CKA 15 Supplement SUPPLEMENT by DIRECTV Enterprises, LLC SES-MOD-20150424-00274 CKA15 Supplement (4-

CKA15 Supplement (4-

SUPPLEMENT submitted by DIRECTV Enterprises, LLC

CKA 15 Supplement

2015-04-28

This document pretains to SES-MOD-20150424-00274 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2015042400274_1086528

COMPLIANCE WITH SECTION 25.203(K)

In this application, DIRECTV requests to modify an existing Ka-band earth station
authorization to add Ka-band Permitted List 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 virtually technically
identical 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.

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.

• 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 incident. 3

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

3
See, e.g., Call signs E050230, E080025, E120109.

Document Created: 2019-04-13 20:34:33
Document Modified: 2019-04-13 20:34:33

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