Attachment GRANT

GRANT

DECISION submitted by FCC,IB

GRANT

2005-05-05

This document pretains to SAT-MOD-20050322-00069 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2005032200069_429922

mee SBT Mobscepsp222—Cat$ l Sin $AG20 on ons Miy 5 FePS Approved by OMB K absies ** Date & Time Filed: Mar 22 2008 13931:#937M j 7 “d 4 2 PiSmon: 56tmomemimnne ies //(/1/(A':/(—/\ jf(lN[ (C%?r > A— EIfecery Tefeucl ¥CC APPLICArION FoR SPACE AND EAKTH STATIONMOD OR AMD = MAIN FORM [FCC Use Only ree 312 MATN FORM FOR OFFICIAL UsE ONLY® APPLICANT INFORMATION Enter a descrition of this application toidentify it on the main menu: TELSTAR 11 MODIFICATION TO RELOCATE 1—8. Leyal Name ofApplicant Name: Loral OrionInc Phone Number: sos—a70—2302 ona Fax Number: sos—a70—2453 Name: Streets 500Hills Dive E—Mait: se@lomildgnetcom r0. Box 7018 Cit: Bedminster State: w Country: USA Zipeode: orear 018 Attention: MrSTANLEY EDINGER

5—16. Nime of ContactReprescntaive(1fother than applicant) Name: MrSTANLEY EDINGER Phone Number: sos—a70—2302 Company:. Loral Skynet Fax Number: sos—a70—2483 Streets 500Hills Drive E—Mai: se@ilorignetcom r0. Box 7018 Cig: Bedminster Sta w Country: USA Zipeode: orszi—z018 Contact MANAGER GOVERNMENT Relationship: Sume Tide: Recations CLASSIRICATION OF FILING 17. Choose the button nex o the lssfeation that appliesto thisAilingfor (NA)b1. Appliation for Licenseof New Station both question . and b.Choose only one (NA)b2. Application for Registation ofNew Domestic Receive—Only Sttion for 1 7a and only onfor 176 & (N/A) b3. Amendiment ta Pending Application @ (N/A) b4. Modifeation of Licenseor Registation ( al. Hatth Sution bS. Assignment of License or Registation @ 2. Spoce Sution b6. Transfr ofContrl ofLicense or Reistation & (NA) b7. Notifation of Minor Modifcation (NA)b. Applicationfor License of NewReceive—Only Sation Using Non—U. Licensed Suctite (NHA) b9. ettr of ftentto Use Non—5. icensed Satelitto ProvideService in the United Stres & (N/A)b10. Other(Please specify)

17cIsa fe submited with hiappliation? @ 1f¥es, complete and attich FCC Form 159. IfNo,indiate reason forfee exemption(see 47 C.ERSetion1.1114) & Governmental B & Noncommercial edueational heense @ Othertnlease explin): 1a. Fee Classifcation BFY ~ Space Stition Modifeation(Goostationary) 18. Ifhisfiling is in reference to an 19. Ifhis fling s an amendimenttoa pending appliation onter both feld, ifthisiling ia existin sation, enter modifiction please enteronly the file mamber, (#) Callsignof stution: (5) Date pending application was Aled: (6 File namber: oxionei san.ontossocorooos7

TyPE or sERVICE 20. NATURE OF SERVICE: This fling is for anauthorzation to provide ouse thefollowing type(o) of ervices) Sclect l that apply: [g] + Bved Sclite [C] b Mobile Satelite [C] & RadiodeterminationSatelite [C] 4BarthBxploration Satelite [C] & Direct o Home Fixed Satellte [] C Disital Adio Radio Service [—] s Oer (neasespeci) 21. STATUS: Chaose the btton nextto the aplicablesatus.Choose [22, IFearh sarionapplican, check all hat apply only one [C] Using U.S. Heensed satelftes & Common Carrier @ Nor—Common Carier [C]Using Non—US. liensed satlites 23. Ifapplicantis providng INTERNATIONAL COMMON CARRIER servicese instritions regarding See. 214 Alings. Chooseore. Are teso nclltes & Camnecte toa Public Switched Network gy Not comected toa Public Switched Network @ NA 24. FREQUENCY BAND(S): Place an ‘Xin the box(es) next to all applcablefeguency bando) [C] +. C Bd @6 O. ggfb KiBand(2/4Git) [C] ©Oiher (Pease specify upper and lower fequenciesin Mitz) Frequency Lower: Frequency Upper: (Please specify additionalfrequencies in n attichment)

TYPE OF STATION 25. CLASS OF STATION: Choose the button nexto the classof siation that apples. Choose only one @ a. Fixed Eath Sttion @ b Temporany—Fixed Barth Sation @ c 12114 Gliz VSAT Nework @ 4. Mobile Barth Sution @ : Geostaionay Space Sttion @ © Non—Geostitionary Space Sation & #. Other (lease specity) 26 Type or Eaiern stamion raciuiry @ TransmitReceive ..( Transmit—Only gy Receive—Only @ NA "For Space Station applications, slect N/A,"

PURPOSE OF MODIFICATION 27. The purpose of this proposed modi n is t (Place an in the boxtes) next o all that apply) [Z]J s — authorizationto d new emisson designatorand relted srvice [C] b suthoriztionto change emision designator and reated service [C] c— authorizationtoincrease EIRP and EIRP density [C] 4 suthorization o replace anterna [C] c authorization to add anterna [C] ¢— authorization telocatefixed stati n O® authorizationtochange frequencyies) [C] i —authorization to add requency 8‘ ~ authorization to add Points of Communication (stelites Ramp; countries [C]i —suthoristion o change Point ofCommunication (stelites &amp countris) [C] k —authoriztionforfcilitesfor which environmental assessment and radiation hazard reporting is required [&] 1 — suthoriztion o change orbit lcation [C] m —authorzation to perform fect management [CJ n —authoriztion o extend milestones [] 0 — Other (Peasespecif)

ENVIRONMENTAL POLICY 28. Would a Commission grant oany proposal in this pplictionor amendment have a signifant environmental 015 @ N impact asdefined by 47 CFR 11307 IfYES,submitthstatement as required by Sections 11308 and 1.1311 of the Commission‘s riles, 47 CER, 11308 and 1.1311, asan exhibitto this applictionA Radiation Hazard Study must accompany all aplications for new transmitingfcilites, major modifiations, or major amendments ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station services are notrequired to espond to Items 30=34, 29. s thapplicana freign government or threpresenttive of any foreign governmen? 0 Ys @ No g NA 30.the applicant an alienor threpresentatve of an alien? 0 ¥s @ No g NA 31. Is the applicant a corporation onganized underthe laws ofany forcign govemment? 9 ¥s @ No q NA 32.Is the applicant a corporation of which more than one—fih othe capitalstock is owned ofrecordor vted by qy Yes @ No qy N/A aliens ortheir epresentaivesor bya foreign government or representativethereaforby any corporation organized underthe laws ofa foreigncountry?

33. s the applicana corporation directly oindrectly contolled by any other corporation of which more than @ 18 o No q NA one—fouth ofthcapital stack i owned ofrecord arvted by aliens,ther representatives,o by a foreign government orepresenative thereofoby any corporation organized under th laws ofa forign country? 34,If any answerto questions 29, 30, 31, 32 and/or 3 i Yes,attach as an extibit an idenifiation ofh allns or A foreign entites, their nationalit,thei relatonship to theapplicant, and the percentageoftock they own orvte. BASIC QUALIFICATIONS 35, Does the Applicantrequest any waivers oreemptions from any of the Commission‘s Rules? qs ow 1f¥es, atach as an exhibit, ces of the equests fr waiversor cxceptions supporting documents 36. Has the applicant or any partytothiaplication oramendiment had any CC sation authorization olcense es on revaked or had any applcation foran intil, modifcationor rencwal of FCC station authoriation, leense,or construction permidenied by the Commission? If¥es, atach asan extibit an explinationofircumstances.

37. Hasthe appliant, oany party to this applcation oramendment,orany partdirectly o ndiectly contrlling gvs @ No the applicantever been comvicted oafelony by any state or federalcourt? If Yatach asanexhibit an expliation ofcircumstan 38, Has any court inlly adjudged th applicant, oany person dirctly o indirecly controling th applicat, ov= e quity of unlawfully monopolizing oatemptiing untawfull to monopalizeradio communicatin,diecty or indirecly, through contralofmanifictureor sale of adio apparatus, exclusivetaffic amangement oany other means or unfair methods of competiton?If¥es, ttach as an exhibit, an explanaton of cireumstances 39.Is tapplican, oany person directy oidirecly conroling the aplcant, currenty a party in any pending ovs x matter refered oin the preceding twoitems? fyes, attach as an exhnit, anexplantionof he circumstances 40. Ifhe applicantis a corporation and i applyingfor a space sttion leense,atach as an exhibit thenames, addess,and itienship ofthosestockholders owning a record and/arvoting 10 percent or more ofthe Filer‘s oting stock and the perntages so held. In the case of fduciry contol indicathe beneficiaryes) or class o beneliciies Also lst thenames and addresses oftheofficrs and directrs ofthe Filer

41. By checking Yes, the underigned ceriffs, that nither applicant nor any other partytothe application is @1= oN subjec o a denial ofFederal benefits thatincludes FCC beneBts prsuant tSection $301 of the Anti—Drug Act of 1988, 21 U.5.C.Section 862, because ofa convition for poss ssioor distibationoa cantrlledsubstance. Sce 47 CFR 1.2002(b)for the meaning of &quotiparty o the app cation"fothese purposes 422. Doesthe aplicantintend to use a non—U.. Hcensed satellite to providesrvicein the United Sates?I¥es, o‘ ex answer 42b and atach an extibit providing th information specified in 47 CRR. 25 137, asapproprit f No, proceed toquestion 43 42b, What administation has feensed or is i the process of ieensing the space sation?Ifo leense willbe issued, what adininstationhas eoordinated ois in the process of eoordiatingthe space ttion? [3 Deserinton. (Summarize the natureofthe aplication and the service o be provided)(lftcompletc descrition doesnot appear in this bos, lease goto the end of the form to view it in it entirety) License modification to relocate the Telstar 11 Ku—band satellite assigned to the 37.50 W. u. orbital location to the 37.55 it.t. orbital. location

CERTIFICATION [The Applicant waives any laim to the use ofany particular requery ootheleciromagnctspecrum asagains the regulatory power ots [United Stits because ofthe previous use of he same, whetherby Ticense or othervise, andrequess an authorzaion n accordance withthis lpplication. The applicantcertifes that granothis appliation would not causethe aplicantt bein violation afthe spectrumagarezation imit in 47 CFR Pant 20. All statements made in exhibits ar a materalpart hereoand ar incorporated hereinas iseouin fullin thisapplcation [The undersigned, individualy and for the pplicant, hereby certfes thatalstatements mad n thisapcation anin allatached oxtibtsare ime, complete and corectto the best ohis or her knowledge n belif, and ae made in good fith (i; Applicantisa (an); (Choose the bution next to applcable response) @ Indvidual @5 Unincorporated Association @ Patmentip @ Comontion & Govemmental Entity @ Other leasespecity) 45. Name ofPeson Sizning 16. Tulsof Peson Signing stantey Epmvork Manaoercovernment keLations wicurul rase sTarEMENTS MADE oN THIS FORM ARE PUNISHABLE BY FINE AND / oR IMPRISONMENT (US. Code Tite 18, Section 1001),AND/OR REVOCATION OF ANY STATION AUTHORIZATION (US. Code Tite 47, Section 312(a)(), AND/OR FORFETTURE (U. Code,Tite 47, Section 502)

rce Norice requnen By Te rAPERWORK REDUCTION ACT "The public eportingforths collction of information s stimated to average 2 hours perresponse,including thime for reviewing instrctions, searching existing dat sources, atheringand maintaning threquied dats, and completing and reviewing thecollection ofinformation. Ifyou have any comments on this burden estimate, or how we can improve the colletionand reduce theburden causes you, please wrie tothe Federal Communications Commission, AMD~PERM, Paperwork Reduction Proect (3060—0678),Washington, DC 20584, We wllalsoaccept your comments regarding the Paperwork Reduction Act spects ofthis collction via thntemmc ifyou send hem to Jboley@cegov. PLEASE bo Nor sEND coPLETED ForMs To Ts Apprss Remember—You are ot equiredto respond to a collction ofinformation sponsoredby the Federal govermment, and the government may not conduct or sponsor this llection, unles it isplays a currently valid OMB control number or ife fil to provide you with thi notiee. This collection hasbeenassigned an OMB control numberof 3060—0678. k ForEcoiNG Norice is requiren By THE PAPERWORK REDUCTION ACT OF 199, PUBLIC LAW104—13, OCromeR 1, 1995, 41 U.C. SECTION 3s07.

PUBLIC INTEREST STATEMENT Loral Orion, Inc., Debtor—in—Possession (‘Loral Orion‘) requests that the Commission grant tis application for modification to relocate and operate the Telstar 11 Ku—band satelite assigned to the 37.5° W.L. orbital location, to 37.55° W.L. This relocation is part of a collocation adjustment to be undertaken in conjunction with the movement of Columbia Communications Corporation‘s (‘Columbia‘s) new AMC—12 C— band sateliteinto the 37.45° orbital position where it will replace Satcom C—1 which is also assigned and currently operating at the 37.5° WL. orbital location. Columbia has fled a similar request for reassignment to 37.46° W.L.1 Grant of the instant application willserve the public nterest by faciltating stationkeeping of Telstar 11 and AMC—12, as agreed to by Loral Orion and Columbia. Telstar 11 and Satcom C—1 (previously Columbia 515) have been collocated in the same box at the 37.5° WLL. orbital location since November 2002. Although an ajacent "box" collocation strategy similato the one proposed in this application would have been useful previously, Telstar 11 has been operating at full capacity unt recently and any movement ofthe satelite would have involved re—pointing thousands of customer antennae —— a very costl endeavor. However, Telstar 11 is nowin inclined orbit and there is nominal customer use of the satelite.. Loral Orion has already received Commission authority to replace Telstar 11 with Telstar 11R. Columbia anticipates that the AMC—12 satelite will arive at the 37.45° WL. orbital location the first week of April. Columbia, and ts parent company SES Americom, have requested 1 Columbia fled a requestfr STA to relocate AMC—12 to 37 45° WL on March 16, 2005 (sar—sta—20csos1e—00085) sn

that Loral move Telstar 11 0.0° to 3755 prior to the artival of AMG—12 in order to operate using an adjacent ‘box" collocation strategy and faciltate technical coordination. Loral Orion has agreed to do so upon the FCC‘s grant ofthe STA filed concurrenty with this application. The relocation of Telstar 11 and the operation of both satelites at the slight offset from their assigned orbitallocation of 37.5° W.L. will greatly simplfy satelite operations for both Loral Orion and Columbia. The need for constant coordination and the possibilty of colision ofthe spacecraft wl be substantially reduced. Moreover, this modification application is consistent with the Commission‘s rules and precedent. In a 1993 Order,the FCC reserved its authonty "to assign orbital longitudes offset by 0.05 degrees or some muliple thereoffrom the nominal orbital location specified in the station authorizations."2 The FCC specificaly noted that this authority is ‘particularly useful with co—located satelites of diferent frequency bands" and that it was codifying industry practice and the Commission‘s previous policies.3 The FCC recently simplfied the rule wherein this policy was codifed; however, it did not eliminate its discretion or authority to allow satelite icensees to operate from a nominal orbitallocation different from what was originally assigned.+ The new Section 25.210() ofthe Commission‘s rules states that Space stations operated in the geostationary satelite orbit must be maintained within 0.05"° of their assigned orbital 2 See in Part 25 ofthe Commission ind R tor Allen Carer Intererence Fixed—Sateltesat Recuced i and to Rev torSenvics. Second Report and Order and FrherNotee ofProposed Rulemaking, 8 FCG Red 1316 (1993)at para. 19 3 ©. 4. OrbitalDebis, Second Report and Order, 19 CC Red 11967 (2004) at para. «3 wim

longitude in the east\west direction, unless specifically authorized by the Commission to operate with a iferent longitudinaltolerance, and except as provided in Section 25.283(b) (End—of—Life Disposal). Thus, it remains to be the casethat the FCC may grant an application for a satelite to be operated from a location that is 0.05° or greater from its originally assigned orbital location. The FCC recently approved a modification application for PanAmSat Licensee Corp. proposing a similar orbital location variation. in that case, PanAmSat sought and the FCC permited PanAmSat to move its Galaxy 5 satellte from 125° W.L. to 125.05° wis Here, Loral Orion‘s modification application should be granted so that Loral Orion is able to move Telstar 11 slowlyin order to conserve as much fuel as possible and be out of Columbia ‘s "half" of the bex by the time AMC—12 arrives in the first week of April 205. Moreover, grant of the modifcation is necessary to allow the agreement between Loral Orion and Columbia to be fulflled. The parties have agreed that an adjacent box collocation strategy, as contemplated by the FCC‘s 1993 Order cited above, is preferred because it offers the lowest probabiity ofinterference or colision for collocated satelites. Finall, as demonstrated by the technical materials attached to this application, this sight shif in orbitallocation will not cause harmful interference to neighboring Ku— band satelite operators, including Intelsat 903 located at 34.5° W.L. and NSS—806, located at 40.5" W.L©_ Although the proposed offset would result in Telstar 11 being 5_ se Notie, Report No. SAT—00222, DA No. 0¢—1746, Fle No SAT—MOD: 20040405—00075 (rl. June 18, 2004) 8. Leral Orion is not submiting new contour maps with tappliaton because the minor stif i oritallocation wil not materaly affect coverage of the satlie as shoun on the maps aleady on fie a3—

slightly closer to NSS—806, the satelltes will stll be 2.95° apart and there will be no material change to the existing interference environment. The Telstar 11 satelite is fuly compliant wih the Commission‘s requirements with respect to two—degree spacing. For the reasons discussed above, grant of tis application for modification is in the public interest. Loral Orion requests that the Commission expeditiously grant this requestto reassign Telstar 11 to 37.56° W.L sn

Loral Orion nc, (Deblorin.Possession),a U.S. corporation, is a whally ouned subsidiay of Loral Space 8 Communications Gomoration (Debtorin Possession), also a U.S. cormoration. Loral Space & Communications Gomoration (Debtarin—Possessionis whally ouned and contraled by Loral Space & Communicatons Lis. (Debtorin—Possession} (Loral Lt DIP), a Bermuda company. Loral Ltd. DIP‘s home marketisthe Unted States." * See In re Applieation of AT&T Corp. and Loral SpaceCom Corporation, Order and Authorization, 12 FCC Red. 925 at 1 9 (1997)

Revocation of authorizations In an orderissued Apri 1, 2009,the ntemational Bureau deciared null and void authorzations held by Lorl SpaceCom Corporation and Loral Space & Communications Comorationto constuct, launch and operate Geostationary Fixed Satelte Servic Ka.band payloads at 80" WL, B1° WL. 47° WL. and 78° EL. [re Loral SpaceGom Corporationand Loral Space & Communicatons Comoraton, Memorandim Opinion, Order and Authorzaton, 18 FCG Red 6301 (It! Bur. 2003)] The Bureau aftrmed ts earierdecision notto extend the constructon miestones associated wth these authorzatons, n re Loral Space & Communicatons Coporation, Order, 18 CC Red. 1104 (Itl Bur. 2001)

NGINEERING STATEMENT Loral Orion Inc (Loral)is currently lcensed to operate Telsta11 at 37.50° WIL utlizing the 14.0—14.5 GHz uplink and 11.45—11.7 GHe, 11.7—122 GHfe, and 12.5—12.75 GHe downlink FSS bands to provide U.S. and Europe coverage.In thisfling, Loral proposes to modify ts license to specify operation ofTelstar 11 from 37.55° WL instead of 37.50° WL. To account forthis change in orbtal location,this engineering statement updates the following technicalinformation that Loral previously had submited: (1) gain contours, (2) PFD levels and (3)link budget analysis. Gain Contours "The coverage pattems ofTelstar 11 operating from the proposed 37.55° WL orbital location will be the same as those specified in the currentlicense. Changing the proposed orbital location from 37.50° WI. to 37.55° WL will produce no visible change in the gain contours. Accordingly, no new beam gain contours are being submitted. Power Flus Density Levels "The power flux density (‘PFD®) levelat the Earth‘s surface produced by Telsta 11 operating from the proposed 37.55° WL orbital location will be the same as those corresponding to operation from 37.50° WL and have already been provided to the FCC. Link Budgetsand Interference Analysis The Commission has adopted a policy in which the nominal spacing between adjacent co—coverage co—frequency satelltes is 2. Moving a satelite by 0.05°, o that there is 1.95° and 2.05° ofseparation, respectively, between the re—located satelfite and ts nearest and next nearest neighbor will cause negligible change in the interference levels introduced into each satellte system. The following analysis substantites this clim. Receiving earth stations, which have of—axis gain characteristics compliant with Section 25.209(a)(1) ofthe FCC rules, would have an offaxis gain of 21.5 dB toward an interfering satelite, which is 2° away from the desirestellte. If the interfering satellte moved 0.05° toward thdesired satllit, so thatthe separation between the desired and interfering satelites is 1.95%, the off—axis gain ofthe receive earth station antenna toward the iterfering satelte would become 21.7 dB. Hence, there would be an increase of0.2 B in tinterference levels from the nearest neighbor satelite. Such a small change in the interference levels would not affect in any meaningful way the existing iterference environment. Regarding the satellte that would be 2.05° away, the iterference environment would also be neeligibly changed. Receiving carth stations, which have offaxis gain characteristics compliant with Section 25.209(@)(1) othe FCC rules, would have an off axis gain of21.5 dB toward an interfering satelite, which is 2° away from the desired satellite. 1f the interfering satelte is moved 0.05° away from the desired satelite, o that the separation between the desired andinterfring satelltesis 2.05®,the ofaxis gain of

the receive earth station antenna toward the interfering satellte would become 21.2 dB. Hence, there would be a decrease of0.3 dB in the interference levels from the next nearest neighbor satelte. Such a small change in the interference levels would not affect in any meaningful way the existing iterference environment. Therefore, moving Telstar 11 by:0.05° to 37.55° WL would result in an insignificant change in the interference environment for both the nearest and neighbor satelfites and the Telstar 11 satelite and theirassociated earth stations. In fact,the operational co—frequency satelites nearest to the 37.55° WL orbitallocation are New Skies Satelftes NSS—806, located at 40.50° WI., and Intelst 903, located at 34.50° WL. These stelltesare 3° away from Telstar 1, making the interference environment more benign than in the case of 2° separation. In the case of NSS—806 and Telstar 11, since the satelftes do not cover the same regions — NSS—806 covers the Atlantic coast of Brazil and Telsar11 provides coverage of the US — the systems inherently introduce low interference levelsinto each other. With the Telstar 11 spacecraft moving 0.05° closer to NSS—806, theinterference levels would increase by about 0.2 dB for earth stations adhering to the off—axis gain characteristicsset forthin Seetion 25.209(a)(1) of the FCC Rules, since the ofaxis gain toward the nterfering satelie would increase from 17.1 dB (in the case 0f3.00° ofseparation between the satelites) to 17.3 B (in the case 0f3.05° ofseparation between the stellites}. This very small change in the iterference levels, on top of the already low interference levels in the nominal case, would not impact the interference environment for NSS—806 and Telstar 11 in any meaningful way. Regarding Intelsat 903, with earth stations adhering to the offaxis gain characterisicsset forth in Section 25.209(a)(1) othe FCC Rules, the already low interference levels would be reduced by less than 0.2 dB. Such a small decrease in the of—axis gain of Intelsat 903 receive earth station will not change in any meaningful way the existing interference environment ofIntelsat 903 receiving earth stations from the proposed operation of Telstar 11 at 37.55° WL.. Similarly,interference from Intelsat 903 transmissions into Telstr 11 receiving earth stations would be substantilly unchanged (0.2 dB variation}. Given that the proposed operation ofTelstar 11 would not resultin any significant change to the existing interference environment as it pertains to Telstar1 1, Intelsat 903, and NSS—806 no link budget analysis is provided hes Schedule S Submission For reasons thatare discussed above,the proposed operation of Telstar 11 from 37.55® WL would notresult iany materialchanges to the operating characteristcsofhe satelliteor the existing interference environment. The information requested in Schedule S, therefore, is duplicative ofthe information that Loralalready has provided. Based on this fact and on discussions with the saff of the Satellte Division, Loral is not including ‘ The Intermational Bureau recently clarified that GSO space station applicants generally are expected to provide this information. See Public Notice, DA 03—3683 (Dec. 3, 2003)

a Schedule S with ts modification application. However, Loralwill prepare and filea Schedule S in the event that the Satelte Division determines t to be necessary. Certiication Statement 1 hereby certify that I am a technically qualified person and am familiarwith Pat 25 of the Commission‘s Rules and Regulations. The contents ofthis engincering statement were prepared by me or under my direct supervision and to the best of my knowledge are complete and accurate. Peter E. Gocttle March 21, 2008


Document Created: 2005-05-05 15:47:23
Document Modified: 2005-05-05 15:47:23
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