Attachment 1990GE Commentsfeb 2

1990GE Commentsfeb 2

COMMENT submitted by GE American

Comment

1990-02-26

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

IBFS_SATMOD1990010500001_1058543

RECEIVED FEB 2 6 1990 Before the Federal Communications Commission FEDERAL COMMUNICATIONS COMMISSION Officeofthe Secretary Washington, D.C. 20554 In re Application of HUGHES COMMUNICATIONS GALAXY, INC. "= RCENTD For Interim Assignment of the Galaxy VI Domestic Fixed—Satellite MAR 1 290 to the 99° W.L. Orbital Position Domestic Facilities Division Sateltite Radio Branch COMMENTS OF GE AMERICAN COMMUNICATIONS, INC. GE Communications, Inc. ("GE Americom") hereby comments on one aspect of the request of Hughes Communications Galaxy, Inc. ("HGC") for an interim assignment of its Galaxy VI satellite to 99° W.L., from 1991 to 1993, purportedly to provide continuity of service to customers after Westar IV reaches its end of life and before HGC replaces it. While GE Americom does not have a position on the merits of HGC‘s request, we would like to comment on the future of Galaxy VI after it completes its two—year bridge service. According to HGC, it plans to seek a further modification‘ of the Commission‘s * HGC has already applied, in File No. 1—DSS—MP/ML—89, to modify its authorization at 99° to locate the Galaxy IV(H) hybrid satellite at this position.

2 carefully—crafted 1988 Orbit Allocation Plan‘, this time to launch a hybrid satellite, to be dubbed Galaxy VII(H), into the 91° orbital location that the Commission assigned to Galaxy VI. Assuming authorization to use a hybrid satellite at 91°, HGC states that, when Galaxy VI is no longer needed in its temporary assignment at 99°, the satellite will become "redundant," entitling HGC to retain this satellite as an in—orbit spare, use it to replace an existing Galaxy satellite, or seek "an appropriate assignment" for it. GBE Americom reserves the right to comment when and if HGC seeks what it considers "an appropriate assignment" for Galaxy VI. In the meantifie, we would simply request the Commission to remind HGC that, if it does not locate Galaxy VI in its assigned position at 91° after its continuity is completed, HGC should not, by virtue of having an in—orbit satellite, receive a preference over any other applicant to reassign Galaxy VI to an available but unassigned orbital location. To grant HGC such a preference to a particular orbital location merely because it has launched an otherwise mothballed satellite, without giving other applicants seeking such a position an opportunity to stake their own claims, would violate basic considerations of fairness, as 2 In the Matter of Assigqgnment of Orbital Locations to Space Stations in the Domestic Fixed Satellite Service, 3 FCC Red 6972 (1988). 3 Request for Interim Assignment of Orbital Location at 4 n. 3.

3 well as the Commission‘s established policy of considering all applications for orbital assignments as a group rather than separately. In other words, if HGC uses Galaxy VI only to provide continuity to service at 99°, it should do so at its risk that it will not necessarily be reassigned to the next available orbital location that becomes open. Respectfully submitted, Absorcdorfitfoefa Alexander P. Humphrey GE American Communications, Inc. 1331 Pennsylvania Ave., N.W. Washington, D.C. 20003 (202) 637—4115 February 26, 1990

CERTIFICATE OF SERVICE I, Patricia L. Campagnone, hereby certify that a copy of the foregoing document was sent via U.S. first class mail, postage prepaid, to: Gary Epstein, Esq. Latham & Watkins Suite 1300 1001 Pennsylvania Avenue, NW Washington DC 20004—2505 Attorney for Hughes Communications Galaxy, Inc.


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Document Modified: 2014-08-19 14:17:31
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