Attachment Swe-dish Comments

Swe-dish Comments

LETTER submitted by Swe-dish Satellite

Informal Comments on the Application of The Boeing Company

2008-07-07

This document pretains to SES-LIC-20080527-00678 for License on a Satellite Earth Station filing.

IBFS_SESLIC2008052700678_653560

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     PATTON
          ARMSTRONG
                  TEASDALE,
                         PLLC
                                                      ATTORNEYS AT LAW

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STEPHEN L . G O O D M A N
WRITER     'S DIRECTD I A L :(202) 454-2851
E MA I L : sgoodman@tighepatton.com




                                                            July 7,2008


      Marlene H. Dortch
      Secretary
      Federal Communications Commission
      c/o Natek, Inc.
      236 Massachusetts Avenue, NE
      Suite 110
      Washington, DC 20002

             Re:            Informal Comments on the Application of The Boeing Company; Call Sign
                            E080128 -- File No. SES-LIC-20080527-00678

      Dear Ms. Dortch:

              SWE-DISH Satellite Systems, Inc. ("S WE-DISH'), pursuant to Section 25.154(b) of the
      Commission's Rules, 47 C.F.R. 0 25.154(b), submits these informal comments on the application
      recently filed by The Boeing Company ("Boeing").' In that application, Boeing seeks a license
      for an AvL .96 meter satellite earth terminal (Model 965 KCR) in a temporary fixed station class,
      communicating with all satellites authorized to operate in the United States ("ALSAT"). SWE-
      DISH is filing these comments because it is not clear that grant of the application as presently
      structured would be consistent with the Commission's Rules.

             In its application in response to Question E. 15, Boeing indicates that "the proposed
      antenna(s) comply with the antenna gain patterns specified in Section 25.209(a) and (b) as
      demonstrated by the manufacturer's qualification measurement." In contrast, the manufacturer of
      The Boeing Company's antenna - AvL Technologies - applied for a license a few years ago for
      what appears to be a similar, .96 Meter antenna.2 In that application, in response to Question
      I
            The Boeing Company application appeared on Public Notice on June 4,2008, Report No.
      SES-01038, June 4,2008.
      2
             AvL Technologies application, File No. SES-MOD-20040225-00277, Report No. SES-
      00593, April 7,2004. The Commission subsequently granted that application, subject to several


Marlene H. Dortch
Secretary
July 7,2008




E. 15, AvL Technologies indicated that the antenna was “non-conforming,” and included in its
application antenna radiation patterns and coordination affidavits from the potentially affected
adjacent satellite system operators. In addition, AvL Technologies sought authority to
communicate with specific satellites, rather than ALSAT.

        The Boeing Company application thus appears to differ in significant respects from the
previously-filed application submitted by the manufacturer of its satellite antenna. Under these
circumstances, SWE-Dish believes the Commission must determine whether The Boeing
Company needs to supplement its application with antenna patterns andor coordination
affidavits, before its application can be granted. Likewise, the Commission must determine
whether the ALSAT designation would be appropriate for the .96 Meter antenna designated in
the application. Finally, if the Commission determines that operations at a reduced power levels
are necessary to conform with the rules, any such power limits should be made an explicit part of
the license.



                                             Sincerely,




                                             Counsel for SWE-DISH Satellite Systems, Inc.


cc: Ron Center




conditions (including power levels reduced below the maximum permitted by the Commission’s
Rules). AvL Technologies, 19 FCC Rcd 22086 (2004).


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Document Created: 2008-07-14 11:24:52
Document Modified: 2008-07-14 11:24:52

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