Attachment Exhibit D

This document pretains to SES-MFS-20120319-00276 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2012031900276_945396

                                                 Exhibit D

                                       Intelsat License LLC
                                        Ellenwood, Georgia
                                Vertex/RSI 13.1 Meter Earth Station
                                        Call Sign: E990365

     Compliance with FCC Report & Order (FCC 96-377) for the 13.75 - 14.0 GHz Band
                              Analysis and Calculations

1.       Background

This Exhibit is presented to demonstrate the extent to which the Intelsat License LLC satellite
earth station in Ellenwood, Georgia is in compliance with FCC Report & Order 96-377. The
potential interference from the earth station to U.S. Navy shipboard radiolocation operations
(RADAR) and the NASA space research activities in the 13.75 - 14.0 GHz Band is addressed in
this exhibit. The parameters for the earth station are:

                          Table 1. Earth Station Characteristics

        Coordinates (NAD 83):                       33 39’ 52.4” N, 84 16’ 13.7” W

        Satellite Location for Earth Station:        Telstar 11N at 37.5 WL

        Frequency Band:                              13.75-14.0 GHz for uplink

        Polarizations:                               Linear and Circular

      Emissions:                                     750KF2D
                                                      64K0G7W
                                                      36M0G7W

        Modulation:                                  Digital

        Maximum Aggregate Uplink EIRP:               85.0 dBW for all Carriers

        Transmit Antenna Characteristics
            Antenna Size:                             13.1 meters in Diameter
            Antenna Type/Model:                       Vertex/RSI
            Gain:                                     63.8 dBi

        RF power into Antenna Flange:                750 kHz
                                                      21.2 dBW
                                                      or -1.5 dBW/4 kHz (Maximum)


                                               64 kHz
                                               21.2 dBW
                                               or 9.2 dBW/4 kHz (Maximum)

                                               36 MHz
                                               21.2 dBW or 15.6 dBW/MHz
                                               or -18.3 dBW/4 kHz


        Minimum Elevation Angle:              27.0 @ 117.5 Az. (Telstar-11N)
             Ellenwood, Ga.

        Side Lobe Antenna Gain:                32 - 25*log()


Because the above uplink spectrum is shared with the Federal Government, coordination in this
band requires resolution data pertaining to potential interference between the earth station and
both Navy and NASA systems. Potential interference from the earth station could impact with
the Navy and/or NASA systems in two areas. These areas are noted in FCC Report and Order
96-377 dated September 1996, and consist of (1) Radiolocation and radio navigation, (2) Data
Relay Satellites.


Summary of Coordination Issues:

1) Potential Impact to Government Radiolocation (Shipboard Radar)
2) Potential Impact to NASA Data Relay Satellite Systems (TDRSS)




2.       Potential Impact to Government Radiolocation (Shipboard Radar)

Radiolocation operations (RADAR) may occur anywhere in the 13.4 - 14 GHz frequency band
aboard ocean going U.S. Navy ships. The FCC’s Report & Order 96-377 allocates the top 250
MHz of this 600 MHz band to the Fixed Satellite Service (FSS) on a co-primary basis with the
radiolocation operations and provides for an interference protection level of -167 dBW/m2/4
kHz.

The closest distance to the shoreline from the Ellenwood earth station is approximately 369 km
Southeast toward the Atlantic Ocean.


The calculation of the power spectral density at this distance is given by:

                                              750 kHz          64 kHz         36 MHz

       1. Clear Sky EIRP:                                     85.00 dBW
       2. Carrier Bandwidth:                   750 kHz           64 kHz        36 MHz
       3. PD at antenna input:                  -1.5            9.2           -18.3
           (dBW/4 kHz)
       4. Transmit Antenna Gain:                            63.8 dBi
       5. Antenna Gain Horizon:                         FCC Reference Pattern
       6. Antenna Elevation Angle:             27.0° Toward Telstar-11N (117.5 Az.)


The existing earth station will radiate interference toward the ocean according to its off-axis side-
lobe performance. A conservative analysis, using FCC standard reference pattern, results in off-
axis antenna gains of -10.0 dBi towards the Atlantic Ocean.

The signal density at the shoreline, through free space is:

750 kHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = -1.5 dBw/4 kHz + (-10.0 dBi) – 10*log[4*(369000m)2]
      = -133.8 dBW/m2/4 kHz + Additional Path Losses (~87.0 dB)
      = -220.8 dBW/m2/4 kHz

64 kHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = 9.2 dBw/4 kHz + (-10.0 dBi) – 10*log[4*(369000m)2]
      = -123.1 dBW/m2/4 kHz + Additional Path Losses (~87.0 dB)
      = -210.1 dBW/m2/4 kHz

36 MHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).
      = -18.3 dBw/4 kHz + (-10.0 dBi) – 10*log[4*(369000m)2]
      = -150.6 dBW/m2/4 kHz + Additional Path Losses (~87.0 dB)
      = -237.6 dBW/m2/4 kHz

Our calculations show additional path loss of approximately 87.0 dB including absorption loss
and earth diffraction loss for the actual path profiles from the proposed earth station to the closest
shoreline.


For the 750 kHz carriers, the calculated PFD including additional path losses to the closest
shoreline location is –220.8 dBW/m2/4 kHz. This is 53.8 dB below the –167 dBW/m2/4 kHz
interference criteria of R&O 96-377. For the 64 MHz carriers, the calculated PFD including
additional path losses to the closest shoreline location is –210.1 dBW/m2/4 kHz. This is 43.1 dB
below the –167 dBW/m2/4 kHz interference criteria of Report & Order 96-377. For the 36 MHz
carriers, the calculated PFD including additional path losses to the closest shoreline location is –
237.6 dBW/m2/4 kHz. This is 70.6 dB below the –167 dBW/m2/4 kHz interference criteria of
Report & Order 96-377. Therefore, for all emissions, there should be no interference to the U.S.
Navy RADAR from the Ellenwood earth station due to the distance and the terrain blockage
between the site and the shore.




3.     Potential Impact to NASA’s Data Relay Satellite System (TDRSS)

The geographic location of the Intelsat License LLC earth station in Ellenwood, Georgia is
outside the 390 km radius coordination contour surrounding NASA’s White Sands, New Mexico
ground station complex. Therefore, the TDRSS space-to-earth link will not be impacted by the
Intelsat earth station in Ellenwood, Georgia.


The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if
an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 13.1 meter earth
station dish will have an EIRP greater than 71 dBW/6 MHz in this band. The total EIRP for all
carriers is 85.0 dBW, and the equivalent EIRP per 6 MHz segment remains at 85.0 dBW/6 MHz
for the 750 kHz and the 64 kHz emissions. The total EIRP for the 36 MHz carriers is 85.0 dBW,
and the equivalent EIRP per 6 MHz segment will be 77.2 dBW/6 MHz. Therefore, there will be
interference to the TDRSS space-to-space link (Table 1).

In order to meet the 71 dBW/6 MHz interference criteria, the earth station would have to be
limited to an RF power density 14 dB lower than the maximum of -1.5 dBW/4kHz or -15.5
dBW/4kHz for the 750 kHz carriers. The earth station would also have to be limited to an RF
power density 14 dB lower than the maximum of 9.2 dBW/4kHz or -4.8 dBW/4kHz for the 64
MHz carriers and an EIRP of 71.0 dBW. Finally, in order to meet the 71 dBW/6 MHz
interference criteria, the earth station would have to be limited to an RF power density 6.3 dB
lower than the maximum of -18.3 dBW/4kHz or -24.6 dBW/4kHz for the 36 MHz carriers.

If this operational condition cannot be met, then the Ellenwood, Georgia earth station may not be
tuned to operate at the frequencies in the 13.772 to 13.778 GHz Band.


4.   Coordination Issue Result Summary and Conclusions

The results of the analysis and calculations performed in this exhibit indicate that compatible
operations between the earth station at the Ellenwood facility and the U.S. Navy and NASA
systems space-to-earth link are possible. These analyses have been based on the assumption of
750 kHz, 64 kHz and 36 MHz bandwidth carriers. Operations in NASA systems space-to-space
link (13772.0 to 13778.0 MHz) will not be permitted.


                                            Table 1

            Excluded Frequency Range for Intelsat License LLC Earth Station

              System                        Frequency Restriction
              TDRSS                         13.770-13.780 GHz (see Note 1)



Note 1: In order to meet the 71 dBW/6 MHz interference criteria, the earth station would have to
be limited to a maximum total EIRP of 71.0 dBW.

No interference to U.S. Navy RADAR operations from the Ellenwood, Georgia site earth station
will occur.



Document Created: 2012-03-19 10:24:21
Document Modified: 2012-03-19 10:24:21

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