Attachment Exhibit C

This document pretains to SES-MOD-20100930-01240 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2010093001240_842582

Exhibit C Response to Form 312, Schedule B, Question E15 Re: 2.4 Meter Fixed Earth Station Fixed Satellite Service C-Band: 5925.0 – 6425.0 MHz Kaufman Broadcast Services Corporation requests authority to use it’s new 2.4 meter antenna for temporary news gathering and event coverage operations in the 5925.0 to 6425.0 MHz frequency band. This antenna is a Vertex Corporation, 2.4 meter antenna, and it does not strictly comply with 25.209 of the FCC Rules and Regulations. Thus Section 25.220 of the FCC’s rules apply. This antenna generally exhibits non-compliance for off-axis angles between 1.0 and 1.7 degrees due to the width of the main lobe. Per antenna manufacturer patterns provided as Exhibit E of this application, this antenna is compliant with the side lobe pattern requirement in Section 25.209 of the Commissions’ rules in the plane of the geostationary satellite orbit for off-axis angles greater than 1.7 degrees. Per the requirement of section 25.220 (b) the measured antenna performance data has been provided in Exhibit E. It consists of a series of plots showing antenna gain patterns for the frequencies 5850 MHz, 6138 MHz, and 6425 MHz, as specified in Section 25.132(b) of the FCC’s rules for angles less than 9 degrees focusing on the area of non-compliance with Sections 25.209 of the FCC’s rules. A review of this data indicates that the antenna does not comply with the antenna patterns specified in Section 25.209 (a)(1). Accordingly the requirements of either Section 25.221 (c)(1) or Section 25.221 (c)(2) will have to be met. Under Section 25.220(c)(1) the applicant must reduce power and power density levels stated in Sections 25.134, 25.211, or 25.212 of the FCC’s rules, whichever is applicable by the number of decibels that the non-compliant antenna fails to meet the antenna performance of Sections 25.209 (a) and (b). Per Section 25.212 (c)(1) the maximum antenna input power density routinely licensed by the FCC for transmissions of digital carriers using a compliant antenna in the C-band is -2.7 dBW/4 kHz. The Kaufman Broadcast Services application requests authority to transmit at a maximum power density of -14.0 dBW/4 kHz, which is 11.3 dB lower than the FCC limit of -2.7 dBW/4 kHz. Hence by transmitting at a reduced power density of -14.0 dBW/4 kHz the 2.4 meter antenna complies with the FCC’s spacing policy. The column titled “Worst Case” in Tables 1, 2, and 3 (Exhibit D) demonstrates that the off-axis EIRP density values resulting from Sections 25.209 (a) (1) and 25.212.212(c)(2) of the Commissions rules are met with a margin of at least 4.0 dB for all off-axis angles. Accordingly, licensing of the proposed earth station will be consistent with the Commissions 2 degree spacing policy.


Document Created: 2019-04-27 15:10:51
Document Modified: 2019-04-27 15:10:51
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