Attachment Compliance Narrative

This document pretains to SES-MFS-20140924-00755 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2014092400755_1062016

                                     COMPLIANCE WITH 25.203(K)

        In this application, DIRECTV requests modify an existing Ka-band earth station
authorization to add Ka-band ALSAT as a point of communication, pursuant to the Ka-Band
ALSAT Order adopted by the Commission.1 This earth station will transmit in the 29.25-29.5
GHz band, which is allocated on a co-primary basis to both GSO/FSS and NGSO/MSS feeder
links. As required under Section 25.203(k) of the Commission’s rules, and as directed in
footnote 31 to the Ka-Band ALSAT Order, DIRECTV demonstrates below that the operation of
this earth station with an ALSAT designation will not cause interference to co-primary, co-
frequency feeder link operations.
         In 2011, DIRECTV applied for and received Ka-band ALSAT authority for several
earth station antennas.2 In the applications to modify the licenses for those antennas, DIRECTV
included an extensive analysis that showed that there would not be unacceptable interference to
co-frequency NGSO MSS feeder link operations from the operation of those antennas. In order
to demonstrate that operation of the currently applied-for earth station will not cause
unacceptable interference to co-primary, co-frequency feeder link operations, DIRECTV notes
the following points:
         The earth station antenna that is the subject of this application is very similar
          technically to the DIRECTV Ka-band ALSAT earth station antennas that were
          licensed in 2011.
         The DIRECTV Ka-band antennas previously licensed with an ALSAT designation are
          located approximately 175-200 km from the closest NGSO MSS feeder link site. The
          antenna that is the subject of this application is on the order of 900 km away from the
          nearest NGSO MSS feeder link site.
         As is stated in Recommendation ITU-R S.1419, “Interference mitigation techniques to
          facilitate coordination between non-geostationary-satellite orbit Mobile-Satellite
          Service feeder link and geostationary-satellite orbit Fixed-Satellite Service networks in
          the bands 19.3-19.7 GHz and 29.1-29.5 GHz,” geographical separation of
          approximately 225 km between GSO FSS and NGSO MSS earth stations is generally
          considered sufficient to ensure compatible GSO/NGSO operations.
         The Ka-band antenna that is the subject of this application is already authorized to
          operate in the subject frequency bands and is located at a site where DIRECTV is
          already licensed for, and has been successfully operating, other Ka-band antennas in
          the same frequency band for several years without incident3.

1
    See 2006 Biennial Regulatory Review – Revision of Part 25, 25 FCC Rcd. 1542 (2010) (“Ka-Band ALSAT
    Order”).
2
    See IBFS File Nos. SES-MFS-20111104-01314, -01315, -01317, -01320, -01322, -01324.
3
    See e.g. Call sign E080026, E120110


Taken together, the above factors demonstrate that the operations of the applied-for Ka-band
ALSAT earth station antenna will not cause interference to co-primary, co-frequency feeder link
operations.



Document Created: 2019-04-26 00:17:23
Document Modified: 2019-04-26 00:17:23

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