Attachment 1990Comment of AMSC

1990Comment of AMSC

COMMENT submitted by AMSC

Comments

1990-11-13

This document pretains to SAT-LOA-19900731-00044 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1990073100044_1061234

P¥rof Before the FEDERAL COHHUNICATIQNS COMMISSITON Washington, D.C. 20554 In the Matter of NN nr n n n r y NORRIS SATELLITE COMMUNICATIONS, INC. Petition For Amendment of Parts 2 RM—7511 and 25 of the Commission‘s Rules to Establish a General Satellite Service in the Ka—Band Application To Launch and Operate ) File Nos. 54—DSS—P/L—90 Communications Satellites in the ) 55—DSS—P/L—90 Domestic Fixed—Satellite Service ) To: The Commission COMMENTS OF AMERICAN MOBILE SATELLITE CORPORATION American Mobile Satellite Corporation ("AMSC"), by its attorneys, hereby comments on the Petition for Rulemaking and Application filed by Norris Satellite Communications, Inc. ("Norris") proposing that the Commission re—allocate the band 19.7—20.2/29.5—30.0 GHz to a General Satellite Service ("GSS") in which fixed, broadcast, mobile and personal access satellite services could be provided."‘ As discussed more fully below, AMSC disagrees with Norris‘s contention that its proposed GSS system operating in Ka—band will alleviate the need for additional L— band allocations for Mobile Satellite Service ("MSS"). In support of its Petition and the underlying application, Norris claims that its proposed satellite system can serve demand AMSC is licensed by the Commission to construct and operate xt the U.S. mobile satellite service system. AMSC Authorization Order, 4 FCC Red 6041 (1989).

2 for MSS that cannot be met using L—band allocations." As evidence of this excess demand, Norris points out that AMSC has requested additional frequencies for MSS." AMSC agrees with Norris that more spectrum is needed for MSS. AMSC has begun international coordination negotiations with two of the administrations that have planned or operational MSS systems (there are more than 30 such systems) in the spectrum assiqgned to AMSC, and it is already evident that there are immediate and serious problems with securing adequate spectrum for a U.S. domestic system. In other proceedings, AMSC has requested that it be assigned specific L—band frequencies for MSS.* AMSC will provide the Commission with additional suggestions for L—band MSS allocations in AMSC‘s comments that will be submitted in response to the Commission‘s Second Notice of Inquiry on the 1992 World Administrative Radio Conference.®" Norris‘s proposal does not, however, hold out an immediate prospect for solving the spectrum shortage for MSS in the L—band. At some point, the Ka—band may be a viable band for MSS, but at present there is no consumer equipment available for the band. Moreover, it would be extremely impractical for a single MSS satellite to operate in both the L—band and the Ka—band. Application at I—10. iss 3 I@. at I—19. * See Comments of AMSC, Docket No. 90—56 (May 11, 1980); Comments of AMSC, RM—7400 (August 20, 1990). * Second Notice of Inquiry, GEN Docket No. 89—554 (rel. October 1, 1990).

3 Therefore, AMSC respectfully requests that any Commission action on the Norris Petition and Application not be viewed as a solution to the L—band spectrum shortage facing the domestic MSS systenm. Respectfully submitted, AMERICAN MOBILE SATELLITE CORPORATION _V//M\ ~ » 7 /,/‘ K 7J | 7 {1 " By : —é/vouz / v[f/vw/% iR_ By : »%W /\({ ' M Bruce D. Jacobs Lon C. Levin Glenn S. Richards Fisher, Wayland, Cooper & Gurman, Kurtis, Blask & & Leader Freedman, Chartered 1255 23rd Street, N.W. 1400 Sixteenth Street, N.W. Suite 800 Suite 500 Washington, D.C. 20037 Washington, D.C. 20036 (202) 659—3494 (202) 328—8200 Its Attorneys Dated: November 13, 1990

. smag1—585e FACSIMILE 202—331—5861 AMERICAN MOBILE SATELLITE CORPORATION DECLARATION I, Michael Ward, under penalty of perjury, do hereby declare as follows: I have reviewed the foregoing Comments of American Mobile Satellite Corporation. The facts contained therein are true and correct to the best of my knowledge and belief. L—f? [, L.[4 2. / L454tfi L? 184CR C on Michael Ward Senior Scientist American Mobile Satellite Corporation (/:/. — DATE: e 1150 Connecticut Avenue, N.W., Fourth Floor, Washington, D.C. 20036

CERTIFICATE OF SERVICE I; Ruth E. Davis, a secretary in the law offices of Gurman, Kurtis, Blask & Freedman, Chartered, do hereby certify that on this 13th day of November, 1990, a copy of the foregoing "Comments of American Mobile Satellite Corporation" was sent by U.S. first class mail, postage prepaid to: John H. Norris Norris Satellite Communications, Inc. P.0. Box 88 Red Lion, Pennsylvania 17356 Leslie A. Taylor 6800 Carlynn Court Bethesda, Maryland 20817 LW1A Ruth E. Davis‘‘


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