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Televisa, SA de CV Dismissal

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Released: July 18, 2014

Federal Communications Commission

Washington, D.C. 20554

July 18, 2014

DA 14-1015

Mr. Norm Leventhal

Holland & Knight LLP

800 17th Street N.W.,

Suite 1100

Washington, DC 20006-3906

Call Sign: E140028

File No.




Dear Mr. Leventhal:

On February 21, 2014, Televisa, SA de CV (Televisa) filed the above-captioned

applications seeking authorization to operate a transmit-only temporary-fixed earth station that

would operate in the Century Link Field stadium area of Seattle, WA. Televisa requested

authority to operate in the 14.0-14.5 GHz (Earth-to-space) frequency band with “ALSAT” as the

point of communication.1 Pursuant to Section 25.112(a)(1) of the Commission’s rules, 47 C.F.R.

§ 25.112(a)(1), we dismiss the application, without prejudice to re-filing.2

Section 25.112(a)(1) of the Commission’s rules, 47 C.F.R. § 25.112(a)(1), requires the

Commission to return, as unacceptable for filing, any earth station application that is not

substantially complete, contains internal inconsistencies, or does not substantially comply with

the Commission’s rules. For the reason set forth below, we find Televisa’s application is

deficient and subject to dismissal.

Televisa incorrectly calculated the Maximum EIRP Density per Carrier for emission

carrier 20MOG2F in Schedule B. Televisa lists the density per carrier as -21.4

dBW/4kHz. As noted below, we calculate it to be 16.8 dBW/4kHz, based upon the

Carrier EIRP value of 53.77 dBW provided by Televisa in item E48 of the Form 312.3

1 ALSAT means “all U.S.-licensed satellites.” It also provides authority to communicate with non-U.S.

licensed satellites included on the Commission’s Permitted Space Station List. See Amendment of the

Commission’s Regulatory Policies to Allow Non-U.S. Licensed Space Stations to Provide Domestic and

International Satellite Service in the United States, First Order on Reconsideration, IB Docket No. 96-111,

15 FCC Rcd 7207, 7215 (para. 19) (1999) (DISCO II Order on Reconsideration).


If Televisa re-files an application identical to the application dismissed, with the exception of supplying

the corrected information, it need not pay an application fee. See 47 C.F.R. § 1.1111(d).

3 Maximum EIRP Density per Carrier = E48 [Carrier EIRP] dBW – E47[Emission Bandwidth](converted

to dB/Hz)+ 36dB/4kHz. In this instance, 53.77 dB/Carrier – (10*log(20,000,000)dB/Hz )+36dB/4kHz =

16.8 dBW/4kHz .


Federal Communications Commission DA 14-1015

There are similar inconsistent values between carrier max EIRP and max EIRP Density

specified by Televisa in the additional emission designator in its application.

Although not a basis for dismissal, we request Televisa provide, pursuant to Section

25.111(a) of the Commission’s rules, 47 C.F.R. § 25.111(a), a demonstration that the NORSAT,

model NS-3200, 1-meter antenna is compliant with Sections 25.209(a) and (b) and 25.132 of the

Commission’s rules.4

If Televisa cannot demonstrate compliance with Section 25.209(a) and (b),

then Televisa must either submit the certifications listed in Section 25.220(d)(1)(i-iv) of the

Commission’s rules, or may cite the IBFS File Number and the call sign of a specific application

in which that type of antenna has been previously approved at or above the maximum EIRP

density requested in this application.5

Accordingly, pursuant to Section 25.112(a)(1) of the Commission’s rules, 47 C.F.R.

§ 25.112(a)(1), and Section 0.261 of the Commission’s rules on delegations of authority, 47

C.F.R. § 0.261, we dismiss Televisa, SA de CV’s application without prejudice to re-filing.


Paul E. Blais

Chief, Systems Analysis Branch

Satellite Division

International Bureau

4 47 C.F.R. § § 25.209(a) and (b); 47 C.F.R. § 25.132.

5 See 2000 Biennial Review – Streamlining and Other Revisions of Part 25 of the Commission’s Rules

Governing the Licensing of, and Spectrum Usage by, Satellite Network Earth Stations and Space Stations,

Amendment of Part 25 of the Commission’s Rules and Regulations to Reduce Alien Carrier Interference

Between Fixed-Satellites at Reduced Orbital Spacings and to Revise Application Procedures for Satellite

Communication Services, Fifth Report and Order in IB Docket No. 00-248 and Third Report and Order in

CC Docket No. 86-496, 20 FCC Rcd 5666 (2005) (para. 59) . The Commission maintains a list of

approved non-routine antennas at


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