Attachment Amendment

Amendment

AMENDMENT submitted by HNS License Sub, LLC (Hughes)

Amendment

2007-02-20

This document pretains to SES-LIC-20061017-01852 for License on a Satellite Earth Station filing.

IBFS_SESLIC2006101701852_551565

                                                24
                         LEVENTHAL SENTER & LERMAN PLLC

                                          February 20, 2007

Stemen D. BarucH                                                                                   Emiu
   gon a165702                                                                              seniuchats.taw.cont
                                                                                                 DRRECT FAX
                                                                                                on 294026




BY HAND DELIVERY
Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
445 12th Street, SW
Washington, DC 20554

                         Re: HNS License Sub, LLC Application for Earth
                             Station License, Castle Rock, Colorado;
                             Call Sign E060382, File No. SES—LIC—20061017—01852

Dear Ms. Dortch:

        HNS License Sub, LLC ("Hughes"), by its attorneys, submits this letter with respect to its
application for a new Earth station at Castle Rock, CO. See Call Sign EO60382, File No. SES—
LIC—20061017—01852, as amended. In its initial application, Hughes requested a waiver of the
requirement in Section 25.115(e) of the Commission‘s Rules, 47 C.F.R. § 25.115(e), to provide
measured data regarding off—axis EIRP spectral density for its proposed new Ka—band antenna.
Hughes noted that the type of antennait proposed to use was a new model that had not yet been
field tested to allow for submission of actual measurement data. It thus sought a limited and
partial waiver of Section 25.115(e) in order to provide actual measurement data on the proposed
antenna with its post—grant certification under Section 25.133(b) of the Commission‘s Rules of
operation in accordance with the license. Hughes Application, File No. SES—LIC—20061017—
01852, at Exhibit C.

         Atthis time, and following consultation with the Commission‘s staff, Hughes withdraws
its request for a waiver of Section 25.115(e). Instead, it will rely on the data and analysis it has
submitted in its application, and will accept a grant that specifies a lower EIRP than the 68.5
dBW level that was requested. Specifically, Hughes has shown in its application, as amended,
that its nominal power at theflange will be —21.7 dBW/40kHz. Based on the off—axis
performancelimits in Section 25.138 of the Commission‘s Rules, 47 C.F.R. § 25.138, an earth
station with an antenna that just met the off—axis gain mask in 47 C.F.R. § 25.209 could have a
flange power that is no more than —10.63 dBW/40kHz. The carrier transmitted by Hughes will
beslightly more than 11 dB below this highest power at theflange that will meetthe off—axis
performance limits. Under these circumstances, and in order to secure a timely grantofits



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February 20, 2007
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   application, Hughes urges that the Commission authorize it now to operate with an EIRP of 56.3
   dBW (11 dB above Hughes‘ nominal EIRP of 45.3 dBW).

           To the extent that actual measurements from the antenna once operational should confirm
   that operating with an additional 12 dB of EIRP would still be compliant with the off—axis EIRP
   density limits in Section 25.138, Hughes reserves the right to return and seek a license
   modification based on such data at the appropriate point in the future. For now, however, it is
   content to rely on the analysis it has provided to date.

             Please do not hesitate to contact the undersigned should you have any questions.

                                              Respectfully submitted,




                                              Steph¢h D. Baruch
                                              Attoriiey for HNS License Sub, LLC

       ce:      Scott Kotler
                Trang Nguyen
                Steven Doiron, Hughes



Document Created: 2007-02-21 11:27:13
Document Modified: 2007-02-21 11:27:13

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