Attachment comments june 18 199

comments june 18 199

COMMENT submitted by PanAmSat

comments

1996-06-18

This document pretains to SAT-STA-19960531-00076 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA1996053100076_1157591

RECEIVED LAW OFFICES GOLDBERG, GODLES, WIENER & WRIGHT JUN 1 8 1996 1229 NINETEENTH STREET, N.W. WASHINGTON, D.C. 20036 FEDERAL COMMUNICATIONS COMMISSION HENRY GoLpsera w(ggg?gfleoo JOSEPH A. GODLES TELECOPIER: JONATHAN L. WIENER (202) 429—4912 HENRIETTA WRIGHT MARY J. DENT DANIEL 5. GOLDBERG W. KENNETH FERREE THOMAS G. GHERARDI, P.C. COUNSEL June 18, 1996 DELIVERY Mr. William F. Caton Acting Secretary Federal Communications Commission 1919 M Street, N.W., Room 222 Washington, D.C. 20554 Re: Application of Columbia Communications Corporation For Special Temporary Authority to n TD atellite at 47° Dear Mr. Caton: PanAmSat Corporation ("PanAmSat"), by its attorneys, hereby submits these further comments with respect to the above—referenced request of Columbia Communications Corporation ("Columbia") for Special Temporary Authority ("STA”) to operate capacity on the NASA TDRS—6 spacecraft located at 47° W.L.. PanAmSat‘s initial submission regarding Columbia‘s STA indicated that, in light of the unusual technical configuration of the TDRS—6 satellite, PanAmSat has a number of technical concerns with Columbia‘s request.! PanAmSat also noted that representatives of PanAmSat and Columbia were planning to meet on June 14, 1996, in order to ascertain whether grant of the STA would impact adversely PanAmSat‘s existing operations via its PAS—1 satellite, located at 45° W.L..2 The June 14, 1996, meeting between the parties was productive, and PanAmSat is committed to continue to work with Columbia in an effort to coordinate the parties‘ respective operations. It appears, however, that unconditional grant of Columbia‘s STA request would result in harmful interference to those PanAmSat customers on PAS—1 that make use of frequencies which overlap with those Columbia seeks to use. Specifically, PanAmSat is concerned that analog transmissions via the TDRS—6 satellite 1 Letter from Daniel S. Goldberg, counsel to PanAmSat, to William F. Caton, Acting Secretary, dated June 7, 1996. 2 Id. PanAmSat‘s June 7, 1996, submission to the Commuission indicated that PanAmSat and Columbia were meeting on June 14, 1996, at PanAmSat‘s request. Following that submission, however, the undersigned learned that such meeting took place at Columbia‘s request.

Mr. William F. Caton June 18, 1996 Page 2 will interfere with narrowband digital VSAT transmissions via PAS—1 on certain common frequencies. PanAmSat understands that Columbia hopes to begin testing of the TDRS—6 satellite in the near term. After carefully reviewing the materials Columbia provided to PanAmSat at the June 14, 1996, meeting, PanAmSat has proposed to Columbia certain test parameters and procedures designed to mitigate the potential for interference to PAS—1 from testing of the TDRS—6 spacecraft. A copy of these parameters and procedures is attached hereto as Exhibit A. While PanAmSat supports commencement of testing of TDRS—6 — and, indeed, has worked closely with Columbia to ensure that such testing is meaningful and can be achieved without causing interference to other users — PanAmSat urges the Commission to condition grant of Columbia‘s STA request on compliance with the test procedures set forth in Exhibit A, hereto. PanAmSat also requests that the Commission make plain that, as is always the case with STAs, operations pursuant to an STA authorization are secondary in nature. Accordingly, in the event that Columbia‘s = transmissions on the TDRS—6 satellite cause harmful interference to PAS—1, Columbia must be required to take steps to resolve immediately such interference, including cessation of all operations upon notice from the Commission. incerely, 1/ Daniel S. Goldberg Attorney for PanAmSat Corporation Attachment cc: Mr. James L. Ball Mr. Thomas S. Tycz Mr. Alex C. Latker Ms. Julie A. Garcia Mr. David S. Keir GOLDBERG, GODLES, WIENER & WRIGHT

EXHIBIT A

€PanAmSat June 18, 1996 VIA FAX: 301—907—2420 Mr. Kenneth Gross Gencral Counsel and Chief Operating Officer Columbia Communications Corporation 7200 Wisconsin Avenue, Suite 701 Bethesda, Maryland 20814 Dear Ken: This letter serves as a follow—up to conversations you‘ve had with Mr. Dick Granger regarding the preliminary testing ofthe TDRS—6 Satellite at 47° W.L. I understand from Dick that you would like to test individual transponders by activating a saturated analog carrier from a Washington uplink at or near the center frequency of cach transponder. The primary purpose of your test is to verify the operational status of the satellite. PanAmSat is fully committed to working with you in conducting such tests. Based on the short notice, we were only able to map your proposed analog frequencies to the PAS—1 transponders and conduct a very limsted analysis of potential interference to our operating carriers. Based on this preliminary andlysis, we are concerned that the saturated analog carriers may cause interference into VSAT SCPC networks operating at or near five of your twelve proposed frequencies. These frequencies are as follows: 3723 MIIz, 3760 MHz, 3960 MHz, 4000 MHz, 4075 MHz Within plus or minus 6 MHz of each of these frequencies we are operating low level SCPC carriers in the northern portions of South America into 2.4 meter and 1.8 meter earth stations. Accordingly, a real potential for interference to these operational carriers exists with the transmission of saturated analog carriers. As an alternative to full power testing of these transponders, we would suggest a small modulated carrier with a 10 dB output backoff. We would be happy to supply suggested carrier frequencies. With respect to the other frequenciecs, we believe that your test should not affect our existing operations. I would, however, like to monitor through our facility in Atlanta your activation of these carriers. As you know we operate an extensive remote monitoring system and have visibility of our transponders in South America. Accordingly, if we are aware of the activation of specific signals, we will be able to correlate any interference in a real time mode. PanAmSat Corporation O# ‘VICK PLAZA » CC ~MCH, CONNECTECUT 06830 + USA — TELEPHONE 1/203/622/6664 « FAX 1/203/622709163

~enneth Gross June 18, 1996 Page 2 To this end, I would request that your operational personnel make contact with the following individual in Atlanta: Mr. Bill Prendergast — Manager, ETOC (Tel: 404—244—2300) A verbal procedure can be established between the two teleports so that the PAS—ETOC can observe the TDRSS carrier activations. In the event that we detect interference as a result of one of the transmissions on the seven frequencies, we will be in a better position to notify your operators to cease the test pending further analysis. I appreciate your invitation to support your operational tests and assure you that the technical personnel in Atlanta will help in any way possible. We obvicusly will need to meet to achieve a more specific coordination following your verification of the satellite‘s operational health. If you have any questions, please feel free to call. Senior Vice President Engineering and Operations co: Fred Landman Phil Rubin Dick Granger Don Bachelder Bill Prendergast Dan Goldberg

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing letter was sent by first—class mail, postage prepaid, this 18th day of June, 1996, to each of the following: David S. Keir Leventhal, Senter & Lerman Suite 600 2000 K Street, N.W. Washington, D.C. 20006—1809 kfimfi\mfl%\} /s / Dawn Hottinger Dawn Hottinger


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