Attachment 1990comments of The

This document pretains to SAT-LOA-19900518-00036 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1990051800036_1060599

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                                            Before the                   FCC MA SECTION
                           Federal Communications Commission
                                  Washington, D.C.         20554
                                                                       Oc     3    J 11 i °30
Application of                         )
Satellite CD Radio, Inc.               )               File Nos 49/50—         (ed
for Authorization of a                 )                             R%SCPéL?A
                                                                            £9 R¥
Digital Audio Radio Service            )               58/59—DSSAMEND—90
Satellite System                       )


              COMMENTS OF THE UNIVERSITY OF COLORADO GRADUATE FCENED
    TELECOMMUNICATIONS PROGRAM IN SUPPORT OF DIGITAL AUDIO RADIO
             SERVICE REGULATORY POLICY CONSIDERATIONS .
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         The University of Colorado Graduate Telecommunications Program is actively involved _

in satellite system research for NASA and other aerospace and telecommunications organizations.

Further, based upon its research and teaching activities, it is also very much involved in §

regulatory policy considerations. As such, we feel qualified to address certain of the regulatory

policy aspects of the referenced Digital Audio Radio (DAR) satellite system.



         The referenced DAR satellite system involves two high—power broadcasting satellites,

launched into geostationary orbit during the middle of 1994. Approximately 100 channels of |

compact disk quality radio programming would be broadcast directly from the satellite to small,

low cost mobile and portable radios. Given the international scope of the offering, the limited

number of channels being offered and regulatory expenses of a conventional approach, a non—

common carrier regulatory structure is proposed. It is recommended that channel sales be

offered directly to local broadcasters as well as new programmers operating on a subscription

basis.



         After preliminary review of the referenced DAR regulatory policy considerations, we

believe the above course of action would be the most streamlined, effective, and conducive to the

growth of this new service. The separation of satellite system operation from satellite system


programing should, of course, help to prevent abuses. The variety of programmer bptions

(advertiser supported or subscription) should also ensure that the public will get those service

that it best desires. A rigid common carrier structure would probably lead to service inflexibility, _

which wold not be in the public interest.



        Finally, we note the rapid increase in demand for mobile satellite services and the need 4

for new or expanded frequency allocations in this field to not only satellite CD radio, but also

AMSC, Iridium, ORBCOM, Starsys and others. Increased activity by the U.S. government to

pursue such goals at WARC/ORB 1992 should be lindertakcn as a matter of priority or all of

these exciting new initiatives will be seriously undermined or completely blocked.


                                                        Respectfully Submitted,


                                                         ~—%€ }) L /\\/ . /2C //l Tsscs

                                                  _—Joseph N. Pelton, Director
                                                        Graduate Telecommunications Program
                                                        University of Colorado at Boulder

Date: November 30, 1990

CC:     Gerald Vaughn, Deputy Chief, Domestic Facilities Division
        Cecily Holiday, Chief, Satellite Radio Bureau
        Rosalee Chiara, Satellite Radio Bureau



Document Created: 2014-09-09 11:22:42
Document Modified: 2014-09-09 11:22:42

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