Attachment reply

reply

REPLY TO COMMENTS submitted by Lockheed Martin

reply

2003-10-01

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

IBFS_SATAMD2003073000149_412737

                                            o                                          ORIGINAL
           Federal Communications Commission=CEIVED
                                    WaASHINGTON, D.C. 20554                                 oct — 1 2003

In re the Applications of                                                                       comssor
                                                                               rweem commeurors c
                                                                                   qs   oen e u
LOCKHEED MARTIN CORPORATION                        File Nos.: SAT—AMD—20030730 00149
                                                     through     00153
For Authority to Launch and Operate Five                       fieceivgd                 Inti Bureau
Geostationary Satellites in the
Radionavigation—Satellite Service                            OCT 0 7 2003                 oct 0 2 2003
m       «2o kBivse~                                          wm“                         Front Office
             REPLY COMMENTS OF LOCKHEED MARTIN CORPORATION

        Lockheed Martin Corporation ("Lockheed Martin®)by itsattomeys and pursuant to
Section 25.154 of the Commission‘s ules, 47 C.FR § 25.154, hereby repliesto the comments that
were filed in response to one of the orbital locations specified in the above—captioned July 30,
2003 amendment to Lockheed Martin‘s above—captioned geostationary—orbit radionavigation—
satellte service (‘RNSS®) system.\ The only entity to file comments on the RPS Amendment was
PanAmSat Corporation (‘PAS"). Although PAS‘s comments were generally supportive of RPS,
and PAS did not object o the grant of Lockheed Martin‘s RPS Application, s amended, PAS
nevertheless reminded Lockheed Martin and the Commission that PAS has some satelite interests
at the 125° West Longitude orbital location, and that there will need to be some coordination
between the two geostationary space—station operators "
       As the proponent of a geostationary—satellite orbit spacecraft at 125° West Longitude (such
a spacecraft proposal would be considered "GSO—like"under Commission rules that went into


*      LockteedMarin‘s system s calledthe Regional ositoning System (‘RPS®). Prio o theabovereferenced
amendment, RPS was comprised of up to twelvestelitsat six orbitallocations. n the Amendment, Lockecd
Martn volunarily dismissd ts application fr spacecrafat one of thlocations, eaving fiv orbiallocations
worldwide. In ts Amendment, Lockheed Marinalso relocted spacecatfrom ts orginllfed slo at 129 West
Longitade o the 125" WestLongitude orbiallocation
       Comments of PanmSat Corp.at 1 2 (PAS Comments‘)


                                                :


effectafter Lockheed Martin filed the RPS Amendment), Lockheed Marti is fully aware ofthe

many Commission and Intemational Telecommunication Union (‘TTU‘) regulations that apply or
will apply to ts use of 125° West Longitude.. Included among these regulations are stationkecping
requirements (47 C.FR. § 25.210(); Nos. 22.6 to 22.10 ofthe ITU Radio Regulations) and the
obligation to coordinate with certain co—frequency spacecraft (47 C.FR. §§ 25.111 and 25.272;
Section II of Article 9 of the ITU Radio Regulations). With regard to PAS‘s comment concerning
"unwanted emissions"from the RPS satelite‘s TT&C operations in C:—band frequencies below
3700 MHz into the current PAS 125° West Longitude satellite‘s operations in C—band fixed

satelite service frequencies above 3700 MHz (see PAS Comments at 2), Lockheed Martin will

comply with any applicable Commission regulations.
       In short, PAS does not object to the grant of Lockheed Martin‘s application for an RPS
spacecraftin the RNSS at 125° West Longitude, and it anticipates the successful resolution of any
outstanding minor intersystem issues. As such, PAS‘s comments interpose no impediment

whatsoever to the grant of Lockheed Martin‘s RPS Application, as amended.
                                                    Respectfully submited.
                                                    LOCKHEED MARTIN CORPORATION




                                                    By:             P
                                                           Stephien D. Baruch
                                                           David Keir
                                                           Leventhal, Senter & Lerman PLLC.
                                                           2000 K Street, N.W., Suite 600
                                                           Washington, D.C. 20006
                                                           (202) 420—2070
October 1, 2003                                     Its Attomeys


                               CERTIFICATE OF SERVICE

       1, Rochelle D. Johnson, do hereby certify that on this 1"" day of October, 2003, I sent by
U.S. first—class, postage prepaid mail, a copy of the foregoing Reply Comments ofLockheed
Martin Corporation to the following:



       Joseph A. Godles, Esq
       Goldberg Godles Wiener & Wright
       1229 19" Street, N.W,
       Washington, D.C. 20036
       Counsel for PanAmSat Corporation

                                                    oRochelle
                                                       lD. Johd
                                                              fi



Document Created: 2005-01-10 11:06:03
Document Modified: 2005-01-10 11:06:03

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