Attachment comment

comment

COMMENT submitted by Telesat

comment

2006-09-29

This document pretains to SAT-MOD-20060821-00090 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2006082100090_531296

0 R IGINAL Before the RECEIVED FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 SEP 2 9 2006 mmnicatlonsCornmiah 0fficeofsecretary In the Matter of 1 1 Satblites Mexicanos, S.A. de C.V. ) File No. SAT-MOD-20060821-00090 ) Modification to the Petition for ) Declaratory Ruling to Add Solidaridad 2 to the Permitted 1 Space Station List at 114.9’ WL 1 Telesat Canada (“Telesat”) wishes to provide the Federal Communications Commission (“FCC” or “Commission”) with the following comment on the above referenced Satelites Mexicanos S.A. de C.V. (“Satmex”) modification application to place Solidaridad 2, located at the 114.9’ WL orbital position, on the Commission’s Permitted Space Station List (“Permitted List”).’ As Satmex notes in its application, Solidaridad 2 was previously on the Commission’s Permitted List at the 113.0”WL orbital position2 and has now been re-located to the 114.9” WL position. Telesat is a Canadian-licensed satellite operator and is well known to the Commission, having had a number of its Fixed-Satellite Service (“FSS”)satellites placed on the FCC’s Permitted List3 and another recent application pending4 The locations of these Canadian ’ Satklites Mexicanos. S.A. de C.V. Modification to Petitionfor Declaratory Ruling To Add Solidaridad 2 to the ~~~ ~~ Permitted Space Station List, File No. SAT-MOD-20060821-00090 (filed August 2 1,2006) (“Solidaridad 2 Petition”). ’ See Satilites Mexicanos, S.A. de C.V. Petition for Declaratory Ruling, Order, 15 FCC Rcd 19,31 1 (2000) (adding Solidaridad 2 and Satmex 5 to the Permitted List) (“Solidaridad2 and Satmex 5 Order“). ’ Telesat Canada: Requestfor Declaratory Ruling or Petitionfor Waiver on Earth Stations’ Use ofAnik E l and Anik E2 Satellite Capacity to Provide Basic TelecommunicationsService in the United States, Order, 15 FCC Rcd 3649, 3653 (7 13) (Int’l Bur. 1999) (,‘An&El and E2 Order“); Telesat Canada: Petitionfor Declaratory Ruling For Inclusion ofAnik FI on the Permitted Space Station List, Order, 15 FCC Rcd 24828,24831 (1 10) (Int’l Bur. 2000) (“AnikF1 Order”); Telesat Canada: Petitionfor Declaratory Rulingfor Inclusion ofAnik FZ on the Permitted Space Station List, Order, 17 FCC Rcd 25287,2529 1 (111) (Int’l Bur. 2002) (,‘An&F2 Order”). In the Anik F2 Order the Commission also granted Telesat authority to offer two-way broadband services at Ka-band in the U.S. market. Telesat (Anik FIR) Petition for Declaratory Ruling for a Replacement Satellite, File No. SAT-PPL- 20050504-00094 (approved July 15,2005). 1

satellites in the North American arc range fiom 107.3”to 118.7”WL, and are as close as 3.8 degrees of separation fiom the Solidaridad 2 location of 114.9’ WL. Accordingly, Telesat has a significant direct interest in the proper operation of Solidaridad 2 at 114.9” WL. Because of the close proximity of the Telesat and Satmex satellite orbital locations, Telesat and Satmex have entered into a comprehensive coordination agreement to ensure that neither party causes unacceptable interference into the other party’s satellite network operations. The agreement currently in force was concluded in August 2003 (“the 2003 Agreement”). Accordingly, Telesat has no objection to Solidaridad 2 being added to the Commission’s Permitted List at the 114.9’ WL position, provided that the Commission includes a condition requiring Satmex’s operation of this satellite to comply with its 2003 Agreement with Telesat. Such a condition would be consistent with Satmex’s statements in its pending petition that “Satmex has completed all required coordinations with U.S. and Canadian satellite operators for the Solidaridad 2 satellite at 114.9’W orbital location” and that ‘‘[all1 traffic on the Solidaridad 2 satellite will be in accordance with these coordination agreement^."^ Telesat notes that such a condition would also be consistent with the ordering clause in the Solidaridad 2 and Satmex 5 Order that “. ..access to the Solidaridad 2 and SatMex 5 satellite networks SHALL BE in compliance with the satellite coordination agreement between SatMex of Mexico, Telesat Canada, and Industry Canada, signed in Istanbul on May 3 1,2000, and any future modifications to which the parties agree.”6 (emphasis in original) Similar conditions also appear in the Commission’s recent grant stamp approval adding Satmex 6 to the Permitted List.7 Telesat Canada: Petitionfor Declaratory Rulingfor Anik F3 to be Added to the Permitted List, SAT-PPL- 20060516-00061 (filed May 16,2006). ’ Solidaridad 2 Petition at 3. ti Solidaridad 2 and Satmex 5 Order at 7 22. See conditions 1 and 2, SAT-PPL-20060329-00030/SAT-AMD-20060724-00080(Int’l Bur.Sat. Div., Auth. By Grant Stamp w/Conditions, August 4,2006). 2

Respectfully submitted, Telesat Canada n Ted H. Ignacy Chief Financial Officer 1601 Telesat Court Ottawa, Ontario Canada, KlB 5P4 September 29,2006 3

CERTIFICATE OF SERVICE I, Pam Conley, do hereby certify that on September 29, 2006 I served a copy of the aforementioned Comment of Telesat Canada upon the following parties either by U.S. first- class mail, postage pre-paid, or by electronic mail delivery (*): Senor Carmen Ochoa General Counsel SATMEX Rodolfo Gaona No. 86, Piso 4 Col. Lomas de Sotelo C.P. Mexico City, Mexico Senor Alonso A. Picazo SATMEX Rodolfo Gaona No, 86, Piso 4 Col. Lomas de Sotelo C.P. Mexico City, Mexico Dr. Richard J. Barnett Telecomm Strategies, Inc. 6404 Highland Drive Chevy Chase, MD 208 15 Mr. Robert Nelson * (via e-mail) Chief Satellite and Radiocommunications Division Federal Communications Commission 445 1 2 ' ~Street, S.W. Washington, DC 20554 Ms. Andrea Kelly * (via e-mail) Chief Policy Branch International Bureau Federal Communications Commission 445 1 2 ' ~Street, S.W. Washington, DC 20554 Ms. Kathryn Medley * (via e-mail) Acting Chief Engineering Branch Federal Communications Commission 445 12'~Street, S.W. Washington, DC 20554

Best Copy and Printing, Inc.* (via e-mail) 445 lYh Street, N.W. Room CY-B402 Washington, DC 20554 E-mail : fcc@bcpiweb.com W Pam Conley


Document Created: 2006-10-11 13:29:51
Document Modified: 2006-10-11 13:29:51
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