FEDERAL COMMUNICATIONS COMMISSION

WASHINGTON, D.C. 20554

DA 04-2689

August 26, 2004

Robert G. Allen, P.C.

9300 Forest Point Circle

P.O. Box 2126

Manassas, VA 20108

Re: Telco214, Inc. ("Telco214")

File No: SES-LIC-20040528-00746

Dear Mr. Allen:

For reasons discussed below, we dismiss the above-captioned application
to request authority to operate a fixed earth station located in
Melbourne, Florida as defective, without prejudice to

re-filing.

A review of the application discloses the following defects:

1.  Intelsat 511, 603, and 605, requested as Points of Communication by
    Telco214, are not at the locations specified in the application.
    Specifically, Intelsat 511 is no longer operational, Intelsat 603 is
    currently located at 340 E.L. not at 335.5 E.L., and Intelsat 605 is
    at 33 E.L not at 332.5 E.L. Consequently, we are not able to
    determine the satellites with which Telco214 seeks to communicate.
    If Telco214 refiles, it must accurately identify the satellites with
    which it seeks to communicate, the orbit locations at which they are
    operating or are authorized if not yet launched, and the frequency
    bands in which operations to and from each satellite will occur.

2.  The eastern satellite arc limit of 30 degrees W.L. in the frequency
    coordination report is inconsistent with the eastern satellite arc
    limit of 10 degrees W.L. entered in E54 of Schedule B. If Telco214
    refiles, the coordination report must be consistent with the range
    of arc proposed for operation, and it must be current within six
    months.

3.  Values of EIRP density of -15 and -4.1 dBW/4KHz entered for the
    emissions 2M46G7W and 205KG7W in Items E49 of Schedule B are
    substantially lower than and inconsistent with the mathematically
    minimum possible values of 30.9 and 41.7 calculated by subtracting
    the bandwidth of the emission divided by 4 KHz, after conversion to
    dB, from the EIRP of 59 dBW. If Telco214 refiles, it must supply
    values for eirp density consistent with eirp and bandwidth.

4.  The value entered for elevation angle east of 26.3 degrees is
    substantially different from and inconsistent with the value of 8.4
    degrees that corresponds to the eastern limit of satellite arc of 10
    degrees W.L. and the earth station location of 28 2 29 North
    Latitude and 80 35 43 West Longitude. If Telco214 refiles, it must
    supply a value for elevation angle consistent with the limits of the
    satellite arc and the location of the earth station.[^1]

5.  The value entered for angle of azimuth east of 111.1 degrees is
    substantially different from and inconsistent with the value of 99.4
    degrees that corresponds to the eastern limit of satellite arc of 10
    W and the earth station location of 28 2 29 North Latitude and 80 35
    43 West Longitude. If Telco214 refiles, it must supply a value for
    azimuth consistent with the limits of the satellite arc and the
    location of the earth station.[^2]

Therefore, pursuant to the Commission's rules on delegated authority, 47
C.F.R. §§ 0.51 and 0.261(a)(4), we find that the above-captioned
application is defective. We dismiss this application, without prejudice
to refilling.[^3] If Telco214 refiles, the application is to be complete
and consistent, and to contain all required technical parameters and
reports applicable to the frequency bands proposed for operation.

In addition, we note that the antenna listed in application
SES-LIC-20040528-00746 is 3.7 meters in diameter, that the frequency
bands listed were 3700 to 4200 MHz for the downlink, and 5925 to 6425
MHz for the uplink, and that the transmit emissions were digital with
bandwidths greater than 200 KHz. While not, in itself, a ground for
dismissal, the minimum diameter acceptable for routine processing with
the frequency bands and emissions listed is 4.5 meters. If Telco214
refiles, the application must include a showing that off-axis eirp is no
greater than that obtained from an antenna conforming to the standards
of Part 25, section 25.209(a), operating within the limits for routine
processing of Part 25, section 25.212(d), or is to include affidavits
from operators of adjacent satellites that they acknowledge and do not
object to the proposed operation.

We also note that for the frequency bands listed, 3700 to 4200 MHz for
the downlink and 5925 to 6425 MHz for the uplink, ALSAT would include
Satmex 5, Solaridad 2, and all Intelsat satellites.

Sincerely,

William Howden

Chief

System Analysis Branch

Satellite Division

International Bureau

cc: Telco214, Inc.

[^1]: There are a number of web sites that support calculation of
    elevation angle, given an orbital location and latitude and
    longitude of an earth station

[^2]: There are a number of web sites that support calculation of
    azimuth, given an orbital location and latitude and longitude of an
    earth station.

[^3]: If Telco214 refiles an application identical to the one dismissed,
    with the exception of supplying the defective information, it need
    not pay a further application fee. *See* 47 C.F.R. § 1.1109(d).