Attachment 1991GTE Spacenet Com

This document pretains to SAT-A/O-19901107-00066 for Authority to Operate on a Satellite Space Stations filing.

IBFS_SATAO1990110700066_1081798

RECEIVED JUN 3 — 1991 FEDERAL COMMUNICATIONS COMMISSICN OFFICE OF THE SECRETARY Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of No w ho h Nh N N NNN MOTOROLA SATELLITE COMMUNICATIONS, INC. File Nos. 9—DSS—P—91(87) CSS—91—010 and ELLIPSAT CORPORATION Applications For L—Band Low Earth Orbit Satellite Systems To The Commission: Comments GTE Spacenet Corporation ("GTE Spacenet") hereby submits Comments on the above—captioned applications and respectfully states as follows: GTE Spacenet has been authorized by the Commission to carry three Radiodetermination Satellite Service ("RDSS") receive—only payloads aboard its SPACENET III and GSTAR III satellites."‘ These RDSS payloads enable the provision of RDSS service to the public on an interim basis until dedicated RDSS facilities are available." These payloads are authorized to receive earth—to—space transmissions from RDSS user terminals in the 1610—1626.5 MHz frequency band (L— Band), convert these signals to Ku—Band frequencies, and route them to a Ku—Band GTE Spacenet Corporation, Order and Authorization, Mimeo 5175; 1 FCC Red 1163 (1986); 4 FCC Red 8461 (1989). These RDSS payloads were initially constructed to meet the needs of a particular RDSS licensee who desired to use them as its interim RDSS system to begin immediate start—up RDSS service pending completion of its dedicated system. While this RDSS licensee no longer has a need for these facilities, the payloads remain available for other L—Band service providers (assuming the requisite FCC authority has been obtained) to provide similar RDSS—type service.

transponder for retransmission back to earth. Thus, GTE Spacenet, as the licensee of facilities authorized to operate at L—Band, is interested in the above—captioned applications. Both the Motorola and the Ellipsat applications seek authority to offer, inter alia, RDSS—type services from Low Earth Orbit (LEO) satellites that will operate in the 1610—1626.5 MHz frequency band. GTE Spacenet‘s Comments on these applications are limited solely to the issue of L—Band intersatellite licensee coordination. As with domestic—fixed satellites licensees, which are required to engage in intersatellite coordination‘ to avoid undue harmful interference and to ensure compatible operations for the provision of quality service to end— users, GTE Spacenet requests that the Commission impose similar coordination requirements on licensees authorized to operate facilities in the 1610—1626.5 MHz frequency bands. To this end, GTE Spacenet expects that Motorola, Ellipsat and any other licensee eventually authorized for operations at 1610—1626.5 MHz agree to coordinate with GTE Spacenet and/or any entity providing service via the RDSS payloads aboard GTE Spacenet‘s satellites, to ensure interference—free operations for A]] licensees operating in this band. GTE Spacenet‘s Comments herein are not intended to signal to the Commission that GTE Spacenet anticipates interference problems to its licensed L—Band payloads from any of the currently proposed LEO satellite systems. In fact, GTE Spacenet has reviewed in detail the CCIR document* of the Joint Interim Working Party to WARC—92 on sharing the 1.6 GHz uplink (i.e. 1610—1626.5 MHz) between LEO and RDSS systems and concluded that sharing does appear feasible based on the parameters specified in the document. — See e.g. 3 FCC Red 6972 (1988). 4 Corrigendem 1 to Document JIWP92/54—E 5 March 1991, CCIR Joint Interim Working Party WARC—92 Geneva, 4—15 March 19910.

To the extent, however, that the parameters which formed the basis of the CCIR sharing proposal are not binding on any RDSS or LEO licensee unless specifically made part of their license terms, GTE Spacenet requests tfiat, similar to domestic—fixed satellite licensees, any licensee authorized to operate in the 1610—1626.5 frequency band be required to coordinate with other licensees authorized to operate facilities in that band, including GTE Spacenet‘s RDSS payloads, to the extent necessary to prevent harmful interference to users of those facilities. Respectfully submitted, GTE SPACENET CORPORATION \j:zw@,}mwé[ ’/W% }ajfl Terri B. Natoli Troy D. EJlington Regulatory and Industry Vice Presfdent, EngineerAng Relations Manager and Ogjerations 1700 Old Meadow Road 1700 014 Meadow Road McLean, Virginia 22102 Mclean, Virginia 22102 (703) 848—1515 (703) 848—1400 June 3, 1991

CERTIFICATE OF SERVICE I, Karen M. Cameron, hereby certify that copies of the foregoing "Comments" were served by first—class mail, postage prepaid, this 3rd day of June, 1991, to the following: Leonard S. Kolsky Vice President and Director of Regulatory Affairs Motorola, Inc. 1350 I Street, N.W. Washington, D.C. 20005 Philip L. Malet Alfred M. Mamlet Steptoe & Johnson 1330 Connecticut Ave., N.W. Washington, D.C. 20036 Attorneys for Motorola Satellite Communications, Inc. Robert Perry Ellipsat Corporation 2420 K Street, N.W. Washington, D.C. 20037 Jill Abeshouse Stern, Esq. Miller and Holbrooke 1225 19th Street, N.W. Washington, D.C. 20036 Attorney for Ellipsat Corporation Arruin _ (Armeior Karen M. Cameron

RECEINED LLS JUN 3 — FEDERAL COMMUNICATIONS COMMISSION OFFICE OF THE SECRETARY GTE Spacenet Corporation 1700 Old Meadow Road Tern B. Natoli McLean. VA 22102 Industry Relations Manager (703) 848—1515 June 3, 1991 Donna R. Searcy Secretary Federal Communications Commission 1919 M Street, N.W., Room 222 Washington, D.C. 20554 Re: Applications of Motorola Satellite Communications, Inc. for L—Band Low Earth Orbit Satellite Systems, File Nos. 9—DSS—P—91(87)/CSS—91—010 and Ellipsat Corporation for L—Band Low Earth Orbit Satellite Systems, File No. 11—DSS—P—91(6) Dear Ms. Searcy: Transmitted herewith for filing on behalf of GTE Spacenet Corporation is an original and required copies of its Comments in the above—captioned proceeding. Should any questions arise, please contact the undersigned. Sincerely, /~ & ,j) //(L/ oobu Terr1 B Natoli TBN/kme Enclosures A part of GTE Corporation


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Document Modified: 2015-03-26 11:22:25
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