Attachment Supplement

Supplement

SUPPLEMENT submitted by AvL - Technologies, Inc.

Supplement

2004-05-14

This document pretains to SES-LIC-20030910-01236 for License on a Satellite Earth Station filing.

IBFS_SESLIC2003091001236_374236

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VIA HAND DELIVERY

May 13,2004.
                                                              w            CElVED

Marlene H. Dortch, Secretary                                   rb~cMl iib *(, R , nltciYS
                                                                                  ~       COMMI~Q~
                                                                    ‘JFFILk L’ Hi bt(,RETMy
Federal Communications Commission                                               3




Office of the Secretary
c/o Natek, Inc.
236 Massachusetts Avenue, N.E.
Suite 110
Washington, DC 20002

Re:      SWE-DISH Satellite Communications, Inc.
         Earth Station Application, FCC File No. SES-AMD-20040116-00057,
         Amendinp FCC File No. SES-LIC-20030910-01236

Dear Sir or Madam:

      Pursuant to Section 25.154 of the Commission’s Rules, and FCC Public Notice No.
SES-00595, attached please find an original and (5) five copies of the Comments of Avl
Technologies, Inc, on the Amended Application of SWE-DISH Satellite Communications
Systems, Inc. a subsidiary of SWE-DISH Satellite Systems AB, of Sweden.


                                                     Best regards,

                                                          ~ L @ L c h I !K          LK\rn2
                                                     William K. Coulter

Enclosures


                          AvL TECHNOLOGIES
             130 Roberts St. Asheville, NC 28801   ph 828.250.9950    fx 828.250.9938


May 13,2004
                                                   Y




Marlene H. Dortch, Secretary
Federal Communications Commission
Office of the Secretary
c/o Natek, Inc.
236 Massachusetts Avenue, N.E.
Suite 110
Washington, DC 20002

       Re:      SWE-DISH Satellite Communications, Inc.
                Earth Station Application, FCC File No. SES-AMD-20040116-00057,
                amendinq FCC File No. SES-LIC-20030910-01236

Dear Ms. Dortch:

              AvL-Technologies, Inc. (‘“AvL”) herein provides the following Supplemental
Comments in response to the Commission’s Public Notice Report No. SES 00595,
dated April 14, 2004, with respect to the above-referenced supplemented earth station
application of SWE-DISH Satellite Communications, Inc. (SWE-DISH”) (“Application”).‘

               In the Supplement to Record, of January 12,2004, SWE-DISH enclosed,
for the record, additional information that signifies that they now recognize the FCC’s
technical requirements for 2” satellite spacing and that the FCC’s rules and regulations
are more stringent than that of other governing bodies, therefore, requiring new and
different technical performance specifications than originally considered by SWE-DISH
when designing their IPT Suitcase antenna. The addition of new affidavits by SWE-
DISH from its space segment providers and its adjacent space segment provider (the
“Coordination Letters”), indicating that, “with the submission of acceptable transmission
plans”, these providers do not believe that the proposed operations by SWE-DISH
would result in unacceptable interference into their specific satellites, is an indication of
this recognition. Based on this additional information submitted, AvL does not oppose
issuing a “non-conforming antenna license” to SWE-DISH for the single “IPT Satellite

1
       Opposition and Response of SWE-DISH Satellite Communications, Inc., FCC File No.
       SES-LIC-20030910-01236 (Nov. 6,2003)(“Oppositiony’). Tripoint filed Comments to
       the Application on October 24,2003. See Comments of Tripoint, FCC File No, SES-
       LIC-20030910-01236 (Oct. 24,2003)(“Tripoint Comments”).
      AvL notes that the Public Notice No. SES-0059 incorrectly notes “ALSAT” as an
      intended “Point” of communications, as this is not supported by the Application or
      Amendment, and is subject to a separate Petition, AvL defers to the prior Petition and
      incorporates it herein by reference.


Terminal Antenna” and the specifically identified satellites for which affidavits have been
submitted and described in its Application, based on the conditions noted below.

Prior to addressing the specific conditions, AvL would like to address again, for the
record, its generic concerns already a matter of record in this amended file, amplified by
the Coordination Letters. AvL would like to note that these concerns are not directly
toward SWE-DISH but rather toward an industry recognition of the potential increase in
satellite commerce using smaller than 1.2M antennas. AvL has an interest in promoting
this potential, but in doing so without increasing satellite interference levels or incidents
because of these smaller than 1.2M antennas. AvL Technologies does not oppose
issuing a license for quantity one IPT Satellite Antenna System to Swe-Dish for
specifically coordinated satellites, as noted above, because of technical reasons if:


      I ) The unit used in the USA meets 29-251ogO for 14.0-14.5 GHz, as required by the
          FCC, as opposed to units produced, used and sold by SWE-DISH elsewhere
          under the IPT identification that only meet 32-291090.

      2) The major axis is aligned with the orbital arc, as required by the FCC, for USA
         satellite antenna manufacturers of similar elliptical shaped antennas. We note
         the existing FCC requirements of license SES-MOD-20010502-00844 paragraph
         2482 as appropriate.

      3) Link budgets approved by the satellite operators, and forming the basis of
         Affidavits, use the 38.4dBi gain at 14.25 GHz as stated in their application.

      4) The transmit power input to the antenna flange never exceeds -14dBw/4kHz, as
         allowed by the FCC.

Because the IPT Suitcase units can be operated without tilting the case for major axis
alignment with the orbital arc and excessive power is built-in that can greatly exceed the
-14dBw/4kHz, AvL recommends that a trained technician, of similar experience as
required by the FCC for installation of fixed earth station antennas of similar aperture
size of elliptical shape, be required to operate the IPT Suitcase until and unless
automatic safeguards can be implemented to avoid accidental adjacent satellite
interference which will be detrimental to the interests of all parties attempting to address
this important market. .




da es L. Oliver
Zident

cc:      Maury J. Mechanick, White & Case, LLP (Counsel to SWE-DISH)
         William K. Coulter, (Counsel to AvL)
         Robert Mansbach (Counsel to Intelsat)
         Joe Godles (Counsel to PanAmSat)
         Marvin Shoemake (Tripoint Global)


                                  CERTIFICATE OF SERVICE

        I, Christine L. Zepka, hereby certify that on this 14th day of May 2004, a true and correct
copy of the foregoing “AvL Technologies Supplemental Comments” was sent via first class mail
to the following parties:


Maury J. Mechanick*
Counsel to SWE-DISH
White & Case
601 Thirteenth Street, N.W.
Suite 600 South
Washington, D.C. 20005


Robert Mansbach
Counsel to Intelsat
Intelsat Global Service Corporation
3400 International Drive, N.W.
Washington, DC 20036


Joe Godles
Counsel to PanAmSat
Goldber Godles, Wiener & Wright
        8.
1229 19‘ Street, N.W.
Washington, DC 20036


Marvin Shoemake
Executive Vice President
TriPoint Global
4825 River Green Parkway                             Christine L. Zepka     8
Duluth, GA 30096




* via Hand Delivery




WASHMGTON 380488~1



Document Created: 2004-05-25 10:11:44
Document Modified: 2004-05-25 10:11:44

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