in approximately the other half of the channel.’ The cross-polar guard band is correctly accounted for. Each row of the table represents the situation at each D4S spot beam peak, and accurately takes account of the D8 CONUS EIRP at that geographic location. For some spot beams there are several rows bccause different EIRP levels are used in different channels in the D5 satellite. The receive earth station cross- polar discrimination (“XPD”) is assumed to bc 22 dB. Thc resulting total cross-polar C/I values are given in the right-most column of Table 2-1, and range fiom 16.5 dB to 23.1 dB . Based on this analysis we conclude that DIRECTV tolerates cross-polar C/I levels as low I This mixed CONUS+Spot interference situation exists because DIRECTV does not operate spot beams on adjacent channels at this orbital location as can be determined from the spot beam channels given in Table 2- 1. 3

as 16.5 dB in its CONUS downlinks at the lOloW orbital position. 4

Table 2-1 - DIRECTV Self-Interference from its Spot Beam Satellite at lOloW from D4S CONUS I 5 i

3. Echostar's Self-Interferencefrom its Spot Beam Satellites at llOoW and 119OW The analysis of the cross-polar self-interference that EchoStar experiences at the 1 10°W and 119OW orbital positions is summarized in Tables 3-1,3-2 and 3-3 below. Table 3-1 shows the current situation at 119"W wherc the EchoStar 7 spot beams operate cross polar to thc EchoStar 7 CONUS beam. The analysis is similar to that described in Section 2 above. Note the different "Bandwidth Advantage" factors account for the situations where there is partial or full (allowing for the guard band) overlap between the spot and CONUS channels. The resulting total cross-polar C/I values are given in the right-most column of Table 3-1, and range from 14.6 dB to 20.2 dB in CONUS with a lower value in Alaska. Table 3-2 shows the current situation at 1 lOoW where the EchoStar 8 spot beams operate cross polar to the EchoStar 8 CONUS beam. The analysis is identical to that described above for EchoStar 7 at 1 19OW. The resulting total cross-polar C/I values are given in the right-most column of Table 3-2, and range from 16.3 dB to 21.4 dB in CONUS with lower values in Alaska and Puerto Rico. Table 3-3 shows the imminent situation at 1 10"W when the EchoStar 10 spot beams will be operating cross polar to the EchoStar 8 CONUS beam. The analysis is very similar to that described above for EchoStar 7 and -8, except only the worst case interference for each EchoStar 10 spot beam is shown. The resulting total cross-polar C/I values are given in the right-most column of Tablc 3-3, and range from 13.2 dB to 19.4 dB in CONUS with lower values in Alaska and Hawaii. 6

Table 3-1 - EchoStar Self-Interference from EchoStar 7 Spot Beams into EchoStar 7 CONUS beam at 119"W 56.0 I 5.4 I 1.05 I 17.7 I I 17.7 E7-15 IMiami- West Palm Beach 160.71 1 1 3 I I 22.0 I 54.7 1 6.0 I 1.05 1 17.1 1 I 17.1 Table 3-2 - EchoStar Self-Interference from EchoStar 8 Spot Beams into EchoStar 8 CONUS beam at 1 1OoW 7

Table 3-3 - EchoStar Self-Interference from EchoStar 10 Spot Beams into EchoStar 8 CONUS beam at llOoW = Double ad& XPND 24 = DwMe sded XPND 19 = single sided E8 8

4. DIRECTV D5 Link Budget Allowance for Cross-Polar Interference The DIRECTV satellite that would be affected by EchoStar 10 at the 1 1OoW orbital position is D5. This satellite was originally designcd to operate at the I1O"W orbital position, but was actually deployed first by DIRECTV at the 1 19"W orbital position in 2000, and subscquently was relocated to 110"W in 2005. In its May 2000 FCC application for this satellite, DIRECTV provides specific data concerning the cross-polar C/I allowance. Table 2 of Appendix A of DIRECTV's May 5,2000 FCC application provides the link budget for the satellite, and is reproduced as Appendix 1 to this document. In this DIRECTV liilk budget there is an allowance for an item referred to as "crosspol interference", and which is quite separate from adjacent satellite interference which is a separate line item in the link budget. This parameter is given values ranging from 17.1 dB to 18.9 dB, with a value of 18.2 dB assigned for the critical case of a downlink rain fade. From this it can be inferred that DIRECTV's operations using the D5 satellite allow for cross-polar interfcrencc levels at least down to a C/I of 18.2 dB. 5. Assessment of Interference in Terms of Impact on Link Availability Additional insight can be obtained into the levels of cross-polar C/l that can be tolerated by DIRECTV by examining the service availability of the D5 downlinks. To ensure the most accurate results we have used DIRECTV's own link budget for D5, as referred to in Section 4 The results are given in Table 5-1, where a pair of columns in the table relates to each of the 18 EchoStar 10 CONUS beams that overlap the DIRECTV licensed channels at I IOOW. Each of thesc beams is labelled in terms of its approximate geographic area and its beam number (e.g.,"Central FL Bcam I"). Thesc beam numbers can be directly rclated to the transmit beam numbers in the EchoStar 10 FCC application. 2 EchoStar considers that this link budget is extremely conservative in that it uses an Eb/No objective of 7 dB,which is approximately 2 dB higher than a typical QPSK, rate 617 transmission requires. 9

For each pair of columns the left hand one provides the reference link budget according to the D5 FCC application (with a C/I allowance for cross-polar interference of 18.2 dB), appropriately modified to refer to the geographic location corresponding to the beam peak of the EchoStar 10 spot beam.3 In this reference column the link availability is calculated based on the available link margin. The right hand column of each pair provides a modified calculation of the availability with the actual C/I resulting fiom the "as-filed" EchoStar 10 satellite. For example, for the first beam the C/1 is reduced from 18.2 to 16.7 dB and the resulting link availability decreases from 99.851% to 99.841%. It should be noted that the reference DIRECTV link budget for D5 states a link availability objective of 99.75%. Therefore, in this example of interference from EchoStar 10 beam 1, the resulting D5 link availability still exceeds the availability objective by a considerable margin. From a review of all the results in Table 5-1 the following observations can be made: 0 From the total of 18 beams, only five result in link availabilities below 99.75%. These are beams 1 1 , 15,2I , 29 and 3 1. In two of these five cases the results are already below 99.75% even in the reference link budget (i,e., without EchoStar 10 interference). 0 From the total of 18 beams, only six result in link availabilities below 99.80%. These are.beams 1 1, 15, 17,21,29 and 3 1. In four off these six cases the results are already below 99.80% even in the reference link budget (Le., without EchoStar 10 interference). 0 From the total of 18 beams, only result in link availabilities below 99.85%. These are beams 1,2, 10, 1 1 , 15, 17, 19, 21,24, 26, 29, 3 1 and 37. In nine off these 13 cases the results are already below 99.85% even in the reference link 3 Note that this analysis is worst case in that it refers to the situations only at the beam peaks of [he EchoStar 10 spot beams. The interference situation rapidly improves away from these beam peaks, and so the calculated interference level occurs only over a relatively small geographic area.

budget (ix.,without EchoStar 10 interference). From the overall results in Table 5-1 it can be concluded that the D5 satellitc downlinks are not uniformly susceptible to interference over the CONUS service area, when considered in terms of the resulting link availability. This is not surprising, and the same situation exists for all DBS satellites, because the different EIRP levels achievable with a satellite antenna across CONUS do not perfectly match the rain attenuation statistics. Therefore, regions of CONUS exist where there is effectively excess ElRP relative to the service availability requirements, and this excess ElRP provides greater robustness to interference. It is cqually important to note that Echostar's ability to improve the interference into DIRECTV's three channels at 110"W is not identical for every EchoStar 10 spot beam, because of the vagaries of the geographic shapes of the DMA service areas and their associated rain attenuation characteristics. Thcrefore, it is not appropriate to define an interference criterion for this situation solely in terms of a fixed C/I level. Rather it is necessary to consider both the availability of the DIREKTV D5 links, and the ability EchoStar has to reduce its EIRP in certain EchoStar 10 spot beams, when attempting to reach a mutually agreeable coordination situation at 1 10"W.

Table 5-1 - Assessment of EchoStar 10 Interference Impact on DKRECTV D5 Downlink Availability ID5 Link Budgets Ia Link Parameters hntral F Beam t tain Down ccordlngto NC B im 2 laln Down ccordfng to Rain Down [With aclw WDC I am 5 Rain Down Rain Down n g with pCfU8l ~ ~ r d l to CLV b i n Down ccordlng to am 9 Rain Down E X UI) c b actual with KY Be m %O lain Down lccoldingto Raln Down : w w actual FCC FCC Echo-X Cn) FCC EchwX Cfi) FCC FCC E c b X Cn) ~ p p l ~ o n rppliion w- 4ppllclUon 4pplkation IIpllnk for 05) for 0 5 ) for DS) -ror DS) F o r 051 Carrier Frequency 17.550 17,550 17.550 17.550 17.550 17.550 17.550 17.550 17,550 17.550 Transmil ElRP 77.9 77.9 77.9 77.9 77 9 77.9 77.9 77.9 77.9 77.9 Gmnd pointing bss -0.3 -0.3 0.3 -0.3 -03 -0.3 -0.3 -0.3 -0.3 -0.3 Uplink path loss -208.7 -208.7 -208.7 -208.7 -208.7 -208.7 -208.7 -208.7 -208.7 -208.7 ntmospharicloss -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 Uplink rain loss 0.0 0.o 0.0 0.0 00 0.0 0.0 0.0 0.0 0.0 satellite Grr 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 4.1 Bandwith -73.8 -73.8 -73.0 -73.8 -73.8 -73.8 -73.8 -73.8 -73.8 -73.0 BolRmann'sconstant -228.6 -228.6 -228.6 -228.6 -228.6 -228.6 -228.6 -228.6 -228.6 -228.6 I Uplink CM (thermal) hvnllnk (dB) 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 Canfer Frequency 12.200 12,200 12.200 12,200 12.200 12.200 12.200 12.200 12.200 12.200 Satellile EtRP 55 55 54 54 55 55 54 54 53 53 Darmlink path loss -205.8 -205.8 -205.8 -205.8 -205.8 -205.8 -205.8 -205.8 -205.8 -205.8 Atmospheric loss -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 -0.1 A v M H y (DTV: S9.75%) wasix 90.841% 09.830% gosoOK 09.91Bx 00.916% 09.9t8K 90.~07~ -1% 98.826% Downlink rain bss -3.972 -3.823 -3.269 -3.059 -3 971 -3.900 3.269 -2.911 -2.617 -2.479 Rain temp I-se -3.6 -3.5 -3.3 -3.2 -3.6 3.6 -3.3 -3.1 -3.0 -2.9 Rain temp increase 161.8 158.1 142.8 136.5 161.8 160.0 142.8 131.9 122.2 117.4 Ground recBivepointing loss -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 -0.3 Ground GK (45 cm antenna) 12.4 12.4 12.4 12.4 12.4 12.4 12.4 12.4 12.4 12.4 Bandwidth -73.8 -73.0 -73.8 -73.8 -73 8 -73.8 -73.8 -73.8 -73.8 -73.8 Bonunann'sconstant -228.6 -228.6 -228.6 -228.6 -228 6 -228.0 -228.6 -228.6 -228.6 -228.6 8.7 8.9 8.7 9.0 67 8.8 8.7 9.2 8.7 8.9 'otdo: Uplink UN (ltmrmal) 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 27.7 Downlmk ON (thermal) 8.7 8.9 8.7 9.0 87 8.8 8.7 9.2 8.7 8.9 Cros~polinterference Cn 18.2 16.7 18.2 16.1 18 2 17.4 16.2 15.1 18.2 16.6 Ad-1 satetlite interferencecn 21.8 21.8 21.8 21.8 21.8 21.a 21.8 21.8 21.8 21.8 Total C/(N+I) (dB) 8 .O 8.0 8 .O 8.0 80 8a 8.0 8.0 8.0 8.0 Total (EW(N+l)o (dB1 7.0 7.0 7.0 7.O 70 7.0 7.O 7.O 7.0 7.0 Required (EW(N+l)o (high mb rate) (dB) 7.0 7.0 7.0 7.0 70 7.0 7.0 7.0 7 .O 7.0 Margin (d5) 0.0 0.0 0 .o 0.0 0.0 0If 0.0 0.0 0.0 0.0 12

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6. EchoStar Proposal to Reduce Interference EchoStar has investigated ways it can reduce the interference into DIRECTV's three channels at 11O'W, by making EIRP reductions in certain of the Echostar 10 spot beams. These proposals are given in Table 6- 1 below, showing the original C/I based on the as- filed Echostar- 10 parameters, the proposed EIRP reduction in the relevant channels, the resulting improved C/I and the resulting D5 link availability. Table 6-1 - EchoStar Proposal to Reduce EIRP in Certain Echostar 10 Spot Beams Note 1: This link only achieves 99.70% availability with CII of 18.2 dB Note 2: This link only achieves 99.736% availability with CII of 18.2 dB Note 3: This link improves to 99.78% availability with more accurate satellite EIRP of 51.5 dBW Note that the resulting availability levcls in the D5 links are generally high, with six out of the 18 beams equal to or greater than 99.9%, ten out of the 18 beams equal to or greater than 99.85%, and 15 out of the 18 beams greater than 99.75%. For two of the three beams with availabilities below 99.75% it should be noted that these do not achieve the stated 99.75% availability level

even with the DIKECTV link budget assumptions, and the additional effect of the EchoStar 10 cross-polar interference is not significantly affecting this situation. For the third beam with availability less than 99.75% it is noted that the satellite EW' level used in the results given in Table 5-1 above was rounded down to the nearest integer dBW level, and in the case of this panicular beam the actual D5 EIRP is more than 0.5 dB higher. When this is accurately taken into account the availability for this case increases to 99.78%. It should also be notcd that all the availabilities results given in Table 6-1, and Table 5-1 in the previous section, are based on the statcd Eb/No requirement in the DTV links of 7 dB. Echostar believes this value is very conservative and could be improved by between 1 and 2 dB for a typical QPSK rate 617 transmission as currently used by DIRECTV.I f this factor was taken into account the availabilities calculated would be significantly higher than those shown here. 7. Conclusions The cross-polar interference mechanism at 1 1O"W that DIRECTV is referring to in its Comments is one that is normally allocated a relatively low C/I level in a system link budget (typically between 15 and 20 dB). This has been demonstrated using several independent approaches in this document (see Section 2, 3 and 4). Providing such a generous C/I allowance for this interference mechanism is necessary in order to allow the natural evolution of the DBS industry and the effective introduction of the vital capabilities offered by spot-beam satellites. Both EchoStar and DIRECTV currently operate mixed spot and CONUS beam collocated satellites and therefore readily acccpt the low CA's duc to this interference mechanism. Furthermore, both operators employ low-cost receive dishes with relatively poor cross-polar discrimination which W h e r aggravates this interference mechanism, but they readily accept the overall interference situation because it constitutes the best overall optimized way of operating a complex and evolving DBS systtm. It should also be noted that this interference is at its worst level only over a small geographic area corresponding to the center of the spot beams. The efffect of EchoStar 10 on the DIRECTV channels at 1 1O"W in all but a very small number of beams is almost inconsequential in terms of the DIRECTV link availability, 16

Nevertheless, in a spirit of cooperation EchoStar has carefully analyzed ways it can reduce its EIRP in all of the overlapping spot beams, and proposed significant reductions in Section 6 of this document. These reductions will be burdensome for EchoStar but will allow the EchoStar 10 satellite to offer the basic level of service for which it was designed. With these reductions the interference into DIRECTV should be acceptable, particularly when considered in terms of the link availabilities. Any Further reductions in the EchoStar 10 EIRP levels will significantly impact the service that the satellite can provide, yet make negligible difference to DIRECTV's operations at I 1OOW. Therefore, EchoStar urges the Commission to permit EchoStar 10 to be operated according to the reduced EIRP levels given in this document.

Appendix 1 DIRECTV Link Budget from May 5,2000 FCC Apvlication for D5 (see next page) 18

Table 2. DIRECTV 5 Link Budget - CONUS (Chicago) UPLINK w Rain Up Pain Down Transmit EIRP. dBW 77.9 90.Q 77.9 Ground pointing loss, dB -0.3 -0.3 -0.3 Uplink path loss, dB -208.7 -208.7 -208.7 Atmospheric loss, dB -0.I -0.1 a.1 Uplink rain loss, dB 0.0 -20.0 0.0 Satellite Gfl. dB/K 4. I 4. L 4. t Bandwidth, dB-Hz -73.8 -73.8 -73.8 Boltzmann's constant, dBW 228.6 228.6 228.6 Uplink CM (thermal), dB 27.7 19.8 27.7 DOWNLINK Satellite E m ,dBW 52.1 52. I 52.1 Downlink path loss, dB -205.7 -205.7 -205.7 Atmospheric loss, dB -0.1 -0.1 -0.1 Downlink rain loss, dB (99.75% avail.) 0.0 0.0 -1.9 Rain temp increase, dB 0.0 0.0 -1.8 Ground receive pointing 10%. dB -0.3 -0.3 -0.3 Ground G/T (45 cm antenna), dB/K 12.4 12.4 12.4 Bandwidth, dB-Hz -73.8 -73.8 -73.8 Bolumann's constant, dBW 228.6 228.6 228.6 Downlink C/N (thermal), dB 13.2 13.2 9.5 TOTALS Uplink C/N (thermal), dE3 27.7 19.8 27.7 Downlink C/N (thermal). dB 13.2 13.2 9.5 Crosspol interference, dB 18.9 17.1 18.2 Adjacent satellite interference,dB 21.8 21.8 21.8 Total C/(N+I), dEl 11.6 10.7 8.6 Total Eb/(N+I)o 10.6 9.7 7.6 Required Eb/(S+I)o (high info rate) 7.0 7.0 7.0 Margm. dB 3.6 2.7 0.6

CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING INFORMATION I hereby declare under penalty of perjury that I am the technically qualified person responsible for preparation of the engineering information contained in the foregoing submission, 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 pleading, and that it is true and correct to the best of my knowledge and belief. /SI Richard J. Barnett, PhD, BSc Telecomm Strategies, Inc. 6404 Highland Drive Chevy Chase, Maryland 208 15 (301) 656-8969 Dated: February 2,2006 20


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Document Modified: 2006-02-07 15:33:36
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