Response to IB lette

LETTER submitted by Skynet Satellite Corporation

Response to IB letter of 06-29-16

2016-07-01

This document pretains to SAT-MOD-20160513-00050 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2016051300050_1141611

LAW OFFICES GOLDBERG, GODLES, WIENER & WRIGHT LLP 1229 NINETEENTH STREET, N.W. WASHINGTON, D.C. 20036-2413 HENRY GOLDBERG (202) 429-4900 JOSEPH A. GODLES TELECOPIER: JONATHAN L. WIENER (202) 429-4912 DEVENDRA (“DAVE”) KUMAR e-mail: ________ general@g2w2.com HENRIETTA WRIGHT website: www.g2w2.com THOMAS G. GHERARDI, P.C. COUNSEL ________ THOMAS S. TYCZ* SENIOR POLICY ADVISOR *NOT AN ATTORNEY July 1, 2016 FILED ELECTRONICALLY Mr. Jose P. Albuquerque Chief, Satellite Division International Bureau Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Skynet Satellite Corporation FCC File No. SAT-MOD-20160513-00050 Call Sign S2462 Dear Mr. Albuquerque: This letter responds to the questions set forth in your letter of June 29, 2016 in the above referenced matter relating to the relocation of the Telstar 12 satellite (“T12”) from the 15° W.L. orbital location to the 109.2° W.L. orbital location. The responses set forth below are numbered to correspond with the questions as enumerated in your letter: 1. If Skynet elects to steer the beams on T12 to a position different from the nominal positions indicated in Attachment A, telemetry, tracking, and control (“TT&C”) operations may have to be transferred to a teleport other than Mt. Jackson that is closer to the center of T12’s coverage area. TT&C operations would be established at the new teleport prior to the beams being steered, and Skynet would ensure that communication with the spacecraft is maintained at all times. Skynet does not have a specific teleport in mind for this purpose, but will notify the Commission, in accordance with Sections 25.172(a)(2)-(3) of the rules, if one is selected. 2. Skynet initially will be using Configuration 1, as identified in Attachment A. Skynet would like the flexibility, either upon notice to the Commission or (if

-2- required) upon additional request, to switch to the alternate configuration identified in the application (Configuration 2). 3. Skynet has considerable experience in the operation of satellites in adjacent stationkeeping boxes, both with other operators and within the Skynet/Telesat Canada fleet, in order to ensure adequate separation and minimize risk of physical collision. With other operators, Skynet coordinates stationkeeping strategies and exchanges orbit ephemerides on a regular basis to ensure safe separation between the satellites. These procedures would be followed with ViaSat. Skynet already has experience successfully using these procedures to coordinate stationkeeping of satellites operated by different parties that have boxes centered as close as 0.1 degrees apart. 4. In Configuration 1, no waiver of NG52 is required, because the downlink bands 10.95-11.2 GHz and 11.45-11.7 GHz will be used in the United States only for international links, i.e., for service between the United States and other countries. In Configuration 2, however, Skynet believes a waiver of NG52 is required, because there will be transmissions that are uplinked from remote terminals in the United States and are downlinked to a single gateway earth station in the United States in the 10.95-11.2 GHz and 11.45-11.7 GHz bands. It is not possible to downlink these signals to the single U.S. gateway in the conventional Ku-band; Beam B does not have conventional Ku band capability on the downlink. Please contact me if I can be of further assistance. Sincerely, Joseph A. Godles Attorney for Skynet Satellite Corporation cc (via email): Steve Duall Alyssa Roberts


Document Created: 2016-07-01 09:55:30
Document Modified: 2016-07-01 09:55:30
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