Reply Comments 70W F

REPLY submitted by Skynet Satellite Corporation

Reply Comments of Skynet Satellite Corporation

2009-12-08

This document pretains to SAT-LOA-20080910-00174 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2008091000174_786121

Before the FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) Skynet Satellite Corporation ) Call Sign S2764 ) (File No. SAT-LOA-20080910-00174) ) Application for Authority to Launch ) And Operate a 17/24 GHz ) Broadcasting-Satellite Service ) Space Station ) REPLY COMMENTS OF SKYNET SATELLITE CORPORATION Skynet Satellite Corporation (“Skynet”) hereby replies to the Comments of SES Americom, Inc. (“SES”)1 submitted with respect to Skynet’s above-referenced application. For the reasons stated herein, Skynet has no objection to SES’s proposal that Skynet’s application be held in abeyance. Under Section 25.262(b) of the Commission rules,2 17/24 GHz band space stations may operate at full power and with full interference protection, even if they are offset by up to one degree from the orbital locations specified in the FCC’s “grid,” so long as there is no licensed 17/24 GHz band space station or prior-filed application at an orbital location less than four degrees from the offset orbital location. Based on this provision, Skynet applied to operate at full power and with full interference protection at 70° W.L., which is one degree from the grid location of 71° W.L. As SES acknowledges, Skynet had no reason to believe when it filed its application that there were any prior-filed 17/24 GHz band applications less than four degrees from 70° W.L. However, a fraction of a second before Skynet’s filing for 70° W.L. was stamped as received at the FCC, SES’s application was stamped as received for its 17/24 GHz band application for 67.5° W.L., which is only 2.5° from Skynet’s proposed orbital location. SES has suggested that Skynet’s application be held in abeyance to give Skynet an opportunity, now that it is aware of SES’s application, to bring itself into 1 Comments of SES Americom, Inc., SAT-LOA-20080910-00174 (Nov. 23, 2009). 2 See 47 C.F.R. § 25.262(b).

2 compliance with Section 25.262(b). Skynet has no objection to this proposal, and is undertaking a review of the engineering and associated factors to determine Skynet’s best course. Respectfully submitted, SKYNET SATELLITE CORPORATION By: /s/Joseph A. Godles Joseph A. Godles GOLDBERG, GODLES, WIENER & WRIGHT 1229 19th Street, N.W. Washington, D.C. 20036 Its Attorneys December 8, 2009

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Reply Comments of Skynet Satellite Corporation was sent by first class mail, this 8th day of December, 2009, to each of the following: Daniel C.H. Mah Regulatory Counsel SES Americom, Inc. Four Research Way Princeton, NJ 08540 Karis A. Hastings Hogan & Hartson L.L.P. 555 Thirteenth Street, N.W. Washington, D.C. 20004 /s/ Jennifer Tisdale


Document Created: 2009-12-08 11:14:33
Document Modified: 2009-12-08 11:14:33
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