Attachment Exhibits A-D

This document pretains to SES-MFS-20140314-00140 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2014031400140_1039514

                                                                               DNET Group, Inc.
                                     Modification Adding Extended Ku-band Frequencies to E120231
                                                                                        Exhibit A

                               EXHIBIT A – APPLICATION SUMMARY

1.0 - Description of Application

        The instant modification application seeks authority for DNET Group, Inc. (“DNET”) to
communicate with the Amazonas-3 satellite located at 61° West longitude in the geostationary
arc using extended Ku-band frequencies.1 Specifically, DNET seeks to modify its authority
under Call Sign E120231 to permit transmission earth-to-space to the Amazonas-3 in the 13.75
to 14.00 GHz frequency range.2 The proposed communications with the Amazonas-3 will use an
existing 4.5 antenna operated Call Sign E120231.3

         The Amazonas-3 has already been approved to serve the United States market using
conventional Ku-band frequencies (11.70-12.20 GHz and 14.00-14.5 GHz).4 DNET seeks to
incorporate by reference the technical parameters for the Amazonas-3’s extended Ku-band
transponders, which were provided to the Commission concurrently with the parameters for the
satellite’s conventional Ku-band transponder payload.5

       DNET seeks authority to use extended Ku-band transponders on the Amazonas-3 because
conventional Ku-band capacity from high-power satellites with high look angles over the
continental United States is scarce and likely to remain so for the foreseeable future.
Specifically, DNET requires a satellite with a footprint with sufficient signal strength on the
ground to work with secondary or tertiary cable network partners throughout the U.S. that intend
to deploy small antennas at cable headends in underserved or unserved communities to receive
Hispanic television programming. The extended Ku-band transponder payload on the
Amazonas-3 is presently the only capacity that satisfies these power and performance
requirements.

       DNET does not seek authority to communicate with any other commercial satellite in the
13.75-14.00 GHz frequency range. Beyond authorization to communicate with the Amazonas-3
in the above frequencies, DNET does not seek to modify any of the technical or carrier
parameters authorized under Call Sign E120231.



1
        The Amazonas-3 is operated by Hispamar Satellites, S.A., and was added to the FCC Permitted List as an
approved point of communication for conventional C-band, Ka-band, andKu-band fixed satellite services on March
14, 2013. See Petition for Declaratory Ruling, Hispamar Satellites, S.A., IBFS File No. SAT-PPL-20121018-00183
(“Amazonas-3 FCC Application”).
2
          The Amazonas-3’s extended Ku-band transponders are paired with space-to-earth transponders that operate
in the conventional band (i.e., 11.7-12.2 GHz). Accordingly, DNET will downlink from the Amazonas-3 pursuant
to its existing authority to receive signals from ALSAT satellites.
3
       The proposed antenna is identified on the current license for Call Sign E120231 as the 4.5m. See IB File
No. SES-LIC-20121109-00999.
4
        See Amazonas-3 FCC Application.
5
        See Id., Schedule-S.


2.0 - Exhibit Table of Contents

                                                                Total
Exhibit       Description
                                                                Pages
Exhibit A     Application Summary & Exhibit Table of Contents   2
Exhibit B     Extended Ku-band Analysis                         5
Exhibit C     Radiation Hazard Analysis                         5
Exhibit D     FAA Notification                                  1




                                       Page 2 of 2


                                                                               DNET Group, Inc.
                                     Modification Adding Extended Ku-band Frequencies to E120231
                                                                                        Exhibit B




                                EXHIBIT B

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




                                  Page 1 of 5


                                           Exhibit For
                                        DNET Group, Inc.
                                     N. Miami Beach, Florida
                                  Andrew 4.5 Meter Earth Station

     Compliance with FCC Report & Order (FCC96-377) for the 13.75 - 14.0 GHz Band
                              Analysis and Calculations

1.       Background

This Exhibit is presented to demonstrate the extent to which a DNET Group, Inc. satellite earth
station in North Miami Beach, Florida is in compliance with FCC REPORT & ORDER 96-377.
The potential interference from the earth station to US 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 (NAD83):                     25° 56’ 59.4” N, 80° 11’ 31.8” W

     •   Satellite Location for Earth Station:     Amazonas-3 (61.0° W)

     •   Frequency Band:                           13.75-14.0 GHz for uplink

     •   Polarizations:                            Linear and Circular

     •   Emissions:                                36M0G7W

     •   Modulation:                               Digital

     •   Maximum Aggregate Uplink EIRP:           72.3 dBW for a 36 MHz Carrier

     •   Transmit Antenna Characteristics
            Antenna Size:                          4.5 meters in Diameter
            Antenna Type/Model:                    Andrew
            Gain:                                  53.6 dBi

     •   RF power into Antenna Flange:             36 MHz
                                                   18.7 dBW, or 3.2 dBW/ MHz
                                                   or -20.8 dBW/4 kHz (Maximum)
     •   Minimum Elevation Angle:
          N Miami Beach, FL                        52.9° @ 141.5° Az. (Amazonas-3) at 61.0° W


     •   Side Lobe Antenna Gain:                   32 - 25*log(θ)


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 Department 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 United States Navy ships. The Federal Communication Commission (FCC)
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 North Miami Beach earth station is approximately
7.35 km East toward the Atlantic Ocean. The distance to the shoreline based upon transmissions
to the Amazonas-3 satellite at 61.0° WL (Azimuth: 141.5°), is 11.74 km. The calculation of the
power spectral density at this distance is given by:

                                                    36 MHz

     1. Clear Sky EIRP:                             72.3 dBW
     2. Carrier Bandwidth:                          36 MHz
     3. PD at antenna Input:                         -20.8
           (dBW/4 kHz)
     4. Transmit Antenna Gain:                     53.6 dBi
     5. Antenna Gain Horizon:                    FCC Reference Pattern
     6. Antenna Elevation Angle:                     52.9°


The proposed earth station will radiate interference toward the Atlantic Ocean according to its
off-axis side-lobe performance. A conservative analysis, using FCC standard reference pattern,
results in off-axis antenna gains of -8.6 dBi toward the Atlantic Ocean.


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


36 MHz Carriers
PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss
(dBw-m2).

       = -20.8 dBw/4 kHz + (-8.6) dBi – 10*log[4Π*(11740m)2]
       = -121.8 dBW/m2/4 kHz + Additional Path Losses (~87.2 dB)
       = -209.0 dBW/m2/4 kHz


Our calculations identified additional path losses of approximately 87.2 dB including absorption
loss and earth diffraction loss for the actual path profiles from the earth station toward the
shoreline in the direction of the Amazonas-3 satellite.


The worst case calculated PFD including additional path losses to the shoreline in the direction
of the Amazonas-3 satellite (Azimuth 141.5°) location is –209 dBW/m2/4 kHz for the 36 MHz
carriers. This is 42.0 dB below the –167 dBW/ m2/4 kHz interference criteria of R&O 96-377.
Therefore, there should be no interference to the US Navy RADAR from the North Miami Beach
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 DNET Group earth station in North Miami Beach, Florida 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
DNET Group earth station in North Miami Beach, Florida.


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 maximum EIRP
for the 36 MHz carriers is 72.3 dBW, and the equivalent EIRP per 6 MHz segment for a 36 MHz
carrier will be 66.3 dBW/6 MHz. Therefore, there should not be interference to the TDRSS
space-to-space link for the 36 MHz carriers.


4.   Coordination Issue Result Summary and Conclusions


The results of the analysis and calculations performed in this exhibit indicate that compatible
operation between the earth station at the North Miami Beach facility and the US Navy and
NASA systems space-to-earth link are possible for all of the proposed carriers. Operations in
NASA systems space-to-space link (13772.0 to 13778.0 MHz) will also be permitted for the 36
MHz carriers.


                                                                                         Exhibit   C
Radiation Hazard Report                                                                  Page 1 of 5


      Analysis of Non-Ionizing Radiation for a 4.5-Meter Earth
                          Station System
This report analyzes the non-ionizing radiation levels for a 4.5-meter earth station system. The analysis and
calculations performed in this report comply with the methods described in the FCC Office of Engineering
and Technology Bulletin, No. 65 first published in 1985 and revised in 1997 in Edition 97-01. The radiation
safety limits used in the analysis are in conformance with the FCC R&O 96-326. Bulletin No. 65 and the
FCC R&O specifies that there are two separate tiers of exposure limits that are dependant on the situation in
which the exposure takes place and/or the status of the individuals who are subject to the exposure. The
Maximum Permissible Exposure (MPE) limits for persons in a General Population/Uncontrolled environment
are shown in Table 1. The General Population/Uncontrolled MPE is a function of transmit frequency and is
for an exposure period of thirty minutes or less. The MPE limits for persons in an Occupational/Controlled
environment are shown in Table 2. The Occupational MPE is a function of transmit frequency and is for an
exposure period of six minutes or less. The purpose of the analysis described in this report is to determine
the power flux density levels of the earth station in the far-field, near-field, transition region, between the
subreflector or feed and main reflector surface, at the main reflector surface, and between the antenna edge
and the ground and to compare these levels to the specified MPEs.


                Table 1. Limits for General Population/Uncontrolled Exposure (MPE)
                   Frequency Range (MHz)            Power Density (mW/cm2)
                           30-300                                0.2
                          300-1500                    Frequency (MHz)*(0.8/1200)
                        1500-100,000                             1.0

                     Table 2. Limits for Occupational/Controlled Exposure (MPE)
                   Frequency Range (MHz)            Power Density (mW/cm2)
                           30-300                                1.0
                          300-1500                    Frequency (MHz)*(4.0/1200)
                        1500-100,000                             5.0


          Table 3. Formulas and Parameters Used for Determining Power Flux Densities
     Parameter                       Symbol            Formula                   Value             Units
     Antenna Diameter                   D                Input                     4.5             m
     Antenna Surface Area             Asurface          π D2 / 4                  15.90            m2
     Subreflector Diameter             Dsr               Input                    47.9             cm
     Area of Subreflector              Asr              π Dsr 2/4               1802.03            cm2
     Frequency                          F                Input                   14250             MHz
     Wavelength                         λ               300 / F                0.021053            m
     Transmit Power                     P                Input                   400.00            W
     Antenna Gain (dBi)                Ges               Input                    53.6             dBi
     Antenna Gain (factor)              G               10Ges/10               229086.8            n/a
     Pi                                 π              Constant                3.1415927           n/a
     Antenna Efficiency                 η              Gλ2/(π2D2)                 0.51             n/a


                                                                                  Exhibit   C
Radiation Hazard Report                                                           Page 2 of 5



1.      Far Field Distance Calculation

The distance to the beginning of the far field can be determined from the following equation:

     Distance to the Far Field Region                       Rff = 0.60 D2 / λ                   (1)
                                                                = 577.1 m

The maximum main beam power density in the far field can be determined from the following
equation:

     On-Axis Power Density in the Far Field                 Sff = G P / (4 π Rff 2)             (2)
                                                                = 21.893 W/m2
                                                                = 2.189 mW/cm2

2.      Near Field Calculation

Power flux density is considered to be at a maximum value throughout the entire length of the
defined Near Field region. The region is contained within a cylindrical volume having the same
diameter as the antenna. Past the boundary of the Near Field region, the power density from the
antenna decreases linearly with respect to increasing distance.

The distance to the end of the Near Field can be determined from the following equation:

     Extent of the Near Field                               Rnf = D2 / (4 λ)                    (3)
                                                                = 240.5 m

The maximum power density in the Near Field can be determined from the following equation:

     Near Field Power Density                               Snf = 16.0 η P / (π D2)             (4)
                                                                = 51.108 W/m2
                                                                = 5.111 mW/cm2

3.      Transition Region Calculation

The Transition region is located between the Near and Far Field regions. The power density
begins to decrease linearly with increasing distance in the Transition region. While the power
density decreases inversely with distance in the Transition region, the power density decreases
inversely with the square of the distance in the Far Field region. The maximum power density in
the Transition region will not exceed that calculated for the Near Field region. The power density
calculated in Section 1 is the highest power density the antenna can produce in any of the regions
away from the antenna. The power density at a distance Rt can be determined from the following
equation:

     Transition Region Power Density                        St = Snf Rnf / Rt                   (5)
                                                               = 5.111 mW/cm2


                                                                              Exhibit   C
Radiation Hazard Report                                                       Page 3 of 5



4.      Region between the Main Reflector and the Subreflector

Transmissions from the feed assembly are directed     toward the subreflector surface, and are
reflected back toward the main reflector. The most    common feed assemblies are waveguide
flanges, horns or subreflectors. The energy between   the subreflector and the reflector surfaces
can be calculated by determining the power density    at the subreflector surface. This can be
determined from the following equation:

     Power Density at the Subreflector                    Ssr = 4000 P / Asr                (6)
                                                              = 887.890 mW/cm2


5.      Main Reflector Region

The power density in the main reflector is determined in the same manner as the power density at
the subreflector. The area is now the area of the main reflector aperture and can be determined
from the following equation:

     Power Density at the Main Reflector Surface      Ssurface = 4 P / Asurface             (7)
                                                               = 100.602 W/m2
                                                               = 10.060 mW/cm2


6.      Region between the Main Reflector and the Ground

Assuming uniform illumination of the reflector surface, the power density between the antenna and
the ground can be determined from the following equation:

     Power Density between Reflector and Ground           Sg = P / Asurface                 (8)
                                                             = 25.150 W/m2
                                                             = 2.515 mW/cm2


                                                                             Exhibit   C
Radiation Hazard Report                                                      Page 4 of 5



7.     Summary of Calculations

          Table 4. Summary of Expected Radiation levels for Uncontrolled Environment

                                            Calculated Maximum
                                        Radiation Power Density Level
Region                                             (mW/cm2)                Hazard Assessment
1. Far Field (Rff = 577.1 m)                   Sff      2.189                Potential Hazard
2. Near Field (Rnf = 240.5 m)                  Snf      5.111                Potential Hazard
3. Transition Region (Rnf < Rt < Rff)          St       5.111                Potential Hazard
4. Between Main Reflector and                  Ssr    887.890                Potential Hazard
    Subreflector
5. Main Reflector                               Ssurface   10.060            Potential Hazard
6. Between Main Reflector and Ground            Sg          2.515            Potential Hazard



           Table 5. Summary of Expected Radiation levels for Controlled Environment

                                            Calculated Maximum
                                           Radiation Power Density
Region                                         Level (mW/cm2)             Hazard Assessment
1. Far Field (Rff = 577.1 m)                   Sff       2.189             Satisfies FCC MPE
2. Near Field (Rnf = 240.5 m)                  Snf       5.111              Potential Hazard
3. Transition Region (Rnf < Rt < Rff)          St        5.111              Potential Hazard
4. Between Main Reflector and                  Ssr     887.890              Potential Hazard
    Subreflector
5. Main Reflector                               Ssurface   10.060           Potential Hazard
6. Between Main Reflector and Ground            Sg          2.515          Satisfies FCC MPE




It is the applicant's responsibility to ensure that the public and operational personnel are not
exposed to harmful levels of radiation.


                                                                                      Exhibit   C
Radiation Hazard Report                                                               Page 5 of 5



8.     Conclusions

Based upon the above analysis, it is concluded that harmful levels of radiation may exist in those
regions noted for the Uncontrolled (Table 4) and Controlled (Table 5) Environments.

The antenna will be installed at the DTNETGROUP, Inc. facility in North Miami Beach, Florida. The
earth station will be fenced in and have secured access in and around the antenna. The earth
station will be marked with the standard radiation hazard warnings, as well as the area in the
vicinity of the earth station to inform those in the general population, who might be working or
otherwise present in or near the direct path of the main beam.

The applicant will ensure that the main beam of the antenna will be pointed at least one diameter
away from any building, or other obstacles in those areas that exceed the MPE levels. Since one
diameter removed from the center of the main beam the levels are down at least 20 dB, or by a
factor of 100, these potential hazards do not exist for either the public, or for earth station
personnel.

Finally, the earth station’s operating personnel will not have access to areas that exceed the MPE
levels, while the earth station is in operation. The transmitter will be turned off during periods of
maintenance, so that the MPE standard of 5.0 mw/cm**2 will be complied with for those regions in
close proximity to the main reflector, which could be occupied by operating personnel.

The applicant agrees to abide by the conditions specified in Condition 5208 provided below:

       Condition 5208 - The licensee shall take all necessary measures to ensure that the
       antenna does not create potential exposure of humans to radiofrequency radiation
       in excess of the FCC exposure limits defined in 47 CFR 1.1307(b) and 1.1310
       wherever such exposures might occur. Measures must be taken to ensure
       compliance with limits for both occupational/controlled exposure and for general
       population/uncontrolled exposure, as defined in these rule sections. Compliance
       can be accomplished in most cases by appropriate restrictions such as fencing.
       Requirements for restrictions can be determined by predictions based on
       calculations, modeling or by field measurements. The FCC's OET Bulletin 65
       (available on-line at www.fcc.gov/oet/rfsafety) provides information on predicting
       exposure levels and on methods for ensuring compliance, including the use of
       warning and alerting signs and protective equipment for worker.


                                                                          DNET Group, Inc.
                                Modification Adding Extended Ku-band Frequencies to E120231
                                                                                   Exhibit D

                             EXHIBIT D – FAA NOTIFICATION

        Pursuant to 47. C.F.R. §17.14 (b), FAA notification is not necessary because the
proposed 4.5 meter antenna is less than 6.1 meters in height and will not adversely affect safety
in air navigation.




A/75941464.1



Document Created: 2014-03-14 18:56:51
Document Modified: 2014-03-14 18:56:51

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