Attachment ex parte

This document pretains to SAT-PDR-20020425-00071 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2002042500071_397807

HARRIS, 1200 ncvrsmim smenrw wsrmeron.oc 20026 WiLTSHIRE & m anerimiomectenrmiom ORIGINAL ww GRANNIS us arromrsar w RECEIVED July 23, 2004 i $A JUL 2 3 200 BY HAND DELIVERY Marlene H. Dortch Office ofthe Secretary Federal Communications Commission 445 12" Street, S.W. Washington, D.C. 20554 Re:— Ex Parte Presentation Report No. SPB—196; SAT—PDR—20020425—00071 Dear Ms. Dortch: On July 22, 2004, Romulo Pontual, Jim Butterworth, David Pattil, Susan Eid, and undersigned counsel on behalf of The DIRECTV Group, Inc. (‘DIRECTV*), met with Tom Tyez, Selina Khan, Chip Fleming, Rockie Patterson, JoAnn Lucanik, Marilyn Simon, and John Martin (by phone) of the International Bureau t discuss the enclosed materials (which were distributed at the meeting). In this presentation, DIRECTV responded to a June 15, 2004 ex parte filing in which SES AMERICOM, Inc. (°SES") discussed Direct Broadcast Satellite ("DBS")/ Direct to Home (‘DTH") satellite operations in the European market. Clearly, SES‘s presentation was designed to leave the impression that satellites serving Burope provide DBS/DTH services on the same frequencies tothe same geographic area from satelltes spaced from 2.3 degrees to 4.3 degrees apart. However, closer reading of the SES filing reveals that frequencies used for DBS/DTH service to small dishes on one satellite are used for low power business services (such as cable backhaul and single channel per carrier transmissions) to much larger dishes on the others. Such an analysis is not informative on any issue in these proceedings. As discussed in DIRECTV‘s presentation, coordinating services with such dissimilar characteristics is hardly impressive. In fact, coordination ofFSS satellites with orbital spacing of only 2.0 deareesis the norm for operators serving the U.S. market From DIRECTV‘s review ofpublicly available information on the operations ofthe satelltes discussed in SES‘s filing, it appeaxsg:r there is no actual DTHDBS sharing No. f C rese List ABCI

Haus, Wicrsime & Grnns uo Marlene H. Dortch July 23, 2004 Page 2of3 of the type that would be relevant to the ssues in these proceedings — Le, sharing by two operators using the same frequencies to provide the same high—power DTH/DBS service to consumers with small receive dishes in the same geographic area." DIRECTV also pointed out that, even if such shating were accomplished over Europe, the differences in the operational characteristics and environmentalfactors facing satellites in Europe and the U.S. would render such an instance oflitle value in this proceeding. DIRECTV urged the Commission not to be misled by SES‘s presentation. 1t contains no evidence that the short—spacing ofhigh—power DBS/DTH services that it proposes for the United States has been successfully employed in Europe. DIRECTV also discussed the impact that SES‘s proposed operations would have on U.S. consumers, who would need larger receive antennas in order to maintain their quality of service in the presence ofthe interference SES proposes to introduce. The expense, inconvenience, and disruption that would accompany any effort to replace existing DIRECTV dishes with larger receive antennas would be a direct cost imposed upon American consumers by SES. DIRECTV also pointed out that, because EchoStar has already secured all ofthe DBS capacity that SES seeks to gain at ts short—spaced orbital location, ts proposal would not even have the benefit of ereating capacity for use by a new entrant into the U.S. market. Moreaver, because EchoStar would control both its own DBS frequencies at 110° W.L and the same frequencies on the SBS satellte at 105.5° W.L., it would be able to "coordinate"with itself—— much as SES does in Burope with the Astra 1G and Astra 3A satelltes discussed in its presentation — which may explain why EchoStar has been essentially acquiescent in SES‘s proposal since it struck its deal with SES. Sincerely yours, Zpticn7bleats, William M. Wiltshire Enclosure in fict, one ofthe satelltes ited in SES‘s presentation (Rutesat11 F3) opertesi a 3. degres inclined orit,and thusis signals can only bereceived by much largerdishes wih tacking actutors —notthe small fixed consumerdishescurenty in usfor DBSDTH in Europe. Thus, this stefte cleady is ot providing DBS/DTH! servie oany ind on any frequency.

Hamus, Wirsime & Granys cur Marlene H. Dortch July 23, 2004 Page 3 of3 ces Tom Tycz Sclina Khan Chip Fleming Rockie Patterson JoAnn Lucanik Marilyn Simon John Martin

DIRECTYV‘s Comments on SES‘s Ex Parte Filing of June 15, 2004 July 22, 2004 piRectv July 2004

SES‘s Claims of Successful Operation of Reduced—Spaced DTH Satellites in Europe .J are Specious and Misleading pirRECcTw + Investigation of SES‘s claims yields little, if any, actual sharing + SES‘s apparent parsing of the 2 GHz of BSS/FSS spectrum with Eutelsat in Region 1 cannot serve as a model for the 500 MHz of BSS in Region 2 + SES‘s coordination of FSS satellites as close as 2.3 degrees for SCPC and cable backhaul is inapposite. Such services in Region 2 are routinely coordinated to 2 degrees + The "other satellites" SES uses in its analysis are Eutelsat‘s W2 (16E) and II—F3 (21.5E) satellites. Both these satellites have little DTH in the 12.5—12.75 GHz band. Additionally, Eutelsat II F3 is inclined 3.9 deg., and is not suitable for DTH/DBS service * The only satellite with "similar characteristics" in SES‘s analysis is its own Astra 3A at 23.5E. This hardly represents a competitive sharing scenario since SES has full control of both satellites and can adjust parameters at any time to optimize service DIRECTV 2 July 2004

SES‘s Analysis and Examples are Not Relevant to DBS in the US -J DIRECTV. Many differences between Region 1 FSS and Region 2 BSS, the most notable being the larger receive antennas for Region 1 FSS (60—90 cm) and less rain in Europe than in US Region 1 FSS and BSS bands have powerlimits, Region 2 BSS does not. Spot beams do not fit this power—limited reduced— spacing model Acceptable C/l levels are not the same for Region 1 FSS and Region 2 BSS due to many factors. Two key factors allow for the use of lower C/Is in R1 FSS than for comparable availability in R2 BSS: — Europe has significantly less rain than the US (see chart p.11) — Region 1 uses linear polarization, which provides better x—pol isolation during rain than circular polarization US BSS spot beams require higher C/ls because they must also contend with adjacent beam interference DIRECTV July 2004

DTH/DBS Service Europe vs. US S» DIRECTV Parameter Europe US Spectrum 2.05 GHz of BSS/FSS 500 MHz of BSS Receive antenna size 60—90 cm 45 cm PFD limits BSS and FSS pfd limits None Polarization Linear Circular Rain attenuation Less More Receive antenna squint None ~0.3 deg. Pointing Easier Harder + triple—sat X—pol isolation Higher during rain Lower during rain DIRECTV July 2004

Astra 1G "Sharing" .J DIRECTV. + SES claims thatits Astra 1G satellite co—exists with other DTH/DBS satellites less than 4.3 degrees away * In fact, the satellites SES uses in its analysis have little DTH programming at all, and are mostly used as backhaul channels (see charts 7—9) + Backhaul channels are typically low power and received by large antennas (e.g., 4.6m for the BBC feeds) * Astra 3A appears to have no DTH at all on channels 13, 14, 15, 20, 22, and 23 in the 12.5—12.75 GHz band. According to LyngSat, these channels are used exclusively for "feeds" (backhaul) DIRECTV 5 July 2004

Astra 1G "Sharing", cont‘d -J DIRECTV. Similarly, Eutelsat II F3 has only two DTH channels in the entire 12.5—12.75 GHz band; the rest are backhaul. Eutelsat W2 has only one DTH channel on transponder F1, and none on transponder F2 Even under the more favorable coordination environment of Region 1, it appears that there is no actual DTH/DBS sharing that involves co—frequency and co—coverage service using 60 cm antennas SES‘s claims are not supported by the information submitted in its analysis, and are simply misleading Moreover, they are irrelevant— especially given the expertise of the FCC and US operators in analyzing spectrum sharing issues DIRECTV July 2004

DIRECTV. Astra 3A (23.5E) Programming and Freq. Plan 127250 T17 n tre050 {10 »} meiso trmso 1 a m T850 n 15250 24 23 are 12m50 o 7 o pirectv July 2004

DIRECTV. Eutelsat W2 (16E) T uks Programming and Freq. Plan icaualacs n pirectv July 2004

Euis B Gnoomar:Siilie, lt updared 200EOT20 — thmhogentconvedtsht 20.4 DIRECTV 3 fru: Rietie thett. hean BE zasoon & Eit hnfi io fesan| %, w Eutelsat II F3 §a Ces amion| . t so aasasn 5 o fug heoopmoss. (Fevitanec (21.5E—incl 3.9°) ip10 io hi wassi n lus hoom in ao xasor n h med late henrmon Programming in o ma Sup aaston ipar late. btie Bs dn and Freq. Plan fasson 4 ledliornons twar neacon, azseen luta hietim 1256 r27s one tw an m sioem x2z h file. ihite: n m pt azeoav . atrow — (paovio ty wa ) * es > s 19| _ 1| Caried on Hot Bird 3 at 13E lt ramov tp «o Ploasure \ Rlve assoar h T rilk: e xazze J : 7 toa Coonttom Abw "Z Th toa B (Saains,Tsl updacd PIOEOLI0 lhnIrgostcomtetthnd piRectv July 2004

Off—Axis Isolation for Receive - l Antenna Size vs. Orbital Spacing birECTV Nominal Orbital Spacing, deg. 4.5° 6.0° 9.0° Receive 45 21.5% 25.3/2\ 29.7) Antenna 60 211| 3189 — = | eq;:vlalenl rovany Size, § cm orbital sep. vs. 75 26.7 29.82 — on mie 90 28.2 31.42 — ! Current Region 2 BSS 2 Typical Region 1 BSS and FSS 3 SES Proposed BO.1213 Reference Pattern DIRECTV 10 July 2004

Rain Rates DIRECTV. Europe has lower rain rates than the US (ITU Rec. 618—8) US 120 — 130 mmhr 110 — 120 mmhe 100 — 110 mmhr 90 — 100 mmfhe 80 —90 mm/hr 70 — 80 mm/hr 60 —70 mm/hr 50— 60 mm/hr 40— 50 mm/hr 30 —40 mm/hr 20 —30 mm/hr 10 —20 mmfhr Europe 0 — 10 mm/hr DIRECTV 1 July 2004

Rain Attenuation !J DIRECTV. Example: Washington, DC has about 2.5 dB more downlink attenuation due to rain than Betzdorf at 99.9% availability 6 @ & w a € —+—Washington, DC | a @ $ E55 —a— Betmdort 8 » a n ses sass ces ces Availabiity 9 pirecrv 12 July 2004

Conclusions .J DIRECTV. SES has long claimed sharing of co—coverage, co—frequency DBS/DTH satellites operating in Europe with less than 4.5 degrees spacing DIRECTV does not consider Region 1 examples relevant to the case in question. Regardless, SES‘s examples always boil down to one SES satellite coordinating with another (Astra 3A and Astra 1G). And in the instant case, DTH sharing with backhaul or inclined satellites This in no way represents the general case of coordination between two independent DTH networks spaced less than 4.5 degrees or is applicable to our case The Commission should not be distracted by the misleading claims and analysis in SES‘s most recent filing pirecrv 13 July 2004


Document Created: 2004-09-28 12:31:32
Document Modified: 2004-09-28 12:31:32
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