Attachment KA313

This document pretains to SES-MOD-20020919-01633 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2002091901633_289009

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 ~~~~~~~p~~~~~ Tn the Matter of TELENOR SATELLITE, Application to Modify Earth Station Authority ) File No. SES-MOD-20020919-01633 In the Domestic Fixed-Satellite Service ) KA313 t 1 COMMENTS OF PANAMSAT CORPORATION PanArnSat Corporation (“PanAmSat”), by its attorneys, hereby comments on the above-referenced modification application (“Application”) of Telenor Satellite, Inc. (“Telenor” or “Applicant”). For reasons that are discussed below, it is not possible to evaluate properly, based on the information that Telenor has provided, whether Telenor’s proposed operations could interfere with adjacent PanAmSat satellites. The Commission, therefore, should require Telenor to clarify matters, and should give PanAmSat an additional opportunity to comment, before acting on Telenor’s application. D ISCUSSION Among other things, Telenor is seeking to add ALSAT as a point of communication and to use additional emissions. It is unclear, however, which emissions are associated with ALSAT and which are associated with Inmarsat satellites. As a result, one cannot determine which C-band emissions, if any, Telenor is proposing to use to communicate with Inmarsat 2 at 98 W.L., which is one degree from PanAmSat’s Galaxy VI at 99” W.L. and three degrees from PanAmSat’s Galaxy III-C at 95” W.L. PanAmSat operates C-band payloads on both satellites.

2 Telenor’s proposed C-band transmissions include TTK and non-TT&C carriers. If Telenor intends to operate non-TT&C C-band carriers at 98 W.L., it is a virtual certainty that those carriers will interfere With’PanAmSat’s adjacent satellite operations. Even if Telenor’s C-band plans at 98 W.L. were limited to TTK transmissions, moreover, at a minimum those transmissions would have to be coordinated with PanAmSat to avoid objectionable interference. Accordingly, Telenor should be required to revise its applications to provide information clearly identifying the relevant carriers and associated satellites. Based on the additional information Telenor provides, it may be necessary to condition any grant on successful coordination with PanAmSat. C ONCLUSION For the foregoing reasons, the Commission should require Telenor to clarify what it is requesting, and give PanAmSat an additional opportunity to comment, prior to action on the Application. Respectfully submitted, GOLDBERG, GODLES, WIENER & WRIGHT 1229 Nineteenth Street, N.W. Washington, D.C. 20036 (202) 429-4900 Its Attornevs November 1,2002

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing was sent by first- class mail, postage prepaid, this 1st day of November, 2002, to the following: Telenor Satellite, Inc. Attention: Bruce A Henoch 6560 Rock Spring Drive Bethesda, MD 20817-1145


Document Created: 2002-11-06 14:49:21
Document Modified: 2002-11-06 14:49:21
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