Attachment letter

letter

LETTER submitted by IB,FCC

letter

2008-04-21

This document pretains to SAT-AMD-20071215-00176 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2007121500176_636244

                          Federal Communications Commission
                                Washington, D.C. 20554




                                             April 2 1, 2008


James M. Talens, Esq.
Counsel for ATCONTACT Communications, Inc.
60 17 Woodley Road
McLean, VA 22 101

                                            Re:      ATCONTACT Communications, LLC
                                                     SAT-AMD-2007 1215-00176
                                                     (Call Sign: S2680)

Dear Mr. Talens:

         This letter refers to the above-referenced application filed by ATCONTACT
Communications, LLC (ATCONTACT). In the application, ATCONTACT proposes to relocate
its authorized satellite from its current location at 83" W.L. to the 87.2" W.L. orbital location, and
add additional frequencies.

         Section 25.140(b) of the Commission's rules requires ATCONTACT to demonstrate that
its proposed operations at the 87.2" W.L. orbital location are compatible with the Commission's
two-degree spacing environment.* ATCONTACT provides this analysis using the SES
Americom AMC-16 and Intelsat Galaxy 28 satellites, which are operating at the 85" W.L. and
89" W .L. orbital locations, respectively.

        To assist the Commission in processing this application, ATCONTACT should amend its
application to include the following information:

         1)      Explain why the frequency band 18.8 GHz is used for the uplink calculations in
                 Tables 1l b and 12b;
        2)       Explain why the calculations in Table 1l b are based on ATCONTACT'S
                 proposed satellite at 87" W.L. instead of the requested 87.2" W.L. orbital
                 location;
        3)       Explain why the space station transmit EIRP density in Tables 1 1a and 11b are
                 different;
        4)       Explain why the earth station receive system noise temperature in Tables 1 la and
                 1l b are different;



' See ATCONTACT Communications LLC, Application File No. SAT-MOD-20070924-00130.
 47 C.F.R. § 25.140(b)(2). See also Public Notice, International Bureau, Satellite Division Information:
Clarification of 47 C.F.R. 5 25.140(b)(2), Space Station Application Interference Analysis. 19 FCC Rcd
10652 (Int'l Bur. 2004).


                Explain why the uplink earth station transmit ElIRP density in Tables 11a and 11b
                are different;
                Explain why the uplink earth station transmit EIRP density in Tables 12a and 12b
                are different. The uplink earth station transmit EIRP density value listed for the
                ATCONTACT satellite in Table 12b should also be a value less than 9.9
                dBW/40kHz (if that is the correct value in Table 1lb), based on an off-axis angle
                of 2 degrees;
        7)      After making corrections to Tables 1 1a, 1 1b, 12a and 12b, state whether the I,,
                IONo,  and uplinWdownlink degradation values, when recalculated in Tables 1 1b
                and 12b, will still offer the positive link margin needed to prove successful
                operation can occur in a two degree environment.

        In amending this application, please take the appropriate steps to assure that the
application is accurate and complete.

         ATCONTACT’S response must be filed with the Commission’s Secretary within 15 days
of the date of this letter, with a courtesy copy to Kal Krautkramer of my staff. Failure to respond
by this date will result in dismissal of this application. Please contact Kal at (202) 418-1335 if
you have any questions.


                                                  Sincerely,



                                                  Robert G. Nelson
                                                  Chief, Satellite Division
                                                  International Bureau




cc: Mr. David M. Drucker
    Manager, ATCONTACT Communications, LLC




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Document Created: 2008-04-21 15:55:51
Document Modified: 2008-04-21 15:55:51

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