Attachment application mar 27 1

This document pretains to SAT-STA-19960405-00051 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA1996040500051_1157592

FEDERAL COMMUNICATIONS COMMISSION Approved by OMB f S 3060—0589 ¥CC REMITRMNCE ADVICE Expires 2/28/97 pagE no. _1 or _1 (RESERVED) a C}MELLON MAR 28 1996 Aitcd "~ .begencen. . apg.—03—006 f (Read instructions carefully BEFORE proceeding.) PAYOR INFORMATION (2) 0C ACCOUNT NUMBER Did you have a number prior to this? Enter it. (2) TOTAL AMOUNT PAID (dollars and cents) tPlif :J i1°1@ T‘ ("iia js1 | 1 1 |I 1 J | 1 1| | |s 5150 (3) BAYOR NAME (If paying by credit card, enter name exactly as it appears on your card) * l AT&T Corp. K886 1.3 4; (4) STREET ADDRESS LINE NO. 1 HMHG—A 1904 295 North Maple Avenue (5) STREET ADDRESS LINE NO. 2 Sateilite Policy Branch intemational Bureau (6) CITY ‘ (7) STATE (8) ZIP CODE Basking Ridge NJ 07920 (9) DAYTIME TELEPHONE NUMBER (Include area code) (10) COUNTRY CODE (if not U.S.A.) 908 ITEM #1 INFORMATION (11A) NAME OF APPLICANT, LICENSEE, REGULATEE, OR DEBTOR | FCC USE ONLY (12A) FCC CALL SIGN/OTHER ID (13A) ZIP CODE (1.4A) PAYMENT TYPE CODE (15A) QUANTITY (16A) FEE DUEFOR KS—6 [— m%fim CODE 1081—DSS—PL/A—80 C R Y $ 575.00 (17A) FCC CODE 1 (18A) FCC CODE / 2 7 M fi% g é (19A) ADDRESS LINE NO. 1 (20A) ADDRESS LINE NO. 2) (21A) CITY/STATE OR COUNTRY CODE ITEM #2 INFORMATION (11B) NAME OF APPLICANT, LICENSEE, REGULATEE, OR DEBTOR FCC USE ONLY (12B) FCC CALL SIGN/OTHER ID (13B) ZIP CODE (14B) PAYMENT TYPE CODE (16B) QUANTITY (IGB) FEE DUE FOR PAYMENT TYPE CODE IN BLOCK 14 $ (17B) FCC CODE 1 (18B) FCC CODE 2 (19B, ADDRESS LINE NO. 1 (20B) ADDRESS LINE NO. 2 (21B) CITY/STATE OR COUNTRY CODE hca>prr caro payvent wrorvatonRon (22) MASTERCARD/VISA ACCOUNT NUMBER: []] Mastercard EXPIRATION DATE: D vi ‘ Month Year 182 AUTHORIZED SIGNATURE DATE (23) Ihereby authorize the FCC to charge my VISA or Mastercard PE for the service(s)/authorization(s) herein describe. Sea nhlin hnrdan estimate on reverse FCC FORM 159

S Arst R. Victor Bernstein Room 325982 Senior Attornay 295 North Maple Avenue Basking Ridge, NJ 07920 908 221—5712 March 27, 1996 BY_HAND Federal Communications Commission c/o Mellon Bank Three Mellon Bank Center 525 William Penn Way 27th Floor, Room 153—2713 Pittsburgh, PA 15219 (Attention: Wholesale Lockbox Shift Supervisor) Re: TELSTAR 302 Domestic Fixed—Satellite Service: Application for Special Temporary Authority Gentlemen: Enclosed for filing are the original and four (4) copies of AT&T‘s Application for Special Temporary Authority to allow the TELSTAR 302 Satellite to continue to be operated in an inclined orbit mode. FCC Form 159 and a check to cover the $575 filing fee are enclosed. The actual filing address is: Federal Communications Commission Satellite and Radio Communication Division P.O. Box 358160 Pittsburgh, PA 15251—5160 Recycled Paper

Please file stamp the extra copy of the Application and return it to the party hand delivering the filing. Sincerely, Lbecte /5_%7@/@(’;% : R. Victor Bernstein ( Enclosures ce: William F. Caton, Acting Secretary Federal Communications Commission 1919 M Street, N.W. Washington, D.C. 20554 FCC Laurel, Maryland Field Office

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 reeimErtcon MAR 28 1996 In the Matter of AT&T CORP. Application for Special Temporary Authority File No. to Allow the TELSTAR 302 Domestic—Fixed Satellite to Continue to Operate in an Inclined Orbit Mode AT&T APPLICATION FOR SPECIAL TEMPORARY AUTHORITY AT&T Corp. ("AT&T"), pursuant to Sections 214, 308 and 309 of the Communications Act of 1934, as amended, 47 U.S.C. §§ 214, 308 and 309, hereby requests the Commission to grant further Special Temporary Authority ("STA") to allow AT&T to continue to operate the TELSTAR 302 domestic— fixed satellite in an inclined orbit mode for an additional period of six months.* AT&T‘s initial STA for TELSTAR 302 expired September 30, 1995." AT&T then filed an STA for a further 180 day period in which to operate TELSTAR 302 on The Commission has previously granted STAs to AT&T and other carriers who have requested permission to operate their satellites in an inclined orbit mode and beyond their original license term. See, e.q., Comsat General Corporation, 4 FCC Red. 3820, 3821 ({{ 8—9) (1989) ("Comsat Maneuver Order"). See American Telephone and Telegraph Company, 10 FCC Red. 3803 (§ 6) (1995).

August 25, 1995, and, now, authority to continue to operate for an additional six months is required beginning March 29, 1996 . TELSTAR 302 was launched on August 30, 1984 and, after in—orbit testing, commenced in—service operation during October 1984.3 Because TELSTAR 302 has been operational for more than a decade, its on—board stationkeeping fuel capacity is virtually depleted. However, with inclined orbit operation, AT&T currently estimates that the in—orbit life of TELSTAR 302 could be extended until January 1, 1998. Since January 1, 1995, the satellite has been successfully operating in inclined orbit at 85° W.L. Grant of this application to allow TELSTAR 302 to continue inclined orbit operation will permit AT&T to serve customers whose needs would otherwise not be met. AT&T therefore requests the Commission to extend the current STA for TELSTAR 302 to permit its continued operation without north—south stationkeeping, so as to conserve fuel and prolong its in—orbit life.* AT&T was granted authority to construct, launch and operate TELSTAR 302 in American Telephone and Telegraph Company, 84 F.C.C.2d 547 (1981). The prescribed east—west stationkeeping of +.05° will remain unchanged.

Operation of TELSTAR 302 in an inclined orbit mode will serve the public interest in that it will permit AT&T to use the satellite to meet customer needs. Because of the acknowledged industry—wide shortage of C—band transponders,5 continued use of TELSTAR 302 remains essential. TELSTAR 402R is already fully booked, primarily with full—time services, and there is little part—time or occasional use capacity available in the United States. TELSTAR 302 will help alleviate this situation, because AT&T will be able to continue to use the satellite to provide service to those SKYNET® Satellite Service customers who employ tracking on their uplink antennas or whose telecommunications needs require only short satellite feeds, such as part—time video users. Operation of TELSTAR 302 in an inclined orbit mode at its current 85° W.L. location will not adversely affect the operations of adjacent satellites. As the Commission has acknowledged, the International Telecommunication Union ("ITU") "has determined that the use of an inclined geosynchronous satellite orbit does not affect a satellite‘s See, e.g., Letter, dated March 9, 1995, from S. B. Harris, Chief, International Bureau, FCC, to M. J. McKeever, Director — SKYNET®, AT&T Corp.; "Satellite Roundtable Initiatives Launched," Report No. IN 95—8, released March 13, 1995; see also T. Foley, "The U.S. Capacity Shortage: The Realities of Supply and Demand Set In," Via Satellite, August 1995, p. 16.

interference potential."6 AT&T notes that, in addition to TELSTAR 302, a number of domestic satellites are currently operating in an inclined orbit mode without causing adverse impacts on adjacent spacecraft. For example, GSTAR III at 932 W.L. is a satellite currently operating in an inclined orbit mode without adverse effects.‘ AT&T‘s TELSTAR 301 also operated in inclined orbit, and its TELSTAR 303 has been operating in inclined orbit, both without problems.8 Hughes Communications Galaxy, Inc., 9 FCC Red. 2155 ({ 4) (1994) ("Hughes Order"); see also Streamlining the Commission‘s Rules and Requlations for Satellite Application and Licensing Procedures, IB Docket No. 95— 117, Notice of Proposed Rulemaking, FCC 95—285, released August 11, 1995, € 15 ("Interference has not proven to be a problem"). For TELSTAR 302, cessation of north—south stationkeeping results in an orbit inclination increase of approximate 0.77 degrees per year or a total of 2.31 degrees until January 1, 1998. Thus, the operation of TELSTAR 302 in an inclined orbit mode will be well within the previous five—degree orbit inclination recommended by the ITU radio reqgulations for a geostationary satellite, although that limitation has now been lifted. See Hughes Order, 9 FCC Rced. 2155 (¢ 3); see also Comsat Maneuver Order, 4 FCC Red. at 3821 (([ 6); see also Possible Use by Space Stations in the Fixed Satellite Service of Orbits slightly Inclined With Respect to the Geostationary— Satellite Orbit in Bands Shared With the Fixed Service, SF 1008, dated September 30, 1993. 7 GTE Spacenet Corporation, 5 FCC Red. 1182 (€ 5) (1990) ("there have been no complaints from other satellite operators regarding the receipt of unacceptable levels of interference from this satellite"). American Telephone and Telegraph Company, 8 FCC Red. 8741 (1993), and AT&T Corp. File No. 55—SAT—STA—95.

—-5‘ WHEREFORE, AT&T requests that the Commission grant ATLT a further STA to continue to operate TELSTAR 302 in an inclined orbit mode for a period of six months. Grant of this application is in the public intef&dt>ih that it will enable AT&T to meet satellita customers‘ neeés, will not result in adverse interference to the operations of adjacent satellites, and will make available C—band transponder capacity during the current industry—wide capacity shortage. AT&T roquests expaditious action on this application bacausgse authority is requizred for this S5TA beginning March 29, 1996. Respectfully subnmitted, ATLT CORP. ,_ Ne é\\/;g Terry, Sate"lit Engineering and Operations Director — SKYNFT® satallita Services 900 Routes 202/206 Roon 2A118 Bedminster, Neéew Jersey O7921 (9PD8]) 234~7496 March 27, 1996


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