Attachment comments

comments

COMMENT submitted by New Skies

comments

2004-10-22

This document pretains to SAT-AMD-20040826-00161 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2004082600161_414274

Before the RE FEDERAL COMMUNICATIONS COMMISSION CE VEDp Washington, D.C. In the Matter of w Coutmmia Comstuntcations Corroration File No. SAT—AMD—20040826—00161 Request to Amend its Pending Modification Application for the AMC—12 Satelite COMMENTS OF NEW skiEs SATELLITES New Skies Satellites N.V. ("New Skies") submits these comments on Columbia: Communication Corporation‘s (*Columbia") request to amend its pending modification application for ts AMC—12 C—band satellte at the 37.5° W.L. orbital location." Among the amendments proposed by Columbia is a dramatic increase in equivalent isotropic radiated power ("EIRP") from the satelite._ As the operator ofthe NSS—806 C:—band satellite that currently provides service to thousands of customers in North America, South America, and Europe from the 40.5° W.L. orbital location, New Skies will be directly affected by the increased EIRP levels proposed by Columbia. As stated in its Application, Columbia has an existing coordination agreement with New Skies that specify operational and technical conditions that each party has agreed to meet in orderto achieve technical compatibility between their C—band networks in the Atlantic Ocean Region, including the 37.5° W.L. and 40.5° W.L. orbital locations. This agreement has been approved by both the Commission and the Netherlands 1\ See Public Notie, Rep. No. SAT—0O2L3 (rel.Sept 24,2004)

administration. Among other things, this agreement specifies maximum satellte EIRP densities not to be exceeded by both parties® satelltes. These levels translate into equivalent satelite EIRP per 36 MHz transponder significantly less than the maximum EIRP levels at which Columbia now proposes to operate all of the AMC—12 beams." Columbia states in its Application thatit is "in the process of coordinating the operation of AMC—12 with neighboring spacecraft and will operate in accordance with coordination agreements developed with adjacent spacecraft operators."". While the coordination agreement does contemplate that the parties could, on a case—by—case basis, coordinate operations at higher EIRP levels than those established in the agreement, no such further coordination has yet been achieved between Columbia and New Skies that would cover the EIRP levels proposed in Columbia‘s Application. In these circumstances, New Skies submits that the Commission cannot grant Columbia‘s request without (1) explicitly conditioning such authorization upon successful completion of coordination with New Skies and operation consistent with any new coordination agreement, and (2) requiring Columbia to operate within the parameters established by existing coordination agreements until such time as new agreements are put in place. Of course, if a new agreement covering the higher proposed EIRP levels is reached while the Application is stll pending, Columbia could so notify the Commission and no such conditions would be necessary. * See Application Namative, Table1 (4dBW) and Schedale S Daa, Tabls 1 and 2 (42 dBW). Application Narativeatp. 2.

Accordingly, in the absence ofa new coordination agreement, New Skies requests that the Commission impose the conditions discussed above on any grant ofthe Application. Respectfully submitted, New Skirs Sareuures NV By: , Williem M. Wiktshire Hamus, Wiursume& Grans 1200 Eighteenth Street, N.W. Washington, DC 20036 202—730—1300 Counselfor NewSkies Satellies N.V. Dated: October 22, 2004

CERTIFICATE OF SERVICE 1 hereby certify that on this 22"day of October, 2004, a copy of the foregoing Comments ofNew Skies Satellites N.V. was served by first class mail, postage prepaid upon: Karis Hestings Hogan & Hartson 555 Thirteenth Street, N.W. Washington, DC 20004—1109


Document Created: 2004-11-09 11:54:04
Document Modified: 2004-11-09 11:54:04
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