Attachment letter

letter

LETTER submitted by IB,FCC

letter

2008-09-15

This document pretains to SAT-AMD-20080505-00099 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2008050500099_664470

                                           Federal Communications Commission
                                                  Washington, DC 20554


International Bureau
                                                     September 15,2008




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

                                               Re: ATCONTACT COMMUNICATIONS, LLC
                                               Files Nos. SAT-MOD-20070924-00130, SAT-AMD-20071215-
                                               00176; SAT-AMD-20080505-00100, SAT-AMD-20080505-
                                               00096 (Call Sign S2680); and SAT-MOD-20070924-00132,
                                               SAT-AMD-20080505-00099 (Call Sign S2682).

             Dear Mr. Talens:

                      This letter requests additional information concerning the above referenced applications
             filed by ATCONTACT COMMLTNICATIONS,LLC (ATCONTACT). In the applications,
             ATCONTACT seeks to make various technical changes to its licensed geostationary satellite
             orbit (GSO) space stations. In each application, ATCONTACT requests a waiver of Section
             25.1 14(d)(3) of the Commission's rules, which requires each space station applicant to provide
             "predicted space station antenna gain contours for each transmit and receive beam requested."' In
             its applications, ATCONTACT states that each satellite will utilize 45 active receive and 45
             active transmit beams, for a total of up to 180 beams. ATCONTACT included a total of four
             representative uplink and downlink beams in Schedule S of its application, maintaining that it
             would burdensome to include all of the beams with its application. ATCONTACT also states that
             it would provide additional gain contour files for other spot beams upon Commission request.*

                     We find that the four representative beams do not provide sufficient information to allow
             us to determine whether ATCONTACT's modified space stations will operate in conformance
             with the Commission's rules and will not cause interference to other systems. In light of
             ATCONTACT's claim that including the contour information for each beam is burdensome,
             ATCONTACT may, in lieu of providing the information as set forth in the rules, either:

                       1. Provide a text file with a table listing all 180 transmitheceive beams (labeled by city
                          and state), the boresight latitude, the boresight longitude, the EIRP at boresight, and
                          the associated antenna beamwidth (major and minor axis for each beam, as well as
                          the orientation of the major axis, as required to generate the beams in GIMS). Within


             ' 47 C.F.R. 6 25.1 14(d)(3).
             'ATCONTACT COMMUNICATIONS, LLC, File Nos.            SAT-MOD-20070924-00130, Technical
             Appendix, at 22-23; SAT-AMD-2007 1215-00176, Technical Appendix, at 24-25; SAT-AMD-20080505-
             00 100, Technical Appendix, at 26; SAT-AMD-20080505-00096, Technical Appendix, at 22; SAT-MOD-
             20070924-00 132, Technical Appendix, at 25; and SAT-AMD-20080505-00099, Technical Appendix, at
             25.


                        the same text file, ATCONTACT must include a second table containing the half
                        cone angle (in degrees) for each contour level (-2, -4, -6, -8, -10, -15, and -20 dB) for
                        the representative co-polarized contours of the spot beams.

                 2. Provide a text file with a table listing all 180 transmitlreceive beams (labeled by city
                    and state), the boresight latitude and the boresight longitude, along with the predicted
                    space station antenna gain contours for each transmit and receive beam (a total of 180
                    beams) in .pdf format showing the contour levels (-2, -4,-6, -8, -10, -15, and -20 dB)
                    of the spot beams.

                 We also note that the link budget information for the 7MOOG7W7700KG2W, lMOOFXD,
         125MG7W, and 600KG7D emission designators in the Technical Appendix of the above-
         referenced applications has not been provided in Schedule S, Sections S 11 and S 12. Please
         provide all of the information required in these sections of the Schedule S forms.

                   Accordingly, ATCONTACT COMMUNICATIONS, LLC must amend its Schedule S
         forms to include the requested information. ATCONTACT COMMUNICATIONS, LLC must
         file its response in the form of amendments to each of the underlying modification applications
         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 may result in dismissal of the applications. Please contact Kal
         Krautkramer 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: 2008-09-15 16:06:02
Document Modified: 2008-09-15 16:06:02

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