Attachment Narrative SAT-STA-20100920-00197

Attachment Narrative

This document pretains to SAT-STA-20100920-00197 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010092000197_840884

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

)
)
In the Matter of )
)
ECHOSTAR CORPORATION ) File No. SAT-STA-2010____-_____
) Call Signs S2454 and S2621
Application for Special Temporary Authority )
to Operate DBS Services at 86.5º W.L. )
Using the EchoStar 4 Satellite )
)

EXPEDITED CONSIDERATION REQUESTED

APPLICATION FOR SPECIAL TEMPORARY AUTHORITY

By this application, and pursuant to Section 25.120(b)(4) of the Commission’s rules, 47

C.F.R. § 25.120(b)(4), EchoStar Corporation (“EchoStar”) respectfully requests Special

Temporary Authority (“STA”) to operate in the Direct Broadcast Satellite (“DBS”) service at the

86.5º W.L. orbital location for a period of 30 days.1 Specifically, EchoStar requests STA to

operate on the DBS frequencies of that location by using the EchoStar 4 satellite. In parallel

with this application, EchoStar requests STA to move the EchoStar 4 satellite from the 77º W.L.

orbital location, where it is currently stationed as a Mexican-licensed satellite, to 86.5º W.L.2

1
See EchoStar Satellite L.L.C. Application to Construct, Launch and Operate a Direct
Broadcast Satellite at the 86.5º W.L. Orbital Location, Order and Authorization, 21 FCC Rcd.
14045 (2006) (“86.5º W.L. Order”). In support of this application, and out of an abundance of
caution, EchoStar submits the information called for by Schedule S, as well as additional
information set forth in the attached Technical Annex. Today, EchoStar is also filing a request
for STA to operate the satellite for 180 days beginning on the expiration of the 30-day period
requested herein.
2
See File No. SAT-STA-2010____-_____. EchoStar also intends to request modification
of its underlying authorization for the 86.5º W.L. orbital location. In evaluating this STA
request, however, the Commission need not address any of the issues arising in that modification

The grant of this application will not cause harmful interference to any authorized user of

the spectrum, and is in the public interest. The application will specifically allow the provision

of additional DBS services from the 86.5º W.L. orbital location years earlier than contemplated

by EchoStar’s license. This significant acceleration will be accomplished without loss of any

services from 77º W.L.

EchoStar requests that this STA be granted for 30 days commencing no later than

November 24, 2010.

I. BACKGROUND AND INTRODUCTION

On November 26, 2006, the Commission authorized EchoStar Satellite L.L.C., a

predecessor-in-interest of EchoStar, to construct a new DBS satellite at the 86.5º W.L. orbital

location.3 As a condition of the Order and Authorization, the Commission mandated that

EchoStar file a modification application specifying its end-of-life planned operations for the

satellite and submitting an orbital debris mitigation statement.4 Authority to launch and operate

the satellite will “be granted if the information submitted demonstrates that EchoStar’s orbital

debris mitigation plans are in the public interest.”5 On December 29, 2008, EchoStar submitted

such a modification application, which remains pending.6 The milestone schedule incorporated

application. The move of EchoStar 4 will be at EchoStar’s own risk, and without prejudice to
the Commission’s ability to judge the modification application on its merits. In addition,
EchoStar intends to file STA requests and modification applications for three earth stations, Call
Signs E070014, E980005, and E020306, to broadcast operations from EchoStar 4 at 86.5º W.L.
by adding the satellite as a point of communication.
3
86.5º W.L. Order ¶ 1.
4
Id. ¶ 28(e).
5
Id.
6
See File No. SAT-MOD-20081229-00239 (filed Dec. 29, 2008).

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in the authorization required EchoStar to complete contracting for its proposed satellite within

one year of the date of the grant; complete its critical design review within two years; complete

construction of the first satellite in the system within four years; and operate its satellite within

six years.7 EchoStar has complied with all of the milestones to date – i.e., with the first two

milestones.

EchoStar 4 is currently a Mexican-licensed satellite operating at the 77º W.L. orbital

location. The satellite’s move to that slot was made subject to an exchange of letters between the

Commission and the Mexican Administration.8 EchoStar 4’s stay at 77º W.L. is further

governed by the license granted to EchoStar’s partner, QuetzSat, S. de R.L. de C.V.

(“QuetzSat”), to use the nominal 77º W.L. orbital location, and by agreements among EchoStar,

SES Global Latin America, S.A. (“SES”), and QuetzSat.9

Under these documents, while at 77º W.L., EchoStar 4 is under the direct control of

QuetzSat, which is allowed to use the nominal 77º W.L. orbital location pursuant to the February

2, 2005 BSS Concession.10 But the exchange of letters also established a clear distinction

between the satellite’s operations at 77º W.L. and any future operations at another orbital

location: “Any operations of the EchoStar 4, other than at the 77º W.L. orbital location, will be

7
86.5º W.L. Order ¶ 30.
8
See EchoStar Satellite LLC Application for Special Temporary Authority to Conduct
Telemetry, Tracking, and Command Operations during the Relocation of EchoStar 4 to the 77º
W.L. Orbital Location, Order and Authorization, 21 FCC Rcd. 4077 at Appendix A (2006) (“77º
W.L. Order”).
9
See Satellite Relocation and Use Agreement for the 77º W.L. Orbital Location, filed in
File No. SAT-STA-20080616-00121, Attachment 3 (granted Oct. 31, 2008) (“EchoStar 8 STA
Application”).
10
BSS Concession, filed in EchoStar 8 STA Application, Attachment 2.

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subject to issuance of a new authorization by the FCC.” 11 Accordingly, the relocation of

EchoStar 4 to the 86.5º W.L. orbital location requires the Commission’s authorization because

EchoStar 4 would no longer be “flagged” as a Mexican-licensed satellite, but a U.S.-licensed

satellite. EchoStar, moreover, understands that neither the Mexican Administration nor QuetzSat

objects to the satellite’s move.12

II. INCLINED ORBIT OPERATIONS

EchoStar plans to operate the EchoStar 4 satellite in inclined orbit mode and to give the

Commission notice as contemplated in the Commission’s rules, 47 C.F.R. § 25.280. All the

prerequisites for inclined mode operation set forth in the Commission’s Rules, 47 C.F.R.

§ 25.280(b), will be satisfied.

III. GRANT OF THIS APPLICATION IS IN THE PUBLIC INTEREST AND WILL
NOT CAUSE HARMFUL INTERFERENCE

The public interest will be served by the grant of this application because U.S. consumers

will have access to additional DBS satellite capacity, thereby increasing the video programming

options available to them, years earlier than currently contemplated under EchoStar’s license.

11
77º W.L. Order, Appendix A at 8.
12
According to the exchange of letters, “in the event that there are any provisions in the
Concession, or any provisions in the Mexican laws and regulations governing the
telecommunications operations of EchoStar that would preclude or otherwise limit the exercise
of EchoStar’s contractual rights within the time frames specified in the EchoStar/SES
Agreement, the FCC would appreciate the opportunity to consult with SCT prior to any exercise
of such licensing authority or application of such law or regulation by SCT.” Id., Appendix A at
9. In response, the Mexican Administration has stated that “there are no provisions in the
license, in our laws or in our regulation that may be applied to directly hinder or limit EchoStar
from exercising its contractual rights with SES.” Id., Appendix A at 16.

-4-

Nor will the move of the satellite entail loss of any service from 77º W.L., where another two

EchoStar satellites, EchoStar 8 and EchoStar 1, are now operational.13

Among other things, EchoStar 4 will provide high-definition (“HD”) local-into-local

broadcast service to the United States from the 86.5º W.L. orbital location

EchoStar 4 will not cause harmful interference at 86.5º W.L. to other authorized satellites

because EchoStar 4 will operate on an unprotected, non-harmful interference basis. In the event

that the satellite causes harmful interference, EchoStar will cease operations immediately.

IV. REQUEST FOR EXPEDITED CONSIDERATION

EchoStar respectfully requests that the Commission grant the requested authority by no

later than November 24, 2010 so that EchoStar’s customer, DISH Network, can marshal this

additional capability to provide additional HD programming. In particular, the prompt move of

EchoStar 4 will help DISH in its efforts to comply with the upcoming February 2011 deadline in

the Commission’s timeline for HD local station carriage.14

V. WAIVER PURSUANT TO SECTION 304 OF THE ACT

In accordance with Section 304 of the Communications Act of 1934, as amended 47

U.S.C. § 304, EchoStar hereby waives any claim to the use of any particular frequency or of the

13
See Stamp Grant, File No. SAT-T/C-20090217-00026, Call Sign S2439 (granted Sept.
17, 2010) (EchoStar 8); Stamp Grant, File No. SAT-T/C-20090217-00027, Call Sign S2739
(granted Sept. 17, 2010) (EchoStar 1). Pursuant to an exchange of letters between the
Commission and the Mexican Administration, “EchoStar 1 and EchoStar 8 spacecraft will
operate at the 77º W.L. orbital location subject to Mexican authority.” Id. at Annex A, 2.
14
Carriage of Digital Television Broadcast Signals: Amendment to Part 76 of the
Commission’s Rules, Second Report and Order, Memorandum Opinion and Order, and Second
Further Notice of Proposed Rulemaking, 23 FCC Rcd. 5351 ¶ 8 (2008) (requiring 30 percent of
each satellite carrier’s HD markets to comply with the HD carry-one, carry-all requirement no
later than February 17, 2011).

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electromagnetic spectrum as against the regulatory power of the United States because of the

previous use of the same, whether by license or otherwise.

VI. CONCLUSION

For the foregoing reasons, EchoStar respectfully requests the grant of its application for

STA for 30 days to operate DBS services at 86.5º W.L. by using the EchoStar 4 satellite.

EchoStar will operate EchoStar 4 at 86.5º W.L. subject to the following conditions.

a) All operations at 86.5º W.L. shall be on a non-harmful interference basis, meaning that
EchoStar shall not cause interference to, and shall not claim protection from, interference
caused to it by any other lawfully operating satellites.

b) In the event that any harmful interference is caused while the satellite is operating at
86.5º W.L., EchoStar shall cease operations immediately upon notification of such
interference and shall inform the Commission immediately, in writing, of such event.

Respectfully submitted,

EchoStar Corporation

________/s/___________
Pantelis Michalopoulos Alison Minea
Christopher R. Bjornson Corporate Counsel
L. Lisa Sandoval EchoStar Corporation
Steptoe & Johnson LLP 1110 Vermont Avenue, NW, Suite 750
1330 Connecticut Avenue, N.W. Washington, D.C. 20005
Washington, D.C. 20036 (202) 293-0981
(202) 429-3000
Counsel for EchoStar Corporation

September 20, 2010

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ECHOSTAR-4

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
§ 25 rules that cannot be entered into the Schedule S software.

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

The ECHOSTAR-4 satellite will operate at the 86.5° W.L. orbital location and will provide BSS
services to CONUS and Mexico by means of two broad beams, to be referred to as the CONUS
beam and the Mexican beam. The satellite was designed to provide 32 channels in medium
power mode or 16 channels in high power mode.

The satellite will be biased such that the beams are steered towards the south in order to protect
the operations of Telesat Canada at the nominal 82° W.L. and 91° W.L. orbital locations. The
coverage of the CONUS beam will be a function of this biasing. The Mexican beam’s reflector
is “gimbaled” and it will be pointed further south in order to provide service to Mexico. The
CONUS beam will be operated in normal-mode only with a peak downlink EIRP of 54.9 dBW.
The Mexican beam can be operated either in normal-mode or high-powered-mode, the latter with
a peak downlink EIRP of 57.6 dBW.

EchoStar will use its two main feeder link earth station facilities with the ECHOSTAR-4
satellite. These are located in Cheyenne, WY and Gilbert, AZ. Spacecraft TT&C functions will

1

take place from EchoStar’s primary TT&C earth station and satellite control facility located in
Cheyenne, WY and the back-up facility located in Gilbert, AZ.

The satellite will be operated with an east-west station-keeping tolerance of ±0.05 degrees and
will be operated in an inclined orbit.

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

The ECHOSTAR-4 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.
These contours reflect the planned biasing of the satellite and the adjustment of the Mexican
beam’s reflector.

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

The ECHOSTAR-4 satellite will provide a range of DBS services to millions of small and
inexpensive subscriber receive-only earth terminals.

Representative link budgets, which include details of the transmission characteristics,
performance objectives and earth station characteristics, are provided in the associated Schedule
S submission.

A.5 Satellite Transponder Frequency Responses
(§ 25.114(c)(4)(vii))

The typical receiver and transmitter frequency responses of each RF channel, as measured
between the receive antenna input and transmit antenna, fall within the limits shown in Table
A.5-1 below.

2

In addition, the frequency tolerances of § 25.202(e) and the out-of-band emission limits of
§ 25.202(f)(1), (2), and (3) will be met.

Table A.5-1: Typical Receiver and Transmitter Filter Responses

Offset from Channel Center Receiver Filter Response (dB) Transmitter Filter Response (dB)
Frequency (MHz)

±5 > -0.5 > -0.4

±7 > -0.7 > -0.5

±9 > -1.0 > -0.8

±11 > -1.5 > -1.7

±12 > -2.0 > -3.6

±17.5 < -18 < -8

±20.2 < -38 < -18

±27.2 < -50 < -35

3

A.6 TT&C Characteristics
(§ 25.114(c)(4)(i) and § 25.114(c)(9))

A summary of the TT&C subsystem performance is given in Table A.6-1.

Table A.6-1: Summary of the TT&C Subsystem Performance

Parameter Performance

On-Station Command Frequency 17,308 MHz
Uplink Flux Density Between -90 and -75 dBW/m2
Uplink Polarization Linear (Vertical)
12,200.5 MHz
On-Station Telemetry Frequencies 12,202.5 MHz
12,698.5 MHz
Maximum Downlink EIRP 15.0 dBW
Downlink Polarization Linear (Vertical)

A.7 Interference Analyses
(§ 25.214(d)(13))

The ECHOSTAR-4 satellite network will operate on an unprotected, non-harmful interference
basis. In the event operations of the ECHOSTAR-4 satellite network cause harmful interference
into these of any other network, EchoStar will either cease operations, or reduce transmission
levels appropriately, immediately upon notification of such interference.

The analyses of the proposed ECHOSTAR-4 satellite network with respect to the limits in
Annex 1 to Appendices 30 and 30A are provided for illustrative purposes in Appendices 1 and 2
to this document. The results of these analyses are discussed below.

4

Appendix 1 shows that the proposed ECHOSTAR-4 satellite network meets the ITU criteria in
the Annex 1 to Appendix 30, except for § 4.2.3 c) of Article 4 of Appendix 30/30A. There are a
number of adjacent Region 2 BSS networks that were deemed to be affected (see Annex 1 to
Appendix 1). The affected foreign administrations are the Bahamas, Canada, Cuba, Dominican
Republic, Haiti, Jamaica, Mexico, Peru, Russia and the United Kingdom. Each of the affected
networks is discussed below:

 The affected networks of the Bahamas, Cuba, Dominican Republic, Haiti, Jamaica and
Peru are all original Plan networks. None of these networks is currently operational, nor
can we find any evidence that any of these networks are under construction or scheduled
for launch.

 The Canadian networks at the nominal 82° W.L. and 91° W.L. locations are deemed to be
affected. The Canadian networks are assigned to Telesat Canada. EchoStar and Telesat
Canada have an agreement in principle for operation of the ECHOSTAR-4 satellite at
86.5° W.L. Telesat Canada has informed EchoStar as to the maximum downlink EIRP
levels that the ECHOSTAR-4 satellite can cause over Canadian territory. The beams of
the ECHOSTAR-4 satellite will be biased towards the south specifically to protect the
Canadian networks to these protection levels.

 Mexico’s networks at the nominal 77° W.L. location are deemed to be affected. The
Mexican networks are assigned to QuetzSat. EchoStar will coordinate the operations of
the ECHOSTAR-4 satellite network with QuetzSat. Coordination should be straight
forward given the 9.5 degree orbital separation.

 Russia’s network at 47.5°W.L. is deemed to be affected. We can find no evidence that
this network is under construction or scheduled for launch. In the event that the network
is progressed, it is expected that coordination could be achieved given the large orbital
separation and the small OEPM degradation caused to the network.

5

 The United Kingdom has five networks at 86.5°W.L. We can find no evidence that any
of the networks are under construction or scheduled for launch.

In addition, there are two USA networks that are deemed to be affected: USABSS-9 at 148°
W.L. and USABSS-15 at 110° W.L. Both of these networks receive small OEPM degradations
and both are assigned to EchoStar’s affiliate, DISH Network.

Based on the preceding, EchoStar concludes that operation of the ECHOSTAR-4 satellite will
not cause harmful interference, or even unacceptable interference, into any adjacent operational
satellite network.

Appendix 2 shows that the proposed ECHOSTAR-4 satellite network meets all of the ITU
criteria in Annex 1 to Appendix 30A.

A.8 Orbital Debris Mitigation Plan
(§ 25.114(d)(14))

A.8.1 Spacecraft Hardware Design

The EchoStar-4 satellite was designed and manufactured by Lockheed Martin and was launched
in 1998. The satellite will not undergo any planned release of debris during its operation.
EchoStar and the satellite manufacturer have assessed and limited the probability of the satellite
becoming a source of debris by collisions with small debris or meteoroids of less than one
centimeter in diameter that could cause loss of control and prevent post-mission disposal. Such
probability has been limited through component placement and the use of redundant systems.

The ECHOSTAR-4 satellite has separate TT&C and propulsion subsystems that are necessary
for end-of-life disposal. The spacecraft TT&C system, vital for orbit raising, is extremely
rugged with regard to meteoroids smaller than 1 cm, by virtue of its redundancy, shielding,
separation of components and physical characteristics. An omni-directional antenna and wide

6

angle horn system are used principally during orbit raising. The command receivers and
decoders and telemetry encoders and transmitters are located within a shielded area and are
redundant and physically separated. A single rugged thruster and shielded propellant tank
provides the energy for orbit raising. Otherwise, there are no single points of failure in the
system.

A.8.2 Accidental Explosion Assessment
(§ 25.144(d)(14)(ii))

EchoStar has assessed and limited the probability of accidental explosions during and after
completion of mission operations. A Failure Mode Verification Analysis has also been
conducted, and the probability of accidental explosions has been limited through extensive
monitoring of ECHOSTAR-4 satellite’s batteries and fuel tanks for pressure and temperature.
Furthermore, bipropellant mixing is prevented by the use of valves that prevent backwards flow
in propellant lines and pressurization lines. Excessive battery charging or discharging is limited
by a monitoring and control system which will automatically limit the possibility of
fragmentation. Corrective action, if not automatically undertaken, will be immediately
undertaken by the spacecraft operator to avoid destruction and fragmentation. Thruster
temperatures, impulse and thrust duration are carefully monitored, and any thruster may be
turned off via redundant valves. At the end of the satellite’s life, all energy sources will be
depleted. Specifically, the batteries will be left in a permanent state of discharge, chemical
propulsion systems will be depleted, and the electrical propulsion system will be disabled.

A.8.3 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-4 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,
networks for which a request for coordination has been submitted to the ITU within ±0.15
degrees of 86.5° W.L. have also been reviewed.

7

There are no operational satellites in the immediate vicinity of 86.5°W.L., nor are there any
pending applications before the Commission to use a slot in the immediate vicinity of 86.5°W.L.

Canada has made ITU submissions for two 17/24 GHz networks at 86.5°W.L. and the UK has
made ITU submissions for five BSS networks at 86.5°W.L. EchoStar can find no evidence that
any of these networks are under construction or scheduled for launch.

Based on the preceding, EchoStar concludes there is no requirement to physically coordinate the
ECHOSTAR-4 satellite with another satellite operator at the present time.

A.8.4 Post Mission Disposal Plan
(§25.144(d)(14)(iv))

Upon mission completion, the ECHOSTAR-4 will be maneuvered to a disposal orbit at least 300
km above its operational geostationary orbit1. EchoStar will reserve 11 kg of fuel to achieve the
disposal orbit at the end of the satellite’s life. The fuel reserve was calculated using two
methods. The first method applied was the pressure-volume temperature method, which uses
tank pressure and temperature information to determine remaining propellant. The second
method applied was the bookkeeping method, which evaluates the flow rate at average pressure
and total thruster on-time of orbital maneuvers to determine the amount of propellant used.
EchoStar has assessed fuel gauging uncertainty and has provided an adequate margin of fuel to
address such uncertainty.

___________________________________

1
The ECHOSTAR-4 satellite was launched in 1998. Pursuant to the Second Report and Order, a calculation of
the satellite’s disposal orbit according to the IADC formula is not required. See Second Report and Order at
¶81 (“we will grandfather all on orbit GEO spacecraft that were launched as of the release of the Notice in this
proceeding”).

8

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/
¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯¯
Stephen D. McNeil
Telecomm Strategies Canada, Inc.
Ottawa, Ontario, Canada
(613) 270-1177

9

APPENDIX 1 TO
ATTACHMENT A (TECHNICAL INFORMATION TO SUPPLEMENT
SCHEDULE S)

Analysis of ANNEX 1 of Appendix 30

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
2673. The CONUS beam was assumed to operate with a peak downlink EIRP of 54.9 dBW,
while the Mexican beam was assumed to transmit with a peak downlink EIRP of 57.6 dBW. The
results of the analysis are contained in Annex 1 to this Appendix. As shown, the affected foreign
administrations are Bahamas, Canada, Cuba, Dominican Republic, Haiti, Jamaica, Mexico, Peru,
Russia and the UK. The results are discussed below for each of these administrations:

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

Page A2-1 of A1-6

 The affected networks of the Bahamas, Cuba, Dominican Republic, Haiti, Jamaica and
Peru are all original Plan networks. None of these networks are currently operational.
The ECHOSTAR-4 satellite network will operate on an unprotected, non-harmful
interference basis. In the event operations of the ECHOSTAR-4 satellite network cause
harmful interference into these and any other network, EchoStar will either cease
operations, or reduce transmission levels appropriately, immediately upon notification of
such interference.
 The Canadian networks at the nominal 82°W.L. and 91°W.L. locations are deemed to be
affected. The Canadian networks are assigned to Telesat Canada. EchoStar and Telesat
Canada have an agreement in principle. The beams of the ECHOSTAR-4 satellite will be
biased towards the south specifically to protect the Canadian networks to the protection
levels required by Telesat Canada.
 Mexico’s networks at the nominal 77°W.L. location are deemed to be affected. The
Mexican networks are assigned to QuetzSat. EchoStar will coordinate the operations of
the ECHOSTAR-4 satellite network with QuetzSat. Coordination should be straight
forward given the 9.5 degree orbital separation.
 Russia’s network at 47.5°W.L. is deemed to be affected. We can find no evidence that
this network is under construction or scheduled for launch.
 The UK has five networks at 86.5°W.L. We can find no evidence that any of the
networks are under construction or scheduled for launch.

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/(m · 27 MHz))
2
for 0.23    2.0
–136.7  1.66  2 2
dB(W/(m · 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 A2-2 of A1-6

The closest Regions 1 and 3 BSS network is the Russian INTERSPUTNIK-47.5W-B network at
47.5°W, which is greater than 10.57 degrees from the 86.5°W.L. location, 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 ECHOSTAR-4 satellite 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 ECHOSTAR-4 satellite network. The GIMS pfd tool showed that no
Administrations are affected and therefore the ECHOSTAR-4 satellite is compliant with this
Section.

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 A2-3 of A1-6

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 GIMS pfd tool was used to verify compliance with this Section. All Regions 1 and 3 FSS
satellites are greater than 10.57° from the 86.5°W.L. location, therefore the –131.9 dB (W/(m2 .
40 kHz)) level applies. The results of the GIMS analysis shows that no administrations are
affected. Therefore the ECHOSTAR-4 satellite network is compliant with this Section.

32
Including assignments operating under No. 5.485.

Page A2-4 of A1-6

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 stations can be affected and the ECHOSTAR-4 satellite network is compliant with this
Section.

Page A2-5 of A1-6

Annex 1 to Appendix 1 to Technical Annex

ECHOSTAR-4

MSPACE Results

Orbital Max. OEPM
Admin Position Network Degradation
(degrees E) (dB)

BAH -87.20 BAHIFRB1 20.052
JMC -92.30 CRBBAH01 0.678
JMC -92.30 CRBBLZ01 3.205
JMC -92.30 CRBJMC01 0.286
JMC -92.70 JMC00002 0.481
CUB -89.20 CUB00001 5.145
DOM -83.30 DOMIFRB2 1.784
HTI -83.30 HTI00002 3.069
PRU -85.80 PRU00004 0.358
CAN -82.00 CAN-BSS1 1.320
CAN -91.10 CAN-BSS2 1.837
MEX -77.00 MEX-TDH1 1.272
MEX -76.80 MEX-TVD1 0.954
MEX -77.20 MEX-TVD2 0.660
MEX -77.00 QUETZSAT-77 1.511
USA -148.00 USABSS-9 0.275
USA -110.00 USABSS-15 0.396
G -86.50 USAT-S3 31.342
G -86.50 USAT-S3 MOD-A 29.861
G -86.50 USAT-S3 MOD-B 30.076
G -86.50 USAT-S3 MOD-C 29.990
G -86.50 USAT-S3 MOD-D 29.861
RUS -47.50 INTERSPUTNIK-47.5W-B 0.296

Page A2-6 of A1-6

APPENDIX 2 TO
ATTACHMENT A (TECHNICAL INFORMATION TO SUPPLEMENT
SCHEDULE S)

Analysis of ANNEX 1 of Appendix 30A

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 shows the results of  T / T calculations for the closest Regions 1 and 3
feeder link space stations, based on the Region 1 and 3 Plan and List. As shown the  T / T’s are
well below the allowed 6% level. Therefore the ECHOSTAR-4 satellite network is in
conformity with this Section.

Page A2-2 of A2-3

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 (%)
Network Name Orbital Peak Victim Temp
Position Receive Satellite (K)
Antenna (dBi)
Gain
(dBi)

INTERSPUTNIK-
-47.5 37 33.3 -111.8 40296 -10 600 0.01%
47.5W-B

MCO-BSS-40.5W -40.5 35.9 33.3 -111.8 40921 -10 600 0.01%

IRL21100 -37.2 48.08 33.3 -111.8 41222 -10 600 0.15%

NGR11500 -37.2 38.47 33.3 -111.8 41222 -10 600 0.02%

DBL-G4-37.2W -37.2 35 33.3 -111.8 41222 -10 300 0.01%

AND34100 -37 48.88 33.3 -111.8 41241 -10 600 0.18%

GMB30200 -37 47.69 33.3 -111.8 41241 -10 600 0.13%

GUI19200 -37 42.29 33.3 -111.8 41241 -10 600 0.04%

POR__100 -37 47.17 33.3 -111.8 41241 -10 600 0.12%

MTN__100 -36.8 37.55 33.3 -111.8 41259 -10 600 0.01%

SMR31100 -36.8 48.88 33.3 -111.8 41259 -10 600 0.18%

6 Limits applicable to protect a frequency assignment in the band 17.8- 18.1 GHz
(Region 2) to a receiving feeder-link space station in the fixed-satellite service
(earth-to-space) (WRC-03)

Does not apply to Region 2 Plan.

Page A2-3 of A2-3

Document Created: 2010-09-20 19:36:21
Document Modified: 2010-09-20 19:36:21

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