Attachment Narrative & Exhibits

This document pretains to SES-MOD-20150416-00219 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2015041600219_1083768

                                                              FCC Form 312
                                                              EchoStar Broadcasting Corporation
                                                              Modification Application
                                                              Page 1 of 2

                                             Narrative
         Pursuant to Section 25.117 of the Federal Communications Commission’s rules,1
EchoStar Broadcasting Corporation (EBC) submits this application to modify call sign E050373
(SES-MOD-20130206-00160). The purpose of this application is to add an additional antenna
facility designated VAT1, correct existing licensed antenna information, add a point of
communications, and correct other points of communications. Further details are provided
below.


Additional Antenna

        EBC proposes to add an additional antenna, VAT1, to call sign E050373 that will operate
under the technical parameters in the form 312 schedule B. The new antenna will be located
within +/- 1 second latitude/longitude of the existing licensed earth stations under this call sign.
In addition, the new antenna will operate at the same technical parameters as the existing license
antennas, VAT3 and VAT4.

        The new antenna will operate within the quiet zone in 47 C.F.R. § 1.924(a)(1). Pursuant
to 47 C.F.R. § 1.924(a)(2), EBC notified the National Radio Astronomy Observatory (NRAO) of
the planned operation on April 10, 2015. A copy of that notification is attached hereto. At the
request of NRA staff, EBC subsequently sent a complete draft form 312 to the NRAO on April
14, 2015. When available, EBC will supplement this application with copy of the NRAO’s
consent letter.

Corrections to Information for VAT3 and VAT4

     EBC requests that the Commission change the existing licensed emission designator,
24M0M1F, for VAT3 and VAT4 to 24M0G7W. The bandwidth is not changing.

     EBC requests that the Commission change the existing licensed antenna manufacturer for
VAT3 and VAT4 from TIW to GDSatcom.
      Finally, there is duplicate “max gain” information for VAT4 because “65.0 dBi @
17.3000 GHz” is listed twice. EBC requests that the Commission move the second “65.0 dBi @
17.3000 GHz” so that it is correctly listed under VAT3.


Add a Point of Communication

           EBC proposes to add EchoStar 15 at 45.1° W.L. as a point of communication.



1
    47 C.F.R. § 25.117.


                                                              FCC Form 312
                                                              EchoStar Broadcasting Corporation
                                                              Modification Application
                                                              Page 2 of 2


Correct Points of Communications

       EBC requests that the Commission delete points of communication 1-9 on the license.
Specifically, EBC requests that the FCC delete the following points of communication:

   1) Mt. Jackson, VA to ECHOSTAR 1 @ 148.0 W.L. of the Direct Broadcast Satellite
      system (U.S.-licensed)

   2) Mt. Jackson, VA to ECHOSTAR 2 @ 148 W.L. of the Direct Broadcast satellite system
      (U.S.-licensed)

   3) Mt. Jackson, VA to ECHOSTAR 3 (S2741) @ 61.5 W.L. of the Direct Broadcast
      Satellite system (U.S.-licensed)

   4) Mt. Jackson, VA to ECHOSTAR 5 satellite @129 W.L. of the Direct Broadcast Satellite
      system (U.S.-licensed)

   5) Mt. Jackson, VA to ECHOSTAR 6 @ 110 W.L. of the Direct Broadcast satellite system
      (U.S.-licensed)

   6) Mt. Jackson, VA to ECHOSTAR 7 @ 119 W.L. of the Direct Broadcast satellite system
      (U.S.-licensed)

   7) Mt. Jackson, VA to ECHOSTAR 8 @ 110 W.L. of the Direct Broadcast satellite system
      (U.S.-licensed)

   8) Mt. Jackson, VA to RAINBOW 1 @ 61.5 W.L. (Direct Broadcast Satellite) (U.S.-
      licensed)

   9) Mt. Jackson, VA to ECHOSTAR 10 satellite @ W.L. of the Direct Broadcast satellite
      system (U.S.-licensed)

FAA Notification

        Notification to the FAA is not required for the proposed antenna facility because the
structure passes slope. EBC has attached the TOWAIR report.

Radiation Hazard Study

       A copy of the radiation hazard study is attached to this application.


                                EGHOSIAR
                                         April 10, 2015
Anthony Beasley
Director
National Radio Astronomy Observatory
Post Office Box No. 2
Green Bank, West Virginia 24944


Dear Mr. Beasley,
       Pursuant to 47 C.F.R. § 1.924(a)(2), this letter is to inform you that EchoStar
Broadcasting Corporation (EBC) is planning to construct a new earth station antenna within the
boundaries identified in 47 C.F.R. § 1.924(a)(1). This new antenna will be located within +/— 1
second latitude/longitude of existing facilities licensed under Federal Communications
Commission call sign E050373. EBC provides the information required under 47 C.F.R. §
1.924(a)(1) below:
       geographical coordinates of the antenna location: 38° 43° 22.4" N, 78° 39° 58.5" W
       address: 1335 Wissler Road, Quicksburg, Shenandoah, VA, 22847
       the antenna height (above ground level): 13.2m
       the antenna site ground elevation above mean sea level: 282.2m
       antenna directivity (if any): 34B beamwidth = 0.09°
       the channel: Transmit, 17300—17800 MHz; Receive, 12200—12700 MHz
       the emission type: 24M0G7W, 1M50G2D, 300KG2D
       power: 84.7 dBW EIRP


      EBC will notify the National Radio Astronomy Observatory when the application for the
new antenna is filed with the FCC. Please contact the undersigned with any questions.


                                                     Sincerély? //
                                                     ezim
                                                  ~ Jesse Jachman
                                                     EchoStar Broadcasting Corporation
                                                     Senior Counsel, Regulatory Affairs
                                                     11717 Exploration Lane
                                                     Germantown, MD 20876
                                                     (301)428—5975
cc: nrgz@gb.nrao.edu


                                                                                  Exhibit
Radiation Hazard Report                                                           Page 1 of 4


     Analysis of Non-Ionizing Radiation for a 13.2-Meter Earth
                          Station System
This report analyzes the non-ionizing radiation levels for a 13.2-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                   13.2           m
     Antenna Surface Area          Asurface           D2 / 4               136.85           m2
     Subreflector Diameter          Dsr              Input                  172.7           cm
     Area of Subreflector           Asr               Dsr 2/4             23424.73          cm2
     Frequency                       F               Input                  17550           MHz
     Wavelength                                     300 / F               0.017094          m
     Transmit Power                  P               Input                1600.00           W
     Antenna Gain (dBi)              Ges             Input                   65.0           dBi
     Antenna Gain (factor)           G              10Ges/10             3162277.7          n/a
     Pi                                            Constant              3.1415927          n/a
     Antenna Efficiency                            G 2/( 2D2)                0.54           n/a


                                                                                Exhibit
Radiation Hazard Report                                                         Page 2 of 4




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 /                     (1)
                                                                = 6115.8 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 Rff 2)               (2)
                                                                = 10.765 W/m2
                                                                = 1.076 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 )                     (3)
                                                                = 2548.3 m

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

     Near Field Power Density                               Snf = 16.0 P / ( D2)                (4)
                                                                = 25.129 W/m2
                                                                = 2.513 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)
                                                               = 2.513 mW/cm2


                                                                              Exhibit
Radiation Hazard Report                                                       Page 3 of 4



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)
                                                              = 273.216 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)
                                                               = 46.767 W/m2
                                                               = 4.677 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)
                                                             = 11.692 W/m2
                                                             = 1.169 mW/cm2


                                                                                 Exhibit
Radiation Hazard Report                                                          Page 4 of 4



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 = 6115.8 m)                   Sff        1.076              Potential Hazard
2. Near Field (Rnf = 2548.3 m)                  Snf        2.513              Potential Hazard
3. Transition Region (Rnf < Rt < Rff)           St         2.513              Potential Hazard
4. Between Main Reflector and                   Ssr      273.216             Potential Hazard
    Subreflector
5. Main Reflector                               Ssurface   4.677              Potential Hazard
6. Between Main Reflector and Ground            Sg         1.169              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 = 6115.8 m)                   Sff         1.076            Satisfies FCC MPE
2. Near Field (Rnf = 2548.3 m)                  Snf         2.513            Satisfies FCC MPE
3. Transition Region (Rnf < Rt < Rff)           St          2.513            Satisfies FCC MPE
4. Between Main Reflector and                   Ssr      273.216              Potential Hazard
    Subreflector
5. Main Reflector                               Ssurface    4.677            Satisfies FCC MPE
6. Between Main Reflector and Ground            Sg          1.169            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.



8.     Conclusions

Based on the above analysis it is concluded that the FCC MPE guidelines have been exceeded (or
met) in the regions of Table 4 and 5. The applicant proposes to comply with the MPE limits by one
or more of the following methods.

The earth station will be located in a Gated and Fenced facility with secured access in and around
the proposed antenna. Since the proposed earth station will not transmit at an antenna elevation of
less than 23.9 degrees, and since one diameter removed from the center of main beam the levels
are down at least 20 dB, or by a factor of 100, public safety will be ensured for the near and far
field regions.

Finally, occupational exposure will be limited, and 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, and subreflector, which could be occupied by operating
personnel.


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   A routine check of the coordinates, heights, and structure type you provided indicates that this
   structure does not require registration.

                                                *** NOTICE ***
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            DETERMINATION Results
            PASS SLOPE(50:1): NO FAA REQ­RWY 10499 MTRS OR LESS & 7898.89 MTRS
            (7.89890 ) KM AWAY
                                                                                  Lowest
                                                                                  Elevation        Runway
            Type C/R Latitude Longitude Name                   Address            (m)              Length (m)
            AIRP R       38­39­     078­42­        NEW         SHENANDOAH 293.3                    890.0
                         30.00N     16.00W         MARKET      NEW MARKET,
                                                               VA

            Your Specifications
            NAD83 Coordinates
            Latitude                                                        38­43­22.4 north
            Longitude                                                       078­39­58.5 west
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            Overall Structure Height (AGL)                                  13.2
            Support Structure Height (AGL)                                  13.2
            Site Elevation (AMSL)                                           282.2
            Structure Type
            LTOWER ­ Lattice Tower


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                                    Response to Question 36

        On July 26, 2011, the FCC declared null and void an authorization of EchoStar
Corporation, the parent company of EchoStar Satellite Operating Corporation (together with
their affiliates, “EchoStar”), to construct, launch, and operate a new Direct Broadcast Satellite at
86.5º W.L. for failure to meet the critical design review milestone, and rejected EchoStar’s
request to modify its 86.5º W.L. authorization to allow the in-orbit EchoStar 8 satellite to provide
service from that orbital location.1

       The FCC also has denied a few of EchoStar’s applications for initial license or
modification.2

       The FCC has dismissed, but not denied on the merits, a few of EchoStar’s license
applications without prejudice to refiling.3




1
    See EchoStar Corporation, Memorandum Opinion and Order, 26 FCC Rcd 10,442 (IB 2011).
2
  See Satellite Communications Services Information Re: Actions Taken, Public Notice, Rpt. No.
SES-00847 (IB rel. Aug. 16, 2006) (denying HNS License Sub, LLC’s, request for extension of
construction milestones regarding File Nos. SES-MOD-20060404-00560 and SES-MOD-
20060404-00561); EchoStar Satellite LLC, Memorandum Opinion and Order, 19 FCC Rcd 7846
(IB 2004) (denying applications to launch and operate four geostationary satellites because of
interference concerns); EchoStar Satellite LLC, Order, 20 FCC Rcd 12,027 (IB 2005); EchoStar
Satellite Corporation, Memorandum Opinion and Order, 17 FCC Rcd 8831 (IB 2002) (denying
request to extend construction milestone dates); EchoStar Satellite Corporation, Memorandum
Opinion and Order, 16 FCC Rcd 14,300 (IB 2001).
3
 See, e.g., Letter from Robert G. Nelson, Chief, Satellite Division, to Pantelis Michalopoulos,
Counsel for EchoStar Corporation, 24 FCC Rcd 7132 (IB 2009); EchoStar Corporation,
Application to Operate a C-Band Geostationary Satellite Orbit Satellite in the Fixed-Satellite
Service at the 84.9º W.L. Orbital Location, Memorandum Opinion and Order, 25 FCC Rcd
10,193 (IB 2010); Letter from Paul E. Blais, Chief, Systems Analysis Branch, Satellite Division,
to Alison Minea, Corporate Counsel, EchoStar Broadcasting Corporation, 28 FCC Rcd 10,214
(IB 2013); Letter from Paul E. Blais, Chief, Systems Analysis Branch, Satellite Division, to
Alison Minea, Corporate Counsel, EchoStar Broadcasting Corporation, 28 FCC Rcd 10,216 (IB
2013).



Document Created: 2015-04-15 16:53:20
Document Modified: 2015-04-15 16:53:20

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