Attachment Narrative SAT-LOA-20100310-00043

Attachment Narrative

This document pretains to SAT-LOA-20100310-00043 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2010031000043_805332

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

)
In the Matter of )
)
ECHOSTAR CORPORATION ) File No. SAT-LOA-2010_________
)
Application for Authority to Launch the )
EchoStar 15 Satellite and for Modified )
Authority to Operate that Satellite at 61.5° W.L. )
)
)

APPLICATION FOR AUTHORITY TO LAUNCH AND
MODIFIED AUTHORITY TO OPERATE

Pursuant to Sections 308, 309 and 319 of the Communications Act of 1934, as amended,1

and Part 25 of the Commission’s rules,2 EchoStar Corporation (“EchoStar”) files this application

for authority to launch the EchoStar 15 satellite and for modified authority to operate that

satellite on the Direct Broadcast Satellite (“DBS”) channels already licensed to EchoStar at the

61.5° W.L. orbital location. EchoStar 15 will operate a single large downlink broadcast beam

encompassing the continental United States and Puerto Rico (“CONUS-plus beam”) in the 12.2-

12.7 GHz band and two uplink spot beams in the 17.3-17.8 GHz bands.3 EchoStar 15 will

specifically be located at 61.55° W.L., within the 61.5° W.L. orbital cluster.

1
47 U.S.C. §§ 308, 309, 319.
2
47 C.F.R. Part 25.
3
EchoStar will file separately a request for Special Temporary Authority to test the
satellite at 61.55º W.L. after launch and before commencement of operations.

EchoStar currently operates over all 32 DBS channels at the 61.5° W.L. orbital location.

Specifically, EchoStar holds permanent authority to operate over channels 1-22 and 25-32.4

EchoStar uses the remaining two channels, channels 23 and 24, under Special Temporary

Authority (“STA”).5 The requested authority will permit EchoStar to replace the aging EchoStar

3 satellite. It will also allow the other EchoStar satellite at 61.5° W.L., EchoStar 12, to use

virtually all of its power for spot beam service.6 This will result in more and higher quality

services for EchoStar’s customer, the DISH Network.

EchoStar will also request an extension and modification of its current STA to operate on

the two unassigned channels, as the public interest rationale for such operation will remain

strong. In addition to the required technical showings for EchoStar’s authorized channels, this

application includes all of the technical information relevant to channels 23 and 24, too.

I. INTRODUCTION

EchoStar is a leading satellite services provider. EchoStar uses its eight owned or leased

in-orbit satellites, among other things, to provide DBS and Fixed-Satellite Service capacity to its

4
Originally, channels 2-22 (even) were licensed to DBSC. Application of Direct
Broadcasting Satellite Corp., Memorandum Opinion and Order, 8 FCC Rcd. 7959 (1993). Those
11 channels were then assigned to EchoStar’s predecessor. See Application of Direct
Broadcasting Satellite Corp. for Assignment of Direct Broadcast Satellite Orbital Positions and
Channels, Order, 11 FCC Rcd. 10494 (1996). Channels 1-21 (odd) were assigned to EchoStar
by Rainbow DBS, and channels 25-32 were assigned by Dominion in 2006. See Rainbow DBS
Company, LLC, Memorandum Opinion and Order, 20 FCC Rcd. 16868 (2005); EchoStar
Satellite Operating Corporation, File No. SAT-ASG-20070608-00081 (grant stamped Sept. 27,
2007), respectively.
5
See EchoStar Satellite Operating Corporation, Order and Authorization, 22 FCC Rcd.
2223 (2007); EchoStar Corporation, File No. SAT-STA-20090821-00092 (grant stamped Dec. 3,
2009) (STA valid until March 27, 2010).
6
EchoStar has recently requested and received STA to move EchoStar 6 to 61.5º W.L.,
and has also requested operating STA for that satellite. This move is primarily intended to
“back-stop” the EchoStar 3 satellite until the arrival of EchoStar 15.

2

sister company, DISH Network Corporation (“DISH”), which is the operator of the DISH

Network television service, the nation’s third largest subscription television service with over 14

million customers.

EchoStar currently operates the EchoStar 3 and EchoStar 12 satellites in the 61.5º W.L.

orbital cluster. The EchoStar 3 satellite, launched in 1998, has experienced failures in a number

of its traveling wave tube amplifiers (“TWTA”s). This has decreased the number of

transponders available for use. The satellite is, moreover, naturally approaching the end of its

useful life. EchoStar 12, on the other hand, was designed to allow access to only 13 of the

frequencies at the 61.5 slot (specifically, frequencies 1-23 odd and 24 even). As the Commission

is aware, EchoStar had intended to replace EchoStar 3 with the AMC-14 satellite in 2008; that

satellite, however, suffered a launch failure and did not reach its intended orbit.7 As a result,

EchoStar designated EchoStar 15 as the replacement for EchoStar 3 to ensure the full utilization

of the DBS spectrum at 61.5 W.L. The satellite will be owned by DISH. DISH has agreed to

lease the satellite to EchoStar; EchoStar, in turn, will sublease the satellite capacity to DISH

while retaining control over the satellite and responsibility for the satellite’s Telemetry, Tracking

and Command functions. Consequently, EchoStar seeks authority to launch and operate the

EchoStar 15 satellite at the 61.55º W.L. orbital location as a replacement for EchoStar 3 and a

supplement to EchoStar 12.

7
See Letter from Pantelis Michalopoulos, Counsel for EchoStar Corporation, to Marlene
H. Dortch, Secretary, FCC, filed in File No. SAT-STA-20070926-00133 (Mar. 25, 2008).

3

companies. By increasing competition in the MVPD market, consumers will benefit through

greater choice, more services, and lower rates.

III. THE APPLICATION SATISFIES ALL COMMISSION RULES

The application satisfies all applicable Commission rules. In particular, because the

satellite will operate on the channels already used by EchoStar at 61.5° W.L., this application is

not subject to the “freeze” on new DBS applications currently in place.9 The technical

information for the EchoStar 15 satellite that is required to be submitted pursuant to Part 25 of

the Commission’s Rules is set forth in the accompanying technical narrative (Attachment A),

FCC Form 312, and Schedule S, all of which are incorporated into this application by reference.

IV. STATUS OF OPERATIONS

EchoStar intends to operate all the transponders on this DBS satellite on a non-broadcast,

non-common carrier basis.10 Ultimately, DISH intends to use the capacity to provide

multichannel video programming services across the United States. DISH’s services will be

offered to consumers on a subscription basis.

V. ITU COST RECOVERY

EchoStar is aware that as a result of the actions taken at the 1998 Plenipotentiary

Conference, as modified by the ITU Council in June 2001, processing fees are now charged by

the ITU for satellite network filings. As a consequence, Commission applicants are responsible

for any and all fees charged by the ITU. EchoStar affirms it is aware of, and unconditionally

accepts, this requirement and its responsibility to pay any ITU cost recovery fees for the ITU

9
See Public Notice, Direct Broadcast Satellite (DBS) Auction Nullified: Commission
Sets Forth Refund Procedures for Auction No. 52 Winning Bidders and Adopts a Freeze on All
New DBS Service Applications, FCC 05-213, at 2 (rel. Dec. 21, 2005).
10
See 47 C.F.R. §§ 25.114(c)(11), 25.114(d)(11).

5

filings associated with this application. Invoices for such fees may be sent to the contact

representative listed in the accompanying FCC Form 312.

VI. WAIVER PURSUANT TO SECTION 304 OF THE COMMUNICATIONS ACT

In accordance with Section 304 of the Communications Act of 1934, as amended,11

EchoStar waives any claim to the use of any particular frequency or of the electromagnetic

spectrum as against the regulatory power of the United States because of the previous use of the

same, whether by license or otherwise.

VII. CONCLUSION

For the foregoing reasons, EchoStar respectfully requests that the Commission promptly

grant this application for launch and operating authority for the EchoStar 15 satellite as in the

public interest, convenience and necessity.

Respectfully submitted,
EchoStar Corporation

_________/s/_____________________
Pantelis Michalopoulos Linda Kinney
Petra Vorwig Vice President, Law and Regulation
Christopher R. Bjornson EchoStar Corporation
Steptoe & Johnson LLP 1110 Vermont Avenue, NW
1330 Connecticut Avenue N.W. Suite 750
Washington, D.C. 20036 Washington, DC 20005
(202) 429-3000 (202) 293-0981

Counsel for EchoStar Corporation

March 10, 2010

11
47 U.S.C. § 304.

6

ECHOSTAR-15

ATTACHMENT A
Technical Information to Supplement Schedule S

A.1 Scope

This attachment contains the information required by §25.114(c) and other sections of the FCC
Part 25 rules that cannot be captured by the Schedule S software.

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

The ECHOSTAR-15 satellite will operate at 61.5°W.L. (specifically at 61.55º W.L., within the
61.5°W.L. ±0.2° orbital cluster and consistent with the ITU Region 2 BSS Plan) and will provide
BSS services to CONUS and Puerto Rico. A single large area coverage beam is used on the
downlink with higher gain spot beams used for the feeder uplink.

EchoStar’s plan is that the ECHOSTAR-15 satellite would initially operate together with three
other existing EchoStar satellites in the 61.5°W.L. orbital cluster. See Section A.10.3 of this
document for details of the specific positions of these EchoStar satellites.

The ECHOSTAR-15 satellite will operate 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 the
channels licensed to EchoStar at the 61.5°W.L. nominal orbital location, or, with respect to the
two unlicensed channels covered by an STA from the Commission. The transponder frequency
plan is identical to that prescribed in the ITU’s Region 2 BSS Plan.

1

At the nominal 61.5°W orbital location EchoStar is licensed for a total of 30 of the 32 available
channels.1 In addition, EchoStar has an STA from the Commission conditionally permitting
operations on the two remaining channels. Like other EchoStar satellites, the ECHOSTAR-15
satellite has been constructed with the capability to be operated at other EchoStar licensed DBS
orbital locations, to provide operational flexibility for the future. The satellite is capable of
operating on all 32 available DBS channels.2 The ECHOSTAR-15 satellite can also be
reconfigured, in orbit, to adjust its beam coverage to better optimize performance at other
possible orbital locations.3

The ECHOSTAR-15 satellite includes 84 TWTAs, each of 150 Watt saturated power capability.
When operated at the nominal 61.5°W orbital location ECHOSTAR-15 will either use up to 32
active transponders in “high power” mode (using 2 x 150 Watt TWTAs combined for each
transponder) or up to 19 active transponders in “super high power” operation (using 3 x 150
Watt TWTAs combined for each transponder), producing peak EIRP levels as high as 58.1 dBW
in super high power mode. Full frequency re-use will be achieved through the use of dual
orthogonal polarizations, within the constraints of the channels licensed to EchoStar, or operated
under STA, at 61.5°W.

EchoStar will use its two main feeder link earth station facilities with the ECHOSTAR-15
satellite. These are located in Cheyenne, WY and Gilbert, AZ.

Spacecraft TT&C functions will take place from EchoStar’s fully redundant TT&C earth station
and satellite control facilities located in Cheyenne, WY and Gilbert, AZ. The TT&C

1
EchoStar is currently licensed by the Commission at the 61.5°W orbital location for channels 1-22 and channels
25-32.
2
The associated Schedule S for ECHOSTAR-15 describes all 32 channels.
3
The associated Schedule S for ECHOSTAR-15 describes only the beam configuration to be used at the 61.5°W
orbital location, as requested in this application. In the event that the ECHOSTAR-15 satellite is to be operated
at other EchoStar licensed orbital locations in the future, the necessary details of the relevant beam
configuration and performance will be provided to the FCC as part of the application requesting such operation.

2

transmissions will take place at the edges of the 17.3-17.8 GHz uplink band and 12.2-12.7 GHz
downlink band, at all phases of the mission.

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

The ECHOSTAR-15 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.

Note that the GXT data files that form part of the ITU submission for ECHOSTAR-15 are
provided as a separate attachment to this application.

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

The ECHOSTAR-15 high powered satellite will provide a range of DBS services to millions of
small and inexpensive subscriber receive-only earth terminals.

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-15 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, and location in the coverage area. There will be millions of
3

these types of terminals across the service area. The feeder uplink earth stations (main and back-
up) will typically use a 13 meter antenna.

A.4.2 Link Budgets

The transmissions on ECHOSTAR-15 will use various modulation and FEC coding schemes.
For QPSK modulation, FEC coding schemes ranging from 3/4 to 7/8 will be used and for 8PSK
modulation, FEC coding schemes ranging from 2/3 to 3/4 will be used. Therefore the associated
Schedule S submission includes the following combinations of modulation and coding, which
bound the transmissions to be used:

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

b) QPSK, DVB-S rate 7/8 inner coding

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

d) 8PSK, Turbo rate 3/4 inner coding

Each of these schemes has its associated bandwidth and power efficiencies as given in Section
S11 of the associated Schedule S.

Representative link budgets for the above schemes, and for both high power and super high
power modes of operation, are provided as attachments embedded in the Schedule S. The
following notes provide additional explanation of these link budgets:

 Each link budget table is for one of the four modulation/coding schemes listed above, and
for either “super high power” mode or “high power” mode, making for a total of eight
link budget tables.

 There are six columns in each link budget table showing different example link budgets
for various locations in the downlink beam.

4

 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 Gilbert uplink beam and
uplink site are approximately the same.

 Subscriber earth terminals with effective antenna diameters in the range 45 cm (~18
inches) to 90 cm (~36 inches) are shown in the representative link budgets.

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-15 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 communications 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 the standard communications antennas of the satellite.

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

5

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

17,791.5 MHz
Command/Ranging Frequencies
17,793.5 MHz

Omni Rx antenna: > -83 dBW/m2 (Command)
Uplink Flux Density (Minimum) -78 dBW/m2 (Ranging)
Comms Rx antenna: > -93 dBW/m2 (Command)
-87 dBW/m2 (Ranging)
Omni antenna during transfer orbit and on-station
emergencies, and for telecommand from earth
Satellite Receive Antenna Types stations other than at Cheyenne, WY and Gilbert,
AZ.
and Modes of Operation
Communications antenna during on-normal on-
station operations for telecommand from earth
stations at Cheyenne, WY and Gilbert, AZ.

Polarization of Satellite Rx/Tx Antennas RHCP for omni antenna
RHCP for communications antenna
Peak Deviation (Command/Ranging) ± 400 kHz

12,692.0 MHz

Telemetry/Ranging Frequencies 12,693.0 MHz
12,694.5 MHz
12,698.5 MHz
Omni antenna during transfer orbit and on-station
emergencies and for telemetry to earth stations
Satellite Transmit Antenna Types other than at Cheyenne, WY and Gilbert, AZ.
and Modes of Operation Communications antenna during on-normal on-
station operations for telemetry to earth stations at
Cheyenne, WY and Gilbert, AZ.

Maximum Downlink EIRP 15.2 dBW (Omni antenna)
18 dBW (Communications antenna)
Telemetry/Ranging Modulation Index:

1 sub-carrier 1.0 ± 0.2 rad pk
2 sub-carriers 0.7± 0.2 rad pk
3 sub-carriers 0.58± 0.2 rad pk

6

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

The predicted 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 A6-1 - Typical Receiver and Transmitter Filter Responses

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

Receive Transmit

CF±6 MHz 0.15 0.10

CF±7.7 MHz 0.19 0.15
In-Band
CF±9.6 MHz 0.30 0.22
Value does not exceed these p-p values
CF±12 MHz 1.00 0.38

CF±13 MHz 2.20 0.50

CF±16.5 MHz -3.0

CF±20.0 MHz -3.0
Out-of-Band
Attenuation is not less than these values
CF±27.0 MHz -25.0

CF±29.1 MHz -30.0

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.
7

A.8 Interference Analyses
(§25.214(d)(13))

The analyses of the proposed ECHOSTAR-15 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-15 satellite network meets the ITU criteria in
Annex 1 to Appendix 30, and so no coordination is required, except with respect to certain
adjacent Region 2 BSS networks. The affected foreign administrations are Canada, the
Netherlands, Russia and the UK. The results are summarized below for each of these
administrations:

 The OEPM degradations to the affected Canadian networks are quite small (less than 0.3
dB) and so it is expected that coordination can be easily completed.

 The affected Netherlands network is 2.5 degrees away from USA BSS networks at
61.5°W, including USA Original Plan networks. The Netherlands is required to obtain
agreement from the USA before it can implement its network. It is noted that the worst-
case OEPM degradation into USA networks at 61.5°W from the Netherland’s network is
almost 10 dB, therefore successful coordination of the NSS-BSS 59 network with USA
networks is expected to be quite difficult. This network will expire within the eight-year
regulatory time period if it is not successfully coordinated, entered into the Region 2 Plan
and brought into use.

 While the UK’s INTELSAT KUEXT 304.5 at 55.5°W is theoretically affected by the
USABSS-33 network, none of the affected beams of the UK’s network has been brought
into use. The INTELSAT KUEXT 304.5 beam that has been brought into use is
unaffected by the USABSS-33 network.

8

 The UK’s USAT-S5 network at 66.3°W is deemed to be affected. This network affects
USA BSS networks at 61.5°W, including USA Original Plan networks. The UK is
required to obtain agreement from the USA before it can implement its network. It is
noted that the worst-case OEPM degradation into USA networks at 61.5°W from the
USAST-S5 network is greater than 14 dB, therefore successful coordination of the UK’s
network with USA networks is expected to be quite difficult. This network will expire
within the eight-year regulatory time period if it is not successfully coordinated, entered
into the Region 2 Plan and brought into use.

 The OEPM degradations to the affected Russian network at 47.5°W are relatively small
(less than 0.5 dB). It is expected that coordination can be achieved due to the small
OEPM degradations coupled with the fourteen-degree orbital separation between the
networks.

Appendix 2 shows that the proposed ECHOSTAR-15 satellite network meets all of the ITU
criteria in Annex 1 to Appendix 30A.

The closest operational adjacent U.S. licensed co-frequency co-polar DBS satellites to the
61.5°W.L. orbital position, other than EchoStar’s own satellites, are at the 101°W.L. orbital
cluster. Interference into these networks will not be a problem because the peak EIRP of the
ECHOSTAR-15 satellite is 58.1 dBW, which is less than the peak EIRP used in U.S. DBS
satellites employing spot beams, and comparable to the peak EIRP of other U.S. DBS CONUS
beam satellites.

A.9 ITU Filing for ECHOSTAR-15
(§25.114(d)(13))

All materials related to the ITU filing for ECHOSTAR-15 (to be filed as “USABSS-33” network
name) will be submitted separately. These consist of the following:

9

 SpaceCap database file (USABSS-33 AP30&30A.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, including both co-polar
and cross-polar; diagrams of the estimated gain towards the geostationary orbit for the
receive beams; and service area definitions. These are combined into a single database file
(USABSS-33 Beams.mdb) that can be read by ITU software (e.g., GIMS and MSPACE).

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

The ECHOSTAR-15 satellite has been designed and built by Space Systems/Loral (“Loral”)
using its FS-1300 spacecraft bus. The information provided below concerning the orbital debris
mitigation plan has therefore been provided by Loral.

A.10.1 Debris Release Assessment
(§25.144(d)(14)(i))

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 during
deployment – the only portion of the mission in which portions of the spacecraft are separated
from the main spacecraft body. 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.

Spacecraft Hardware Design: To protect the spacecraft from small body collisions, the design of
the ECHOSTAR-15 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

10

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-15
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 basically 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.10.2 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.

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,
meaning that, at the completion of orbit raising, the pressurant will be isolated from the fuel
system, thereby causing 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

11

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.10.3 Safe Flight Profiles
(§25.144(d)(14)(iii))

In considering current and planned satellites that may have a station-keeping volume that
overlaps the ECHOSTAR-15 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 61.5° 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-15 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. Also,
ECHOSTAR-15 is assumed to be located at exactly 61.55°W.L. for the purpose of this analysis.

At the time of launch of the ECHOSTAR-15 satellites it is expected that there will be three other
operational EchoStar satellites in the vicinity of 61.5° W.L., as follows 4:

 ECHOSTAR-3 at 61.45°W.L.
 ECHOSTAR-6 at 61.65°W.L.
 ECHOSTAR-12 at 61.35°W.L.

4
Subject to EchoStar separately seeking and obtaining appropriate Commission authorization for the relocation
of these other EchoStar satellites.

12

By locating the ECHOSTAR-15 satellite at 61.55°W.L., and maintaining an east-west station-
keeping tolerance of ±0.05° on all four EchoStar satellites, there will be no overlap in the
station-keeping volume of any of these satellites, and so no risk of collision.

There are no pending applications before the Commission for additional satellites to be located at
an orbital location in the immediate vicinity of 61.5°W.L. There are no FSS networks within
±0.15 degrees of 61.5°W.L.

Based on the preceding, EchoStar concludes there is no requirement to physically coordinate the
ECHOSTAR-15 satellite with another satellite operator at the present time.

A.10.4 Post Mission Disposal Plan
(§25.144(d)(14)(iv))

At the end of the operational life of the ECHOSTAR-15 satellite, EchoStar will maneuver the
satellite to a disposal orbit with a minimum perigee of 330 km above the normal GSO
operational orbit. This proposed disposal orbit altitude exceeds the minimum required by
§25.283, which is calculated below.

The input data required for the calculation is as follows:

Total Solar Pressure Area “A” = 110 m2
(includes area of solar array, satellite body and deployed antennas)
“M” = Dry Mass of Satellite = 2479 kg
“CR” = Solar Pressure Radiation Coefficient (worst case) = 2

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

= 36,021 km + 1000 x CR x A/M
= 36,021 km + 1000 x 2 x 110/2479

13

= 36,110 km
= 324 km above GSO (35,786 km)

Adequate margin has already been accounted for in the calculation of the designed disposal orbit
of 330 km above GSO, which includes margin relative to the above calculation. Attaining the
altitude of 330 km above the GSO orbit will require approximately 15.6 kg of propellant, which
will be reserved, taking account of all fuel measurement uncertainties, to perform the final orbit
raising maneuvers.

A.11 Additional Information Concerning Certain Data in the Associated Schedule S

Owing to limitations in the permitted data for certain fields in the Schedule S software, it has not
been possible to enter the correct values in a small number of cases, as follows:

 In S7 (Space Station Antenna Beam Characteristics), column “n”, the Schedule S
software does not accept a noise temperature higher than approximately 32,000K, and so
this value has been entered in the Schedule S. For beams TCOS1 and TCOS2, because
of the input attenuator, the correct value for T is 63,096K.

 In S7 (Space Station Antenna Beam Characteristics) of the Schedule S there is a 4th row
entry that is not required (beam called “NA”). Owing to a glitch in the Schedule S
software, it is not possible to delete this row.

___________________________________

14

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

March 10, 2010

15

Appendix 1 to
Attachment A (Technical Information to Supplement Schedule S)
(ECHOSTAR-15)

Analysis of ANNEX 1 of Appendix 30
for USABSS-33

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

Does not apply to the Region 2 Plan.

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

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

The MSPACE analysis was performed utilizing the Region 2 BSS Plan as contained in
IFIC 2661. The results of the analysis for foreign networks are contained in Annex 1 to
this Appendix. As shown the affected foreign administrations are Canada, the
Netherlands, Russia and the UK. The results are summarized below for each of these
administrations:
 The OEPM degradations to the affected Canadian networks are quite small (less
than 0.3 dB) and so it is expected that coordination can be easily completed.
 The affected Netherlands network is 2.5 degrees away from USA BSS networks
at 61.5°W, including USA Original Plan networks. The Netherlands is required
to obtain agreement from the USA before it can implement its network. It is

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

Page A1-1 of A1-8

noted that the worst-case OEPM degradation into USA networks at 61.5°W from
the Netherland’s network is almost 10 dB, therefore successful coordination of the
NSS-BSS 59 network with USA networks is expected to be quite difficult. This
network will expire within the 8-year regulatory time period if it is not
successfully coordinated, entered into the Region 2 Plan and brought into use.
 The UK’s INTELSAT KUEXT 304.5 at 55.5°W is affected by the USABSS-33
network. None of the affected beams of the UK’s network have been brought into
use. The INTELSAT KUEXT 304.5 beam that has been brought into use is
unaffected by the USABSS-33 network.
 The UK’s USAT-S5 network at 66.3°W is deemed to be affected. This network
affects USA BSS networks at 61.5°W, including USA Original Plan networks.
The UK is required to obtain agreement from the USA before it can implement its
network. It is noted that the worst-case OEPM degradation into USA networks at
61.5°W from the USAST-S5 network is greater than 14 dB, therefore successful
coordination of the UK’s network with USA networks is expected to be quite
difficult. This network will expire within the 8-year regulatory time period if it is
not successfully coordinated, entered into the Region 2 Plan and brought into use.
 The OEPM degradations to the affected Russian network at 47.5°W are relatively
small (less than 0.5 dB). It is expected that coordination can be achieved due to
the small OEPM degradations coupled with the fourteen-degree orbital separation
between the networks.

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

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

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

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

Page A1-2 of A1-8

The closest Regions 1 and 3 BSS network is the Russian INTERSPUTNIK-47.5W-B
network at 47.5°W, which is greater tha 10.57 degrees from the USABSS-33 network,
therefore the –103.6 dB(W/(m2 . 27 MHz)) PFD level applies for this network and all
other Regions 1 and 3 networks. The GIMs Appendix 30 pfd tool was used to assess
compliance with this Section. Using the antenna gain contours and power levels of the
beams the GIMS pfd tool showed that no administrations are affected. Therefore the
USABSS-33 network is compliant with this Section.

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

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

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

–148 dB(W/(m2  4 kHz)) for   5°

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

–138 dB(W/(m2  4 kHz)) for 25° <   90°
where represents the angle of arrival. (WRC-03)

The GIMS pfd tool was used to determine the administrations whose terrestrial services
may be affected by the USABSS-33 modification to the Region 2 Plan. Using this tool,
the results show that the pfd limit is exceeded in Canada only. However, 4.2.3 d) of
Article 4 of Appendix 30 states that the above pfd limits apply to countries not having
frequency assignments in the broadcasting-satellite service in the channel concerned.
Since Canada is assigned all 32 channels in the Plan, and therefore will not be deploying
co-frequency terrestrial services, these limits do not need to be met on its territory.

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

Page A1-3 of A1-8

5 (Not used.)

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

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

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

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

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

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

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

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

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

The USABSS-33 network causes lower PFD levels over all territories in Regions 1 and 3
than those caused by USA Original Plan networks at 61.5°W and therefore the network is
compliant with this Section.

32 Including assignments operating under No. 5.485.

Page A1-4 of A1-8

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

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

using the method of Appendix 8 (Case II). (WRC-03)

From a review of the available ITU space network databases there are no assignments
registered in the Earth-to-space direction in the frequency band 12.5-12.7 GHz.
Therefore no Region 1 space station can be affected and the USABSS-33 network is
compliant with this Section.

Page A1-5 of A1-8

Annex 1 to Appendix 1 to Technical Annex

ECHOSTAR-15

MSPACE Results

Orbital
Max. EPM
Adm. Position Beam
Sat.Network Id. Affected Channels Degradation
Symbol (degrees Name
(dB)
E)
CAN -129.00 CAN-BSS4 00010028 2,4,6,8,10,12,14,16 0.262
CAN -72.70 CAN-BSS3 00008452 2,4,6,8,10,12,14,16 0.265
G -66.30 USAT-S5 00009466 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.952
G -66.30 USAT-S5 00009467 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.138
G -66.30 USAT-S5 00009468 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.445
G -66.30 USAT-S5 00009469 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.711
G -66.30 USAT-S5 00009470 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.952
G -66.30 USAT-S5 00009471 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.138
G -66.30 USAT-S5 00009472 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.446
G -66.30 USAT-S5 00009473 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.712
G -66.30 USAT-S5 00009474 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.952
G -66.30 USAT-S5 00009475 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.137
G -66.30 USAT-S5 00009476 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.445
G -66.30 USAT-S5 00009477 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.713
G -66.30 USAT-S5 00009478 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.043
G -66.30 USAT-S5 00009479 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.205
G -66.30 USAT-S5 00009480 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.482
G -66.30 USAT-S5 00009481 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.602
G -66.30 USAT-S5 00009482 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.043
G -66.30 USAT-S5 00009483 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.204
G -66.30 USAT-S5 00009484 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.482
G -66.30 USAT-S5 00009485 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.603
G -66.30 USAT-S5 00009486 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.043
G -66.30 USAT-S5 00009487 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.205
G -66.30 USAT-S5 00009488 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.481
G -66.30 USAT-S5 00009489 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.604
G -66.30 USAT-S5 00009490 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.619
G -66.30 USAT-S5 00009491 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.725
G -66.30 USAT-S5 00009492 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.949
G -66.30 USAT-S5 00009493 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.725
G -66.30 USAT-S5 00009494 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.619
G -66.30 USAT-S5 00009495 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.726
G -66.30 USAT-S5 00009496 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.949

Page A1-6 of A1-8

G -66.30 USAT-S5 00009497 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.725
G -66.30 USAT-S5 00009498 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.620
G -66.30 USAT-S5 00009499 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.726
G -66.30 USAT-S5 00009500 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.949
G -66.30 USAT-S5 00009501 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.724
G -66.30 USAT-S5 00009502 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.610
G -66.30 USAT-S5 00009503 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.718
G -66.30 USAT-S5 00009504 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.869
G -66.30 USAT-S5 00009505 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.652
G -66.30 USAT-S5 00009506 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.610
G -66.30 USAT-S5 00009507 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.718
G -66.30 USAT-S5 00009508 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.869
G -66.30 USAT-S5 00009509 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.651
G -66.30 USAT-S5 00009510 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.610
G -66.30 USAT-S5 00009511 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.718
G -66.30 USAT-S5 00009512 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.869
G -66.30 USAT-S5 00009513 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 0.651
INTELSAT
G -55.50 10010450 22,24,26,28,30 0.302
KUEXT 304.5
INTELSAT
G -55.50 10010451 21,23,25,27,29,31 0.400
KUEXT 304.5
INTELSAT
G -55.50 10010452 22,24,26,28,30,32 0.460
KUEXT 304.5
INTELSAT
G -55.50 10010453 21,23,25,27,29,31 0.703
KUEXT 304.5
INTELSAT
G -55.50 10010456 22,24,26,28,30,32 0.730
KUEXT 304.5
INTELSAT
G -55.50 10010457 21,23,25,27,29,31 1.641
KUEXT 304.5
INTELSAT
G -55.50 10010460 22,24,26,28,30 0.394
KUEXT 304.5
INTELSAT
G -55.50 10010461 21,23,25,27,29,31 0.477
KUEXT 304.5
HOL -59.00 NSS-BSS 59W 10010548 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.236
HOL -59.00 NSS-BSS 59W 10010549 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.665
HOL -59.00 NSS-BSS 59W 10010552 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.236
HOL -59.00 NSS-BSS 59W 10010553 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.664
HOL -59.00 NSS-BSS 59W 10010556 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 1.236
HOL -59.00 NSS-BSS 59W 10010557 3,5,7,9,11,13,15,17,19,21,23,25,27,29,31 0.664
HOL -59.00 NSS-BSS 59W 10010560 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.059
HOL -59.00 NSS-BSS 59W 10010561 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.495
HOL -59.00 NSS-BSS 59W 10010564 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.058
HOL -59.00 NSS-BSS 59W 10010565 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.496
HOL -59.00 NSS-BSS 59W 10010568 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30,32 1.058

Page A1-7 of A1-8

HOL -59.00 NSS-BSS 59W 10010569 2,4,6,8,10,12,14,16,18,20,22,24,26,28,30 0.496
INTERSPUTNIK-
RUS -47.50 10013209 1,3,5,7,9,11,13,15,17,19 0.468
47.5W-B
INTERSPUTNIK-
RUS -47.50 10013210 2,4,6,8,10,12,14,16,18 0.496
47.5W-B

Page A1-8 of A1-8

Appendix 2 to
Attachment A (Technical Information to Supplement Schedule S)
(ECHOSTAR-15)

Analysis of ANNEX 1 of Appendix 30A
for USABSS-33

1 (SUP - WRC-2000)

2 (SUP - WRC-2000)

3 Limits to the change in the overall equivalent protection margin with
respect to frequency assignments in conformity with the Region 2 feeder-
link Plan33 (WRC-2000)

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

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

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

Page A2-1 of A2-3

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

Does not apply to the Region 2 Plan.

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

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

The following Table calculates the  T / T for the closest Regions 1 and 3 feeder link
space stations, based on the Region 1 and 3 List. As shown the  T / T’s are well below
the allowed 6% level. Therefore USABSS-33 is in conformity with this Section.
Closest Region 1 or 3 Feeder Link Space E/S E/S Range E/S Victim Calculated
Station Lat Long (km) Gain Satellite Rx T/T
(°N) (°E) towards System Noise (%)
Victim Temp
Network Name Orbital Peak Satellite (K)
Position Receive (dBi)
Antenna
Gain
(dBi)
INTERSPUTNIK-
-47.5 37 33.3 -111.8 40296 -0.2 600 0.11%
47.5W-B
MCO-BSS-40.5W -40.5 35.9 33.3 -111.8 40921 -4.6 600 0.03%
IRL21100 -37.2 48.08 33.3 -111.8 41222 -6.1 600 0.35%
NGR11500 -37.2 38.47 33.3 -111.8 41222 -6.1 600 0.04%
DBL-G4-37.2W -37.2 35 33.3 -111.8 41222 -6.1 300 0.03%
AND34100 -37 48.88 33.3 -111.8 41241 -6.2 600 0.42%
GMB30200 -37 47.69 33.3 -111.8 41241 -6.2 600 0.32%
GUI19200 -37 42.29 33.3 -111.8 41241 -6.2 600 0.09%
POR__100 -37 47.17 33.3 -111.8 41241 -6.2 600 0.28%
MTN__100 -36.8 37.55 33.3 -111.8 41259 -6.3 600 0.03%
SMR31100 -36.8 48.88 33.3 -111.8 41259 -6.3 600 0.41%

Page A2-2 of A2-3

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

Does not apply to the Region 2 Plan.

Page A2-3 of A2-3

Document Created: 2010-03-10 18:34:36
Document Modified: 2010-03-10 18:34:36

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