Attachment opposition

This document pretains to SAT-LOA-20030609-00113 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2003060900113_432955

Received MAY 1 8 2005 Before the TokB RECEIVED FEDERAL ConMUNica Tions Commrsstony yay 1 6 2005 WaskingtonPC—atied FedenlConmincatons Connission Oe t Secrvy In the Matter of EchoStar Satelite LL.C. File No. SAT—LOA—20030609—00113 Application to Construct, Lounch & Operate a DBS Satelite (‘DBS®) At the $6.5° W.L. Orbital Location orrositi OF BELL EXPRESSVU LIMITED PARTNERSHIP 1. Bell ExpressVu LP. (‘ExpressVa‘" or "the Company) wishes to provide the Federal Communications Commission (‘FCC‘) with the following comments on the sbove referenced application by EchoStar Sstelite LL.C. ("EchoStar®) for suthority to construct, Ieunch and operate a Direct Broadcast Satelite (DBS") in the 12.2—12.7 GHz and 17.3 —17.8 GHe frequency bands at the 86.5° W.L. orbital location. 2 ExpressVia has a specifi directinterestin this matter, stemming from itsstatus as a Hicensed Conadian satelite—based direct—to—home (‘DTH") DBS provider. This icence is jssued by Canada‘s domestic broadcast regulator, the Canadian Radio—Television and Telecommunications Commission ("CRTC). 2. ExpressVi owns all the transponders ofthe BSS satelites Nimig 1 and Nimig 2 operating at 91° WL and 82° WL. These satellitesare, n turm, owned and operated by Telesat Canada (‘Telesat") and licensed by the Canedion federal government (Idustry Canada). The agreements between ExpressVand Telesatrespecting these arrangements are also approved by the CRTC. 4. The Nimig satellitesat 91° WL and 82° WL have been designed, deployed and operated pursusnt to the International Telecommunications Unions® (TTU®) Region 2 Plan. ExpressVu‘s entire satelite—based telecommunications network has been built on the basis of 1

this plan. The network also includes the receive equipment forthe company‘s 1.6 million residential subscribers. 8. ExpressVfully supports the submission ofTelesat, In particuler, ExpressVa wishes to underscore Telesat‘s submission that the proposed DBS Operation at 86.5° WL would be disruptive to its existing DBS operations at 82° and 91° WL. Furthermore, the financial consequences ofa change from 9 degree satllie spacing to 4.5 degree spacing would undermine billions of dollars of satelite—based infiastracture investment by ExpressVa and its customers. Accordingly, such action would be manifesly unfar to the satelite faciities and service providers who have relied on the ITU Region 2 Plan. 6. ExpressVu further supports Telesat‘s comments that,to ensure adequste protection for the existing Canadian DBS operations at 82° and 91° WL, very substantial eductions of power levels on the proposed EchoStar satelite would sppear to be the only way that the MSPACE triggers could be removed. Itis our understanding that such power reductions would render the use ofthese frequencies at 86.5° WL totallyimpractical. 7. In light ofthe foregoing, ExpressVa is ofthe view that the Commission should not grant the EchoStar application for use ofthe 86.5° WL position. Respectfully submitted, Bell ExpressVu Cbac Famto Chiis Frank Sr. Director, Regulatory & Government Affairs Floor 6— 110 O‘Connor St. Oftewe, Ontario Caneda, KIP TH1 May 16, 2008

CERTIFICATE OF SERVICE 1, Nancy Krieger, do hereby certify that a copy of the foregoing Opposition of Bell ExpressVu L.P. was served by first—class mail, postage prepaid on this 16" day of May 2005 to the following: Pantelis Michalopoulos David K. Moskowitz Philip L. Malet Senior Vice President and General Counsel Steptoe & Johnson LLP EchoStar Satellte Corporation 1350 Connecticut Avenve, NW 5701 South Santa Fe Washington, DC 20036—1795 Litlton, CO 80120 David R. Goodfriend Director, Legal and Business Affairs EchoStar Satellite Corporation 1233 20° Street, NW Suite 701 Washington, DC 20036


Document Created: 2005-05-18 12:40:02
Document Modified: 2005-05-18 12:40:02
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