Attachment Narrative

This document pretains to SAT-MOD-20120315-00050 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012031500050_945137

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

In the Matter of                                    )
                                                    )
115 License Subsidiary, LLC                         )   File No. SAT-MOD-2012__________
                                                    )
Application to Modify 115° W.L. 17/24 GHz           )
Broadcasting Satellite Service Authorization        )   Call Sign: S2700
                                                    )

                                        MODIFICATION

       115 License Subsidiary, LLC (“115 License Sub”) files this modification to provide the

predicted transmitting antenna off-axis gain information for 115 License Sub’s 115.0° W.L.

17/24 GHz Broadcasting Satellite Service (“BSS”) authorization (Call Sign S2700). Pursuant to

recently released rules, current authorization holders are required to file a modification

application to supplement the file with all required information.1 This application has been filed

electronically as an attachment to FCC Form 312. The remaining technical information in 115

License Sub’s current authorization is unchanged and is incorporated by reference.2




1
        47 C.F.R. § 25.264(a). See also International Bureau Announces Effective Date for New
Information Requirements in the 17/24 GHz Broadcasting-Satellite Service and Establishes
Filing Deadline for Pending Applications and Current Authorizations, Report No. SPB-239, DA
12-71 (Jan. 20, 2012) (Public Notice) (requiring each current 17/24 GHz BSS authorization
holder to file a conforming modification to its authorization no later than March 15, 2012).
2
       Stamp Grant, File Nos. SAT-LOA-20060412-00044, SAT-AMD-20080114-00023
(granted December 17, 2008).


       New Section 25.264(a) requires the submission of predicted transmitting antenna off-axis

antenna gain information:


              (1) In the X-Z plane, i.e., the plane of the geostationary orbit, over
              a range of 30 Degrees from the positive and negative X-axes in
              increments of 5 degrees or less.

              (2) In planes rotated from the X-Z plane about the Z-axis, over a
              range of up to 60 degrees relative to the equatorial plane, in
              increments of 10 degrees or less.

              (3) In both polarizations.

              (4) At a minimum of three measurement frequencies determined
              with respect to the entire portion of the 17.3-17.8 GHz frequency
              band over which the space station is designed to transmit: 5 MHz
              above the lower edge of the band; at the band center frequency;
              and 5 MHz below the upper edge of the band.

              (5) Over a greater angular measurement range, if necessary, to
              account for any planned spacecraft orientation bias or change in
              operating orientation relative to the reference coordinate system.
              The applicant must also explain its reasons for doing so.


       115 License Sub submits the requested antenna data predictions for its space station in

the attached technical materials.3 The required information is produced for a CONUS beam and

a Mexico beam. Consistent with the new rule, for the CONUS beam, the predictions were made

in both polarizations (i.e., RHCP and LHCP) at three measurement frequencies in the 17.3-17.7

GHz frequency band over which its proposed space station is designed to transmit.4 For the


3
        Because 115 License Sub does not plan for any spacecraft orientation bias or change in
operating orientation relative to the reference coordination system, it does not provide
predictions over a greater angular measurement range as specified in Section 25.264(a)(5). See
47 C.F.R. § 25.264(a). Similarly, because the power flux density of 115 License Sub’s proposed
space station will not exceed the coordination trigger of -117 dB W/m2/100 kHz at the location
of any prior-filed U.S. DBS space station, 115 License Sub has not provided the calculation
otherwise required in Section 25.264(b). See 47 C.F.R. § 25.264(b).
4
       The attached technical materials for the CONUS beam note frequencies 17.3 GHz, 17.5



                                                2


Mexico beam the predictions were made in both polarizations at three measurement frequencies

in the 17.7-17.8 GHz band, which are the only frequencies operated for this beam.5 The data is

calculated over a range of +/- 30 degrees from the X axis in the X-Z plane, and over a range of

+/- 60 degrees in planes rotated about the Z axis. In addition, consistent with Sections

25.114(d)(18) and 25.264(h)(2) of the Commission’s rules,6 115 License Sub will maintain the

maximum orbital eccentricity to less than 3.1 x 10-4.

       For the foregoing reasons, 115 License Sub requests that its authorization be modified to

include the attached transmit antenna off-axis gain information.



                                                     Respectfully submitted,

                                                     115 License Subsidiary, LLC



                                                     By: /s/ Scott Blank
                                                        Scott Blank
                                                        Senior Vice President, General Counsel,
                                                          and Secretary

March 15, 2012




(Continued . . .)
GHz, and 17.7 GHz that have been rounded. The actual measurement frequencies are 17.305
GHz, 17.5 GHz, and 17.695 GHz.
5
      The attached technical materials for the Mexico beam note frequencies 17.7 GHz, 17.75
GHz, and 17.8 GHz that have been rounded. The actual measurement frequencies are 17.705
GHz, 17.75 GHz, and 17.795 GHz.
6
       47 C.F.R. §§ 25.114(d)(18) & 25.264(h)(2).



                                                 3


                      ENGINEERING CERTIFICATION

The undersigned hereby certifies to the Federal Communications Commission as follows:

(i)     I am the technically qualified person responsible for the engineering information
        contained in the foregoing Application;

(ii)    I am familiar with Part 25 of the Commission’s rules; and

(iii)   I have either prepared or reviewed the engineering information contained in the
        foregoing Application, and it is complete and accurate to the best of my
        knowledge and belief.




                                           Signed:



                                                /s/ Milenko Stojkovic
                                              Milenko Stojkovic
                                              Senior Engineer
                                              W.L. Pritchard & Co., L.C.

                                              March 15, 2012



Document Created: 2012-03-15 21:36:26
Document Modified: 2012-03-15 21:36:26

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