Attachment Comment

Comment

COMMENT submitted by PANAMSAT CORPORATION

Sola Comments

2003-06-20

This document pretains to SES-LIC-20030515-00670 for License on a Satellite Earth Station filing.

IBFS_SESLIC2003051500670_322402

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SOLA COMMUNICATIONS INC. ) ) Application for Earth Station Authority ) File No. SES-LIC-20030515-00670 In the Domestic Fixed-Satellite Service ) E030114 ) COMMENTS OF PANAMSAT CORPORATION PanAmSat Corporation (“PanAmSat”), by its attorneys, hereby comments on the above-referenced application (“Application”) of Sola Communications Inc. (”Sola”). PanAmSat is filing these comments out of an abundance of caution based on a possible conflict between the points of communication requested in Sola’s Application and the points of communication shown in the public notice accepting the Application for filing. Assuming that the authorized points of communication for Sola’s proposed earth station are limited to AMC-2, however, PanAmSat has no objection to the Application. DISCUSSION Sola seeks a license to operate, inter alia, a 2.4-meter “Remote 1” C-band transmit/receive fixed-satellite service (“FSS”) earth station.1 Sola proposes to use this 1 Sola proposes to use a Channel Master 2.4 meter antenna for its “Remote 1” station. Application at FCC Form 312, Schedule B ("Remote 1") (Items E30-E32). Although not the subject of these comments, Sola also seeks authority to operate an Andrew Corporation, LNR ESA24 4.5-meter “Hub Site” C-band transmit/receive FSS antenna. Application at Schedule B ("Hub Site") (Items E30-E32). The above- referenced Application includes two FCC Form 312 Schedule B forms, one pertaining to the “Hub Site” antenna and the other the “Remote 1” site antenna.

2 earth station as part of a “C-SAT Network” facility in order to provide digital voice, data and fax services to oil platforms located throughout the Gulf of Mexico.2 Sola’s Application appears to indicate that the proposed earth station will communicate only with AMC-2 at 85° W.L. The public notice accepting the Application for filing, however, makes no mention of AMC-2.3 Rather, it lists “Other” as the proposed point(s) of communication, and does not specify an orbital location(s). If Sola’s proposed earth station were to be licensed on an ALSAT basis or were authorized to communicate with satellites adjacent to any of PanAmSat’s C-band satellites, then PanAmSat would have an objection to the Application. PanAmSat’s analysis indicates that, in these circumstances, its adjacent satellites would face a significant risk of harmful interference unless Sola could demonstrate an ability to align the “Remote 1” antenna to within 0.5 degrees of the intended satellite and otherwise to comply with the Commission’s two-degree spacing requirements.4 Accordingly, if Sola is seeking authority to communicate with satellites other than AMC-2, PanAmSat should be given an opportunity to supplement these comments with a technical showing. 2 Application at FCC Form 312, Schedule A (Items 43). 3 Public Notice, Report No. SES- 00499, May 21, 2003 (“Public Notice). 4 See 47 C.F.R. § 25.209 and 47 C.F.R. § 25.212.

3 CONCLUSION For the foregoing reasons, PanAmSat has no objection to Sola’s Application, so long as the authorized points of communication are limited to AMC-2 at 85° W.L. Respectfully submitted, PANAMSAT CORPORATION By: /s/ Joseph A. Godles Joseph A. Godles Michael A. McCoin GOLDBERG, GODLES, WIENER & WRIGHT 1229 Nineteenth Street, N.W. Washington, D.C. 20036 (202) 429-4900 Its Attorneys June 20, 2003

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was sent by first- class mail, postage prepaid, this 20th day of June 2003 to the following: Sola Communications Inc. Attention: Pat Meche 124 Toledo Drive Lafayette, LA 70506 Ryan N. Terry


Document Created: 2003-06-23 11:25:27
Document Modified: 2003-06-23 11:25:27
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