Attachment 1990The University o

1990The University o

COMMENT submitted by University of Colorado Graduate Telecommunications Program

Comments

1990-12-03

This document pretains to SAT-AMD-19900801-00046 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD1990080100046_1080350

Before the Federal Communications Commission Washington, D.C. 20554;, m Py q t 1 #(}4 2o i4 Hij JJ Application of ) ralel.: j Satellite CD Radio, Inc. ) File Nos 495GB3§—P1A—90 for Authorization of a ) Nes Digital Audio Radio Service ) 58/59—DSS—AMEND—90 Satellite System ) COMMENTS OF THE UNIVERSITY OF COLORADO GRADUATE 1%0 E ' V E D TELECOMMUNICATIONS PROGRAM IN SUPPORT OF DIGITAL AUDIO RA SERVICE REGULATORY POLICY CONSIDERATIONS 9 A y0C, DFC 3344Qqp Domesiic Facilities Division The University of Colorado Graduate Telecommunications Program is actively involved in satellite system research for NASA and other aerospace and telecommunications organizations. Further, based upon its research and teaching activities, it is also very much involved in regulatory policy considerations. As such, we feel qualified to address certain of the regulafory policy aspects of the referenced Digital Audio Radio (DAR) satellite system. The referenced DAR satellite system involves two high—power broadcasting satellites, launched into geostationary orbit during the middle of 1994. Approximately 100 channels of compact disk quality radio programming would be broadcast directly from the satellite to small, low cost mobile and portable radios. Given the international scope of the offering, the limited number of channels being offered and regulatory expenses of a conventional approach, a non— common carrier regulatory structure is proposed. It is recommended that channel sales be offered directly to local broadcasters as well as new programmers operating on a subscription basis. After preliminary review of the referenced DAR regulatory policy considerations, we believe the above course of action would be the most streamlined, effective, and conducive to the growth of this new service. The separation of satellite system operation from satellite system

programing should, of course, help to prevent abuses. The variety of programmer options Cadvertiser supported or subscription) should also ensure that the public will get those service that it best desires. A rigid common carrier structure would probably lead to service inflexibility, which wold not be in the public interest. Finally, we note the rapid increase in demand for mobile satellite services and the need for new or expanded frequency allocations in this field to not only satellite CD radio, but also AMSC, Iridium, ORBCOM, Starsys and others. Increased activity by the U.S. government to pursue such goals at WARC/ORB 1992 should be undertaken as a matter of priority or all of these exciting new initiatives will be seriously undermined or completely blocked. Respectfully Submitted, \,_.fl,/foseph N. Pelton, Director Graduate Telecommunications Program University of Colorado at Boulder Date: November 30, 1990 CC: Gerald Vaughn, Deputy Chief, Domestic Facilities Division Cecily Holiday, Chief, Satellite Radio Bureau Rosalee Chiara, Satellite Radio Bureau


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Document Modified: 2015-03-11 16:54:29
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