Attachment ex parte

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

IBFS_SATPDR2002042500071_398255

EX PARTE OR LATE FILED PAUL, WEISS, RIFKIND, WHARTON 8 GARRISON LLP rypememeer n memens vavs c meer e sees amur ormemencis mm mere Halre mes, Wadhnaron, oC roose ses enreuren Tt s movin orcovnhs ORIGINAL 2oz223—7340 2022237440 pepector@paubweiss.com fekcie August 18, 2004 BX HAND Marlene H. Dortch RECEIVED (onPommmenione Commtenion aus 1 8 200 445 — 12th St, S.W. Fedeal Conmuncaton Connianon Washington, DC 20554 OteaotSecay Re: ExParte® ; Report No. SPB—196; SAT—PDR—20020425— Dear Ms. Dortch: On behalf of SES AMERICOM,Inc.(°SES AMERICOM®), we writein response to an exparfiling submitted by The DIRECTV Group, Inc. (°DIRECTV®) in the above—referenced dockets." The DIRECTV Ex Parte consists of materials presented to International Bureau ("IB") staff in a meeting on July 22, 2004, responding to an SES AMERICOM ex parte presentation made on June 15, 2004, on the topic ofDirect Broadcast Satelite (‘DBS") and Direct—to—Home (‘DTH") satellite operations in Europe:* t x Pare Notie, The DIRECTV Group,In., Report No, SPB—196; SAT—PDR—20020425—00071, July 23, 2004 (he "DIRECTV & Pare‘) 4 Ex ParieNotics, SES AMERICOM In, Report No. SPB—196; SAT—PDR—20020425—00071, Jun15, 2004 (the "SES AMERICOM Ex Pare). h ofl 5. of Copios recid _ bervcrimis

raull weiss. RIFKIND, wharton a carrison Lip Marlene H. Dortch 2 L Introduction and Summary In June, SES AMERICOM presented to Commission staff an overview of European DBS/DTH satellte operations, focusing in detail on the interference into the consumer dishes of one DTH satelite from closely neighboring satellites. That DTH satellite, Astra 1G, is currently serving millions ofhouscholds in Europe, with high availability, in a fiercely competitive marketplace. The SES AMERICOM study shows that DTH services are being delivered successfully in an interference environment that is greater and more complex than the current 9*—spacing environment in the United States. DIRECTV argues that the presented analysi is not relevant to the DBS environment in the United States, due to differences in the services and technical parameters of the satellites considered in the study. However, the interference analysis performed by SES AMERICOM depends on the actual interference contributed by the neighboring satellites, and not on their services per se, and takes into account differences between Buropean and U.. DTH systems, such as dish size. Therefore, the resulting interference levels can be meaningfully compared to U.S. levels, and such a comparison supportsthe viability oreduced spacing in the United States. Importantly, however, there is no need for the Commission to determine whether reduced U.S. DBS spacing is feasible in the general case or in any specific case. Rather, the Commission should follow existing international and domestic rules for entry of new DBS satellites, which prescribe case—by—case coordination ofproposed new systems under the auspices ofthe Intemational Telecommunication Union (‘TTU). The Commission should fully support these ongoing proceedings, and should refrain from adopting rules or policies that could arbitrarily and unnecessarily constrain the coordination agreements which may be reached by the operators. 11. The Experience of Buropean DTH Operators Supports the Viability of Reduced Spacing in the United States. DIRECTV claims that the SES AMERICOM analysis of European DTH operations is not relevant to the question of reduced satellite spacing in the United States, because the analysis does not show DTH/DBS sharing that involves co—frequency and co— coverage service using 60 em antennas."". DIRECTV also argues that, even if such sharing f DIRECTV x Part,slide 6. Forthisreason, DIRECTV claims thatthepresentation was*misleading." 1. However, SES AMERICOM explicity indcated in the mesting with TB stafFand in the £t Partnoice that the two neighboring Eutesatsatlites included in the anlysis provided primarily ingle channel percarier (‘SCPC)serviees,and hatthe neighboringAsta 3A saelit included in the analysis provided primaily diect to—cable service (although wth DTH—lik signal characteritic). See SES AMERICOM At Part t 1; see also (d. sid 4 (indieatngthatthe neighboring steies considered in the analysis are providing "other servies") merscriama

rauL. weiss. RIEKIND, WhARTON 8 GARRISON LUP Marlene H. Dortch 3 were present,the differences in the operational characteristies and environmental factors facing satellites in Burope and the U.S. would render such an instance oflitle value in the U.S. context.". DIRECTV mischaracterizes both the purpose of, and the importance of the results from, SES AMERICOM‘s analysis. As an initil matter, SES AMERICOM has never presented European spacing scenarios as perfect analogies to the U.S. DBS environment.® The subject & Parte presentation, which stemmed from discussions with TB staffmembers, was intended to aid in understanding the situation in Europe, in which DTH services o small dishes are successfully provided in an environment that includes interference contributed by closely—spaced, co— frequency, co—coverage satellites, at higher levels than currently experienced in the U.8 environment of uniform 9° spacing. Because ofthe differences in the European environment (in terms of satellite spacing, antenna size, etc.), SES AMERICOM focused its study on a parameter that measures the true impact of adjacent satellites on a DTH system, independent of such details: the interference level received by that system, expressed relative tothe desired signal strength (ie., the carrier—to—interference ratio, or "C/1"). SES AMERICOM computed the aggregate C/1into consumer dishes served by the Astra 1G satellte from several closely—spaced (2.39, 3.25,and 4.3°), co—frequency and co—coverage satellites (Eutelsat II3, Eutelsat W2, and Astra DIRECTV alssttes that one of thase Batesatsatlites, Eatlsat HP,is operate in an inclied.orbit and therefore cannot be used for DTH service. See DIRECTV Ee Parie at2, and slde2. However,SES AMERICOM‘s analysi id noassume that the satelite was used for DTH service. As discussed below,the contrbution ofht sitelite t heintrfrence experienced bythe Asta 1G satlite was detrmined based on is actal signal characterisis(athenomina orbitlloction, and it is that contribution (and not th servicesper ) that is elevantto th results presenie y SES AMERICOM £ DIRECTV Ex Parteat 2. For example, DIRECTV notes that largr dishes(60—90 enare usd in Europe, while 45 em dishesare usein the United Sutes. DIRECTV A Parie, slides3, 4. ¢ In fct, thstelites studied by SES AMERICOM —at 2383.2%, and 4.3 spacing from the Asta 1G satelite oinerest —are closer(itwo cases farclosenthn SES AMERICOM‘s proposed DBS satelite would be to any US. DBS satelte. See SESAMERICOM, In, Pettonfor Declaratory RulingTo Serve the US Merket Using BSSSpectunfom the 105 3° W L. Orbital Location, SAT—PDR—20020425—00071, April 25, 2002 (the "SES AMERICOM Pertion®), The satlite roposed by SEAMERICOM at108.5° W.L. would be 4.5° from DIRECTV and EchoStar satlites at 101° W.L.and 110° W merncraumes

rauc. weiss. RIFKIND. wharton 8 CarRIsoN Lr Marlene H. Dortch 4 3A, respectively)." The EIRP levels of each satelite, including relevant factors such as transponder back—offdue to multi—carrier operations, were taken into account in the analysis." As indicated in the SES AMERICOM presentation, the satellites adjacent to Astra 1G contribute a combined interfering power density similar t the contributions of an adjacent, reduced—spaced DTH satellite.* The interference contributed by these neighboring satelites, and not the type of services these satellites provide,is the critical factor in the presented interference analysis.. Whether or not the interference comes from satellites providing DTH service is irrelevant." It is the resulting C that determines the impact on Astra 1G services. € In its presentition, DIRECTV suggests hatt orbital spacingfor ixed—steit ervice (*FSS") and broadcasting—sitelit service(‘BSS") in Buropeistypically 6. DirecTV Ee Parc,slde 10. However, as evidenced by SES AMERICOM‘sanalysis, o—fequency, co—coveragestelltesarespaced asclos as 23 t .3 dearces rom an operating DTH FSS satelite v See SES AMERICOM Ex Part, slide7, whererous 6,7 and 8 othe C1 calcultiontabl provide various fctor employed in the analysis. As explainedtoTB staffdaring the presentiion, these fctostake ino accountthe différence in the power densitesdue o (1) thdifference i sturated EIRPs between the iterfring sateieand Asta 1G (row 6) (2) thdifferencein transponder bandwidtis between th interferingsatellteand Astra 1(row 7(3)the transponder backofofthiterferig satelit dueto mult—carter operation 3 dB reductonin EIRP for both Butelat satlltes(row 6), and (4) th eduction in iterfring power density due to approsimated carie spacing (0.5 dB reduction in power densty for both Eutlststelits) (row 8). * Indeed, tAstra 3A satellte, spaced 4.3 rom Astra 1transmis fully—saturated diial video carviers, atcomparable power densites to 1G, repardless ofwhether the signals are being received by cable hexd—andsor consumerdishes.Itisnot he case,as DIRECTV suggests (DIRECTV &Pore,slide 5 thtthis satelte operates at lower powe levelsthin DTH service. (Note tht, while the saturted EIRP on Astra 1G and 3A is equivalen, the C/ analysi assumed a pover density1.4 B lowerforAsta 3A because t uses 36 MIte iranspondes, while Asta 1G uses 26 MHs tansponders See SBS AMERICOM B Porie, slie 7 Moreover, DIRECTV is wrong when iarguesthatthe Ast 3A "hardly representsa compotitve sharing seetariosince SBS has ull contrl oboth stelites and can adjst parametersat anytime to optimize servic." 14, slide2; see also id, side 13. As SES AMERICOM has explained, the Astra stelits are operted as open architectre plaforms, providing capacit t hid—party eail DTH service providers. SES AMERICOM & Parie Notice,side 2. Full transponder usrs are given fillpower and bandwidih ofthe transponders without downlink power or bandwidthresticions.I2. For thisreason, Buropean satelite operators have much less contrl ovethe loading ofhei ransponders than do the U.S. DBS providers 0. f However,as noted above, theAsta 3A stelit,4.3° fom Astr 1G, trnsmits DTH—lik signals in terms ofbotl pover and signal charicterstis)providing an accurte madel ofth impact ofa closey—spaced DTH stelte on Asta 1G DTHI operations. merncrison

raukl weiss. RirkIND wharton s carrison Lr Marlene H. Dortch 5 Moreover, the C/Ifigure takes into account and subsumes antenna size, power fevels, and other parameters that differ between European and U.S. systems, and allows comparisons to be made among systems based solely on the level of interference in which they operate."" The results show that the Astra 1G system receives a higher level of interference from neighboring systems relative to the strength ofitsdesired signal than do U.S. DBS systems. The fact that the systems employ different dish sizes, for example,is irrelevant t this fundamental conclusion. For the above reasons, the C/I levels computed by SES AMERICOM accurately model the interference experienced by the Astra 1G DTH system, and can be directly compared to the C/I levels of U.S. DBS systems. DIRECTV dismisses the relevance of that result, arguing that, for a variety of reasons, higher C/I levels are required in the United States. As explained in detail in the attached Technical Appendi, this is not the case. None of the reasons proffered by DIRECTV necessarily produce the impact claimed by DIRECTV, and all can be — and routinely are — dealt with in coordination. 11. Coordination, and Not a Commission Rulemaking, is the Appropriate Forum for Dcbate of These Issues. The European environment llustrates the possibilities for reduced spacing in the United States. However, as SES AMERICOM has explained repeatedly in various fora, each case is different and must be assessed individually."" The feasibility ofcoordinating a new satelite at a given spacing from existing satellites depends on a variety of considerations, including the proposed spacing; the power levels, frequeney plans, coding techniques, and coverage pattems of proposed and existing satelltes; and the services provided by the satelltes. Importantly, SES AMERICOM is not asking the Commission to determine whether 4.5—degree spacing is feasible in the general case or in any specific case, and there is no need for the Commission to do so. Rather, the Commission should follow existing intemational and domestic rules and proceduzes for entry of new DBS satellites, which 1*=— For thisreason, ts imelevant that Buropean DTH and DBS operations aresubject o PFD limits. See DIRECTV Ex Part, lides 3,4. * See, e Comments of ES AMERICOM, Inc, Report No. SPB—196, Jantary 23, 2004 (‘SES AMERICOM Reduced Spacing Comments")at 21—2, 27—33;Reply Commens ofSES AMERICOM Inc, Report No SPB—196, Febrwary 13, 2004 (‘SES AMERICOM Reduced Spacing Reply") at 10—10 eervcriume

pauL, weiss. RIFKIND, wharton s carrison Lip Marlene H. Dortch 6 prescribe individual coordination ofproposed new systems..". The appropriate forum for resolution of the issues raised by DIRECTV is coordination under the auspices of the TTU." The eoordination procedures allow the determination ofthe appropriate protection levels for systems on a case—by—case basis by the involved operators, avoiding the need for generic measures that would place unnecessary constraints, based on worst—case assumptions, on the introduction of new systems. The limitations that result from a one—size— fits—al, worst—case analysis are significant, and would render such new systems commercially non—compctitive. The ongoing coordination of the proposed SES AMERICOM satellite at 105.5° W.L. involves study ofthat satellite and neighboring satellites o a level of detailfar beyond what is possible in a rulemaking proceeding. This effort is necessary to permit introduction of new, competitive DBS services at reduced spacing. The Commission should fully support these ongoing proceedings, and encourage good fuith among the participants. Most importantly, the Commission should not prejudge the outcome ofthe coordinations by adopting rules or policies that would unnecessarly constrain the agreements that may be reached by the concerned partis. For these reasons, the Commission should act quickly to dismiss the DIRECTV ralemaking petiion, " and to grant the SES AMERICOM Petition, subject to the outcome ofcoordination."" Respectfully submitted, wA ///,// 74 eZe i Phillip L. Spector Diane C. Gaylor Attorneysfor SES AMERICOM, Inc 9 SBS AMERICOM Reduced Spacing Comments at —15; SES AMERICOM Reduced Spacing Replyat 210. 8 See, eg, Conlidted Reply of ES AMERICOM, Inc., SAT—PDR.—20020425—00071, Jly3, 2002 (the "SBS AMERICOM Reply)at 27—29; SES AMERICOM Reduced Spacing Reply t 13 i ‘See Pettionof DIRECTV Emerprises, LLC for a Rulemaking on the Feasibilty of Reduced Orbial Spacing in the U.S. DiectBroadeast Satelite Servie, RM No. 10804, Sept 5,2003; Public Norice, Report No: 5PB—196, December 16, 2003. !5— SeeSES AMERICOM Reduced Spacing Commentsat3536, mesvcrsons

rauL, weiss, RirIND, wharton s carrison Lup Marlene H. Dortch ec:—— Thomas Tycz John Martin Sclina Kahn Chip Fleming Rockie Patterson JoAnn Lucanik Marilyn Simon Intemational Bureau William M. Wiltshire, Bsq. Attomey for DIRECTV

SES AMERICOM Ze PartePresenation Report No. SPB—196,SAT—PDR—20020425—00071 August 18,2004 Technical Appendix As explained in the attached letter, SES AMERICOM has computed the C/1levels experienced by a successfully—operating DTH platform in Burope. DIRECTV has argued that the analysis is rrelevant because higher C/I levels are needed in the United States, for a variety ofreasons. However, none ofthe reasons proffered by DIRECTV necessarily produce the impact claimed by DIRECTV, and all can be — and routinely are — dealt with in coordination. Spot Beams and Dish Size. DIRECTV argues that higher O/I levels are needed in the United States to accommodate higher power spot—beams, which must contend with adjacent beam interference." DIRECTV also argues that a lower CT would requireit to adopt larger receive antennas in order to maintain its quality of service" DIRECTV‘s claim that reduced—spacing would unduly limit use ofspot— beams is unsupported by any analysis. Similarly, DIRECTV provides no support for its laim that larger dishes would be required in the United States for reduced spacing operations." SES AMERICOM believes that coordination of spot beam operation is feasible in a reduced spacing environment, as is coordination ofthe earth stations deployed for DBS service in the United States. This assessment is based on SES AMERICOM‘s review ofthe C/1‘s resulting from analysis performed for the 105.5° W.L. sharing scenario." SES AMERICOM is not alone in its conclusion that reduced spacing in the United States can be successfully coordinated. In its comments in the Commission‘s proceeding on reduced spacing, EchoStar stated that ts "more advanced assessment of interference in a 4.5° orbital spacing environment llustrates very well C x Parte Noics, The DIRECTV Group,In., Report No. SPB—196; SAT—PDR20020425—00071, July 23, 2004 (he "DIRECTV & Part‘),slte 3. * 14 ar2 * In the past, DIRECTV has atempted o jusify such conclusions based on application of the coordination triggercrterionemployed by the ITU‘s MSPACE program. Se, eg. Oppostton of DIRECTV, . File No. SAT—PDR20020425—00071, Jane 17, 2002, at17—18, Technical Amner at8—9; Ex Parie Notic, DIRECTV, Inc, File No. SAT—PDR—20020425—00071, November 12, 2002,at67; Comments of DIRECTV, In., Report No. SPB—196, Jammary 23,2004at 4. As SES AMERICOM has explained on ntmerous occasions, MSPACE analyisfunctions asa coortinationtigner only, and cannot support DIRECTV‘s claims regarding spo.beams and dis izes. See, eg, Consoldated Reply ofSES AMERICOM, In, SAT—PDR—20020425—00071,July3, 2002(‘SES AMERICOM Reply®)ar22.25, ‘SeeSES AMERICOM Reply, Appendix 1. These sharing studies have contined to evlvein the context oth ongoing coordination ofthe 105.5° W.L.satlite. However,SES AMERICOM‘s findamenialconclusion regarting the feasblity ofcoordination has not changed. mervcriumn

SES AMERICOM Et Parie Presetation Report No. SPR—196,SAT—PDiR—20020425—00071 August 18, 2004 Technical Appendix how detailed technical coordination between satellite operators can ensure mutually compatible operation, whereas the application of worst case interference assessment can lead to the conclusion that such operation is not possible." Like DIRECTV, EchoStar has a spot beam satellite currently in operation 4.5° away from the 105.5° W.L. orbital position. In the analysis presented in its comments, EchoStar reviewed the shoring scenario between 105.5° W.L. and its spot—beam satellite, considered the availability achieved for these areas, and addressed certain spot beams on a case—by—case basis." The EchoStar analysis supports SES AMERICOM‘s assessment that creative solutions permitting DBS reduced—spacing can be developed through detailed coordination discussions among the involved parties. As discussed in the attached letter, the appropriate forum in which to assess the needed C for DIRECTV‘s systems is the ongoing coordination under the auspices ofthe ITU. Limits. DIRECTV argues that BSS and FSS operations in Europe are subject to power flux—density (°PFD") limits, which is not the case in the United States. First, however, power limits are irrelevant to the C/I calculations performed by SES AMERICOM, because these computations assess reative, not absolute, power levels. For ESS in the 12.5—12.75 GHtz band, the subject of the SES AMERICOM presentation, Region 1 (the ITU Region encompassing Europe) does have PFD limits in Article 21 of the Radio Regulations. However,the PFD limits in 12.5— 12.75 GHte apply only to countries specified in Nos. 5.494 and 5.496 ofthe Radio Regulations. Germany, the country used in the SES AMERICOM analysis, not * Comments ofEchoStar Satelite LLC., Report No. SPB—196, January 23, 2004, Technical Annex,at2. EchoStar notedthat ts original astessment of ES AMERICOM‘s proposal conservatively assumed wors—case valvesfothe parametersused in the interfrence clculations, which ld to HchaSa‘s earlr concluton hataccommodation othe proposed new satelte was nottechnically feasible, 2d,at 1. EchoSta demonstited that such analysis s not an accurte predictor ofechnical feasibilit in many case, and that detailed coortination is necessary fopartesto reach informed conclusions with respect t th possiblity ofDBS opertion in a 4.5 spacing environment 14. In particul, Echoar demonstrted the importance otaking int accountthespecific charactrise ofthe particalarstelit under consideation (sich as frequency plas,and modultion and coding). 24at67 EEchoStaralso explained how coortiation allows the parties o conside a wide range ofparametrs(such as relative EIRP level or C/levels, l ofwhich may provide acceptable end resuls, when viewed in combination with othr fctors. 2L at$, 14—18. € 14, 15—18; EchoStar compotesa C aslow as 145 dB forthe worst—cas iterferenceinto the edge ofcoverage ofone ofts spot beams. perscriam

SBS AMERICOM & Pore Presentation Report No. SPB—196, SAT—PDR.—20020425—00071 August 18, 2004 Technical Appendix included (nor are most other Buropean countries), which means that the PFD limits do not apply in Germany. For BSS, European BSS and Region 2 BSS are treated in the same manner in Appendix 30. Both have PFD levels that trigger coordination with terrestrial services on an administration‘s territory, but only in channels that are not assigned to that administration in the Plan or List for BSS. Setting aside whether or not the PFD levels apply in each territory, for the United States and Germany these PFD levels are quite permissive, allowing EIRP levels ofapproximately 63 dBW in 27 MHz or 62.7 dBW in 24 MHz. These levels certainly allow for higher EIRP in Europe than the satellites considered in SES AMERICOM‘s analysis (where the maximum EIRP considered was on the order of53 dBW in 26 MHz). Rain. DIRECTV also argucs that lower C/I levels are acceptable in Burope because it experiences less rain than does the United States." However, the westem half of the United States has comparable rain rates to Europe, or much lower rain rates.". In the southeastem United States, which does have higher rain rates, the impact ofrain is ameliorated by U.S. operators by use of higher EIRP in that area than in other parts of the United States. In a coordination, if the adjacent satellites have similar concentrations ofhigher EIRP levels in the southeast, the C/I levels can be optimized. In addition, the southeastem United States, because of its lower latitudes, has greater topocentric angles than do northem parts of the United States. A greater topocentric angle means a greater off—axis discrimination of the earth station, and hence a higher C/L. In Germany, where the SES AMERICOM analysis was performed, the latitude ranges from approximately 45 to 55 degrees north latitude. This is much further north, and with a correspondingly smaller topocentric angle, than the southeastem United States, which ranges from approximately 25 to 35 degrees north latitude. Depending on the orbital separation considered, the receive anterna size, and the roll—aff ofthe reference anterna pattem, relatively small variations in the topocentric angle can result in over a dB difference in C/. DIRECTV Bx Part, lides —12 1 See Recommendation ITU—R P.837—2. Germany hasrainintensity for 0.01%6 othe average year from 25—30 mmThe UnitedStatesranges from 80 mm in Floidato15 man‘h in th southwest merscrunes

SES AMERICOM & Pare Presentatin Report No. SPB—196, SAT—PDR20020425—00071 August 18, 2004 Technical Appendix Polarization. DIRECTV also argues that Europe employs lincar polarization (‘LP")." which provides better cross—polarization (*X—pol") isolation during rain than circular polarization (°CP")." In general, however,tdifference in the link performance of a CP system as compared to an LP system is not significant. Furthermore, for DTH applications, the X—pol efféct on an average CP or LP link (with decent installer polarization alignment for LP) is almost negligible, so any difference between CP and LP X—pol performance does not significantly affect the analysis. More generally, there are differences in the performance and installation of CP and LP dishes that each operator or service provider assesses in detail prior to deciding which polarization to use. LP dishes have a more complex installation process, because in addition to pointing towards the desired orbit location, the horizontal and vertical polarizations must be rotationallyaligned. This additional alignment requirement can lead to additional losses for LP dishes ifnot performed properly. It is often the simplified installation process that encourages the use of CP for DTH services Dish Pointing. DIRECTV suggests that U.S. receive antennas are more difficult o point than are European anternas, particularly considering the use oftriple= feed dishes in the United States."" The relevant issue here is whether the mispointing angle that SES AMERICOM assumed in its European C/I analysis is appropriate. First, SES AMERICOM used a mispointing of 0.4 degress for the 50 and 60 em dishes in its analysis. In its Petition for Rulemaking, DIRECTV stated that a 0.5 degree mispointing should be used for 4 em dishes."" If one scales the mispointing angle based on increased antenna size, then 0.4 degrees for 50 em dishes is consistent with the 0.5 degree value that DIRECTV proposes Moreover, even if one assumes that the Buropean dishes are casier to point, for 60 em dishes — where the scenarios considered in SES AMERICOM‘s * As noted in the SES AMERICOM presentation,all Ku—band operationsin Europe today are lieatly pobarized, including DBS. £ Parte Noice SES AMERICOM In. Report No. SPB—196; SAT— PDR—20020425—00071, June 15, 2004 (he"SES AMERICOM & Paree®), slie 3. DIRECTV &Pare,side 3. A w °. DIRECTV Enterprises, LLC, Pettionfora Rulemaking on the Feasillity ofReduced Orbial Spacing in the U.S. Diect Broadeast Satelite Service, RM No. 10804Sept 5, 2003,at 17 mervcriemes

SES AMERICOM & Parte Presenttion Report No. SPB—196, SAT—PDR20020425—00071 August 16, 2004 Technical Appendix presentation are generally in the 29—25 log (off—axis angle) portionof the Recommendation BO.1213 antenna pattem — use of a smaller mispointing (such as 0.3 degrees) would only result in a small (about a couple oftenths of a dB) change in the earth station off—axis gain. Use of a smaller mispointing assumption for Europe would not significantly raise the computed O/I values. Conclusion. DIRECTV has not demonstrated that higher C/I levels are needed in the United States than in Europe In any case, each proposal for a satellte at reduced spacing should be judged on its own meris, which requires evaluation ofthe specific operational characteristics of the neighboring satelltes. The C/Irequirements ofthe DIRECTV satellites should be dealt with in the context ofthe ongoing coordinations. nervciama

CERTIEICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING INFORMATION Ihereby dectare thatI am a technically qualified person responsible for preparation ofthe engineering information contained in this expurte presentation, that I am familiar with Part 25 ofthe Commission‘s Rules, and that have either prepared or reviewed the engincering information submitted in this exparte presentation, and that it is complete and accurateto the best ofmy knowledge and belief. By ¢ . Satlite Markert SES AMERICOM, Inc. August 18, 2004


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