Attachment comments

comments

COMMENT submitted by PanAmSat

comments

2003-09-17

This document pretains to SAT-AMD-20030730-00149 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2003073000149_412735

                                                                              ORIGINAL
                                  Before the
                    FEDERAL COMMUNICATIONS ComMISSION
                                    Washington, D.C. 20554                     RECEIVED

  Salellite Prrision                                   Int Bureau                 e.
                                                                           FedealCommuneatont Conmissin
                                                                                  on
In the Matter of                              )         Sep 23 203                  Medtssme
                                              )         Front Office
LOCKHEED MARTIN CORPORATION )
                                     )
Amendment of Applications to         ) File Nos.: SAT—AMD—20080730 00149/
The Launch and Operate Satellites in )                       g/151/1527153
Redio Navigation Service             ) CallSigns: 52570;5           sane sa7s
                                     )                   $EP p 3
                                                                               4;


                     COMMENTS OF PANAMSAT COI‘(PORATIO!G""Q,,

       PanAmSat Corporation ("PanAmSat"), by its attorneys, hereby comments on the
above—captioned amendment("Amendment") of Lockheed Martin Corporation
(‘Lockheed") to its applications for authority to launch and operate a Regional
Positioning System global radionavigation satellite service using L—band frequencies
PanAmSat‘s comments are limited to Lockheed‘s requests to: (1) change the proposed
orbital location of one of its proposed satellites; and (2) use extended C—band
frequencies for tracking, telemetry and control ("TT&C") at the new orbital location.
PanAmSat has no objection to Lockheed‘s application as amended, but is filing these
comments to bring to the Commission‘s attention the need for Lockheed to coordinate
these elements of ts Amendment with PanAmSat,




" See Public Notice Report No.SAT—00160 (Aug. 18, 2003). Salso File Nos. SAT—LOA—19990427—
voo15/a6/47/a9750.


                                         Discussion
         In its Amendment, Lockheed proposes that one of its space stations be located
at 125° W.L. instead of 129° W.L. as initially proposed. Implementation of this proposal
will require careful coordination with PanAmSat for stationkeeping purposes, because
PanAmSatalready operates Galaxy V, a C—band satellite, at 125° W.L. Furthermore, the
Commission has granted special temporary authority for PanAmSat to relocate SBS—4, a
Ku—band satellite, to 125° W.L. Thus, Lockheed‘s space station would be the third space
station to be located at 125 W.L. PanAmSat and Lockheed already have begun
discussions to address the stationkeeping issue, and PanAmSat has every reason to
believe these discussions will be successful.
         Lockheed proposes to use the extended C—band for its TT&C operations at 125°
W.L2 This proposal also will require careful coordination with PanAmSat, to avoid
out—of band emissions causing interference to PanAmSat‘s transmissions via Galaxy V
in the standard C—band. PanAmSat and Lockheed have initiated coordination
2 Se Amendment at Table 411
3 As used in these comments,the standard C:band referto the 37004200 MHz and 5925—6425 MHz
frequency bands


                                          «4.

discussions concerning this issue as well, and PanAmSat believes that the discussions

will be successful.



                                        Respectfully submitted,
                                        PANAMSAT COJ




                                        GOLDBERG, GODLES, WIENER & WRIGHT
                                        1229 Nineteenth Street, N.W.
                                        Washington, D.C. 20036
                                        (202) 425—4900
                                        Its Attorneys


September 17, 2003


                              CERTIFICATE OF SERVICE




         1 hereby certify that a true and correct copy of the foregoing was sent by first—
class mail, postage prepaid, this 17th day of September 2003, to the following:

        David . Keir
        Leventhal Senter & Lerman PLLC
        2000 K Street, N.W.
        Suite 600
        Washington, DC 20006—1809


                                                   Candace G%



Document Created: 2005-01-10 11:03:41
Document Modified: 2005-01-10 11:03:41

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