Attachment 1990NPR Informal Com

1990NPR Informal Com

COMMENT submitted by National Public Radio Inc.

Informal Comment

1990-03-01

This document pretains to SAT-MOD-19900105-00001 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD1990010500001_1058539

RECEIVED Before the FEDERAL COMMUNICATIONS COMMISSION MAR 1 — wqo Washington, D.C. 20554 Federat Communications Commission Office of the Secretary In the Matter of HUGHES COMMUNICATIONS File Nos. 1—DSS—MP/ML—89 GALAXY, INC. 2—DSS—MP/ML—89 3 =DES—ML—B89 Request for Authority i?f;(‘o'~ to Modify Authorizations mdi]%7 Ey for Galaxy A and Galaxy IV El} In the Matter of HUCHES COMMUNICATIONS caALXXY, INC. Request for Interim Assignment of the Galaxy VI Domestic Fixed—Satellite to the 99° Orbital Position INFORMAL COMMENTS OF NATIONAL PUBLIC RADIO National Public Radio, Inc. ("NPR") hereby submits informal comments on the above captioned Requests by Hughes Communications Galaxy, Inc. ("Hughes"). Hughes requests authority to modify its existing authorizations for the Ku—band satellite Galaxy A and the C—band satellite Galaxy IV by constructing, launching, and operating a single hybrid satellite ("Galaxy IV") at 99° W.L., with service to commence in 1993. In addition, Hughes requests an interim assignment of its C—band satellite Galaxy VI to 99° W.L. for the period between the end— of—life of Westar IV in 1991 and the beginning—of—service of Galaxy IV in 1993 (the "interim period"). NPR is a nonprofit, noncommercial organization which

provides programming and interconnection services to 384 full— service public radio stations, and represents them in developing and maintaining a viable and diverse public radio service for the American public. NPR‘s interest in these proceedings arises from the fact that the Public Radio Satellite Interconnection System ("PRSIS") is the owner of one transponder on the satellite currently located at 99° W.L., Westar IV. NPR manages the PRSIS for the benefit of participating public radio stations under the legislated authority of the Corporation for Public Broadcasting. NPR has recently concluded an extensive process of identifying replacement space seqgment capacity for the period following the end—of—life of Westar IV, and has contracted with Hughes for the purchase of two transponders for the public radio system on Galaxy IV, contingent upon Hughes obtaining the necessary authority to construct, launch, and operate Galaxy IV. This service is scheduled to commence in 1993. In addition, NPR has entered into a lease arrangement with Hughes for transponder capacity at 99° during the interim period, contingent upon the ability of Hughes to provide such capacity. The PRSIS currently consists of more than 300 receive earth terminals located at public radio stations serving all fifty states, as well as twenty—two transmit—capable earth terminals which permit immediate access to the system from widely diverse geographic locations. The existing intact and fully functioning ground system of more than 300 C—band earth

terminals, combined with the inability of existing or planned Ku— band satellites to provide adequate full fifty—state coverage, has contributed in large part to NPR‘s decision to continue operations at C—band. Ssome public radio stations are geographically located in areas that cannot be served by satellites located East of 99° wW.L., such as those on the North Slope of Alaska. Thus, a major portion of the domestic satellite arc is precluded from use by the public radio system. In addition, replacement or costly major modifications would be required to many of the system‘s existing receive antennas if the replacement satellite was located West of the 125° W.L. position. These factors confirm that the 99° W.L. position is particularly well suited for public radio‘s continued use. Uninterrupted program delivery to the nation‘s public radio stations and the listening public will, therefore, be best served by the availability of continuous service at the 99° W.L. position, both during the interim period and upon delivery of permanent replacement satellite capacity. While NPR has taken all steps possible to assure continuity of service in the future, there is still a degree of uncertainty remaining, caused by Hughes!‘ present lack of governmental authority to provide both the interim and permanent service. Since the availability of service at the 99° position is not completely assured during the interim period, NPR has made arrangements for alternative capacity on another satellite should it be required. Major

disruption to the Public Radio Satellite System would be caused by the necessity of repointing all of the transmit and receive antennas twice, as well as providing parallel service on two satellites during two separate transition periods. NPR believes that the public interest will be best served by the favorable and timely resolution of the two outstanding Hughes Requests, so that the planning for the future of the Public Radio Satellite Interconnection System can continue with the knowledge that the requlatory issues relating to the availability of space seqgment have been settled. Continuity of service at 99° W.L. for the PRSIS would provide real and valuable benefits to a large segment of the American public. NPR respectfully requests that the Commission consider the benefits to the Public Radio Satellite Interconnection System in its decision on the matters raised by the Hughes Requests and rule on these matters favorably and expeditiously. Respectfully submitted, NATIONAL PUBLIC RADIO, INC. 2025 M Street, N.W. Washington, D.C. 20036 / / / By : 7)717Z w/\;{:“% ; Peter @f Loewensteln Vice—President for Distribution /Cé,‘l{:«./ By “ZZMWW EKdren ChrfiStensen Mary fou Joéeph 7 _ Agting General Counsel Representati@n Division March 1, 1990

CERTIFICATE OF SERVICE I, Ethyl L. Tiller, hereby certify that on this ist day of March, 1990, copies of the foregoing were mailed, first class mail, postage prepaid to the following: Cecily C. Holiday, Esq.* Chief, Satellite Radio Branch Common Carrier Bursau Federal Communications Commission 2025 M Street, N.W. Room 6324 Washington, D.C. 20554 Fern J. Jarmulnek, Esq.* Common Carrier Bureau Federal Communications Commission 2025 M Street, N.W. Room 6324 Washington, D.C. 20554 Gary M. Epstein, Esq. James P. Rogers, Esq. John P. Janka, Esq. Latham and Watkins 1001 Pennsylvania Avenue, NW Suite 1300 Washington, D.C. 20004 Counsel for Hughes Communications Galaxy, Inc. Joan M. Griffin, Esq. Contel Corporation 555 13th Street, N.W. Suite 480 West Washington, D.C. 20004 Counsel for American Satellite Company ("Contel ASC") Karl R. Savatiel Director, Satellite Communications AT&T Room 4A115 Routes 202/206 North Bedminster, NJ 07921 Carl J. Cangelosi GE American Communication, Inc. Four Research Way Princeton, NJ 08540 W/%‘J / Ethy¥ L. Tiller *Hand Delivered


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