March 4, 1999 In comments filed earlier this week, Virtual Geosatellite, LLC urged the U.S. Federal Communications Commission (FCC) to mandate "virtual geostationary orbits" (VGSO) for all new non-geostationary orbit entrants in the "Ku" frequency band as the best way to protect existing geostationary systems and services from harmful interference. While strongly endorsing the FCC’s basic proposals contained in its Notice of Proposed Rulemaking for the newly available frequencies, Virtual Geosatellite, LLC recommended the Commission impose more stringent technical requirements to provide the incumbent geostationary systems with the best possible protection from unacceptable frequency interference. Specifically, the recommendation is for all non-geostationary satellite systems to use a VGSO configuration, rather than a circular orbit configuration. In order to accomplish the twin objectives of maximizing efficient use of the frequency spectrum and fully protecting the geostationary systems, Virtual Geosatellite, LLC contends that VGSO configurations are inherently superior to circular orbit configurations. VGSO systems use a specific pattern of inclined, elliptical medium earth orbits, which appear to "hang" over their service areas, that always have a minimum angular separation from the geostationary satellite arc of at least 40 degrees or more. This contrasts with circular orbits, which generally have only a 10 degree angular separation, and rely on a complex pattern of satellite coordination, exclusion zones and other artificial constraints to avoid interference with the geostationary systems. The VGSO solution can accommodate many non-geostationary satellite systems, without complex administration and enforcement procedures and without adding to the cost and complexity of the satellites. Virtual Geosatellite, LLC has proposed a VGSO system, Virtual Geo(TM), which will provide global coverage with 15 satellites and is designed to provide affordable, digital, high data rate telecommunication services, including Internet access. Virtual Geo(TM) provides a combination of very high elevation angles, low signal propagation delays, limited intersatellite handoffs, and proportionally more capacity allocated to the northern hemisphere to meet demand efficiently. Virtual Geosatellite, LLC provided comments on the FCC’s Notice of Proposed Rulemaking in the matter of Amendment of Parts 2 and 25 of the Commission’s Rules to Permit Operation of NGSO FSS Systems Co-Frequency with GSO and Terrestrial Systems in the Ku-Band Frequency Range and Amendment of the Commission’s Rules to Authorize Subsidiary Terrestrial Use of the 12.2-12.7 GHz Band by Direct Broadcast Satellite Licensees and Their Affiliates (ET Docket No. 98-206 [RM-9147, RM-9245] released November 24, 1998).

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