From the same original filing:
The orbital spacing between DBS satellites serving the same geographic area, combined with both the satellite transmit characteristics and receive earth station antenna performance, determines the amount of interference a DBS system will receive. The Commission took notice of the possibility of reduced-spacing DBS satellites in 2002. In the Part 100 Order, the Commission stated that provision of service “into the United States from future entrants such as non-U.S. DBS satellites could result in smaller satellite spacing than the current nine-degree separation between U.S. DBS orbital locations.” Also in the Part 100 Order, the Commission adopted Section 25.114(c)(22)(i), which required that applicants provide sufficient technical showings that their proposed systems could operate satisfactorily if all assignments in the BSS and feeder-link Plans are implemented, and Section 25.114(c)(22)(ii), which required that applicants provide analyses of the proposed system with respect to the limits in Annex 1 to Appendices 30 and 30A of the ITU Radio Regulations. The Commission also adopted Section 25.148(f), which states that operation of DBS systems with characteristics differing from those in the Appendix 30 and 30A plans may be permitted with adequate technical showing, and if a request has been made to the ITU to modify the appropriate Plans to include the system’s technical parameters. The Commission also stated that in accordance with the ITU Radio Regulations, other countries wishing to serve the United States will normally have to modify their assignments in the ITU BSS and feeder-link Plans to allow them to provide service in the United States. The ITU modification process will identify the U.S. DBS systems that are affected by the proposed Plan modification of another administration, giving the United States an opportunity to work with the subject administration to ensure that no modification is made that will cause harmful interference to U.S. DBS systems.
E* and D* at that time objected because Spectrum Five presented none of this required info but Spectrum argued that they would "comply" with the requirements of the Region 2 BSS plan from the 1980's. Then when the results of their proposed spotbeams was revealed, they said they would reduce power and use larger customer dishes.