Attachment 1990Comments GTE Spa

1990Comments GTE Spa

COMMENT submitted by GTE Spacenet Corporation

Comments

1990-06-08

This document pretains to SAT-MOD-19900416-00015 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD1990041600015_1058877

                                                  (MDVAI                 RECEIVED
                                                  U?z'}b ®
                                                     ie




                                                   @                         JUN 8 — 1990
                                                                                                        on
                                                                       Federal Communications Commissi
                                                                              Office of the Secretary




                                                   GTE Spacenet Corporation I
                                                   1700 Old Meadow Road
Term B. Natoli—                                    McLean, VA 22102,;JUN
                                                                      ,) )     > 4000
                                                                             1 3 199
Industry Relations Manager                         (7os sag—1s1s




 June 8, 1990



 Donna R. Searcy
 Secretary
 Federal Communications Commission
 1919 M Street, N.W., Room 222
 Washington, D.C. 20554

 Re:          AT&T Application for Modification of TELSTAR 4 Series Satellites
           ~ File Nos:           25—DSS—P/L—90
                                 26—DSS—P/AL—90
                                 27—DSS—P/L—90
                                        ML
 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,

    p             a          .
   Jez @ Natsbu
 Terri B. Natoli

 TBN/kme

 Enclosures




A part of GTE Corporation


                                                                                RECEIVED
                                                                                 JUN 8 — 1990
                                                                            Federal Communicatiens Commission
                                                                                   Office of the Seqretary

                                         Before the
                             FEDERAL COMMUNICATIONS COMMISSION
                                   Washington, D.C. 20554




In the Matter of                           )
                                           )
AMERICAN TELEPHONE AND                     )File Nos.       25—DSS—P/L—90
TELEGRAPH COMPANY                          )                26—DSS—P/L—90
                                           )                27—DSS—P/L—90
Application for Modification of            )
TELSTAR 4 Series Satellites                )


To the Commission:



                                          Comments



       GTE Spacenet Corporation ("GITE Spacenet") hereby submits its Comments on

the above—captioned application of the American Telephone and Telegraph Company

("AT&T") and respectfully states the following:

       On April 13, 1990, AT&T filed an application with the Commission to modify

the   licenses   for   its    TELSTAR   401,   402,   and    403   satellites    ("TELSTAR         4

satellites") to permit certain technical changes to be made to those satellites.

Specifically, AT&T seeks authority to:

       1.    Modify the Ku—Band configuration of the TELSTAR 4 satellites from
             the previously authorized eight 54—MHz and 12—36 MHz transponder
             configuration to 16—54 MHz transponders;

       2.    Add an independent, ground—controlled, on—board switching capability
             to convert any of the upper four Ku—Band transponders in either
             polarization into two 27 MHz transponders;

       3.    Extend the currently authorized power boost capability for any six
             C—Band and Ku—Band transponders to all 24 C—Band transponders and

                                               1


                the upper six Ku—Band tran;ponders.'

         One of AT&T‘s TELSTAR 4 satellites, TELSTAR 402,             is assigned to operate

at 89°W.L.," two degrees away from GTE Spacenet‘s SPACENET III satellite assigned

to, and operating at, 87°W.L.              As a result, GTE Spacenet is concerned about

potential interference from a further modified TELSTAR 402 satellite into current

and planned SPACENET III traffic.*
         AT&T‘s new Ku—Band frequency plan assigns high—power traffic to the uppeé

half of the frequency spectrum.             This is consistent with GTE Spacenet‘s band

segmentation and traffic assignment policy and normally would not present any'

additional      potential      interference problems.      However,    because under AT&T‘s

proposed modification the upper four Ku—Band transponders would be capable of

being . split     into   two    27   MHz   transponders,   the   potential   for   AT&T   video

interference into GTE Spacenet‘s co—polarized video transponders has increased.

This increased interference potential arises from the additional video center

frequency which will have to be avoided in coordinating the transponders that

are switched into the 27 MHz mode.              As a result, it is imperative that AT&T

coordinate the usége of these transponders with GTE Spacenet in a way which

reduces any resulting adverse interference to its SPACENET III transponders.




                Memorandum, Opinion,and Order, Assignment of Orbital Locations to
                Space Stations in the Domestic Fixed—Satellite Service, FCC 88—373
                released December 7, 1988.

     2          On June 29, 1989, AT&T filed its first modification application for
                the TELSTAR 4 satellites to inter alia add a C—Band spot beam for
                coverage of Hawaii. GTE Spacenet filed comments on August 18, 1989,
                expressing concern about potential interference into its SPACENET
                III transmissions to Hawaii and requesting assurances from AT&T that
                an effective coordination agreement with respect to that modification
                would be achieved. On March 2, 1990, the Commission granted this
                modification application.      Order_ and Authorization, DA—90—279
                released March 2, 1990.


         As to the C—Band power boost capfibi]ity fdr all the C—Band transponders,

a éapabi1ity which will permit the increase in C—Band power from 10 watts to 20

watts, GTE Spacenet has concern regarding interference into some of its sensitive

single channel per carrier ("SCPC") traffic.          While AT&T‘s previous authority

permitted the power boost capability for only six C—Band transponders," it is

unclear     from the    instant modification    application   how many   of the C-Ba?d

transponders could be expected to operate in the high—power mode at any time:

Because the SPACENET II1I satellite has been operational since March, 1988, its

coordination flexibility is somewhat lTimited.        Thus, GTE Spacenet asserts that

the increase in the number of potential high—power C—Band transponders will be

difficult to effectively coordinate if AT&T desires to employ this capability

on transponders corresponding to GTE Spacenet‘s existing inflexible SCPC traffic.

         In spite of the above concerns, GTE Spacenet is not herein opposing AT&T‘s

proposed TELSTAR 4 modifications.         GTE Spacenet has always advocated Commission

authorization of new technological          developments to better serve the public

interest.      Yet,    simultaneously,   GTE Spacenet has just as   strongly advocated

preservation and protection from interference of those existing services which

are meeting the needs of the public today.          As with AT&T‘s previous TELSTAR 4

modification application,"* GTE Spacenet is submitting these comments to urge the

Commission to be cognizant of the potential interference from AT&T‘s proposed

modifications to the SPACENET III operations, and to put AT&T on notice that

careful transponder planning and coordination are necessary to ensure that GTE

Spacenet‘s current and planned SPACENET III services are not adversely affected.




     3         AT&T, Order and Authorization, FCC 88—375, released December 7, 1980.

               Supra, note 2.


       As   always,   GTE Spacenet agree§ to work.with AT&T to ensure that an

effective coordination agreement can be achieved, however, GTE Spacenet expects

AT&T to recognize that because the SPACENET III satellite has been operational

since early 1988 its flexibility in traffic loading and reassinging will be

limited.


                                      Respectfully submitted,

                                      GTE SPACENET CORPORATION



  F0        g.
Terri B. Natoli
Industry Relations Manager
1700 Old Meadow Road
Mclean, Virginia 22102                MclLean, Virginia 22102
(703) 848—1515                        (70O3) 848—1400



June 8, 1990


                           CERTIFICATION OF PERSON RESPONSIBLE
                          FOR PREPARING ENGINEERING INFORMATION
                                SsUBMITTED IN THIS APPLICATION


        I hereby certify that I am the technically qualified person responsible

for preparation of the engineering information contained in this application and

the   exhibits     attached   thereto;   that    I   am   familiar   with   Part   25   of   thé

Commission‘s Rules; that I have either prepared or reviewed the engineering

information submitted in this filing and the exhibits attached thereto; and that

it is complete and accurate to the best of my knowledge.



: tdboy 7/%
      Sidney M      jei
      DirectorW‘   Eng1neer1n

      GTE Spacenet Corporation
      1700 Old Meadow Road
      MclLean, Virginia 22102


Dated this &th day of % ,&                      , 1989.



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Document Modified: 2014-08-20 17:51:29

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