Reply to Intelsat Op

REPLY submitted by New Skies Satellites B.V.

Reply to Opposition to Petition to Deny

2009-03-13

This document pretains to SAT-MOD-20081124-00218 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008112400218_700414

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 __________________________________________ ) Application of ) ) INTELSAT NORTH AMERICA LLC ) File No. SAT-MOD-20081124-00218 ) (S2401) To Modify Authorization to Operate the ) Intelsat 706 Satellite at 54.85° E.L. ) __________________________________________) REPLY TO OPPOSITION TO PETITION TO DENY OR CONDITION New Skies Satellites B.V. (“New Skies”) hereby replies to the Opposition filed by Intelsat North America LLC (“Intelsat”) with regard to its application for authority to operate the Intelsat 706 satellite at the 54.85° E.L. orbital location.1 New Skies welcomes Intelsat’s clarification that it will operate Intelsat 706 under the same non- interference and other conditions imposed on the operation of Intelsat 702 at the same location.2 This is a very significant and positive step, although New Skies notes that this matter would have been more straightforward if Intelsat had clarified these conditions in its original application. While New Skies remains concerned about the potential for interference into its operations at 57° E.L. from Intelsat’s operations nearby, it believes that an enforceable set of non-interference conditions on Intelsat’s license to operate Intelsat 706 at 54.85° E.L. would result in a workable regime in this very unusual set of circumstances. In 1 See Opposition to Petition to Deny or Condition, IBFS File No. SAT-MOD-20081124-00218 (filed Mar. 6, 2009) (“Opposition”). 2 See id. at 1, 3.

particular, New Skies is reassured by the fact that the indicative power density levels proffered by Intelsat3 (while insufficient in New Skies’ estimation to protect the use of its ITU filings at 57° E.L.) will be subject to Intelsat’s overriding obligation to operate on a non-interference basis and, thus, subject to reductions in power below those levels in the event New Skies suffers harmful interference. As a result, given Intelsat’s willingness to address interference events immediately4 and the Commission’s ability to enforce the non-interference condition, New Skies believes that its existing and future operations at 57° E.L. should be adequately protected. Accordingly, New Skies does not object to the grant of Intelsat’s application to operate Intelsat 706 at 54.85° E.L. under the same conditions as those imposed on the operation of Intelsat 702 at the same location, as noted above. Respectfully submitted, NEW SKIES SATELLITES B.V. By: __/s/______________________________ William M. Wiltshire Joslyn Read HARRIS, WILTSHIRE & GRANNIS LLP Vice President, Regulatory Affairs 1200 Eighteenth Street, NW SES NEW SKIES Washington DC 20036 2001 L Street, NW (202) 730-1300 Suite 800 Washington, DC 20036 Counsel for New Skies Satellites B.V. 202-478-7100 Dated: March 13, 2009 3 Id. at 5-6. 4 Intelsat states that it is “willing immediately to respond” should New Skies bring any interference concerns directly to its attention. Id. at 7.

CERTIFICATE OF SERVICE I hereby certify that, on this 13th day of March, 2009, a copy of the foregoing Reply was served by first class U.S. mail, postage prepaid, upon: Susan H. Crandall Assistant General Counsel Intelsat Corporation 3400 International Drive, N.W. Washington, DC 20008 Bert W. Rein Jennifer D. Hindin Carl R. Frank Wiley Rein & Fielding LLP 1776 K Street, N.W. Washington, DC 20006 __/s/________________________ Alex Reynolds


Document Created: 2009-03-13 15:39:46
Document Modified: 2009-03-13 15:39:46
© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC