Attachment Exhibit 1

This document pretains to SES-AMD-INTR2019-00430 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMDINTR201900430_1628150

                                              EXHIBIT 1

                               DESCRIPTION OF AMENDMENT
                             (Response to Question 43, FCC Form 312)


          Pursuant to 47 C.F.R. § 25.116, HNS License Sub, LLC ( “Hughes”) submits this

amendment to its pending applications (“Applications”) for authority to operate twenty (20)

gateway earth stations1 (listed in Table 1 below) that will communicate with EchoStar XXIV

(also known as “HNS 95W” or “Jupiter 3”), a Ka- and Q/V-band geostationary satellite orbit

(“GSO”) space station licensed to provide fixed-satellite service (“FSS”).2 Specifically, Hughes

seeks to amend its Applications to permit the following changes to its proposed gateway

operations: (i) adding frequencies at 28.6-29.1 GHz (Earth-to-space) for FSS uplinks;3 (ii)

changing the coordinates of the proposed gateway locations to the sites specified in Table 1

below; (iii) increasing the equivalent isotropically radiated power (“EIRP”) and EIRP density;

and (iv) increasing the antenna size of 10 proposed gateways from 9.2 meters to 10 meters in

diameter, as specified in Table 1 below. These changes are further reflected in the

accompanying Schedule B, FCC Form 312, for each proposed gateway. All other information

previously provided in the pending Applications, including requested waivers, remains materially

unchanged.

          Hughes plans to launch and place EchoStar XXIV into operation in 2021. Accordingly,

the Commission should grant the Applications as soon as possible to provide the regulatory



1
    See Hughes, Applications, IBFS File Nos. SES-LIC-20170807-00876 et seq. (Aug. 3, 2017).
2
    See Hughes, Stamp Grant, IBFS File No. SAT-LOA-20170621-00092 (Mar. 20, 2018).
3
  Hughes has filed an application for modification of its EchoStar XXIV satellite license to add the same
Ka-band spectrum for FSS uplinks, along with the 18.8-19.3 GHz band for FSS downlinks to user
terminals. See Hughes, Application for Modification, IBFS File No. SAT-MOD-20190212-00011 (Feb.
12, 2019) (“Satellite Modification Application”).


certainty required to ensure a successful launch of new broadband services, offering substantial

public interest benefits for consumers throughout the country and abroad.

       Proposed Additional Ka-band Spectrum. Hughes seeks to operate its proposed gateways

on additional Ka-band frequencies at 28.6-29.1 GHz (Earth-to-space) in order to provide

additional FSS capacity for broadband services to consumers. The proposed gateways will meet

the antenna performance masks and off-axis EIRP density limits specified in Sections 25.209(a)

and 25.138(a), respectively, of the Commission’s rules for the 28.6-29.1 GHz band (as well as

for other frequency bands).4

       Moreover, consistent with the Commission’s rules and domestic Ka-band plan, 5 the

proposed gateway uplink operations at 28.6-29.1 GHz will be on a secondary (i.e., unprotected,

non-harmful interference) basis with respect to non-GSO (“NGSO”) FSS systems. Hughes will

implement coordination mechanisms to avoid causing harmful interference to authorized NGSO

FSS operations at 28.6-29.1 GHz.6 As previously demonstrated, mutually agreed coordination

agreements will enable shared use of the 28.6-29.1 GHz band, while allowing NGSO systems to

operate free of harmful interference from GSO operations. 7



4
  Hughes’ request set forth in its pending Applications, for a limited waiver of Section 25.132(b)(1)’s
requirement for submission of antenna measurement data remains applicable to the proposed gateways, as
modified hereunder. See Hughes, Applications, Exhibit C, at 2-3 (Waiver Requests). As previously
stated, Hughes will accept a license condition requiring submission of the required antenna measurement
data within 30 days after filing its post-grant certification of completion of construction. See id.
5
 See 47 C.F.R. § 2.106 n.NG165; see also Update to Parts 2 and 25 Concerning Non-Geostationary,
Fixed-Satellite Service Systems and Related Matters, Report and Order and Further Notice of Proposed
Rulemaking, 32 FCC Rcd 7809, ¶ 14 (2017).
6
 See Response of Jennifer A. Manner, Senior Vice President, Regulatory Affairs, Hughes Network
Systems, LLC to letter from Jose P. Albuquerque, Chief, Satellite Division, FCC, IBFS File No. SAT-
LOA-20170621-00092 (Sep. 8, 2017).
7
 See id. In fact, Hughes already has coordination agreements with a number of authorized NGSO FSS
operators, and expects to reach similar coordination arrangements with additional NGSO FSS systems to
provide appropriate technical mechanisms for achieving technical compatibility with those systems.


         Proposed Changes in Gateway Locations, EIRP/EIRP Density, and Antenna Size.

Hughes further seeks to change its proposed gateways to the sites specified in Table 1 below.

Additionally, Hughes seeks to increase the antenna size of ten (10) of its proposed gateways from

9.2 meters to 10 meters in diameter, as specified in Table 1 below. Hughes also seeks to increase

the EIRP and EIRP density, as specified in the accompanying Schedule B for each proposed

gateway.

         Revised technical data, including increased EIRP and EIRP density, for each proposed

gateway is provided in the accompanying Schedule B. As shown in the accompanying Schedule

B, each proposed gateway will meet all applicable antenna performance masks and off-axis EIRP

density limits specified in Sections 25.209(a) and 25.138(a), respectively, of the Commission’s

rules.


      Table 1:       Gateway Earth Station Sites

                                                                           Antenna
                                       Site Contact Information                               Latitude                      Longitude
                                                                           Diameter
       Site and Call Sign                                                  (meters) Degree   Minutes     Seconds   Degree   Minutes     Seconds
          Flagstaff, AZ         1677 E. Butler Ave., Flagstaff, AZ 86001
1.                                          301−428−7205
                                                                             9.2    35         11           25.9   111        37        55.8
           E170156
           Boise, ID           10215 W. Emerald Street, Boise, ID 83704
2.                                        301−428−7205
                                                                             9.2    43         36           27.5   116        18        33.8
           E170155
           Bend, OR            20845 NE Sockeye Place, Bend, OR 97701
3.                                                                           10.0   44         5            10.6   121        17         2.0
           E170151                         301−428−7205
      North Las Vegas, NV     1 Aerojet Way, North Las Vegas, NV 89030
4.                                                                           9.2    36         14           11.8   115         7         5.5
            E170154                         301−428−7205
        Rapid City, SD         3850 Tower Road, Rapid City, SD 57701
5.                                                                           10.0   44         2            53.1   103        14        38.2
            E170157                         301−428−7205
          Billings, MT         1030 Central Avenue, Billings, MT 59102
6.                                          301−428−7205
                                                                             10.0   45         46           7.3    108        32        29.0
           E170158
         Missoula, MT          8404 El Way, Suite 1, Missoula, MT 59808
7.                                          301−428−7205
                                                                             9.2    46         56           10.3   114         6        53.9
           E170168
         Bismarck, ND          4202 Coleman Street, Bismarck, ND 58503
8.                                         301−428−7205
                                                                             10.0   46         51           7.2    100        46        56.7
           E170169
                            1003 East State Farm Road, North Platte, NE
        North Platte, NE
9.                          69103                                            10.0   41         5            26.8   100        45        10.4
           E170170                           301−428−7205
          Tucson, AZ         1135 East Pennsylvania St, Tucson, AZ 85714
10.                                          301−428−7205
                                                                             10.0   32         10           20.4   110        57        17.5
           E170162
         Cheyenne, WY          530 EchoStar Drive, Cheyenne, WY 82007
11.                                         301−428−7205
                                                                             10.0   41         7            54.5   104        44        15.2
           E170164
        Simi Valley, CA         4514 Ish Drive, Simi Valley, CA 93063
12.                                                                          9.2    34         16           9.8    118        42        12.8
           E170163                         301−428−7205


                                  Site Contact Information                Antenna
                                                                                        Latitude                Longitude
                                                                          Diameter
       Quincy, WA           2200 M Street NE, Quincy, WA 98848            (meters)
13.                                                                         10.0   47    14        43.4   119     48        58.7
        E170153                       301−428−7205
         Rifle, CO             235 E 21st Street, Rifle, CO 81650
14.                                                                         9.2    39    32        54.2   107     46        53.9
        E170166                        301−428−7205
        Lindon, UT              333 S 520 W, Lindon, UT 84042
15.                                                                         9.2    40    19        58.1   111     43        50.2
        E170165                         301−428−7205
      Santa Clara, CA     2050 Martin Avenue, Santa Clara, CA 95050
16.                                                                         10.0   37    21        54.3   121     57        41.2
        E170152                        301−428−7205
        Yuma, AZ           575 South Madison Ave, Yuma, AZ 85634
17.                                                                         9.2    32    43        0.0    114     37        8.0
        E170167                        301-428-7205
        Reno, NV        1 Superloop Circle, Suite 3, McCarren, NV 89434
18.                                                                         9.2    39    30        53.0   119     28        46.0
        E170160                          301-428-7205
        Taos, NM          201 Camino de la Merced, Taos, NM 87571
19.                                                                         10.0   36    23        16.0   105     35        16.5
        E170159                        301-428-7205
        Driggs, ID             1670 N Hwy 33, Driggs, ID 83422
20.                                    301-428-7205                         9.2    43    44        53.7   111      6        51.2
        E170161


           Commission Policy and Public Interest Benefits. The proposed gateway amendments

reflect corresponding changes in the EchoStar XXIV satellite design and are integral components

of the overall satellite network, as described in the space station modification application. 8

Commission approval of such technical changes is consistent with the Commission’s established

policy of leaving satellite design decisions to system operators in order “[t]o promote

competition, flexibility, and technical innovation.”9 Accordingly, the Commission consistently

has approved satellite system modifications “when a proposed modification presents no

significant interference problem and conforms to the Commission’s rules and policies.”10

           The EchoStar XXIV satellite system is designed to utilize approximately 20 gateway

earth stations at sites distributed throughout the United States. These sites were selected after

careful examination as they will have sufficient electrical facilities, reliable fiber-delivered

broadband capacity, and ease of access for personnel to provide operational support for the

operation of EchoStar XXIV, which will bring high-speed broadband services throughout the

continental United States and the Americas. The distribution of the gateway earth stations over a

wide area facilitates spectrum efficiency by permitting Hughes to use the same set of frequencies

in the respective uplink beam and downlink beam for each gateway earth station simultaneously,

without causing interference to other gateways. Geographically separated earth stations also

enhance reliability by allowing Hughes to shift traffic among the different gateways in the event

of a transient service interruption at a particular site.

           The changes proposed herein will serve the public interest by adding significant

broadband capacity to the Hughes satellite fleet. EchoStar XXIV, by virtue of its capacity and

8
    See Satellite Modification Application, Exh. 1 (Description) at 2-3.
9
    See New ICO Services G.P., Memorandum Opinion and Order, 21 FCC Rcd 14603, ¶ 5 (IB 2006).
10
     Id.

                                                       6


speed capabilities, will join the Hughes satellite fleet to offer a true competitive broadband

alternative across the country. The EchoStar XXIV satellite system will provide additional

capacity to further enable Hughes to provide advanced broadband services at approximate

download speeds of 100 Mbps to enterprises, the government, small businesses, and residential

customers across the United States. EchoStar XXIV also will support a variety of applications,

including broadband access, aeronautical services for in-flight connectivity, residential and

business VOIP, and next generation communications services, including 5G. Hughes plans to

launch and place EchoStar XXIV into operation in 2021.

          Coordination and Compatibility with Terrestrial Operations. As demonstrated in the

attached Comsearch Report (Attachment A), frequency coordination has been successfully

completed for all proposed Ka-band gateway operations, as amended herein. Specifically, prior

notification letters were sent to incumbent terrestrial Ka-band licensees, and all proposed sites

have cleared the coordination process with no objections or concerns raised.11

          Additionally, as demonstrated in the attached UMFUS Compatibility Showing

(Attachment B), the proposed gateways comply with the Section 25.136’s requirements for

compatibility with UMFUS operations in the 27.5-28.35 GHz (“28 GHz”) and 47.2-48.2 GHz

(“47 GHz”) bands,12 except to the extent that a limited waiver is requested to permit any de

minimis non-conformance with respect to four proposed gateways.

          FAA Notification. For all proposed gateway earth station antennas, the Commission’s

TOWAIR application was used to verify compliance with the limits specified in 47 C.F.R. §


11
  Section 25.136(d)(4)(iv)’s coordination requirement is inapplicable to Hughes’ proposed Q/V-band
gateway operations because there are currently no terrestrial Upper Microwave Flexible Use Service
(“UMFUS”) licensees in the Q/V-band. See 47 C.F.R. § 25.136(d)(4)(iv).
12
     47 C.F.R. § 25.136(a), (d).

                                                  7


17.7(b). As shown in Attachment C (TOWAIR Verification), all gateway earth stations passed

this verification.

       Radiation Hazard Analyses. For the proposed antenna types, radiation hazard analyses

were conducted using the predictive methodology identified in OET Bulletin 65. The results are

provided in Attachment D (RADHAZ Calculations). The analyses were based on the maximum

RF power at the antenna flange of 200 watts for the 9.2-meter and 10-meter antennas. This is the

maximum uplink power control power, which will only be used for very short periods of time

during rain. During clear-sky operations, RF levels will be significantly lower.

        Attachment D shows that the average exposure levels for the protection of the general

public are met in the near field, transition field, far field, and between the reflector and ground.

As is typically the case with parabolic antennas, the average exposure level for the protection of

the general public is exceeded between the feed horn and the reflector. However, since these

large antennas will be mounted on a pedestal, the volume of space between the feed horn and

reflector where the limit is exceeded will always be above the head of anyone standing in front of

the antenna. To further ensure the protection of the general public, the antenna will be located

either behind a fence or on private commercial property with limited access. Technicians

responsible for operating these antennas are trained to shut down and secure the transmitter

before performing any maintenance work.

        Waiver Requests. Hughes renews its requests in the Applications for waivers of the

following requirements to the extent necessary:

        •   Section 25.132(b)(1)’s requirements with respect to certain measured antenna
            information required to be submitted with FSS earth station applications; and




                                                  8


          •   the twelve-month earth station construction and bring-into-use requirement of
              Section 25.133(a)(1).13

Further, as detailed in the attached UMFUS Compatibility Showing (Attachment B), Hughes

requests a limited waiver of Section 25.136’s UMFUS compatibility requirements in order to

permit any de minimis nonconformance with respect to four proposed gateways.

          The requested waivers are necessary to permit efficient design, construction, and

operation of the EchoStar XXIV satellite system. With launch and operation of EchoStar XXIV

scheduled for 2021, Hughes is reaching a crucial time period to begin construction of its

proposed gateway earth stations, including extending fiber to many of these gateway sites.

Accordingly, expeditious action on these Applications, including grant of the requested waivers

of Section 25.133(a)(1)’s construction requirements and other Commission rules, is critical to a

successful launch of new broadband services. Further, grant of the requested waivers will enable

development of an innovative, advanced broadband delivery system potentially reaching

millions of consumers across the United States, providing high-capacity broadband at estimated

download speeds of approximately 100 Mbps, and offering other substantial public interest

benefits described in the initial Applications.

          Conclusion

          As the Commission has noted, 24 million Americans lived in areas that lack terrestrial

fixed, high-speed Internet access at the end of 2016.14 High-speed Internet access is critical to

ensuring economic opportunity and bridging the digital divide, 15 and satellites, including

13
     See Hughes, Applications, Exh. C (Waiver Requests).
14
  See Inquiry Concerning Deployment of Advanced Telecommunications Capability to All Americans in a
Reasonable and Timely Fashion, 2018 Broadband Deployment Report, 33 FCC Rcd 1660 ¶ 50 (2018).
15
  Ajit Pai, Chairman, FCC, Testimony Before the Senate Commerce, Science, and Transportation
Committee: Oversight of the Federal Communications Commission, at 1 (Mar. 8, 2017),
https://apps.fcc.gov/edocs_public/attachmatch/DOC-343814A1.pdf.

                                                    9


Hughes’s fleet of broadband-capable satellites, play a crucial role in expanding such

opportunities to the millions of American customers who live in areas that lack access to

terrestrial high-speed broadband.16 For these reasons, the Commission should promptly grant the

applications, as amended, to operate the proposed gateway earth stations. As demonstrated in the

record, the proposed gateway operations will serve the public interest by advancing the

Commission’s17 and the Administration’s18 goals for solving the digital divide and expanding the

commercial use of space. Timely grant of these Applications, as amended, will permit Hughes to

launch new broadband service as early as 2021, offering substantial public interest benefits for

consumers in the United States and abroad.




16
  See Getting Broadband, FCC, https://www.fcc.gov/consumers/guides/getting-broadband (last visited
Feb. 20, 2019) (“Satellite broadband . . . is useful for serving remote or sparsely populated areas.”).
17
  See, e.g., Bridging the Digital Divide for All Americans (statement of current FCC Broadband Policy),
https://www.fcc.gov/about-fcc/fcc-initiatives/bridging-digital-divide-all-americans (last visited Feb. 20,
2019).
18
  See, e.g., Presidential Memorandum, Space Policy Directive-2 of May 24, 2018: Streamlining
Regulations on Commercial Use of Space, 83 Fed. Reg. 24901 (May 30, 2018).

                                                    10



Document Created: 2010-01-01 00:00:00
Document Modified: 2010-01-01 00:00:00

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