Attachment submission

submission

SUBMISSION FOR THE RECORD submitted by Wildblue

submission

2004-12-13

This document pretains to SAT-MOD-20040915-00178 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2004091500178_410628

UE 1200 ncereovme smeen tw wsrmiron.oc 20036 ie 9e T rozmaist0 necasrmoioot CA (sno avormeiuies December 13, 2004 BV HAND DELIVERY RECEIVED Ms. Marlene H. Dortch DEC 1 3 200 Secretary Federal Communications Commission 445 12° Street, S.W. odeaCommniea cinyCmm OnesstSetoe Washington, DC 20554 Re: WB Holdings 1, LLC Milestone Extension Request, SAT—MOD—2004091$—00178 Call Sign: 82211 Dear Ms. Dortch: WildBlue Holdings 1, LLC (‘WBH") hereby responds to the Intemational Bureau‘s request for additional information in connection with WBH‘s application for an extension of the launch and operation milestone for its Ka—band satellite authorization at the 109.2° W.L. orbitallocation." Specifically, the staff has asked WBH to state whether (1) construction ofthe satellte is complete, and (2)it has a launch contract. As discussed further below, despite WBH‘s best efforts, and despite the fact that WBH has a current Iaunch contract with Arianespace for that satellite, remaining uncertainty has effectively precluded it from securing a launch date that would meet the currently—applicable milestone and continues to justify the eighteen—month extension requested. Construction of the WildBlue—1 satellite is virtally complete. Although final testing revealed certain defects, the manufacturer, Space Systems/Loral, should be able to rectify them before the March 2005 deliverydate specified in the revised construction contract recentlyapproved in the Loral bankrupteyproceeding. However, WildBlue—1 has a verysimilar design to the Intelsat Americas 7 (‘LA—7") satelltethat recently suffered an in—orbit anomaly and was almost lost entirely. Moreover, many ofthe components of the two satellites are identical or ofidentical heritage. Loral is in the process of reviewing the IA—7 stuation to determine what,if any, design changes should !— See Leterfrom Fem J Jarmulnck to Willam M. Witshire(dted Dec. 8, 2004)

Famus, Wicrsume & Grans ui Marlene H. Dortch December 13, 2004 Page 2 of3 be incorporated into similar satelites stll under construction in order to decrease the likelihood that they will suffer similar difficulties. That review must be completed — and. any design changes must be effectuated — before the WildBlue—1 satellite will be ready for delivery and launch" Unfortunately, given the recency of the 1A—7 anomaly, Loral‘s review is i its most preliminary stage and there is no way to know when that review will be completed, what measures will be required to address the situation, and how long it will take t implement and test such measures with respect to WildBlue—1. The uncertainty surrounding completion of the satellite continues to undercut WBH‘s ability to secure a definitive launch date. WBH entered into a launch contract with Arianespace in January 2003As i fairly standard under such contracts given the vagaries of satellite construction schedules, the launch date is not specified. Rather,the process for establishing a launch window is as follows. WBH must give notice to Arianespace that it desires to be placed on the launch manifest. That notice creates a Haunch windowthat opens no sooner than 180 days after notice and closes 90 days thereafter. The actual period is dependant on the available launch opportunities on the date ofthe notice and therefore could be considerably longer than 270 days from the notice date. Moreover, even after the initial launch period is set, it can be further extended by Arianespace to accommodate its manifest, co—passenger logistis and the like. In summary, the earliest WBH could expect to receive a completed satellite fom Loral is March 2005. However, that date is likely to be moved back in light of t 1A=7 anomaly, but the duration of that delay is not known at this time. Only after WBH has a firm delivery date for its satellite will it be in a position to give notice (and begin making the multi—million dollar payments associated with the launch call up) to Arianespace that will open a launch window. Moreover, onee that launch window is set, it is stll subject to further extension by Arianespace under certain circumstances. In light of all of the uncertainty and contingeney that continues to surround the construction and launch process for the WildBlue—1 satellite, WBH believes that a milestone extension to December 25, 2006 is still warranted. While WBH will continue to work toward a launch well in advance ofthat date, there is no guarantee that ts efforts will be successful. Accordingly, WBH submits that the requested eighteen—month milestone extension is stll justifed and should be granted. We notetha Intlsahas dlayed the aunch ofts nex atellte (the aleady—complete1A—#) ntithe 1A=7 nvestgation report is completedstating hatthe complexiy ofheevent means it may take severalmonth o delivra finl report" See Press Relase, Intlsat Americas=7 Investigaion Launch Temporarly on Hokd" (Dec.10, 2004) (available at h itelntcomaboutusressrelenses aspx

Hamus, Wirstime & Grannis i Marlene H. Dortch December 13, 2004 Page3 of3 Ifyou have any further questions, please do not hesitate to contact me. Sincerely, tsM—Aithch.a, William M. Wiltshire Counselfor WB Holdings 1, LC ce: Alyssa Roberts


Document Created: 2004-12-15 12:08:32
Document Modified: 2004-12-15 12:08:32
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