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

TIGHE PATTON ARMSTRONG TEASDALE, PLLC ATTORNEYS AT LAW 1747 PENNSYLVANIA AVENUE, N.W. Third Floor WASHINGTON, DC 20006-4604 T E L E P H O N E (202)4 5 4 - 2 8 0 0 FACSIMILE 1202) 4 5 4 - 2 8 0 5 www.tighepatton.com 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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