Attachment letter

letter

LETTER submitted by IB,FCC

letter

2008-04-21

This document pretains to SAT-MOD-20080226-00052 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008022600052_636246

                             Federal Communications Commission
                                   Washington, D.C. 20554




                                             April 21,2008


James M. Talens, Esq.
Counsel for ATCONTACT Communications, Inc.
601 7 Woodley Road
McLean, VA 22 1 0 1

                                                      Re: ATCONTACT Communications LLC
                                                          SAT-MOD-20080226-00052
                                                          (Call Sign: S2681)



    Dear Mr. Talens:

         This letter refers to the above-referenced application filed by ATCONTACT
Communications, LLC (ATCONTACT). In the application, ATCONTACT proposes to relocate
its authorized satellite from its current location at 121" W.L. to the 11 5.2" W.L. orbital location.

           Section 25.140(b) of the Commission's rules requires ATCONTACT to demonstrate
that its proposed operations at the 1 15.2" W.L. orbital location are compatible with the
Commission's two-degree spacing environment.' Specifically, Section 25.140(b)(2) requires
applicants to submit an interference analysis demonstrating that the proposed satellite is
compatible with authorized or proposed satellites. In instances where there are no authorized or
proposed satellites, the applicant may use the technical data of its own satellite.* Because there
are no authorized or proposed satellites within 2 degrees of ATCONTACT's proposed satellite,
ATCONTACT uses the technical parameters of its own satellite in its analysis and assumes the
adjacent satellite is operating at the 1 17" W.L. orbital location.

        To assist the Commission in processing this application, ATCONTACT should amend its
application to include the following information:

           1)       Explain why the calculations in Table 12 are based on ATCONTACT's proposed
                    satellite operating at 1 15" W.L. instead of the requested 1 15.2" W.L. orbital
                    I ocat ion ;
           2)       Explain why the space station transmit EIRP density in Tables 1 1 and 12 are
                    different;


'47 C.F.R. tj 25.140(b)(2). See also Public Notice, International Bureau, Satellite Division Information:
Clarification of 47 C.F.R. tj 25.140(b)(2), Space Station Application Interference Analysis, 19 FCC Rcd
10652 (Int'l Bur. 2004) (Clarzfication Public Notice).

    Clarification Public Notice.


        3)      Explain why the earth station receive system noise temperature in Tables 11 and
                12 are different;
        4)      Explain why the uplink earth station transmit EIRP density in Tables 11 and 12
                are different;
        5)      After making corrections to Tables 11 and 12, state whether the I,, IJN,, and
                uplinlddownlink degradation values, when recalculated in Table 12, still offer the
                positive link margin needed to prove successful operation can occur in a two
                degree environment.

         In amending this application, please take the appropriate steps to assure that the
application is accurate and complete.

         ATCONTACT’s response must be filed with the Commission’s Secretary within 15 days
of the date of this letter, with a courtesy copy to Kal Krautkramer of my staff. Failure to respond
by this date will result in dismissal of this application. Please contact Kal at (202) 41 8-1335 if
you have any questions.


                                                  Sincerely,



                                                  Robert G. Nelson
                                                  Chief, Satellite Division
                                                  International Bureau




cc: Mr. David M. Drucker
    Manager, ATCONTACT Communications, LLC




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Document Created: 2008-04-21 15:54:07
Document Modified: 2008-04-21 15:54:07

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