Attachment reply

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RESPONSE TO REPLY COMMENTS submitted by MSV

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2005-01-10

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

IBFS_SATAMD2004092800192_413268

Befo j Federal Cummunimfigssiun QBMML Washington,D;C.205545 JAN 1 0 2005 In the Matter of luin es Futun CommunticatrrsCommissen intlnational Bureau Mobile Satellite Ventures Subsidiary LLC ) File No. SAT—AMD—20040928—00192 ) File No. SAT—AMD—20040209—00014 Application for Authority to Launch and Operate a ) File No. SAT—AMD—20031118—00335 Replacement L—band MSS Satellite at 101°W ) Call Sign $2358 RESPONSE OF MOBILE SATELLITE VENTURES SUBSIDIARY LLC Mobile Satellite Ventures Subsidiary LLC ("MSV") hereby files this Response to the Comments of DIRECTV, Inc. and the Opposition of PanAmSat Corporation (‘PanAmSat"), Intelsat LLC ("Intelsat"),and SES Americom, Ic. (°‘SES") (collectively, the "Commenters") to MSV‘s application for a next—generation replacement Mobile Satellite Service (°MSS") satellte at 101°W with a +0.1° East—West station—keeping box." As discussed herein, MSV has fully justified its request to operate its proposed next—generation replacement satellite with a £0.1° East—West station—keeping box. Background MSV is the successor to the entity authorized by the Commission in 1989 to construct, Jaunch, and operate a United States MSS system in the L—band." MSV‘s current satellite was launched in 1995 and operates at 100.95°W." In July 1998, MSV filed an application to launch ‘ Comments of DIRECTV, Inc., File No. SAT—AMD—20040928—00192 (November 8, 2004) ("Directy Comments"); Opposition ofPanAmSat Corporation, Intelsat LLC, SES Americom, Inc.,File No. SAT—AMD—20040928—00192 (November 8, 2004) (*PandmSat/IntelsatSES Comments"). * Order and Authorization, 4 FCC Red 6041 (1989); remanded by Aeronautical Radio, Inc. v FCC, 928 F.2d 428 (D.C. Cir. 1991); Final Decision on Remand, 7 FCC Red 266 (1992); af. Aeronautical Radio, Inc. v. FCC, 983 F28 275 (D.C. Cir.1993); see also AMSC Subsidiary Corporation, Memorandum Opinion and Order, 8 FCC Red 4040 (1993). * See File No. SAT—MOD—20040623—00120 (granted August 23, 2004).

and operate a higher—power, replacement satellte with substantially greater capacity.‘ On February 9, 2004, MSV filed an amendment to request additional feeder link frequencies." In the application, MSV requested authority to operate ts proposed replacement satellite with a +0.1° East—West station—keeping box.". As required by the Bureau, MSV filed another amendment to the application on September 28, 2004 o provide (i) a two—degree spacing analysis and i) further justifiation regarding the need for a +0.1° East—West station—keeping box." The Bureau subsequently placed MSV‘s amended application on Public Notice in October 2004. See Report No. SAT—00248 (October 8, 2004). On November 8, 2004, DIRECTV filed Comments and PanAmSat, Intelsat, and SES filed a joint Opposition expressing concem with MSV‘s request to operate ts proposed replacement satellite with a +0.1° East—West station—keeping box. First, they argue that MSV‘s request to operate with a wider station—keeping box than other satelites at T01°W will make it more difficult to collocate satellites atthis already—congested orbital location. No Commenter alleges that operation with a £0.1° East—West station—keeping box will increase the potential for RB interference to other satellites. Second, they argue that MSV has not justified its need for a wider station—keeping box than that required by the Commission‘s rules for Fixed Satellite * See Application ofAMSC, File No. SAT—LOA—19980702—00066 (July 2, 1998). To accommodate this greater capacity, the application, as amended in December 2000, requested authority to use additional feeder link frequencies. See Application of Motient Services Inc., SAT—AMD—20001214—00171 (December 14, 2000). On November 18, 2003, MSV filed a minor amendment to revise the technical parameters ofthe proposed satellite. See MSV, Minor Amendment, File No. SAT—AMD—20031 1 18—00335 (November 18, 2003) (*MSV November 2003 Amendment®). ° See MSV, Amendment, Fle No. SAT—AMD—20090209—00014 (filed February 9, 2004) ("MSP February 2004 Amendment") © 1d. at 6—7 and Appendix A at 16—17. " See MSV, Amendment, File No. SAT—AMD—20040928—00192 (September 28, 2004) ("MSF September 2004 Amendment®).

Service ("FSS®) satellites. While the Commenters acknowledge that operating with a wider station—keeping box saves fuel, they argue that this is true ofall satelites and that there is nothing unique about MSV‘s proposed satellite thatjustifes a wider box. MSV‘s response to the Commenters was originally due November 23, 2004.. MSV and the Commenters agreed to an extension until January 10, 2008 for MSV to file its response." Discussion As an inital matter, MSV notes that it does not need a waiver of any Commission rule to operate its replacement satelite with a +0.1° East—West station—keeping box. In its February 2004 Amendment, MSV explained that it was requesting a waiver of Section 25.210() of the Commission‘s rules (which mandates a £0.05° East—Weststation—keeping box only for SS satelltes), only to the extent that the Commission modified this rule in the pending Orbital Debris Mitigation rulemaking to apply to GSO MSS satelltesWhile MSV‘s amendment was pending, the Commission adopted a decision in this proceeding in which it refrained from applying a £0.05° East—West station—keeping box to GSO MSS satelltes."" MSV has also fully justifed its proposal for a £0.1° East—West station—keeping box." As discussed more fully in the attached Technical Appendix,there are two reasons dictating MSV‘s * See Mobile Satellite Ventures Subsidiary LLC, Consent Motion for Extension of Time, File No. SAT— AMD—20040928—00192 (November 22, 2004); Mobile Satellite Ventures Subsidiary LLC, Consent Motion for Extension ofTime, File No. SAT—AMD—20040928—00192 (December 9, 2004). The Bureau denied MSV‘s request for a further extension to file a response to the Commenters. See Letter from Fem Jarmulnck, FCC, to Lon Levin, MSV, File No. SAT—AMD—20040928—00192, File No. SAT—AMD— 20040209—00014, File No. SAT—AMD—20031 1 18—00335 (January 7, 2004) ° See MSV February 2004 Amendment at 16; Mitigation ofOrbital Debris, Notice ofProposed Rulemaking, TB Docket No. 02—54, FCC 02—80 (March 18, 2002). ‘° See Mitigation of Orbital Debris, Second Report and Order, 1B Docket No. 02—54, FCC 04— 130 (June 21, 2004), at % 44. "" MSV is also committed to eoordinating it station keeping with other operators at the 101°W orbital location.

need for a station—keeping box that is wider than that required for ESS satellites and that employed by Broadcasting Satellite Service (BSS") satelltes. See Technical Appendix. First, MSV‘s planned replacement will have a much larger masthan typical FSS and BSS satellites. To achieve itsfinal geosynchronous orbit, the satellte will be required to expend virtually all of its available fuel. As a result, only a very small amount offuel wl remain to provide the required East—Weststation—keeping. Second, solar pressure on MSV‘s satellite, resulting from the satellite‘s very large reflector and solar array area, also dictates a wider East—West station— keeping box. As demonstrated in MSV‘s Seprember 2004 Amendment, requiring MSV to operate its replacement satellte with a £0.05° East—West station—keeping box would reduce the life of the satellte by half. Moreover, MSV notes that no adverse precedent will be set by allowing MSV to operate with a £0.1° East—West station—keeping box. Any precedent established will extend only to GSO MSS satelltes, of which there are only three in the entire full—CONUS orbital are today."* Given the unique mass characteristics of MSS satellites, no argument can be made that a decision favorable to MSV in this case will set a precedent for FSS or BSS satellites. "MSAT—I at 106.5W; AMSC—I at 1OIW; Inmarsat—2 at 98W

Conclusion MSV requests that the Bureau act consistently with the views expressed herein. Respectfully submitted, xX¥ dtC Bruce D. Jacobs fat . Lon C. Levin David S. Konczal Vice President SHAW PMTMAN LLP MOBILE SATELLITE VENTURES 2300 N Street, NW SUBSIDIARY LLC Washington, DC 20037—1128 10802 Parkridge Boulevard (202) 663—3000 Reston, Virginia 20191 (703) 300—2700 Dated: January 10, 2005

CERTIFICATE OF SERVICE 1, Sylvia Davis, a secretary with the law firm of Shaw Pittman LLP, hereby certify that on this 10° day of January 2005, served a trie copy ofthe foregoing "Response" by first class United States mail, postage prepaid, upon the following: Thomas Tyee* Cassandra Thomas* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12® Street, SW . 445 12" Stree, S.W Washington, DC 20554 Washington, DC 20554 Steven Spacth* Robert Nelson® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12° Street, SW. 445 12® Street, S.W. Washington, DC 20554 Washington, DC 20554 Andrea Kelly® William M. Withire International Bureau Michael D. Nilsson Federal Communications Commission Harris, Wilshire& Grannis LLP 445 12" Street, S.W 1200 Eighteenth Street, N.W. Washington, DC 20554 Washingion, D.C. 20036 James Butterworth Kalpak Gude Senior Viee President VicePresident & Associate General Counsel DIRECTV,Inc. PanAmSat Corporation 2230 E. Imperil Highway 1801 K Street, N.W., Suite 440 El Segundo, CA 90245 Washington, DC 20006 Humberto Henriques Nancy J. Eskenazi Director, Telecomm Policy and Regulations Vice President & Associate General Counsel mtEsarice SES Americom, Ic 3400 International Drive, NW. Four Research Way Washington, DC 20008 Princcton, NJ 08540 A Syivia Davis *By hand delivery

Technical Appendix This report responds to the filings by DIRECTV, PanAmSat Corporation, Intelsat LLC, and SES Americom, Inc. (collectively, the "Commenters") in opposition to the application of Mobile Satellite Ventures Subsidiary LLC (°MSV") for a replacement Mobile Satellite Service (*MSS") satelliteat 101°W. The comments are limited to MSV‘s proposal to employ a +0.1° East—West station—keeping box. MSV*s need for a wider station—keeping box than Fixed Satelite Service ("FSS®) and Broadeasting Satellite Service (°BSS") satelltes is dictated by (3) the large mass of MSV‘s replacement MSS satellte and (i) the effect of solar pressure on a satellte with a very large reflector and solararray. MSV has determined that in order to meet the service objectives ofits next—generation MSS system, its satellte could have a mass of as much as 6,400 to 6,800 kg. Contemporary FSS and BSS satellites have a launch mass of onlabout 5,600 kg. The mass of MSV‘s next— generation satellite is compatible with only the largest ofthe launch vehicles——the Atlas V and the Ariane 5. Achieving final geosynchronous orbit will require virtuallyall of the fuel available on the satellte. Once final geosynchronous orbit is achieved, only a very small amount of fuel will remain to meet the required East—West station—keeping limit. Solar pressure on MSV‘s satellte, resulting from the satellte‘s very large reflector and solar array area, also dictates a wider East—West station—keeping box. The large area—to—mass tatio ofthe proposed replacement satellte makes it more susceptible to the effects ofsolar pressure which can cause large accelerations and decelerations ofthe satellite during the course of the solar day. This will result n a rapid build up of eccentricity which is the primary factor that determines the magnitude and/or frequency of the East—West station—keeping maneuvers The current AMSC—1 satellite is maintained within a +0.05° East—West station—keeping box. As a result, it is subject to the same propellant inefficiencies to maintain this tighter box. mentioned by the Commenters. These penalties, however, are minor compared to the impact of a +0.05° East—West station—keeping box on a satellite of the mass and solar pressure area contemplated for MSV‘s replacement satellite. As indicated previously, the Bocing analysis for a similar satelite showed that a +0.05° East—Westlimits would reduce the life of the satellite by half. This is the equivalent of reducing the satellite revenue potential by at least half, and possibly more. Recently, MSV has been evaluating a satellte design that has a slightly smaller reflector (18 meters vs. 22 meters). A comparable analysis of that design indicated an operational lifetime penalty of 33%, with an equivalent or greater revenue loss, if the satellte was constrained to the + 0.05° East—Westlimit versus the 0.1° East—West limit. The station keeping of satellitesin inclined orbit mode, such as MSV‘s proposed replacement satellites, is an established and routine procedure. More than sixty satellites currently are being operated in inclined geosynchronous orbits throughout the world. A relevant example is the Thuraya satellitesystem, in which the satellites were initilly launched into an inclined orbit ofsix degrees and are maintained within +0.1° East—Westlimits.

CERTIFICATION 1, Robert M. Sorbello, Vice President, Space Segment Programs, Mobile Satellte Ventures L.P. (‘MSV"), certify under penalty ofpegjury that: I am the technically qualified person with overall responsibility for preparation ofthe information contained in the foregoing. I am familiar with the requirements ofthe Commission‘s rules, and the information contained in the foregoing is rue and correct. Executed on January 10, 2008 Robert M Sortello Vice President, Space Segment Programs


Document Created: 2005-01-12 12:50:38
Document Modified: 2005-01-12 12:50:38
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