Attachment Letter

This document pretains to SES-MFS-20070419-00489 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2007041900489_580847

@ LEVENTHAL SENTER & LERMAN PLLC July 27, 2007 STEPHEN D. BARUCH E—MAIL (202) 416—6782 SBARUCH@LSL—LAW.COM DIRECT FAX (202) 429—4626 BY HAND DELIVERY Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Application of HNS License Sub, LLC (File No. SES—MFS—20070419—00489) Dear Ms. Dortch: HNS License Sub, LLC ("Hughes"), by its attorneys and pursuant to Section 25.111 of the Commission‘s rules, 47 C.F.R. § 25.111, hereby supplies additional information that has been requested of it by the Commission in connection with the above—referenced application for a modification of Hughes‘ license for a Germantown, MD—based VSAT network (Call Sign EO00166). In its April 2007 Modification of License application, Hughes proposed, inter alia, to add a hub antenna at Hagerstown, MD to its licensed VSAT network. See Modification Application at Exhibit A. Hughes described how it had acquired by contract exclusive rights to access Intelsat‘s Galaxy 26 satellite on specified frequencies via the hub antenna that Intelsat LLC now operates in Hagerstown under Call Sign EO30051. Id. at 1—2. Hughes indicated as well that its traffic through the Hagerstown antenna would be remotely controlled from Hughes‘ Germantown headquarters. See Modification Application, Schedule B, Questions E61—68. In response to a request for further details on the control arrangement, Hughes provides the following explanation. Signals from all Hughes VSAT‘s oriented toward Galaxy 26 will be received by the spacecraft and retransmitted towards Earth using transponders that Hughes has exclusive contractual rights to use. These signals will then be received by the Hagerstown, MD hub antenna and will be downconverted to slightly different L Band frequencies, combined and light multiplexed in order to be sent by optical fiber to the Hughes facility in Germantown. The signals will then be converted back from optical to L—band, separated into individual carriers typically having a bandwidth of 400 kHz, converted into a digital bit stream and then processed by Hughes‘ baseband system. On the reverse path, signals will be transmitted to the VSAT terminals in a similar manner, with the preparation by the Hughes baseband system in Germantown of four separate multiplexed data streams containing data for the many VSAT terminals that operate through Galaxy 26. The data streams will then be modulated into four separate L—band carriers. The carriers will be light multiplexed and sent 2000 K STREET, NW, SUITE 600, WASHINGTON, DC 20006—1809 TELEPHONE 202.429—8970 FAX 202.293.7783 WWWLSL—LAW.COM

@ Marlene H. Dortch July 27, 2007 Page —2— by fiber to the Hagerstown facility. Once received at Hagerstown, the optical signal will be converted back to four L—band signals, which will be translated to Ku band, amplified, and transmitted toward the subject Galaxy 26 transponders and will then be re—transmitted towards Earth for reception by the deployed VSAT‘s. Intelsat cannot access or interpret the digital contents of the modulated carriers it carries, and there is no way for Intelsat to order the shut down of any specific VSAT terminal operating in conjunction with Galaxy 26. At most, Intelsat could effect a disconnection of Hughes signals to the hub antenna, resulting in a broad shutdown of all Hughes VSAT‘s operating on the satellite. Only Hughes staff on duty at the Hughes Network Control Center located in Germantown have the capability of querying and controlling individual VSAT terminals by making use of a network management system which is integrated in the Hughes baseband. Through this management system, Hughes can either reduce the power transmitted by a terminal or altogether disable any specific VSAT. Hughes‘ Network Control Center is manned on a 24/7 basis and has staff having both the training and the tools necessary to investigate and respond to concerns that may be raised about the performance of any specific VSAT or group of VSAT‘s — including those operating through Hagerstown. Hughes stands prepared to provide any additional information the Commission may request. Please do not hesitate to contact me if you have any questions in this regard. Respectfully yours Sllnye /S@phe Baruch Attornéy for HNS License Sub, LLC ce: Scott Kotler, FCC (by e—mail) Steven Doiron, Hughes (by e—mail)


Document Created: 2019-04-17 17:33:27
Document Modified: 2019-04-17 17:33:27
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