Attachment 1990Application65 s

1990Application65 s

APPLICATION submitted by GTE

Application to modify

1990-09-25

This document pretains to SAT-MOD-19900926-00054 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD1990092600054_1060660

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HOGAN & HARTSON                                                                                                  sethEsoa, manygANG20817
                                                                                                                       s01/493—0080         60b
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      555 THIRTEENTH STREET NW                                                                                  saLtimore, MARYLAND 21202 :;
                                                                                                                        201/es9—2700
      WASHINGTON, DC 20004 —1109
             202/837—5600                                                                                         8300 GREENSBORO ORIVE
                                                                                                                   McLEAN, VIRGINIA 22102
       wRITEA‘s DIAECT DiAL NUMBER                                                                                     ros/848—2600
  202/637—5793



                                                                                 September 25,                1990



Secretary
                                                                                             65— 9585 —ML—40
                                                                                                         —
Federal Communications Commission
1919 M Street, NW
Washington, DC 20554

Service:                    Fixed Satellite Space Station
Application:                Modification of Authorization
Number:                     One (Space Station IR)

Dear Ms.          Searcy:

         Submitted herewith on behalf of GE American
Communications, Inc. (GE Americom) is an application to modify
the authorization for its Satcom IR space station, in order to
change the authorized orbit=1 position for that space station
(Fee Code BFY).  GE Americo: is simultaneously filing an
application for temporary authorization to relocate its C—1
space station (Fee Code CRY).

         These two requests are set forth in the attached
written request.   A single written request is submitted because
the two=®requests are interrelated.  Because different fees are
required for these two separate actions, we are submitting two
cover sheets with separate checks made payable to the Federal
Communications Commission.  This is the transmittal sheet for
the modification request for space station IR, and the $5,000
fee is being submitted with the attached FCC Form 155.

         Please Girect any questions concerning this matter to
the undersigned counsel for GE Americonm.


              L                                                            Sincerely,
                                                                                         ft%
                                                                             rald E.         Oberst,          Jr.

co:               Fern Jarmulnek,                 Esq.




           CABLE: "HOGANDER WASHINGTON"‘» TELEX: 248370 (RCA), 892757 (WU) » FACSIMILE: 202//637—5910 + EASYLINK: 62776734


aApprovedg by OMB                   FEDERAL COMMUNIcaTions commMiIssion
  2080 —0440                         FEE PROCESSING FORM
Expires   12/31/90


 Please read instructions on back of this form before completing it. + Section 1 MUST be completed. . If you are 3 in £
 concurrent actions which require you to list more than one Fee Type Code, you must also complete gecnon H.D?ms g,‘or?:.
 must accompany all gaymems. Only one Fee Process:n? Form may be submitted per application or filing. Please type or ormnt
  legibly. All required       blocks must be completed or application/filing will be returned without action.               ~

 SECT | ON                      I
  APPLICANT NAME (Last first, middle Initial)

          CE American Communications,                               iInc.
  MAILING ADDRESS (Line !) (Maximum 85 characters — refer to Instruction (2) on reverse of form)

          c/o G. Oberst, Hogan & Hartson
  MAILING ADDRESS (Line 2) (If required) (Maximum G§6 characters)

          555 Thirteenth Street,                             N.W.
 CITY
      Washington
 STATE OR COUNTRY (if foreign address)                       ZIP CODE                       CALL SIGN OR OTHER FCC IDENTIFIZRGf apphcate
          D.C.                                                20004                             Space Station IR
 Enter in Column (A) the correct Fee Type Code for the service you are applying for. Fee Type Codes may be found in FCC
 Fee Filing Guiges. Enter in Column (B) the Fee Multiple,               if applicable. Enter in Column (C) the result obtaimed from muitipiying
 the value of the Fee Type Code in Column (A) by the number entered in Column (B), if any.
                    (A)                                (B)                                      (C)
                *                                 FEE MULTIPLE                     FEE DUE FOR FEE TYPE               mos       :   .
 e      FEE TYPE CODE                              lif required)                       COdE IN COLUMN (a)             i fORvAFCC USE ONLY


          C |        _R   Y                                                        $      500.00



  SECT i ON                      |   |      —     To be used only when you are requesting concurrent actions which result n a
                                                  requirement to list more than one Fee Type Code.


                    (A)                                (B)                                     (C)
        FEE TYPE CODE                           FEE MULTIPLE                       FEE OUE FOR FEE TYPE
                                                 (if required)                      CODE IN COLUMN (A)




 (2)                                                                               $


                     3e
 (3)                                                                               $




 (4)            ]                                                                  3




 (5)                                                                               $


 ADD ALL AMOUNTS SHOWN IN COLUMN C, LINES (1)
 THROUGH (§)}, AND ENTER THE TOTAL HERE.                                               TOTAL AMQUNT REMITTED          ie o
       j      *                                                                                                         FOR FCC USE ONLY
 THIS AMOUNT SHOULD EQUAL YOUR ENcLosED                                                with TyHS AAReCATIN
 REMITTANCE.                                                              )
                                                                                  *       _500.00
Inms form has been authorzed             for reproduction.


                                  Before The                                =
                      FEDERAL COMMUNICATIONS COMMISSION
                           wWashington, D.C.                   20554



In the Matter of Application of




                                           Nt N N N Ne NP ut
GE AMERICAN COMMUNICATIONS,        INC.                          File No.

for Authority To Position and
Operate Certain In—Orbit Fixed
Satellites


                                APPLICATION OF
                       GE AMERICAN COMMUNICATIONS, INC.
        «_             ____FQ@POSITIQON_SATELLITES_____

        GE American Communications, Inc.                       (GE Americom) requests
(a)     a modification of the license for its Satcom IR C—band
satellite in order to position and operate it at 131° W.L.                            and
(b) temporary authority to position and operate GB Americom‘s
C—band C—1 satellite at 139°.


        In November,    1990, GE Americom‘s C—1 satellite will be
launched aboard an Arianespace rocket.                          This satellite will
become GE Americom‘s in—orbit spare, providing inter—satellite
protection to customers on GE Americom‘s other C—band
satellites.        That role is currently playsed by GE Americom‘s
Satcom IR satellite now operating at 139° W.L.                          When C—1
becomes operational in January 1991, it will be available to
perform the functions of Satcom IR.


        At that time, GE Americom intends to use Satcom IR to
replace the Satcom IIIR satellite, which is located at 131°
wW.L.        Satcom IIIR is used exclusively to distribute cable
televiszsion programming.      The satellite was launched in November
1981 and, although still possessing fuel that permits continued
station keeping,       is beyond its nominal design life of eight
years.        Further, the satellite‘s remaining command receiver,


which is essential for maintenance of the satellite at its
assiqgned orbital location,    requires power levels in excess of
its design specification in order to access the satellite.
Also, because of the satellite‘s age,     its solar arrays are
slowly but irreversibly degrading to the point that they can no
longer support the satellite‘s full load of transponders.          We,
therefore, plan to take the satellite out of gervice once a
replacement for it is available.


      The mosgst efficient and least disruptive meang of
maintaining cable programming for customers on Satcom IIIR is
to move the in—orbit spare satellite, Satcom IR, to the
Satcom IIIR location at 131°.*      Satcom IIIR‘s transponders
transmit video programming destined for cable systems across
all of the fifty states.      Approximately 8,500 receive antennas
at cable headends nationwide are pointed at the 131° W.L.
orbital location,    It would take several waeks of effort to
cocrdinate the shifting of all of these antennas from the
131° W.L. position to 139° W.L., which is Satcom IR‘s assigned
location.   The average cost of repointing an antenna is
approximately $250, which would mean a total cost to customers
of cable programming services of approximately $2,125,000.
Moreover, unless GE Americom could arrange dual uplink
programming feeds to Satcom IR and Satcom IIIR during the time
that the thousands of antennas are being shifted, our cable
programming customers would suffer a serious disruption in
service to their own customers — the cable systems.        These
systems, which number more than 6500,    provide video programming
from Satcom IIIR to approximately 50 million homes.     A much
more efficient,   non~eGisruptive and highly favorable solution




*   Satcom IR would then operate at the 131° wW.L. position until
    the operational date of C—3, Satcom IIIR‘s authorized
    replacement, in the first quarter of 1993.


for the cable television industry is to move Satcom IR to the
131°    location to transfer the cable programming to a more
stable satsellite.*


          GE Americom has pionsered both the use of satellites for
aistribution of cable programming services and the protection
of those services with an in—orbit spare satellite.        It has
historically been GE Amsricom‘s plan,    if at all feasible, to
move the in—orbit spare to the location of a failed cable
satellite,    rather than to disrupt customer services by
attempeting to shift those services to the location of the
in—orbit spare.


          The course of action requested in this Application
should be wholly unobjectionable with respect to Satcom IR
since that satellite is a conventional C—band satellite
operating with moderate power levels.     Each Satcom IR
transponder operates in a wide full—CONUS beam mode with 8.5
watts of power.     Moreover, Satcom IR and Satcom IIIR have very
similar polarization schemes.     Under these circumstances,
operation of Satcom IR at the 131° W.L. location will not pose
a risk of harmful interference to adjacent satellites, the
nearest of which is three degrees away.**     In the extremely




*      The current plan for Satcom IIIR, subject to further
     review, is to turn the balance of its communications
     payload off and to maintain the satellite as a
     non—Ooperational, in—orbit spare at 131° W.L,

**   The Galaxy I satellite operates at 134° W.L,.   Although its
     assigned orbital location is 133° W.L. Galaxy I will not be
     required to move to 133° W.L. until GE Americom‘s C—4
     satellite is launched into the 135° W.L. position in the
     third quarter of 1992.  ASC 1 operates at 128° W.L. and
     will not have to move to its assigned position at 129°
     until the launch of the Spotnet 2 satellite, scheduled for
     September 1993.


unlikely event that operation of Satcom IR might result in
harmful interference to adjacent spacecraft, GE Americom will
coordinate with the operators of those spacecraft to eliminate
 the interference.


          The moving of Satcom IR to replace Satcom IIIR at 131°
wW.L. will necessitate temporarily positioning GBE Americom‘s C—1
satellite at 139° W.L.,       in lieu of immediately placing it at
its permanent assignment at 137° W.L., in order to maintain
service to the customers now receiving service on Satcom IR at
the 149° W.L.    location.     These include several major radio
networks which opsrate with more than 5,000 antennas located at
radio stations across the country,       including Alaska and
Hawaii.     Locating C—1 at 139° (and operating it in the vertical
polarization to match the polarization of Satcom IR) would be
less d@isruptive than placing C—1 at its assiqgned location at
137° W.L.    (where it would have to operate horizontally
polarized)    and shifting these thousands of antennas to the new
location as well as a different polarization.*        The latter
approach would inevitably result in major service disruptions
and significant expense to users.        As we noted earlier, the
average cost of repointing a single antenna from one Oorbital
location to another is estimated to be approximately $250
resul&king in an aggregate cost to users in this case of
approximately $1,250,000.       Moreover, the affected customers
will eventually take service on the Aurora II satellite to be
launched in May,     1991 and located at the 139° wW.L. position.
If this application is not granted,       in January 1991 thousands
of customers‘    antennas will be repointed temporarily from
139° W.L.    to 137° W.L.    and their polarizations switched to
operate with C—1 at 137° W.L.       They would again have to be
repointed and their polarization changed six months later to




*#   C—1 is equipped with polarization switching capability.


operate again at 139° W.L., this time with Aurora II.         Thus,
total cost to users of the FIR and Aurora II satellites,        if
this GE Americom request is not granted, is approximately
$2,500,000.    A better solution is a no cost, no disruption
alternative for the users which allows continuous operation at
139° W.L. first with C—1 and shortly thereafter with Aurora II
when it becomes operational at that position.


       The operation of C—1 at 139° W.L. will be necessary for
only a few months —— from its operational date, now planned for
January,   1991, until July,   1991 when the Aurora II satellite,
whose assigned location is 139° W.L., becomes operational.            At
that point,   the services on C—1 will for the most part be
transitioned to Aurora II,     and C—1 will be moved to its
permanent orbital position at 137° W.L.


       As with the operation of Satcom IR at 131° W.L.,
temporary operation of C—1 at 139° W.L. as requested in this
Application should be wholly unobjectionable.      C—1 is equipped
with a polarization switch so that it can remain cross—
polarized with its neighbors if C—1 is located at ceither 137°
wW.L. or 139° W.L.   C—1l‘s designed power level (8.5 watts) is in
fact lower than that of the satellite, Aurora II, that is
assiqfted to the 139° W.L. position (10.0 watts).     Hence, there
is virtually no likelihood that operation of C—1 at 139° W.L.
for the requested few months would cause harmful interference
to any adjacent spacecraft.      This is particularly true since
during the time C—1 is operating at 139° W.L., the closest
C—band satellite would be the Aurora I satellite,     four degrees
away at 143° W.L.    Moreover,   in the very remote chance that
harmful interference might result from C—1‘s operation at 139°,
GE Americom would coordinate with affected parties to resolve
any problems that might occur.


        GE Americom, therefore, respectfully requests that the
Commissilon expeditiously authorize (a) the positioning and
coperation of GE Americom‘s Satcom IR satellite at 131° W.L.       and
(b) the temporary positioning and operation of GE Americom‘s
C—1 satellite at 139° W.L.       Rapid Commission action on this
request is important because the launch of C—1 is scheduled for
November 20,     1990 and GE Americom plang to begin the move of
Satcom IR to 131° W.L. as soon as Satcom C—~1 is operational and
able to receive the traffic from Satcom IR which is scheduled
for January 1991.       In order to properly coordinate tha
transfer,   and avoid expansive implementation of contingency
plans to cover the eventuality that the Commissgsion would not
grant this request, GE Americom needs to know as early as
possible but no later than early December that Satcom IR is
authorized to operate at 131° W.L.


                                    Respectfully submitted,




                                      ilip   ¥. Otero




                                    William F. Taylor


                                    GE American Communications,    Inc.
                                    4 Research Way
                                    Princeton, N.J.     08540



Sseptember 25,   1990



Document Created: 2014-09-09 17:07:58
Document Modified: 2014-09-09 17:07:58

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