Attachment opposition

opposition

OPPOSITION submitted by PanAmSat Corp.; Intelsat LLC; SES Americom

opposition

2004-11-08

This document pretains to SAT-AMD-20040928-00192 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2004092800192_405608

Before the FEDERAL COMMUNICATIONs commisston RECEIVED Washington, D.C. 20554 NOV = 8 2004 In the Mater of Amendment o odeal Communcalom Comnianion Oifce o Secay MOBILE SATELLITE VENTURES File No. SAT—AMD—2004092—00192 SUBSIDIARY LLC To Application for Authority to Launch and Operate a Replacement L—Band Mobile Satellte Service Satellite at 101° W.L i OPPOSITION OF PANAMSAT CORPORATION, INTELSAT LLC, AND SES AMERICOM, INC. The above—captioned amendment‘ modifies the application filed by Mobile Satellite Ventures Subsidiary LLC (°MSV") for a replacement satellte to operate at 101° W.L. Specifically,in response to a Commission Order released on September 15, 2004," MSV provided additional information with regard to its request for an expanded East—West station—keeping tolerance of + 0.1° for the replacement spacecraft. For the reasons described below, PanAmSat Corporation ("PanAmSat"), Intelsat LLC (‘Intelsat"), and SES Americom, Inc. (‘SES Americom") oppose the MSV station— keeping request. First, grant of MSV‘s request for a larger station—keeping box at 101° W.L. would adversely affect operators ofcollocated satelltes. The simplest, most fuel—efficient, and possibly the safest way to collocate satelltes is t stritly maintain adjacent, non— overlapping longitude assignments or boxes. If MSV is granted a larger longitude box, less room will remain for other satelltes to be safely and easily collocated nearby.‘ * Amendmentto Applicationfor Authorit to Lanch and Operatea Replacement L—band Mobile Satlite Service Satellte arl01° W.L, SAT—AMD—20040928—00192, Call Sign $2358 (Aled Sep.28, 2004). * Mobile Satelite Ventures SubsidryLLC, Order, DA 02985 (Sat Div. Sep 15,2004) * FSS sateitesare constained by ITU sttionkeeping requrementsand th need o operte consisenty with U fings. The TTU Radio Regulations estictthe eastwest sttion kecping boxes ofFSS stelites 10 £0.1%zee No 2.8 ofhe TTU Radio Regulations). While hibx is large than llowed under ECC rales, it doss not give fexibliy for FSS satlites o b lcated wth morethan minimal offets fom their nominalorbitloctions. The need to coordinate with other opertor t o—deyree spacing alsorestricts theabilty ofSS spicecafto operae at an ofiefrom ther nominalpoiions. Movingcloset an adiacentsatlite in the same band could require the FS9 satelite t modify ts opertions in ordeto avoid interferenc to th neighboring spocecrft

This is a particularly serious issue at 101° W.L. because there are five spacecraft other than MSV‘s assigned to locations between 100.8 and 101.2° W.L, including SES Americom‘s AMC—4 and three DIRECTV satelltes (DIRECTV—1, 1R, —2 and —48). With the many satellites clustered at 101° W.L., some satellites might be foreed to operate in overlapping longitudinal boxes. This would necessitate an alternate collocation strategy to adjust orbit geometries to reduce the risk ofclose approaches, atthe cost of increased fuel usage for these neighboring satelltes. Maneuver and strategy coordination would also likely be required between the satellte operators. MSV might save propellant and extend the lif of its satellte, but adjacent and collocated satellites could be forced to expend additional propellant, shortening the lives of their satellites. There is no justification for permitting MSV to conserve fuel while imposing additional fuel costs on other operators. Second, MSV is requesting unjustified specialtreatment. Section B ofhe Technical Appendix contained in the MSV‘s submission of September 28, 2004 provides justification to operate a satelite in a +0.1° longitude box. MSV correeily states that the main factor driving the requirement for a larger longitude box is the large orbit eecentrcity needed to optimize fuel usage for a satellite with a large area to mass rato, as is the case for its proposed Mobile—Satellte Service ("MSS") satellite. Longitude deviation due to eccentricity is approximately equal to two times the eccentricity (¢)ie., if e is expressed in radians, the longitude deviation in degrees would be given by (2.¢,180/7). For an orbit with MSV‘s proposed eccentricity of 0.0006, the Jongitude deviation due to eccentricity is approximately £0.069°. MSV could operate its satellite in a £0.05° longitude box by maintaining a smaller eccentricity with either a sun— pointing or a 2—part maneuver strategy, albeit with a fuel penalty. However, this is a penalty that all satelite operators have to pay in order to comply with Commission station—keeping rules. For example, PanAmSat is currently using the station—keeping strategy described above with all of it body—stabilized satelites because they have area to mass ratios that would require longitude boxes larger than +0.05° ifa fuel—optimized eccentricity was used.. Intelsat uses either the sur—pointing maneuver strategy or the 2—part maneuver strategy, depending on the satellite. While MSV might save fuel if it was allowed to operate in a larger longitude box, so would PanAmSat, Intelsat, SES Americom, and many other satelite operators. MSV provides no evidence of specialcircumstances that would justify allowing MSV to operate with +0.1° station keeping at 101° W.L. Finally, MSV‘s analysis skews the technical facts. In Section B of the Technical Appendix contained in the September 28, 2004 submission, MSV explained how the orbit of ts proposed satellite is designed to have a large inclination (6°)at the onset. MSV further refers to a Bocing filing‘ that discusses the high orbitinclination of MSS satelites. Both papers seem to imply that the longitude box applies only near the equator * See Leterfrom Boeingto Ms. Marlene H. Dorich, File No. S4T—AMD—20030827—00241 e al (Decenber 19,2003)

and longitude deviations that occur when a satellite is sufficiently above or below the equator are safe and permissible.Iso, then orbit inclination has litle bearing on the longitude box since the effects ofinclination are small near the equator, contrary totheir claim The same Bocing filing states that "the use of.a 0.05° longitudinal station keeping tolerance...would resultin as much as a six—fold increase in the amount ofpropellant that would be consumed to maintain the spacecraftin ts assigned orbit." While this statement could be true, the reference point for making this statement is not clear. For example, it is important to compare the amount propellant needed to maintain MSV‘s proposed satellte within the +:0.05° East—West limitsat the equator to the amount of propellant needed by an FSS satellite of similar size to do the same thing. Such a comparison would allow us to put the statements made by Bocing and MSV in context. Since most MSS satellites are designed to operate in inclined orbit from the onset, they have the advantage of using less propellant when compared to FSS satellites. Therefore, the statement made above by Boeing, and affirmed by MSV, is misleading because it is predicated on an inherently low propellant level in MSS satellites, so any additional station keeping maneuvers required would have a larger relative effect on their propellant usage. If such a maneuver is evaluated in the context of average propellant usage for a similar maneuver on FSS satelltes, the impact will not be as significant as MSV and Boeing imply. It appears that MSV is trying to enhance the inherent advantage that MSS satellites have, when it comes to propellant usage, atthe expense ofthe orbital Nexibility ofFSS satelltes.

Forthe foregoing reasons, PanAmSat,Itelsat, and SES Americom oppose MSV‘s request for a £0.1° station keeping tolerance for ts proposed replacement satellite act0r° W.L. Respectfully submitted, PANAMSAT CORPORATION INTELSATLLC By: //Kalpak Gude By: /s/ Humberto Henrigues Kalpalk Gude Humberto Henriques Vice President & Director, Telecomm Policy and Regulations Associate General Counsel INTELSATLLC PANAMSAT CORPORATION 3400 International Drive, N.W. 1801 K Street, N.W., Suite 440 Washington, D.C. 20008 Washington, D.C. 20006 SES AMERICOM, INC. By: //Nancy J. Eskenazi Nancy J. Eskenazi Vice President & Associate General Counsel SES AMERICOM, Inc. Four Research Way Princeton, NJ 08540 November 8, 2004

cernmricaTe or sERVICE 1, Debra M. Hosang, do hereby certify that on this 8" day ofNovember, 2004, a copy of the foregoing "Opposition ofPanAmSat Corporation, Intelsat, LLC and SES Americom, Inc." was sent to the following parties by first class mail Lon C. Levin Mobile Satellite Ventures 10802 ParkridgeBlvd. Reston, Virginia 20191 Bruce D. Jacobs Shaw Pittman, LLP 2300 N Street, N.W. Washington, D.C. 20037 Debra M. Hosang ?


Document Created: 2004-11-18 14:06:25
Document Modified: 2004-11-18 14:06:25
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