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"i~'^:DPddDDDdp4D48dddddddddd88pppX|pDL|pp||D8D\dDXdXdXDdd88d8ddddDL8ddddX`(`lD4l\DDD4DDDDDDDDd8XXXXXX|X|X|X|XD8D8D8D8ddddddddddXdbdddpdXXXXXlX~|X|X|X|XdddldldD8DdDDDdplld|8|P|D|D|8dvddddDDDpLpLpLpl|T|8|\ddddddl|X|X|Xd|DdpL|Dd~4ddC$CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxH\dDXddddd8@d<@d<DDXXdDDxddzHxxHvppDXd<"dxtldpxxd2DXs;,=K?K5B<?xxx,>^x6X@`7X@7jC:,3Xj\  P6G;XP7gC9,)Xg\  PAXPW!@(#,9h@\  P6G;hPqȲqqKozoY~dz]sY84zddvkdsqrqzdd~YYzozzz~CdzszCCdddo"*^9D]gdCDDgq3q39gggggggggg99qqq[~~vCN~sk~CCDddCYdYdYCdd88d8ddddJN8ddddYc)cN_xdxdCYdgdddddFCChhd44ddzdddvooChdF"dȇdpqqq9"qDDqqq||CRodq8f3UYd||֐Z||fqȲqqKozoY~dz]sY84zddvkdsqrqzdd~YYzozzz~CdzszCCdddo[[nxx<[xHFAA.SSxSSJR"RNOdxSxS8JSVSSSSS;88VVS++SSfSSxSc]]8VS;"xxSxxqS]^^^z0^88^^^zxzzzggx8E]S^/zU*FJSvggxxxxxzzzzKxggqU^^^zxxxxzzK|lr]f]oJiSfM`xJ.+fS{Sc|YoS`x^_^eSSiJxJofx]fff|i8Sxxf`lrf88SSS]LL\dd2Ld<:628b<A.SSxSSJR"RNOdxSxS8JSVSSSSS;88VVS++SSfSSxSc]]8VS;"xxSxxqS]^^^z0^88^^^zxzzzggx8E]S^/zU*FJSvggxxxxxzzzzKxggqU^^^zxxxxzzK|lr]f]oJiSfM`xJ.+fS{Sc|YoS`x^_^eSSiJxJofx]fff|i8Sxxf`lrf88SSS]<?xxx,>^x6X@`7X@7jC:,3Xj\  P6G;XP7gC9,)Xg\  PAXPW!@(#,9h@\  P6G;hPy.X80,IX\  P6G;Py.V80,V\  PAP7nC:,Xn4  pG;X<R&HHH,>K,H6X@`7h@<r5ddd,|d6X@`7@7nC:,|Xn4  pG;X2KLZO"i~'^:DpddȨDDDdp4D48ddddddddddDDpppd|Ld|pȐD8DtdDdpXpXDdp8Dp8pdppXLDpdddXP,PhD4htDDD4DDDDDDdDp8dddddȐXXXXXJ8J8J8J8pddddppppddpddddzpdddXXhXXXXXdddhdptL8LpLDLpphhp8ZDP8pppddƐXXXpLpLpLphfDtppppppȐhXXXpDppLDd4ddC6CWxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxNHxxHjdDddddddWashington, D.C. 20554  X_4In the Matter of hhCq) ` `  hhCq)  X14COLUMBIA COMMUNICATIONS CORP.) File Nos. CSS90010  X 4` `  hhCq)pp CSS92002ML  X 4Application for Modification of hhCq)pp77SATMP/ML98  X 4Authorization to Permit Operation ofq)pp  X 4CBand Satellite Capacity on thehhCq)  X 4INTELSAT 515 Satellite to be hhCq)  X 4Located at 37.5$ West LongitudehhCq  )  Xy4^ MEMORANDUM OPINION, ORDER AND AUTHORIZATION  XK4Adopted: September 4, 1998qReleased: September 8 (%}\ , 1998 By the Chief, International Bureau:  X41. ` ` By this Order, we authorize Columbia Communications Corp. ("Columbia") to modify its existing satellite authorization to permit it to operate the Cband capacity on a  X4satellite previously owned by INTELSAT.yZ X:4#Xj\  P6G;3XP#э#X\  P6G;IP#The Cband is used here to refer to the 37004200/59256425 MHz frequency bands. The Kuband traditionally refers to the 11.712.2 GHz/14.014.5 GHz frequency bands. The INTELSAT 515 satellite also has  yO'Kuband downlink capabilities in the 10.711.7 GHz frequency band.   *#X\  P6G;IP# This satellite, formerly INTELSAT 515 and now  X4Columbia 515,A Z Xd4#Xj\  P6G;3XP#э #X\  P6G;IP#The terms INTELSAT 515 and Columbia 515#X\  P6G;IP# are both used to refer to the same satellite. INTELSAT 515 is used as a designation for the satellite prior to the coordination agreement reached between Columbia and INTELSAT in December 1997. The designation Columbia 515 is used to describe the satellite subsequent to the coordination agreement. is located at 37.7$ W. L.XZ Xm!4#Xj\  P6G;3XP#э#X\  P6G;IP#Columbia initially requested to operate at 37.5$ W.L., but decided to move the satellite to 37.7$ W.L. to  yOV"'allay fears of a collision with the Orion1 satellite also located at 37.5$ W.L. X This authorization will implement a coordination agreement ("Coordination Agreement") between INTELSAT and Columbia after long and difficult negotiations and it will permit Columbia to continue to be a viable competitor in the  Xe4Atlantic Ocean Region ("AOR ").e Z X&4#Xj\  P6G;3XP#э#X\  P6G;IP#See Columbia Communication Corporation, DA 96703 (released May 6, 1996) for the background of the coordination negotiation. "N 0*0*0*4"  X4^I. Backgroundă  X42. ` ` Columbia has offered video, voice, and data communications using Cband capacity leased on Tracking and Data Relay Satellite Service ("TDRS") satellites in the Atlantic and Pacific Ocean regions since 1991 through an arrangement with the National Aeronautics and Space Administration ("NASA"). Columbia provided service in the AOR  X_4using the TDRS4 satellite at 41$ W.L._ X4#Xj\  P6G;3XP#э#X\  P6G;IP#Columbia Communications Corp., 7 FCC Rcd 122 (1991). Columbia's operations at 41$ W.L. were subject to a consultation agreement reached with INTELSAT, which planned to operate a Cband satellite  X14at the 40.5$ W.L. location beginning in 1997. Under the terms of the agreement, Columbia  X 4was to operate the Cband capacity on the TDRS4 satellite at 41$ W.L. until the end of  X 41997, when INTELSAT would be ready to launch and operate its planned satellite. y X-4#Xj\  P6G;3XP#э#X\  P6G;IP#Thereafter, Columbia's operations were not to cause harmful interference to INTELSAT's operations. In August 1995, NASA extended Columbia's right to market the Cband capacity on TDRS4 for an additional four years based on changed assumptions regarding the satellite's life expectancy. Soon after, Columbia and INTELSAT began further negotiations regarding  X 4extended Columbia operations at 41$ W.L.  Xy43. ` ` INTELSAT and Columbia reached a new agreement concerning operations at  Xb4the 41$ W.L. orbital location in December 1997. The terms of this Coordination Agreement are as follows: 1) INTELSAT will transfer title of the INTELSAT 515 satellite (to be renamed Columbia 515) to Columbia on April 1, 1998; 2) Columbia 515 will be relocated to  X4the 37.5$ W.L. orbit location; 3) Columbia will lease back to INTELSAT, at no cost, a number of Cband transponders on Columbia 515; 4) INTELSAT will transfer to Columbia  X4ownership of two Cband transponders on the INTELSAT 605 satellite located at 27.5$ W.L. for a fourtofive year period beginning January 1, 1998; 5) Columbia will turn off all C X4band transponders on the TDRS4 satellite at 41$ W.L. by May 15, 1998; and 6) the Commission will withdraw its filing with the International Telecommunications Union  X4("ITU") for U.S. use of the Cband frequencies at the 41$ W.L. orbital location.J* Xn4#Xj\  P6G;3XP#э#X\  P6G;IP#See Comsat Corporation's Further Supplement dated January 21, 1997 in Application File No. CSS 93009(4) setting forth the terms of the Columbia/INTELSAT agreement announced on December 16, 1997.J    Xe44. ` ` In order to implement the agreement, Columbia must secure Commission  XN4approval to use the INTELSAT 515 satellite at the 37.7$ W.L. orbital location. AN X#4#Xj\  P6G;3XP#э #X\  P6G;IP#On March 8, 1998, the Commission granted Columbia special temporary authority to operate the  yO$'Columbia 515 satellite at the 37.7$ W.L. orbital location for 180 days. See Letter from Thomas S. Tycz, Chief, Satellite and Radiocommunication Division, FCC to Kenneth Gross, Esq., President and Chief Operating Officer, Columbia Communications Corp. (March 8, 1998).  Thus, Columbia requests permanent modification of its existing AOR authorization to specify"7 0*((+"  X4operation at 37.7$ W.L. In its application, Columbia requests, if necessary, a waiver of the  X4Commission's "freeze" on the filing of applications for new satellites in the orbital arc  X4between 60$ W.L. and 30$ W.L.,4  XK4#Xj\  P6G;3XP#э#X\  P6G;IP#Processing of Pending Applications for Space Stations to Provide International Communications Service,  yO4'FCC 85296 (released June 6, 1985) ("Freeze Order").4 and waivers of certain space station technical requirements  X4of the Commission's rules.8 AA X4#Xj\  P6G;3XP#э#X\  P6G;IP#Specifically, Columbia requests waivers of Section 25.210(b) of the Commission's Rules, 47 C.F.R. 25.210(b), which sets power flux density requirements for Fixed Satellite Service ("FSS"); Section 25.210(g) of the Rules, 47 C.F.R. 25.210(g), which sets requirements for space station crosspolarization isolation; and Section 25.210(h) of the Rules, 47 C.F.R. 25.210(h), which sets requirements for orbitalposition maintenance. 8  X45. ` ` Orion Network Systems, Inc. ("Orion"), yJ X 4#Xj\  P6G;3XP#э#X\  P6G;IP#Loral Orion Network Systems, Inc. is the new name of Orion Network Systems, Inc. following a  yOq'transfer of control approved by the Commission in File No. 1SATTC98(5). Order and Authorization, DA 98409, released February 27, 1998. which operates a Kuband satellite at  Xv437.5$ W.L., filed a petition to deny Columbia's application, asserting that the Coordination  X_4Agreement is contrary to Commission policy, illegal, and anticompetitive. A_  X4#Xj\  P6G;3XP#э#X\  P6G;IP#Orion incorporated by reference a petition to deny it filed in connection with Comsat Corporation's application to participate in the procurement and operation of the INTELSAT 806 satellite. Those arguments are  yOL'either addressed in the context of the INTELSAT 806 order or here. See Comsat Corp., DA 98985 (released May 22, 1998). Orion also  XH4argues that the colocation of the Columbia 515 satellite at the 37.5$ W.L. is technically infeasible because of the risk of collision with its Orion1 satellite at that location, and is in derogation of Orion's longterm interests at that location. In addition, Orion argues that Columbia's request for waivers should be denied. In the event we grant Columbia's request, however, Orion asks that we ensure such authority does not extend beyond the term of its initial license or the useful life of the Columbia 515 satellite, whichever is shorter.   X4_II. Discussionă  Xb46. ` ` We find that the public interest will be served by a grant of Columbia's application to modify its existing AOR license to permit it to operate the Columbia 515  X44satellite at the 37.7$ W.L. orbital location. A grant of Columbia's modification application fulfills the United States' international obligation to coordinate U.S.licensed satellites with those of other countries or administrations. This modification implements the terms of the Coordination Agreement reached by Columbia and INTELSAT, and supported by the United States, concerning international coordination between the Columbia satellite and INTELSAT's  X4planned satellite at 40.5$ W.L. The Department of State supports Commission grant of" 0*(("  X4Columbia's application as necessary to implement the Coordination Agreement. a Xy4#Xj\  P6G;3XP#э#X\  P6G;IP#In a letter dated March 3, 1998, Ambassador Vonya B. McCann recognized the significance of the agreement in allowing Columbia to continue operations. Ambassador McCann also stated that efforts by ITU member administrations to implement such accommodations are "essential to the orderly conduct of foreign relations." Ambassador McCann states that the Coordination Agreement required more than two years of sensitive and difficult negotiations and "allows Columbia, one among only a handful of competitors in the  yO'international satellite services market, to continue operations." See Letter from Ambassador Vonya B. McCann, United States Coordinator, International Communications and Information Policy, United States Department of State to Regina M. Keeney, Chief, International Bureau, Federal Communications Commission (March 3, 1998). In this case, Columbia is moving to an unassigned orbit location as a means of completing coordination with INTELSAT in a manner that permits Columbia to continue to serve its AOR customers.   X47. ` ` In granting Columbia's modification application, we reject Orion's claim that the Coordination Agreement, upon which it is premised, is unlawful and contrary to the public policy. According to Orion, the Coordination Agreement involves a "sham" transfer of title  X_4that gives INTELSAT access to the U.S. orbital location at 37.5$ W.L. In support of this claim, Orion cites Columbia's lease back of capacity to INTELSAT on the Columbia 515 satellite and INTELSAT's continued provision of Tracking Telemetry and Control ("TT&C") services for the Columbia 515. Orion also argues that the "sham" transfer gives only one U.S. operator, Columbia, any access to capacity on INTELSAT 515. Finally, Orion argues that the Coordination Agreement results in the relinquishment of valid U.S. commercial rights for the  X 441$ W.L. orbital location, permitting INTELSAT to confer an unfair competitive advantage upon its privatized spinoff entity, New Skies Satellites, N.V. ("New Skies"), whom it intends  X 4to operate the satellite at 40.5$ W.L.  Xy48. ` ` We are not persuaded that the transfer of title of the satellite to Columbia was a "sham" transaction. Columbia will operate the satellite to serve its AOR customers. It is not unusual for satellite operators to obtain TT&C operations from a third party provided the operator retains ultimate responsibility for the satellite's operation. The Coordination Agreement clearly spells out that Columbia will have full responsibility for the satellite, even if TT&C is provided by INTELSAT. In addition, there is nothing inherent in the lease back arrangement in itself to indicate that INTELSAT still controls the satellite. Based on the record, neither of these two factors, taken individually, or when taken together, support a finding that Columbia has not assumed full control of and responsibility for the satellite.  X49.` ` Orion also argues that, under the Coordination Agreement, the United States  X|4improperly relinquished its claim to valid U.S. commercial rights at 41$ W.L. To the  Xe4contrary, United States use of the 41$ W.L. location was always predicated on the knowledge  XN4that INTELSAT planned to launch a Cband satellite into the 40.5$ W.L. location which  X74would limit any continued operation at the 41$ W.L. location. Orion has not identified any  X 4interest in this orbital location either in terms of having an existing satellite at or near 41$ W.L. or a pending application to locate a satellite at or near that location that would be  X4affected by the United States' decision to relinquish its claim to 41$ W.L. as part of the" 0*((t"  X4Coordination Agreement.TA Xy4#Xj\  P6G;3XP#э#X\  P6G;IP#The fact that Columbia's Cband authorization at 41$ W.L. is being transferred to 37.7$ W.L.,  yOb'where it is nominally colocated with the Orion1 satellite at 37.5 $ W.L., does not give Orion an interest  yO*'sufficient to challenge the Commission's decision to withdraw its ITU filing for 41$ W.L. As discussed in  yO'paragraph 13, infra, Orion had no interest in Cband operations at 37.5 $ W.LT   X4 10. ` ` Further, we need not address Orion's argument that INTELSAT's affiliate, New Skies, will enjoy a competitive advantage over U.S. licensees through its operation from  X440.5$ W.L. As with other satellites to be transferred to New Skies, operation of this New Skies satellite in the United States requires Commission authorization pursuant to the  Xv4standards established in the Commission's DISCO II decision.v X 4#Xj\  P6G;3XP#э#X\  P6G;IP#Amendment of the Commission's Regulatory Policies to Allow NonU.S. Licensed Space Stations  yO 'Provide Domestic and International Satellite Service in the United States, IB Docket No. 96111, Notice of Proposed Rulemaking, 11 FCC Rcd 18178 (1996), Report and Order, FCC 97399, 12 FCC Rcd 29094, 62 FR  yOq'64167 (released November 26, 1997) ("DISCO II"). See also Comsat Corp., DA 98985 (released May 22,  yO9'1998) (authorizing Comsat's temporary operation with the INTELSAT 806 satellite at the 40.5$ W.L. orbital location until it is transferred to New Skies). The framework adopted in  X_4DISCO II is designed to "prevent potential anticompetitive or market distorting consequences of continued relationships or connections" between an Intergovernmental Organization  X14("IGO"), such as INTELSAT, and its affiliates.f1j  XL4#Xj\  P6G;3XP#э#X\  P6G;IP#Id. at para. 136. The Commission recently issued a public notice soliciting comment on the transfer of  yO5'INTELSAT satellites to New Skies. See FCC Public Notice, Report No. DS1851 (June 12, 1998).f Applications have been filed to operate with  X 4New Skies and placed on public notice.  X4#Xj\  P6G;3XP#э #X\  P6G;IP#See FCC Public Notice, Report No. DS1874 (August 17, 1998).  X 4 11. ` ` In addition to its concerns about the terms of the Coordination Agreement, Orion also argues that the Commission acted improperly by giving Columbia assurance of Commission approval of the Agreement before the Columbia 515 satellite began its drift from  X 421.3$ W.L. to the 37.7$ W.L. orbital location. The basis for Orion's assertion is a letter dated February 20, 1998 from Columbia to the Commission indicating that in May 1998 the  Xy4Columbia 515 satellite would be located at 37.5$ W.L. According to Orion, Columbia would not have begun to move the satellite without having received assurance from the Commission that it would ultimately approve the relocation. To the extent that Orion is suggesting that the Commission indicated its support for the relocation in the coordination process, before it solicited public comment, it is correct. This, however, is consistent with our international obligation to coordinate U.S. systems with those of other administrations and to use good faith efforts to accommodate each other's requirements. In this case, the United States agreed  X4to support INTELSAT's longplanned satellite at 40.5$ W.L. while at the same time assuring  X4that Columbia would be able to continue to serve its Cband customers from the 37.5$ W.L. orbital location. Assigning Columbia to an unassigned location would not adversely affect"0*(("  X4any other U.S. interests.y Xy4#Xj\  P6G;3XP#э#X\  P6G;IP# Indeed, the Commission indicated that it was considering relocating Columbia's AOR operation from  yOb'41$ W.L. to 37.5$ W.L. in November 1997. See Columbia Communications Corp., DA 972503 (released November 26, 1997). Columbia did not comment on this option. Nevertheless, we required Columbia to file a modification  X4application to transfer its AOR operations from 41$ W.L. to 37.5$ W.L. to give any potentially affected entity an opportunity to comment. Orion, in its comments, has provided no persuasive reason why the Coordination Agreement should not be implemented.  X4 12.` ` Orion also argues that the proposed colocation of the Columbia 515 satellite  Xv4with Orion's satellite at 37.5$ W.L. is not technically feasible because of the risk of collision.  X_4Since the filing of Orion's petition to deny, Columbia moved its satellite an additional 0.2$  XH4westward to allay Orion's concerns. Since the move to 37.7$ W.L., there have not been any incidents resulting from the colocation. We have traditionally assigned satellites that operate in different frequency bands to the same orbit location. This approach has enabled us to make maximum use of scarce orbital resources and has become the cornerstone of our orbital assignment policies.  X 4 13. ` ` We also reject Orion's argument that relocation of Columbia's AOR operations  X 4to the 37.5$ W.L. orbit location is in conflict with its interest at that location. Orion says that  X4it has a longterm interest in the 37.5$ W.L. orbital location because it currently operates a Kuband satellite at the location and that the location was reserved for its future Cband operations because it prepared Cband ITU filings for that location. Contrary to Orion's suggestion, the ITU filing for Cband operations at that location was done to protect U.S. interests in the location and not the interests of any particular company. Moreover, the ITU filings were prepared and submitted in 1990. If Orion was interested in pursuing Cband operation at this location, it had ample opportunity to file an application. It did not prior to  X4notice that Columbia and INTELSAT had reached an agreement in December 1997.J  X4#Xj\  P6G;3XP#э#X\  P6G;IP#Orion did not express an interest in Cband operations at the 37.5$ W.L. orbital location until it filed an application on January 14, 1998 to modify its existing Kuband satellite by adding a Cband payload.  yOZ'See Application of International Private Satellite Partners L.P. (d/b/a Orion Atlantic L.P.)File No. 76SATMP/ML98. On March 6, 1998, the Commission dismissed Columbia's modification application for failure to  yO'pay the fee required to construct and launch a new satellite. See #X\  P6G;IP#Letter from Thomas S. Tycz, Chief Satellite and Radiocommunication Division, FCC to Julian Shepard, Esq., attorney for International Private Satellite Partners  Xz4L.P. (d/b/a Orion Atlantic L.P.) (March 6, 1998).#Xj\  P6G;3XP# #X\  P6G;IP#Subsequently, Orion filed an application on May 11, 1998 to  yOc 'construct and operate a hybrid C/Kuband satellite at the 37.5$ W.L. orbital location after the expiration of Columbia's license. Consequently, we deemed that location as available for consideration in resolving the U.S.INTELSAT coordination.  X4 14.` ` We further find that the "freeze" does not preclude authorization of this application, as Orion contends. The "freeze" was initiated in 1985 and was intended to  Xe4address congestion in the portion of the orbital arc between 60$ W.L. and 30$ W.L. by suspending the processing of new applications involving these locations. Columbia's"N 0*((" modification request, however, does not involve assignment of an additional orbit location in this portion of the arc. Rather, it merely relocates Columbia's AOR operation from one location in the arc to another.  X415. ` ` Last, we recognize that the INTELSAT 515 satellites does not meet  X4Commission regulations regarding saturation flux densities,A X4#Xj\  P6G;3XP#э#X\  P6G;IP#Section 25.210(b) of the Commission's rules requires FSS space station to have the "minimum capability" to change transponder saturation flux densities by ground command in 4 dB steps over a range of 12 dB. 47 C.F.R. 25.210(b). The Columbia 515 satellite is capable of altering saturation flux densities in steps of 7.5 dB over a range of 15 dB. space station antenna cross Xv4polarization isolation,Av X 4#Xj\  P6G;3XP#э#X\  P6G;IP#Section 25.210(g) of the Commission's rules requires that FSS space station antennas be designed to provide a crosspolarization isolation so that the ratio of the on axis copolar gain to the crosspolar gain of the antenna in the assigned frequency band is at least 30 dB within its primary coverage area. 47 C.F.R. 25.210(g). The Columbia 515 satellite achieves a 27 dB ratio. and orbitalposition maintenance properties.Av X4#Xj\  P6G;3XP#э#X\  P6G;IP#Section 25.210(h) of the Commission's rules requires that space stations in geostationary orbit be  yO'designed with the capability of maintaining within 0.05$ of their assigned orbital longitude. 47 C.F.R. 25.210(h). The Columbia 515 satellite was designed to maintain its assigned  yOz'longitude within 0.1$. Contrary to Orion's assertion, however, we find Columbia has justified a waiver of these rules. As Columbia points out, INTELSAT 515 cannot at this point be modified to meet the Commission's technical requirements. Further, the satellite will not cause harmful interference into any  X 4other satellites since the nearest satellite is separated from it by three degrees.  X4#Xj\  P6G;3XP#э#X\  P6G;IP#Columbia has completed coordination with adjacent satellites. In addition, the satellite has only a limited useful life of approximately 34 years. Under these circumstances, we find that a waiver of these technical requirements is justified in the public interest for the remainder of Columbia's license term.  X 4 III. Conclusion and Ordering Clausesă  Xy416. ` ` Accordingly, Columbia's application to modify its existing AOR license, File  Xb4Nos. CSS90010, CSS92002ML and 77SATMP/ML98, to reflect its operation at 37.7 $  XK4W.L. instead of 41$ W.L. IS GRANTED.  X417.` ` IT IS FURTHER ORDERED that, with the exception of additional Cband capabilities on the Columbia 515 satellite, this authorization confers upon Columbia no greater rights than those contained in its authority, as modified, to conduct Cband operations  X4on the TDRS4 satellite at 41$ W.L. until the expiration of its AOR license term.  X418. ` ` IT IS FURTHER ORDERED that Orion's petition to deny Columbia's application IS DENIED. "0*(("Ԍ X4ԙ19.` ` This authorization is issued pursuant to Section 0.261 of the Commission's rules and is effective upon adoption. Petitions for reconsideration under Section 1.106 or applications review under Section 1.115 of the Commission's rules may be filed within 30  X4days of the public notice of this order (see Section 1.4(b)(2)).   X4 ` `  Xv4 ` `  hhCFEDERAL COMMUNICATIONS COMMISSION ` `  hhCRegina M. Keeney ` `  hhCChief, International Bureau ` `