FCC 92-1 Federal Communications Commission Record 7 FCC Red No. 2 
Before the 
Federal Communications Commission 
Washington, D.C. 20554 
In the Matter of 
Amendment of C-Band Satellite 
Orbital Spacing Policies to Increase 
Satellite Video Service to the Home 
REPORT AND ORDER 
RM-7627 
RM-7628 
Adopted: January 2, 1992; Released: January 15, 1992 
By the Commission: 
I. INTRODUCTION 
1. Two petitions for rulemaking have been filed with 
the Commission requesting that it alter its orbital spacing 
policies for domestic fixed-satellites. Current policy pro­
vides that separations between satellites will be two de­
grees by the mid-1990s when all authorized facilities are 
expected to be launched and operating. The petitions 
request that spacings between at least some satellites be 
allowed to remain at three degrees to facilitate the use of 
smaller antennas for home reception of video program­
ming. 
2. The first petition was filed by the Satellite Dealer 
Forum and K-Sat Broadcasting (K-Sat petition). The sec­
ond petition was filed by a group of twelve entities that 
includes satellite equipment manufacturers and retailers, 
satellite programming distributors. and a programming 
provider (GIC petition). 1 The petitions were opposed by a 
number of parties including licensees of satellites pro­
posed to be located 3 degrees apart.2 Based on the record 
compiled, we find that granting petitioners' requests for 
rulemaking would not be in the public interest because 3° 
orbital spacings would cause unnecessary costs, severe 
disruption, uncertainty and instability in the satellite in­
dustry and would not achieve the ultimate benefits sought 
by the petitioners. Accordingly. the petitions for 
rulemaking are denied. 
Petitioners are: Channel Master Division of Avnet, Inc. 
(Channel Master); Chaparral Communications, Inc. (Chaparral); 
Consumer Satellite Systems, Inc. (Consumer Satellite); Earth 
Terminal TV, Ltd. (Earth Terminal); General Instrument Cor­
poration (GIC); the National Rural Telecommunications Coop­
erative (NRTC); PrimeTime 24 (PrimeTime); the Retail Council 
of the Satellite Broadcasting and Communications Association 
(Retail Council); Satellite Receivers, Ltd. (Satellite Receivers); 
Satellite Sports Network (SSN); Warren Supply Company (War­
ren) and Winegard Company (Winegard). 
2 See Appendix A for list of Commenters. 
3 Licensing of Space Stations in the Domestic Fixed-Satellite 
Service and Related Revisions of Part 25 of the Rules and 
Regulations, 88 FCC 2d 318 (1981) (Reduced Spacing Notice). 
4 Id. 
456 
II. BACKGROUND 
3. The move to 2° spacing was initiated ten years ago 
when the Commission determined that the best way to 
accommodate increased demand for satellite transponder 
capacity would be to maximize the use of the orbit by 
providing for the launch of more satellites. 3 The Commis­
sion noted that this demand stemmed in part from the 
development of new and innovative equipment and ser­
vices offered by an increasing number of entrepreneurs in 
the industry. It expressed concern that regulatory policies 
continue to assure availability of satellite capacity to sat­
isfy current needs as well as encourage new entrants in 
this market. The Commission stated that it initiated the 2° 
spacing rulemaking at that time in order to resolve the 
question of orbital spacings prior to the launch of addi­
tional new or replacement satellites. It emphasized that 
the smallest practical orbital spacing should be selected in 
order to conserve the orbital arc. 4 
4. In 1983, the Commission adopted its 2° spacing 
policy.5 In doing so, it recognized that an immediate 
implementation of reduced spacing in the C-band would 
pose serious difficulties and cause significant costs. It 
therefore decided on a transitional plan with 2° as an 
ultimate goal but with a longer implementation schedule 
to allow operators several years to amortize and upgrade 
or replace existing facilities. 6 The Commission also noted 
that the parties commenting in that proceeding conceded 
that spacings of less than three degrees were ultimately 
necessary to accommodate demand. It also noted that 
licensees preferred incurring the costs necessary to imple­
ment 2° spacing to the costs and delays of comparative 
hearings which might be used to choose among applicant~ 
if the demand for orbital locations exceeded their supply.' 
5. Receive-only earth stations were deregulated in 1979 
when the Commission established an optional licensing 
program for those desiring interference protection from 
terrestrial microwave facilities operating in the same band 
while allowing those not desiring such protection the 
right to use unlicensed facilities. 8 Most owners of home 
satellite earth stations (HSDs) choose not to license their 
equipment.9 Because of their unlicensed status. the poten­
tial affect of 2° spacing on HSDs was not evaluated in 
Reduced Spacing. 10 
6. In 1985 and again in 1988 the Commission 
reaffirmed its commitment to 2° spacing when assigning 
orbital locations to new space stations. 11 The Commission 
referred to the uniform 2° policy as the "cornerstone of 
our orbital assignment policy" designed to maximize the 
5 Licensing of Space Stations in the Domestic Fixed-Satellite 
Service and Related Revisions of Part 25 of the Rules and 
Regulations, 48 Fed. Reg. 40233 (1983) (Reduced Spacing). 
6 Id. at para. 41. 
7 Id. at para. 18. 
8 Deregulation of Receive-Only Earth Stations, 74 FCC 2d 205 
p979). 
The Commission recently adopted a registration program for 
domestic receive-only earth stations to replace optional licensing 
for facilities where interference protection is desired. See 47 
C.F.R. 25.131. 
10 See Id. at note 31. 
11 See Assignment of Orbital Locations to Space Stations in the 
Domestic Fixed-Satellite Service, 50 Fed. Reg. 35228 (August 30 
1985) (1985 Assignment Order); Assignment of Orbital Locations 
to Space Stations in the Domestic Fixed-Satellite Service, 3 FCC 
Red 6972 (1988) (1988 Assignment Order). 
7 FCC Red No. 2 Federal Communications Commission Record FCC 92-1 
number of satellites that could be authorized in order to 
assure that the demand. for satellite services could be 
met.12 
7. The entities authorized to construct and launch space 
stations in 1988 have begun to implement their proposed 
facilities. 13 Many of these satellites are scheduled to be 
launched in the next three years and are assigned to 
orbital locations with 2° separations although the satellites 
they are replacing are currently operating in locations 
spaced further apart. 
8. Two groups have filed petitions for rulemaking re­
questing changes in our orbital spacing policies. The K­
Sat petition lists four reasons why it is in the public 
interest to change our spacing policy from 2° to 3°. 14 
These are as follows: 1) 3° spacing would allow the use of 
smaller C-band reception antennas that would not be 
adversely affected by adjacent satellite interference, 2) 
smaller dishes would reduce zoning conflicts, 3) 3° spac­
ing would allow for "an interim transition to Ku-band 
specialized packages while preserving high powered 
steerable C-band use", and 4) for "other unmentioned 
reasons". This petition does not contain elaboration or 
supporting information. 
9. The GIC petition was filed by a group of entities 
with varying interests in the market for satellite delivered 
video programming. It requests the initiation of a 
rulemaking that would lead to the adoption of 3° spacing 
in certain portions of the arc at C-band as well as the 
adoption of any other changes that would facilitate the 
use of smaller earth stations. GIC asserts that demand for 
C-band transponder capacity has decreased since 2.° spac­
ing was adopted and, therefore, wider spacing between 
satellites providing entertainment video services can be 
maintained. GIC contends that 3° spacing will help the 
development of the HSD industry by allowing the use of 
smaller antennas. In reply comments. GIC clarifies its 
position and states that the petition is requesting main­
tenance of spacings at 3° for the life of currently au­
thorized satellites carrying cable programming, i.e., 
approximately a ten year period. 
10. The GIC petition offers two alternative proposals for 
3° assignment plans for satellites located in the western 
portion of the orbital arc. 15 Satellites of primary concern 
are those that carry video programming for distribution to 
cable systems as well as HSDs and that are currently 
assigned to locations between 137° W.L. and 125° W.L. 16 
11. Fourteen oppositions to the petitions were filed. 17 
Other parties filed pleadings captioned as comments that 
expressed opposition to the petitions. Opponents include 
satellite operators. non-entertainment video users of sat­
ellite services and certain video programmers. Comments 
12 1988 Assignment Order at para. 5. 13 Satellite construction schedules require long lead times. The 
space stations authorized in our 1988 orders were generally 
required to be constructed and launched by 1994. See general 
discussion of this policy in Licencing Space Stations in the 
Domestic Fixed-Satellite Service, 50 Fed. Reg. 36071 (September 
5, 1985) at paras. 26-28. 14 The petition is unclear about whether it is requesting a 
change in all portions of the arc in both bands. in the entire 
C-band orbital arc, or only in part of the C-band. C-band refers 
to 3700-4200 MHz downlink pared with 5925-6425 MHz uplink. 
Ku-band refers to 11.7-12.26 GHz downlink with 14 GHz 
457 
supporting the pet1t10n were filed by entities involved in 
the manufacture of HSD equipment as well as by some 
programming providers. 
III. DISCUSSION 
12. After balancing the benefits petitioners claim will 
accrue from their requested change against the costs and 
disruption the change would cause in the satellite in­
dustry overall, we conclude that instituting the proposed 
rulemaking would be contrary to the public interest. Both 
petitions fail to demonstrate sufficient reasons to justify 
the consideration of such a major policy shift. Maintain­
ing 3° spacing, even in only part of the orbital arc, would 
not achieve the result sought by the petitioners because of 
technical limitations, would cause major costs, disruption 
and uncertainty in the satellite industry and would result 
in a substantial loss of regulatory flexibility. 
A. Technical Considerations 
13. GIC's position that 3° spacing should be permitted 
in certain portions of the arc is premised on certain 
technical assumptions regarding the feasibility of using 
four foot diameter antennas to receive video signals at 
C-band. GIC claims that" advances in satellite technology 
now make the use of antennas four feet or less feasible as 
long as adjacent satellite interference can be adequately 
rejected. Petitioners assert that with 3° spacing, four foot 
antennas will be able to provide an acceptable quality 
picture but that if spacings are reduced to 2°, antennas 
will have to be larger. They cite the fact that many of the 
new satellites recently authorized will be transmitting with 
16 watts of power per transponder in contrast to the 
present facilities operating with 5 to 10 watts of power. 
They conclude that these higher power levels contribute 
to the feasibility of smaller dishes. In addition, petitioners 
assert that other advances in transistor technology make 
smaller HSD receivers more efficient. 
14. Attached to the petition is a technical analysis sup­
porting the contention that under 2° spacing conditions, 
an eight foot antenna is necessary to reject adequately 
adjacent satellite interference. This analysis purports to 
demonstrate that if satellites remain at 3° spacing, four 
foot antennas would provide adequate reception. Petition­
ers also indicate that they have been operating two experi­
mental four foot HSD systems in California and have 
included the results of these experiments in their analysis. 
15. Opponents dispute the petitioners' assertions that 
four foot antennas will provide an acceptable quality pic­
ture with 3° spacing and offer several technical analyses in 
support. Although their conclusions vary as to the mini­
mum size antenna necessary, all question the petition's 
uplink. 1 The portion of the geostationary satellite orbital arc in 
~uestion is that between 120° W.L. and 142° W.L. at C-band. 
6 These include GE's Satcom C-1. C-2, and C-3 satellites and 
Hughes's Galaxy V and Galaxy IR satellites. Four of these 
satellites are assigned locations within seven degrees of each 
other; Satcom C-1 at 137° W.L., Satcom C-4 at 135° W.L., 
Galaxy IR at 133° W.L. and Satcom C-3 at 131° W.L. 17 Many oppositions and comments were addressed to both 
petitions and, unless specifically noted. in order to avoid confu­
sion, we will refer to both petitions collectively in this order. 
FCC 92-1 Federal Communications Commission Record 7 FCC Red No. 2 
four foot claims.18 Based on opponents' technical assess­
ments, they conclude that larger antennas are necessary 
for adequate reception with 3° spacing. Opponents claim 
that petitioners' technical analysis fails to consider several 
relevant factors that impact on the feasibility of their 
~pm~. . 
16. Based on an evaluation of the record compiled here 
as well as on an independent staff analysis, we conclude 
that even with satellite spacings of 3°, a four foot antenna 
will provide a picture of only marginal quality, i.e., a 
picture with discernable sparkles, in some portions of the 
country and will be incapable of providing even a mar­
ginal quality picture in other portions of the country. 19 In 
addition, more expensive consumer equipment may be 
necessary. In view of this conclusion and considering the 
anticipated costs and disruption and the potentially 
adverse impact that a change in policy would have on our 
regulatory flexibility, dismissal of these petitions is war­
ranted. 
17. Another technical concern raised by opponents 
stems from GIC's proposed assignment plans, both of 
which would create a situation where satellites with the 
same polarization would be adjacent to each other. Adja­
cent C-band satellites currently are required to have op­
posite transponder polarizations in order to reject 
interference under 2° spacing conditions.20 Opponents as­
sert, and petitioners do not refute, that even with 3° 
spacing, adjacent satellites must have opposite polariza­
tions to avoid unacceptable interference. They note that 
the only way of avoiding this interference if satellites are 
co-polarized is to reduce transponder power substantially. 
Opponents conclude that this power reduction would ad­
versely affect the ability of smaller dishes to receive sig­
nals and thus would be contrary to the results desired by 
the petitioners. They contend that changing the polariza­
tion of the satellites involved would be extremely costly, if 
not impossible at this stage. In reply, GIC states that 
satellite operators have been on notice that switchable 
polarization might be required and thus they should have 
constructed their satellites accordingly. It also questions 
the assertions by GE about costs and difficulties of chang­
ing polarization on partially constructed satellites. 
18. We find that the problem of incompatible polariza­
tion is a serious flaw in both of the proposed assignment 
plans offered by petitioners. We agree that even with 3° 
spacing, satellites must be cross-polarized to operate effec­
tively. There currently is no requirement that satellite 
18 GTE states that some 5 to 7 foot antennas might work in 
some "best case" situations with 3° spacing. GE states that an 8 
foot antenna would be required to achieve adequate results with 
3° spacing. Hughes states that because no industry-wide standard 
for minimum quality video signals has been established, it can­
not be determined if 4 foot antennas will perform adequately 
even with 3° spacings. The petition and our discussion is based 
on an analysis of the feasibility of 4 foot antennas. Standard 
antenna size feasible for most areas of the country under 2° 
s~acing conditions is 8 feet to 10 feet. 1 See Appendix B for the staff's technical analysis. 20 See Licensing of Space Stations in the Domestic Fixed­
Satellite Service and Related Revisions of Part 25 of the Rules 
and Regulations, 99 FCC 2d 737 (1985) at para. 6. 21 Such a requirement is under consideration. See Amendment 
of Part 25 of the Commission's Rules and Regulations, 2 FCC 
Red 762 (1987). 22 With respect to the costs involved in redesigning spacecraft, 
GE has provided in its comments a detailed explanation of the 
458 
operators construct their facilities with switchable polar­
ization.21 The present generation of spacecraft was au­
thorized without requiring polarization switches and the 
1988 Orbital Assignment Plan alternated assignments of 
horizontally and vertically polarized satellites. Any modi­
fication of this assignment plan will have to take polariza­
tion of adjacent satellites into account.22 
19. An additional issue raised here involves the use of 
other frequencies to provide video services directly to 
consumers' homes. As opponents point out, spectrum in 
other frequency bands has been allocated exclusively to 
the provision of direct-to-home video service (DBS). Al­
though this service is not yet in operation, it has the 
potential of providing video programming directly to con­
sumers' homes using very small and inexpensive anten­
nas.23 In addition, at least two video programming services 
are scheduled to be offered in the Ku-band24 where small­
er antennas in the range of two feet are technically fea­
sible.25 Use of the Ku-band and DBS26 in the bands 
established for that purpose will, according to opponents, 
accomplish the result sought by petitioners, i.e., smaller 
antennas at less cost to the consumer. without causing the 
disruptions and costs anticipated by relocations in the 
C-band.27 
20. GIC replies that direct-to-home video programming 
services in Ku-band have not been established and are 
only in the test marketing stage and thus are not at this 
time a viable substitute for C-band services which carry 
"name brand" programming designated for cable distribu­
tion.28 GIC states that programmers are committed by 
contract to transponders in the C-band for at least ten 
years and thus Ku-band is not a realistic option for dish 
owners. GIC also questions whether DBS will ever be 
implemented. 
21. Although neither Ku-band direct-to-home service 
nor DBS service are as yet fully established, we expect 
that as these technologies develop. they will become via­
ble alternatives to Cband HSD service. Until that time, 
most HSD consumers are not faced with a choice of doing 
without service altogether. Instead, by using somewhat 
larger antennas. they, along with the other services using 
C-band, are ensuring that orbital spectrum is efficiently 
used and that all users can sucessfully co-exist. 
difficulties and expense involved in redesigning polarization in 
substantially constructed facilities and the record does not in­
dicate that this description is incorrect. 
23 Comments of USSB. 
24 See GE Americium Communications, Inc., 3 FCC Red 6871 
(1988) for discussion of establishment of "high-density" arc at 
Ku-band for direct-to-home video service. 25 Prime Star has begun test marketing its Ku-band service in 
certain parts of the country and SkyPix is scheduled to begin 
service in the near future. 
26 The Commission has allocated the 12.2-12.7 GHz frequency 
band for DBS. 
27 With respect to zoning problems encountered by HSD own­
ers, the Commission is currently considering a Petition for 
Declaratory Ruling filed by the Satellite Broadcasting and Com­
munications Association of America specifically addressing these 
issues. 
28 See also Reply Comments of Chapparal contending that the 
program offerings on Ku-band are limited. 
7 FCC Red No. 2 Federal Communications Commission Record FCC 92-1 
B. Cost and Disruption 
22. The GIC petition asserts that circumstances have 
changed since the Commission adopted its 2° spacing 
policy. GIC states that when 2° spacings were adopted in 
1983, demand for transponder capacity in the C-band was 
high. Since then, some of the traffic carried by satellites 
has been transferred to fiber optic cable. Several planned 
C-band systems never were implemented, and the owner­
ship of fixed satellites has been consolidated and con­
centrated in a few major licensees. The pressure for 
C-band transponder expansion has disappeared, according 
to petitioners, and growth has been stronger in the 
Kuband. The GIC petition contends that the only growth 
at C-band has been in the video distribution market. GIC 
states that they are not requesting that 3° spacing be 
maintained indefinitely. Rather, their petition requests 
that 3° spacing be implemented for the life of the next 
generation of spacecraft, approximately ten years. They 
contend that the Commission should reevaluate the spac­
ing situation when it considers future applications for 
space stations proposed to be launched after this ten year 
period. 
23. The petition also states that while the need for 2° 
spacing has subsided, the benefits to be derived from the 
use of smaller receiving antennas have increased. It asserts 
that the HSD market is strongly affected by the size of the 
receiving antenna that can be used. GIC claims that with 
the 8 to 10 foot antennas currently used. it is anticipated 
that the market will expand from approximately 2.6 mil­
lion to 4 million earth station owners over the next five 
to eight years. With dishes 4 feet or less, it estimates the 
market could grow to 10 million in the same time period. 
Smaller dishes will, according to the petition, eliminate 
some of the local zoning problems that many HSD own­
ers are experiencing. 
24. Opponents argue that the demand for C-band tran­
sponders is not declining. For example, one satellite 
operator states that the four primary cable satellites have 
been over 70 percent presubscribed prior to launch.29 
Other commenters assert that contrary to petitioners' 
claims. introduction of new technologies such as digital 
video compression will increase rather than decrease de­
mand for C-band transponders by increasing opportunities 
for new services.30 Because an expansion in spacing will 
decrease the number of orbital locations available for 
domestic satellite use,31 commenters fear that a transpon­
der shortage will result which will stifle the growth of 
29 Comments of GE. 
3° Comments of GE, Hughes. These parties caution that the 
introduction of digital compression technology will necessitate 
expensive installation of new ground equipment and that such 
expense may delay implementation. Commenters state that most 
major programmers have binding contracts for full transponders 
and that once compression techniques are available, the industry 
will use the resulting extra capacity to accommodate new ser­
vices. 
31 Hughes states that the GCI petition's proposal will result in 
the loss of three orbital locations in the western portion of the 
arc. 
32 GE estimates that petitioners' plans will have this effect. 
33 Comments of GTE. 
34 USSB states that there is no evidence of a decrease in 
demand for C-band capacity. Hughes states that C-band tran­
sponders are heavily used. ARC states that demand varies at 
peak hours and that any measurement of usage conducted dur-
459 
new services as well as drive up the price of satellite 
capacity. Opponents argue that the GIC petition has failed 
to demonstrate that the market for C-band transponders is 
so diminished that a 20% reduction in capacity32 that 
would result from increased spacing will not adversely 
affect services. They also state that relocations at C-band 
will imract Ku-band services and transponder availability 
as well. 3 
25. It is not clear, based on this record, whether there is 
now an excess of transponder capacity at C-band.34 It is 
even less clear what the future use of this band will be.35 
In the past, new and innovative satellite services have 
been introduced at C-band as technology has developed 
and we have no reason to believe that this trend will not 
continue. Under these circumstances, we cannot conclude 
that demand is so reduced that restricting capacity to the 
extent suggested by petitioners is warranted. 
26. Opponents of the petition also cite significant costs 
that they will be forced to incur if spacing policies are 
changed. Since adoption of 2° spacing in 1983, industry 
participants have been preparing for its full implementa­
tion and have already expended considerable time and 
money on transition plans to accommodate operations 
under 2° spacing conditions. Additional costs would be 
incurred if spacings were to be changed to 3° and oper­
ators had to adjust their equipment accordingly. These 
include the costs of repointing antennas36 and modifying 
spacecraft currently under construction37 Significantly, 
many of these opponents are participants in the HSD 
industry. 38 
27. GIC asserts that opponents should be required to 
document the costs and economic impact they claim will 
result from a change in spacing policies. Such documenta­
tion would include, according to GIC, contracts claimed 
to be disrupted. In addition. GIC challenges opponents to 
document costs of repointing antennas.39 
28. Alascom states that a service that would be adversely 
affected by petitioners' proposal to relocate Aurora 2 
would be telephone service to the bush communities of 
Alaska. Antennas serving these communities are not 
steerable and it would take two to four weeks to repoint 
ing off-peak hours must take this fact into consideration. IDB 
states that there is a shortage of C-band transponders for video 
services, particularly for occasional video use. 
35 Commenters argue that new technologies will be imple­
mented at C-band. 
36 See Comments of ABC. 
3; See Comments of GE. 
38 E.g., HBO and C-Span provide programming that is sold to 
HSD customers. GE and Hughes are licensees of satellites that 
serve cable as well as HSD customers. 
39 Specifically, GIC states that challengers should document 
the costs incurred as a result of relocations occasioned by the 
recent demise of Alascom's Aurora 1 satellite. When this sat­
ellite became nonfunctional, emergency measures were taken to 
relocate temporarily Alaskan telephone traffic until its replace­
ment, Aurora 2, was launched. GlC claims that documentation 
of these costs will give an accurate indication of the actual 
expenses involved in repainting antennas. 
FCC 92-1 Federal Communications Commission Record 7 FCC Red No. 2 
them, assuming good weather. This process would cause 
temporary suspension of telephone service in these iso­
lated areas. 40 
29. In addition, many opponents are concerned that 
relocation of satellites under GIC's proposals will prevent 
certain satellites from providing 50 state coverage.41 For 
example, satellite users are concerned that both of the 
petitioners' proposed assignment plans require Aurora 2 
to move from 139° to 1420'_42 These users contend that this 
move would adversely affect the majority of radio net­
works using that satellite. They assert that they have con­
tracts for the distribution of radio programming which 
are based on the satellite's ability to cover all 50 states and 
relocation would severely disrupt these business arrange­
ments. They also state that these services must be carried 
on one satellite in order to be efficiently delivered.43 GE 
states that if its satellites are relocated. it will cost $1000 
to repoint each of its 3000 antennas used to provide radio 
programming. 44 
30. We agree with a major concern of opponents that' a 
change in satellite spacing policies at this time will result 
in significant cost and disruption to an industry that is, by 
its nature, subject to substantial risks. 45 As one provider of 
video services stated," the very filing of the Petition per­
haps jeopardizes or at least casts a cloud of uncertainty 
over the elaborate and complicated transition plans. "46 Pe­
titioners' proposal that 3° spacing be imposed as a tem­
porary measure will only compound the uncertainty 
generated by a policy shift that may be reversed in ten 
years. 47 We believe that the disruption and uncertainty 
that will be generated by increased spacing is not justified, 
especially where proposed changes will only assist a dis­
crete segment of users to the detriment of other users and 
4° Comments of Alascom. 
41 See. e.g., comments of Viacom. C-Span. GE. ABC and 
Alascom for additional concerns about 50 state coverage. 
42 See, e.g., comments of ABC, Westwood One. Inc .. CBS. 
Opponents say a satellite located at l.:12° W.L. will not be able to 
provide service to most of New England while GIC asserts that 
only the northernmost tip of Maine will be affected. Under one 
of petitioners' proposals. GE's Satcom C- l would be relocated to 
140° W.L. where GE states it will be unable to provide 50 state 
coverage. Our calculations suggest that service from locations 
west of 139° W.L. may be marginal in parts of New England. 
43 Comments of ABC. 
44 GIC cites information that the digital audio tape (DAT) 
technology used to deliver these radio services may be aban­
doned. However. this is not confirmed in the record and does 
not answer opponents' general concerns about disruption of 
radio services caused by relocations. 
4 s For example, space station facilities requiring expenditures 
of approximately $ 100 million are subject to launch and in-orbit 
failures. 
46 Comments of HBO. GTE states that perceptions of 
predictability and stability are critical factors in consumer 
choices of telecommunications systems and that relocations 
could cause users to reject satellite-based facilities in favor of 
terrestrial facilities. 
47 ARC states that if companies invest in equipment that will 
be compatible with 3° spacing, it will be difficult and expensive 
to replace this equipment if spacings are changed back to 2° at a 
later date. 
48 Comments of AT&T and Alascom. 
49 See Comments of HBO. Hughes states that five of the 
satellites of most concern if 3° spacing is to be implemented will 
be launched by late next year and that any change in spacing 
will require costly in-orbit relocations. GE states that GIC's 
460 
where the alleged benefits are speculative.48 We also agree 
with those opponents who state that it is very late in the 
implementation process to be proposing a change in sat­
ellite spacings.49 
31. On balance, based on the record before us, we find 
that the costs and disruption that would result from even 
a temporary change in our spacing policy would be sig­
nificant.so Although we have stated that orbital locations 
are not assigned permanently and are subject to change 
upon thirty days notice,51 we have also attempted to avoid 
unnecessary disruption and relocation in this highly 
capital intensive market.52 In reaching this conclusion, we 
recognize the public interest potential of satellite delivered 
video grogramming services as a competitive alternative to 
cable, 3 but the result requested by the petitioners will 
cause potential economic harm to other users of satellite 
services and may not offer the benefits that petitioners 
predict.54 Judging from this record. a change in satellite 
spacing is supported primarily by those involved in C­
band video programming distribution directly to individ­
ual homes.5 Other providers and users of satellite services 
are strongly opposed, including those operators of space 
stations that would be located 3° apart and who might 
derive some potential benefits from a relaxed interference 
environment.56 Public interest considerations, based on an 
evaluation of the entire satellite industry, do not support 
granting these petitions. 
C. Loss of Regulatory Flexibility 
32. Another major concern articulated by opponents is 
that a change in spacing policy may adversely impact the 
traditionally flexible regulatory policies the Commission 
has applied to the satellite industry. Opponents cite the 
concerns should have been raised eight years ago in a pettt10n 
for reconsideration of Reduced Spacing. GTE points out that 
although petitioners state that they have tried to minimize 
relocations. their plans do not take into account the phased-in 
launch schedules of the various satellites involved and the fact 
that not all orbital locations will be available at the same time. 
50 The burden is on the petitioner to demonstrate the justifica­
tion for the institution of a rulemaking and the record here 
indicates that the costs of relocation of satellites on a scale 
requested by the Petitions would be substantial. 
SI See, e.g., Hughes Communications Galaxy, Inc., 3 FCC Red. 
6989 (1988) at para. 23. 
52 See GE American Communications, Inc .. 3 FCC Red. 6871 
( 1988) at para. l l. See also comments of Hughes regarding the 
amount of investment necessary. 
s3 See Competition, Rate Deregulation and the Commission's 
Policies Relating to the Provision of Cable Television Service. 5 
FCC Red .:1962 (1990); Inquiry into the Existence of Discrimina­
tion in the Provision of Superstation and Network Station Pro­
~ramming, 6 FCC Red 3312 (1991). 
4 GIC submitted a market study with its reply comments that 
was based on a telephone survey of HSD retail dealers and 
reflects their opinion that they might sell more equipment if 
the size of the antenna were reduced. It is also questionable 
whether four foot antennas will provide adequate service under 
3° spacing. See discussion supra at Section A. 
ss GTE states in reply comments that opposing parties 
comprise virtually all the domestic fixed satellite licensees, ma­
!or users and resellers of satellite capacity and DBS licensees. 
6 See, e.g., comments of Hughes and GE. operators of satellites 
that would be spaced at 3 under petitioners' proposals. 
7 FCC Red No. 2 Federal Communications Commission Record FCC 92-1 
fact that if spacings are not uniform throughout the or­
bital arc, satellite locations can no longer be considered 
fungible. 57 Consequently. locations spaced 3° apart would 
be more desirable than those spaced 2° apart because of 
reduced mutual interference and comparative hearing 
procedures might be necessary to evaluate applicants for 
particular locations. In addition. reserving 3° locations for 
those involved in distribution of entertainment video 
might have the effect of establishing a monopoly for video 
service providers with little opportunity for entry or exit 
in the market without relocating facilities. Opponents 
argue that such an approach would not be consistent with 
the "open skies" policies traditionally applied to this in­
dustry which enable the Commission to accommodate 
expeditiously all qualified applicants5' and enables all li­
censees to determine which services they will provide. 
GIC responds that because its proposed assignment plan is 
only temporary. hearings to authorize new facilities would 
not be necessary. 
33. We believe that any spacing policy that establishes 
different interference environments for different classes of 
operators and users without significant public interest 
benefits would undercut the traditional flexibility that has 
been the basis of our regulation of the satellite industry. 
GIC's proposal that 3° spacing be instituted only as a 
temporary measure does not relieve the situation. Oper­
ators would still be under different constraints depending 
on the service they are offering for at least ten years. In 
addition. competing applications for particular orbital lo­
cations. even for replacement satellites. in the part of the 
arc where 3° spacing is in effect. might be mutually 
exclusive and thus subject to the cost and delay of hearing 
requirements. Absent the imposition of a moratorium on 
applications for the western arc at C-band for a limited 
time. there is no guarantee that such applications will not 
be filed in the next several years and that we would not 
be faced with the prospect of costly and time consuming 
comparative hearings as well as disruptive reevaluation of 
spacing policies. We also agree that a policy which estab­
lishes spacing based on the type of service offered at one 
point in time would have the effect of reserving orbital 
locations based on private business arrangements which 
might be changed. For example. satellites carrying video 
traffic today may be used for other services in the 
future. 59 Such a policy is inconsistent with our flexible 
regulatory approach to this industry. 
34. Opponents also fear that a reduction in the number 
of orbital locations caused by the expansion of spacings 
will impact on the Commission's ability to accommodate 
57 See 1988 Orbital Assignment Order. supra note l l at para. 3. 
for a general discussion of fungibility. 
58 Comments of Hughes. 
59 See comments of GTE regarding establishment of a 
monopoly for the video distribution business. 
6° Comments of Alascom. 
61 Comments of Hughes. GE. GTE. 
6l Hughes Communications Galaxy, 6 FCC Red 72 ( 1991 ). 5 
FCC Red 3423 (1990). See also comments of GTE and AT&T 
regarding the benefits of hybrid technology. 
63 National Exchange (NEX) has filed for an extension of time 
in which to begin construction of this satellite. which is still 
pending. GE states that if NEX's request for an extension of 
time is denied. it would be interested in applying to use the 
hybrid location at 127° W.L. The authorization of another hy­
brid satellite which was assigned to a location in this portion of 
461 
new technologies either at C- or Ku-band. 00 They state 
that by changing the spacing of satellites at C-band, the 
number of hybrid locations available for assignment to 
satellites operating in both bands will be reduced because 
spacings will no longer be coincident.61 Although GIC 
offers its opinion that hybrid satellite locations may not 
be in demand. noting that there are no currently pending 
applications for hybrids and that hybrids may be too 
heavy to launch economically. other commenters dis­
agree. In particular. Hughes states that hybrid technology 
is economicallv efficient and cites its recent authorizations 
to consolidate- four single-band space stations into two 
state-of-the-art hybrid space stations.62 In addition, under 
both of GICs proposals. one authorization. that of NEX's 
Spotnet 2 satellite. would have to be cancelled.b3 
35. Further. both of petitioners' proposed assignment 
plans would place a U.S. satellite at 122° W.L. instead of 
123° W.L. and would reduce the space between the U.S. 
satellite and a Canadian satellite from 4.3 degrees to 3.3 
degrees. The petition notes that this change may require 
bilateral negotiations between the U.S. and Canadian gov­
ernments but indicates that there should be no technical 
objection from Canada and that any problems should be 
resolvable. In contrast. GTE. the operator of the satellite 
currently located at 120° W.L. and a participant in bi­
lateral negotiations with Canada. strongly asserts that any 
renegotiations of the agreements in question would prob­
ably be unsuccessful. 04 
36. Based on the record before us. we conclude that a 
retreat from our long established policy of 2° satellite 
spacings would have a severe impact on our regulatory 
policies in this area. Although this impact might not. hy 
itself. be determinative in deciding to dismiss the pending 
petitions. when coupled with the fact that such a change 
would result in substantial costs and disruption to the 
majority of satellite industry participants and with the 
significant questions that have been raised about the tech­
nical assumptions and feasibility of petitioners' proposals. 
it lends further support to our conclusion that consider­
ation of a change in satellite spacing policies is not in the 
public interest. 
IV. CONCLUSION 
37. We conclude that grant of the petitions would not 
be in the public interest. Our technical evaluation of 
petitioners' proposals indicate that four foot antennas will 
not produce an acceptable quality picture under 3° spac­
ing conditions and that higher cost consumer equipment 
the orbital arc. Contelsat-2 at 128° W.L.. was relinquished by 
GTE Spacenet Corporation after the petitions were filed. See 
Letter to Secretary from Terri B. Natoli. July 24. 1991. This 
letter also indicates that the operational life of ASC-1. the 
satellite that Contelsat-2 was supposed to replace, will be longer 
than expected and thus the relinquishment of the Contelsat-2 
authorization will not necessarily result in a vacant orbital 
location in the near future. 
114 See Comments of GTE for description of difficulties in­
volved in such international negotiations. Because such a move 
would impact on a trilateral agreement with the U.S .. Canada. 
and Mexico. negotiations would also have to include the Mexi­
can government. 
FCC 92-1 Federal Communications Commission Record 7 FCC Red No. 2 
will be required. In addition, establishing 3° spacing, even 
in only part of the orbital arc, will cause major costs and 
disruption to satellite licensees and to users of satellite 
services. Such costs include the necessity to repoint anten­
nas, to modify spacecraft under construction and to modi­
fy long range operating plans. Relocations necessitated by 
3° spacing would cause certain satellites to Jose their 
ability to serve all 50 states and would adversely affect the 
delivery of certain services. contracts for which were 
based on 50 state coverage. Disruption to customers of 
satellite operators, including those providing essential tele­
phone service, would be significant. Finally. a change to a 
3° spacing policy would impact flexible Commission regu­
latory policies by establishing different user classes. by 
reducing the number of C-band and hybrid orbital loca­
tions and by necessitating the reopening of international 
treaty negotiations. 
38. ACCORDINGLY. pursuant to Section 1.407 of the 
Commission's rules, 47 C.F.R. § 1.407, the petitions filed 
by the Satellite Dealer Forum and K-Sat Broadcasting and 
by General Instrument Corporation. et. al. are hereby 
denied. 
FEDERAL COMMUNICATIONS COMMISSION 
Donna R. Searcy 
Secretary 
APPENDIX A 
Comments/Oppositions: 
Oppositions: 
ABC Radio Network. Inc. (ABC) 
Alascom. Inc. (Alascom) 
American Telephone & Telegraph Co. (AT&T) 
ARC Professional Services Group. Inc. (ARC) 
GE American Communications. Inc. (GE) 
GTE Spacenet Corporation (GTE) 
Hughes Communications Galaxy. Inc. (Hughes) 
IDB Communications Group. Inc. (IDB) 
International Family Entertainment. Inc. (!FE) 
National Cable Satellite Corporation. d/b/a C-Span 
(C-Span) 
QVC Network. Inc. (QVC) 
United States Satellite Broadcasting Company, Inc. 
(USSB) 
Viacom International Inc. (Viacom) 
Westwood One, Inc. (Westwood One) 
Comments: 
CBS Inc. (CBS) 
Home Box Office, Inc. (HBO) 
National Exchange Satellite, Inc. (NEX) 
462 
The Space Segment Group of SBCA (SBCA) 
Cascade Cable Systems 
North Atlantic Satellite Systems 
Cable TV Associates. Inc. 
7 FCC Red No. 2 Federal Communications Commission Record FCC 92-1 
Reply Comments: 
Chaparral Communications. Inc. (Chaparral) and 
Addendum 
General Instrument Corporation (GIC) 
GTE Spacenet Corporation 
Home Box Office, Inc. 
Hughes Communications Galaxy, Inc. 
National Cable Television Association, Inc. (NCTA) 
National Rural Telecommunications Cooperative 
(NRTC) 
Space Systems/Loral (Loral) 
Warren Supply Company (Warren) 
National Cable Television Cooperative, Inc. (NCTC) 
GE American Communications, Inc. Reply to Ad­
dendum 
Congressional Correspondence: 
Honorable Mike Synar 
Honorable Rick Boucher 
Honorable Jim Cooper 
Honorable Billy Tauzin 
Honorable Ralph M. Hall 
Honorable Jim Slattery 
Honorable Bill Richardson 
TECHNICAL APPENDIX B 
1. Petitioners assert that four foot antennas will produce 
a picture of acceptable quality under conditions of 3° 
spacing. Based on evaluation of the petitions' proposals, 
the oppositions. comments and reply comments. we con­
clude that several crucial technical factors have been 
omitted in petitioners' analysis. These include the follow­
ing: 1) the effect of the voltage standing-wave ratio 
(VSWR) on the carrier-to-thermal noise (C/N) ratio: 2) 
the C/N expected to be received in the operating environ­
ment: 3) the carrier-to-interference plus thermal noise 
C/(1 + N) ratio expected: and 5) the necessity of a higher 
cost commercial quality low-noise-block-converter (LNB ). 
When these factors are taken into consideration. we con­
clude that the petitioners· proposals are not feasible. 
A. The effect of VSWR on Carrier-to-noise ratio 
2. Voltage standing-wave ratio (VSWR) is an electrical 
phenomenon resulting from the mismatch of the char­
acteristic impedance between the low-noise-block-convert­
er (LNB) and the antenna feed. This electrical 
phenomenon introduces additional signal loss between the 
antenna feed and the LNB and, consequently, increases 
the receiving system noise temperature. 
65 Petition at 21 and Attachment at 4-05. 
66 Petition at Attachment and Chaparral reply comments at 6. 
67 LNR Communications. Inc., Locus, Inc., Tampa Microwave 
463 
3. As the petitioners assert, due to the rapid commer­
cialization of the high electron mobility transistor 
(HEMT) in the last few years, it is possible for C-band 
LNBs to achieve lower noise temperature as low as 25 K, 
and 40 K LNB is rapidly becoming the new standard. The 
petitioners further state that a 4 foot antenna having an 
efficiency of 65% and an antenna temperature of 40 K, 
with the next generation domestic satellites with equiv­
alent isotropically radiated powers (EIRP's) of 40 dBW, 
could produce a C/N of 10 dB at home receivers. The 
petitioners also claim that even currently operating do­
mestic satellites with 5 to 10 watts of transmitter power 
can produce acceptable video signals for home viewing 
because a 7 dB of C/N is a minimum value for good 
quality video reception (FM-receiver-threshold).65 
4. The petitioners also indicate that a 4 foot HSD 
system has been operating at Chaparral Communications 
in San Jose, California and a home installation nearby for 
over a year. The petitioners further claim that the power 
levels, antenna parameters, and LNB performance are all 
measured quantities and the performance is exactly as 
shown in the analysis. 66 We accept the fact that the sys­
tems are performing as claimed. However, the petitioners' 
analysis fails to take several factors into account in evalu­
ating the HSD operating environment. 
5. To evaluate the effect of the LNB upon performance, 
it is necessary to know how much noise it contributes to 
the total system noise in the received C/N. Based on our 
analysis. the LNB used by Chaparral Communications in 
its operational 4 foot HSD system must be a high quality 
professional unit with a VSWR range approximately be­
tween 1.2: I to 1.25: 1 and an antenna feed VSWR also in 
the same range. Using these estimates and the parameters 
identified in paragraph 3 above. the 4 foot receiving an­
tenna gain-to-system noise temperature (G/T) ratio is 
about 13.6 dB which is identical to the number shown in 
Figure 2 of Attachment A to the petition. We have re­
cently received technical specifications and cost informa­
tion from LNB manufacturers and trade journals.67 These 
indicate that the unit cost of a high quality professional 
LNB is several thousand dollars. This information also 
indicates that a commercial quality LNB with a typical 
VSWR of 1.3:1 costs approximately $550 and an HSD 
quality LNB with a typical VSWR of 3.0: 1 costs less than 
$150. The corresponding 4 foot receiving antenna GIT for 
these two LNBs is 11.6 dB and 9.2 dB. respectively. For a 
satellite emitting an EIRP of 40 dBW, the received ther­
mal noise video signal C/N for 4 foot antennas using 
professional. commercial and HSD quality LNBs is 10.0 
dB. 8.0 dB, and 5.6 dB. respectively in an interference 
free environment. It should be noted that a commercial 
quality LNB could produce barely acceptable video sig­
nals because the current C/N for the FM-receiver-thresh­
old level for a good picture is about 7 to 8 dB.68 For an 
HSD quality LNB. the received C/N would not allow 
reception of acceptable video signals for home viewing 
because a 5.6 dB of C/N is below the FM-receiver-thresh­
old level. Therefore, a 4 foot antenna with an HSD qua!-
Lab, Inc .. California Amplifier, In. and Via Satellite. The in­
formation obtained from these sources has been made part of 
the record in this proceeding. 
68 AT&T at 3 footnote. Petition at Attachment 4-05. 
FCC 92-1 Federal Communications Commission Record 7 FCC Red No. 2 
ity LNB will not provide reception of a clear video 
picture with any satellite spacings. Many commenters 
reach the same conclusion.69 
B. Carrier-to-noise ratio in the operating environment 
6. The petitioners assert that C-band satellite transmit­
ting technology has changed. The next generation of C­
band satellites will use amplifiers of up to 16 watts. The 
petitioners further assert that this power level, coupled 
with an improved LNB, means that HSD sizes of 4 feet or 
less will produce a good picture, provided that the anten­
nas can reject interference from adjacent satellites. 70 This 
assertion is accurate provided that all the petitions' as­
sumptions are true and the EIRP is at least 40 dBW. The 
petitioners also contend that the next generation domestic 
satellites will provide acceptable video reception by anten­
nas 4 feet or less "over most of the country." 71 In order 
to clarify these assertions, we need to look at the expected 
C-band satellite environment. 
7. Based on the technical information that we provided 
to the IFRB for international coordination purposes72 and 
the technical information in the relevant domestic sat­
ellite application files, the expected C-band satellite EIRP 
environment is not as homogeneous as the petitioners 
claim.73 Based on our examination, the western arc C­
band satellite environment shows that the expected EIRP 
ranges between 36.2 dBW and 43.0 dBW for different 
parts of CONUS. The specific expected EIRPs for five 
domestic satellites in the western arc are illustrated in 
Attachment 1. These are extracted from the available 
spacecraft transmitting antenna gain contours and the cor­
responding maximum video signal peak power into the 
antenna. 
8. The carrier-to-noise ratio is directly proportional to 
the EIRP from the satellite. Using the petitioner's 4 foot 
antenna, the commercial quality LNB as described in 
paragraph 5 and the EIRP from Attachment 1, the ex­
pected received video signal C/Ns are illustrated in At­
tachment 2.74 The C/N values are for thermal noise con­
ditions without interference from adjacent satellites. The 
result indicates that only two of the five satellites in the 
western arc that we analyzed could provide a video signal 
C/N level of 7 dB and higher for the entire CONUS 
coverage. The other three satellites provide C/N as low as 
4.2 to 6.5 dB in many regions of CONUS. Based on the 
thermal noise C/N alone, the petitioners' claim of accept­
able video performance for 4 foot antennas over most of 
the country is misplaced because a C/N of 4.2 to 6.5 dB 
can not enable the reception of a clear video picture. 
69 See e.g., comments of GE at 10, GTE at 6. 
70 Petition at 11. 
71 Petition at 21-22. 
72 International coordination is conducted under the auspices 
of the International Telecommunication Union (ITU) and Inter­
national Frequency Registration Board (IFRB) which is one of 
the permanent organs of the ITU with the responsibility to 
publish the coordination information and to record the coordi­
nated satellite networks in the Master International Frequency 
Register. Coordination is intended to ensure that the operation 
of U.S. satellites will be protected from harmful interference by, 
and will not cause harmful interference to, other countries' 
satellites. The technical information sent to the IFRB is pro-
464 
C. Carrier-to-interference ratio 
9. The petitioners claim that HSD sizes of 4 feet or less 
will produce a good picture, provided that the antenna 
can reject interference from adjacent satellites. 75 The peti­
tioners state that "[a] 4 foot antenna has a beamwidth of 
4.2 degrees. This means that when the 4 foot dish is 
pointed at the desired satellite. it will also be receiving the 
full si~nal from an unwanted satellite spaced 2 degrees 
away." 6 The petitioners further claim that 3 degree spac­
ing will result in acceptable performance for 4 foot anten­
nas. 77 Many commenters indicate that a 3 degree spacing 
environment in the western arc will not provide sufficient 
off-axis discrimination for acceptable performance for 4 
foot antennas. 78 Our assessment also indicates that 4 foot 
antennas will fail to attain the inter-satellite discrimina­
tion necessary to produce an interference-free signal for 
HSD viewing over most of the country. Therefore, the 
petitioners' claim is misplaced. 
10. In a homogeneous video satellite environment, the 
"carrier-to-interference (C/I) ratio at the receiving earth 
station is primarily determined by the apparent satellite 
separation as viewed from the earth, the corresponding 
receiving antenna off-axis discrimination and the polariza­
tion isolation factor. The petitioners indicate that the 
apparent satellite separation for San Jose, California is 3.4 
degrees for satellites separated by 3 degrees in the 
geostationary-satellite orbit. The corresponding antenna 
isolation is 11 dB. 79 For the western arc satellites, the 
apparent satellite separation angle is smaller for other 
CONUS locations. Earth stations located in New England 
states, for example, have apparent satellite separation an­
gle of about 3.16 degrees. The corresponding antenna 
isolation is only 9 dB. The apparent satellite separation 
angle for other locations is illustrated in the top row of 
Attachment 3 and the corresponding antenna isolation is 
illustrated in the second row. Assuming the earth station 
vided by the licensee pursuant to 47 C.F.R. Section 25.11 l(b) 
and conforming to these technical parameters is a condition 
J,Jlaced on each spacecraft's authorization. 
'
3 Petition At-tachment at Figure 2; Chaparral reply comments 
at Attachment. 
74 We concluded earlier that the 4 foot antenna with a HSD 
quality LNB (i.e., LNB having a VSWR in the range of 3.0:1 ) 
will not enable reception of a clear video picture. 
75 Petition at 11. 
76 Petition at 21. 
77 Petition at 21 and Attachment at 4-07-09. Chaparral reply 
comments at 6. 
78 Comments of GE at 10, comments of GTE at 4, comments 
of Hughes at 3. 
79 Petition at Attachment 4-08. 
7 FCC Red No. 2 Federal Communications Commission Record FCC 92-1 · 
antenna has a cross-polarization isolation of 10 dB,80 the 
C/I for a single adjacent satellite is between 21 dB and 19 
dB. See the fourth row of Attachment 3. The aggregate 
C/I is between 17.3 dB and 15.3 dB because, in a domestic 
satellite environment, there are adjacent satellite interfer­
ence sources from both sides of the satellite. The expected 
aggregate C/I for the scenario is illustrated in the last row 
of Attachment 3. There are additional external interfer­
ence sources that have not been taken into account, e.g., 
terrestrial fixed-microwave and the 20 MHz offset co­
polarized transponders.81 These factors would further de­
grade the aggregate C/I. 
11. Chaparral in its reply comments indicates that a C/I 
of 15 dB is considered "[n]early perfect - few noise spark­
les - still below cable quality -perfect for home" and a C/I 
of 18 dB contains "[n]o interference visible at all." 82 
Chaparrars experiment verified information provided to 
the Commission by the satellite industry in 1976. 83 That 
information indicated that "interference was first detect­
able with a protection ratio (C/I] of 18 dB. clearly notice­
able at 16 dB, and became unacceptable at 14 dB." 
Therefore, based on this information, a 4 foot antenna 
will not be able to provide a video picture without any 
noise sparkles over most of the country since the es­
timated aggregate C/I is between 17.3 dB and 15.3 dB. 
D. Carrier-to-interference plus thermal noise ratio, 
C/(I+N) 
12. As we have demonstrated, a 4 foot antenna with a 
commercial quality LNB will provide a range of a video 
C/N between 4.2 dB and 11 dB. We have also dem­
onstrated that the estimated aggregate C/I is between 15.3 
dB and 17.3 dB. The composite total C/(I + N) is between 
3.9 dB and 10.2 dB.84 As noted by the petitioners, Chap­
arral and AT&T. a common FM-receiver-threshold is ap­
proximately 7-to-8 dB.85 This threshold level is the 
minimum value for a good picture. The composite 
C/(I + N) for the five satellites is illustrated in Attachment 
4. This information demonstrates that there will be many 
regions in CONUS unable to receive an acceptable video 
picture using a 4 foot antenna. 86 Furthermore, no single 
satellite in the scenario could provide acceptable HSD 
video reception in all regions in CONUS. 
E. Cost of an effective system 
13. GE's comments state that it received price quota­
tions from a local HSD dealer for C-band equipment.87 It 
indicates that the least expensive 10 foot antenna system 
was approximately $3000 installed and the price of a 4 
foot antenna system would be $2700 installed, the $300 
difference being attributable to the difference in the cost 
of antennas alone. Warren Supply Company (Warren) in 
its reply comments indicates that a 7 foot system costs 
80 47 C.F.R. Part 25.209(2b). This rule applies to a transmitting 
antenna in the 6 GHz band. If a 4 GHz receiving antenna can 
not meet this standard, the cross-polarization isolation will be 
less than 10 dB. 
81 Comments of GTE, Appendix A at 1. 
82 Chaparral reply comments at Attachment A. 
83 Declaratory Ruling and Order, RM-2614 and RM-2725, 
FCC-1169 (released January 7, 1977). 
84 The carrier-to-interference plus thermal noise ratio is the 
465 
between $1850 to $2000 and a 4 foot system would cost 
$200 less. Warren claims that the equipment "savings to 
consumers based on a $200 per unit savin~s with 850,000 
systems a year, is $170 million dollars. 8 However, in 
order to make a 4 foot system work in the San Jose area, 
for example, the HSD quality LNB (a LNB having a 
VSWR around 3.0:1) needs to be upgraded to a commer­
cial quality LNB (a LNB having a VSWR around 1.3:1).89 
Commission staff has received price quotations from LNB 
manufacturers and distributors. These do not include in­
stallation costs and indicate that a commercial quality 
LNB is approximately three times as expensive as an HSD 
quality LNB, a difference of approximately $400. There­
fore, the petitioners' claims of lower costs and annual 
consumer savings possible with 4 foot HSD's appears 
inaccurate. 
effective aggregate signal level received by an HSD receiver. 
This ratio determines the quality of the video picture in an 
adjacent satellite interference environment. 
85 See notes 7 and 10. 
86 Acceptable picture implies that the video picture quality is 
"good" under the FM-threshold condition and there are no 
noise sparkles under adjacent satellite interference conditions. 
87 GE comments at 42. 
88 Petition at 25. Warren reply comments at 2. 
89 See para. 5, supra. 
EXPECTED SATELLITE EIRP FOR VARIOUS PARTS OF CONUS 
I Approximate EIRP (dBW) in the Region of 
Orbital I I I Maximum I I Northern I I I Southern 
Location I I I EIRP (2} I West I Plane I New I East I Florida 
(oeg.WL) I Satel 1 ite Name I Pol ( 1) I (dBW) I Coast I States I England I Coast I 8. Texas 
I I I I I 
137 Satcom C-1 H 38.2 37.2 36.2 36.2 37.2 36.2 
v 39.0 37.0 38.0 38.0 38.0 37.0 
135 Satcom C-4 H 41.5 39.5 39.5 39.5 40.5 39.5 
v 43.0 40.5 39.0 39.0 40.0 40.0 
133 Galaxy IR H 41.1 40. 1 39.1 39. 1 40.1 39.1 
v 40.5 40.0 38.5 38.5 39.5 38.5 
131 Satcom C-3 H 43.0 41.0 41. 0 41.0 42.0 41.0 
v 43.0 40.0 39.0 39.0 40.0 40.0 
~I 125 Galaxy v-w H 41. 1 39. 1 39. 1 39. 1 40.1 39.1 v 40.5 39.5 38.5 38.5 39.5 38.5 
__ I I I I I I 
Note: (1) This is the type of polarization; H stands for horizontal and V stands for· vertical. 
(2) The maximum EIRP is at the transmitting antenna beam boresight. 
AlTAOlllENT 1 
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137 
135 
133 
131 
125 
EXPECTED VIDEO SIGNAL CARRIER-TO-NOISE (C/I) RATIO AT THERMAL NOISE 
WITHOUT ADJACENT SATELLITE INTERFERENCE 
Approximate C/N (dB) in the Region of 
I I Maximum I I Northern I I I Southern 
I I C/N (2) I West I Plane I New I East I Florida 
Satellite Name I Pol (1) I (dB) I Coast I States I England I Coast I & Texas 
I I ,_ ____ I 
Satcom C-1 H 6.2 5.2 4.2 4.2 5.2 4.2 
v 7.0 5.0 6.0 6.0 6.0 5.0 
Satcom C-4 H 9.5 7.5 7.5 7.5 8.5 7.5 
v 11 .0 8.5 7.0 7.0 8.0 8.0 
Galaxy IR H 9. 1 8. 1 7. 1 7. 1 8. 1 7. 1 
v 8.5 B.O 6.5 6.5 7.5 6.5 
Satcom C-3 H 11 .0 9.0 9.0 9.0 10.0 9.0 
v 11.0 8.0 7.0 7.0 8.0 8.0 
Galaxy V-W H 9. 1 7. 1 7. 1 7. 1 8.1 7 .1 
v B.5 7.5 6.5 6.5 7.5 6.5 
__ I I I I 
'-
Note: (1) This is the type of polarization: H stands for horizontal and V stands for vertical. 
(2) The maximum C/N is at the transmitting antenna beam borasight. 
ATTACJ-NEN'T 2 
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ESTIMATED AGGREGATE CARRIER-TO-INTERFERENCE (C/I) RATIO 
FOR SATELLITES SPACED AT 3 DEGREES INTERVAL 
Apparent satellite separation (deg.) 
West 
Coast 
3.37 
Receiving antenna isolation (dB} (1) 11.0 
Assumed cross-polarization isolation (dB) 10.0 
Single-entry C/l ratio (dB) 21 .0 
Aggregate C/I ratio (dB) 17.3 
Northern 
Plane 
States 
3.28 
10.0 
10.0 
20.0 
16.3 
New 
England 
3. 16 
9.0 
10.0 
19.0 
15.3 
Note: (1) The entry is extrapolated from the Figure in the petition. 
East 
Coast 
3.2 
9.0 
10.0 
19.0 
15.3 
ATTAQ-NENT 3 
Florida 
3.27 
10.0 
10.0 
20.0 
16.3 
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ATTACHAENT 4 
ESTIMATED COMPOSITE CARRIER-TO-INTERFERENCE PLUS TI-IERMAL NOISE, C/(l+N), RATIO (1) 
Estimated Composite C/(I+N) ,dB in the Region of 
Maximum I I Northern I I I 
Cl (I =N) I west I Plane I New I East I 
Satellite Name I Pol ( 2) I (dB) I Coast I States I England I Coast I Florida 
I I I I 
Satcom C-1 H (5.9) (4.9) (3.9) (3.9) (4.8) (3.9) 
v (6.0) (4.B) (5.0) (5.5) (5.5) (4.7) 
Satcom C-4 H 8.B 7. 1 7.0 (6.8) 7.7 7.0 
v 10. 1 8.0 (6.5) (6.4) 7.3 7.4 
Galaxy IR H 8.5 7.6 (6.6) (6.5) 7.3 (6.6) 
v 8.0 7.5 ( 6. 1) (6.0) (6.8) (6.1) 
~I Satcom C-3 H 10. l B.4 B.3· 
8. l 8.9 8.3 
v 10. 1 7.5 (6.5) (6.4) 7.3 7.4 
Galaxy v-w H 8.5 (6.7) (6.6) (6.5) 7.3 (6.6) 
v 8.0 7. 1 (6. 1) (6.0) (6.8) (6. 1) 
I I I I I I I 
---
Note: (1) The entry enclosed by a set of parentheses is below a typ1cal FM-rece1ver-threshold level of 7 db. 
(2) Th1s ls the type of polar1zat1on: H stands for horizontal and V stands for vertical. 
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