Attachment certification

certification

SUBMISSION FOR THE RECORD submitted by Virtual Geosatellite

certification

2007-01-19

This document pretains to SAT-AMD-20041222-00227 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2004122200227_548378

LEVENTHAL SENTER & LERMAN PLC January 19, 2007 VIA HAND DELIVERY F] Aam 525%’:fi; g;K1 §§§ Ms. Marlene H. Dortch JAN Secretary AN 1 ?Q@? Federal Communications Commission Federalggz’%”” Commisglp 445 Twelfth Street, S.W. 0e 0f the Secretary Washington, D.C. 20054 Re: Virtual Geosatellite, LLC, Call Sign $2366 Dear Ms. Dotrtch: Virtual Geosatellite, LLC ("Virtual Geo"), by its attorneys and pursuant to Paragraph 80 of the Order and Authorization in Virtual Geosatellite, LLC, DA 06—2560, slip op. at 25 (Int‘l. Bur., released, December 21, 2006) ("Virtual Geo Order"), hereby submits the attached certification regarding compliance of Virtual Geo‘s "Virgo" system with the aggregate EPFDdown limits that protect Ku—band geostationary orbit Ku—band fixed—satellite service ("FSS") and broadcasting—satellite service ("BSS") networks from co—frequency non—geostationary orbit FSS systems. The Commission determined in the Virtual Geo Order that Virtual Geo had demonstrated that it meets the single—entry validation EPFD limits. See Virtual Geo Order, DA 06—250, slip op. at 9 (Y[ 28). Virtual Geo confirms that the assumptions that went into its submission remain unchanged. Moreover, because Virtual Geo is the sole entity with a license or authorization for a Ku—band non—GSO FSS system that will serve the United States, there are presently no other Ku— band non—GSO FSS systems that could combine with Virgo to result in an exceedance of the aggregate EPFDaoy,, limits in Sections 25.208(h) and (m) of the Commission‘s Rules, 47 C.EF.R. §§ 25.208(h) and (m). Accordingly, an operational Virgo system using the parameters applied for and authorized to Virtual Geo in the Virtual Geo Order would not exceed the aggregate EPFDaown limits. Virtual Geo is mindful of its obligations regarding continued compliance with all of the single—entry and aggregate EPFD limits in the Commission‘s Rules, and will supplement the showings it made in its application for license and the certification it makes here, as needed, to ensure that these limits continue to be satisfied even if additional systems emerge. SrTt—LOA — 19990102dooas7 SA._ fAimiy 2009091 G— ooiN2 SA Amb— aqdo4 1329 — ocea7 SYt— A ma‘:wza@ffg i2 —D0da24a. 200U K SIREEL NVV, SUH E 6UV, WASMINGIUN, UC 2Zuuvb—10u7 TELEPHONE 202.429—8970 FAX 202.293.7783 WWWLSL—LAWCOM

Ms. Marlene H. Dortch January 19, 2007 Page —2— Please direct any questions regarding this submission to the undersigned. Respectfully submitted, e M5/z’% r/ \ aul R/Rodriguez Stephetg;q D. Baruch \ Attorneys for Virtual Geosatellite, LLC. ce (by e—mail): Robert Nelson Andrea Kelly Cassandra Thomas Mark Young Steven Spaeth Karl Kensinger

TECHNICAL CERTIFICATION 1, John W. Brosius, IH, hereby certify, under peraity of perfury, that I am familiar with Part 25 of the Commission‘s Rules, and that the information contained in the foregoing letter regarding the present and future technical compliance of Virtual Geosatellite, LLC‘s "Virgo" system with the aggregate EPFDa,,, limits contained in Sections 25.208(h) and (m) of the Commuission‘s Rules, 47 CFER. §§ 25.208(h) and ({m), is true and correct to the best of my knowledge and belief. January 18, 2007 By: (‘% *+**> Joh:yfiv‘ Brosius,\ffi\_j Virtual Geosatellite, LLC


Document Created: 2007-02-01 12:52:18
Document Modified: 2007-02-01 12:52:18
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