TelesatTelesat Canada1601 Telesat Court Ted H. IgnacyGloucester, Ontario Chief Financial OfficerK1B5P4

January 22, 2007

Ms. Chantal Beaumier

Director, Space and International Regulatory ActivitiesRadiocommunications and Broadcasting Regulatory BranchIndustry CanadaRoom 1564C-Jean Edmonds Tower North

300 Slater Street

Ottawa ON Kl A 0C8

Dear Ms. Beaumier:

Subject: Gazette Notice DGRB-001-06 - Reply Comments by Telesat (amended)

Telesat is pleased to have the opportunity afforded in this phase of the Department's Call for Applications

to Licence Satellite Orbital Positions ("Call") to provide its Reply Comments.

Telesat has structured its Reply Comments to address the common themes that satellite users have

expressed, as well as comment upon specific points that were made regarding Telesat's applications.

Telesat's Reply is structured in three parts focusing on:

i) the strong support of Canadian satellite users for Telesat's applications;

ii) the need and overwhelming support for adoption of spectrum aggregation by the Department as

a governing principle of this, and future, licensing processes; and

iii) the Canadian benefits associated with Telesat's orbital licence applications.

At the outset, Telesat notes that the Department has enumerated several application information

requirements and criteria against which applications are to be assessed, namely:

• Adherence to Canada's telecommunication policy objectives as set out in section 7 of the

Telecommunications Act. including

Tel: (613) 748-0123 « Fax:(613)748-8780

o satisfying the needs of Canadian satellite users for the provision of basic and

advanced services while fostering the future introduction of new and innovative

broadcasting and telecommunications services;

o enhancing the competitiveness of Canadian telecommunications at both the national

and international levels; and

o fostering the development of a Canadian satellite infrastructure which will advance

Canadian satellite service offerings in the domestic market and the larger market of

the Americas while recognizing the importance of delivering reliable and affordable

telecom and broadcasting services to all regions of Canada including the North;

• providing coverage of all regions of Canada, and to other areas of the Americas where such

coverage is consistent with the viability of the satellite project;

• compliance with ITU Radio Regulations;

• satellite capacity and other benefits for underserved communities;

• compliance with the Canadian ownership and control requirements of the

Telecommunications and Radiocommunication Acts;

• operation of the spacecraft under Canadian direction and control;

• a fully-developed business plan which includes an industry/market overview, the business

strategy, revenue and cost projections of the satellite project, the product offerings and an

overview of the distribution model and channels to market, as well as a description of the

implementation phase including support and human resources needed; and

• project milestones.

Telesat’s six applications are fully compliant with and responsive to the Department’s requirements. All

of the Company’s satellite development plans are squarely aimed at enhancing the competitiveness of the

Canadian and international satellite services market and bringing to Canadians highly advanced and

innovative satellite-delivered services. Telesat consistently has demonstrated this commitment to

competition and the provision of state-of-the-art satellite services over the past four decades, and it is these

fundamental objectives that underlie its future plans and orientation. Although Telesat’s core market is

Canada and its focus is Canada-first, the Company has long recognized that, in order to compete in the

consolidating satellite services sector and ensure that Canadians continue to enjoy the many benefits that

flow from fully competitive markets, Telesat must expand its scope of operations and position itself to

compete with the larger international operators and their affiliates capable of serving Canada, North

America more broadly, and the rest of the world. Failure to do so will imperil Telesat’s future and the

millions of Canadians that rely daily on its facilities and services.

In addition to the policy objectives embodied in section 7 of the Telecommunications Act, the Department

has set forth four evaluation criteria against which applications are to be assessed:

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1. Benefits to Canadians: satisfying Canadian requirements for capacity and services (including the

necessities and conveniences of direct-to-consumer services), the provision of a Canadian

Satellite Capacity and Services Plan which describes the consultations undertaken with users, the

amount and characteristics of capacity being made available and the assumptions underlying the

requirements, as well as a description of the process through which the capacity will be made

available to Canadian users; securing Canadian access to orbital resources which includes

credible plans with which to meet first-come-first-served ITU deadlines; and other benefits to

Canadians;

2. Financial commitment to the project: evidence that the applicant can carry out the proposed plan:

i.e. supporting documentation and letters of support from partners, investors etc., sources of

financing and an overview of the financing needs of the project;

3. Technical plan: a full description of the satellite design and capabilities and the applicant’s

ability to follow through with a satellite procurement project; and

4. Technical, operating and institutional competencies: a demonstration by the applicant that it has

the experience and ability to procure, launch and operate a satellite, as well as business

management capabilities and the relationship with partners, investors, resellers and customers

necessary to make the project a success.

A review of the record demonstrates that Telesat alone has satisfied the Department’s licensing criteria in

this proceeding with respect to the orbital locations and frequencies for which Telesat has applied.

Specifically, and as discussed below, (1) Telesat’s applications (and the detailed commercial and technical

submissions therein), (2) the strong and broad based letters of support from Canadian satellite users and

others participating in the Canadian space sector, and (3) Telesat’s long track record of technical and

operational achievements and financial commitment (which have brought state-of-the-art, innovative

satellite services to all Canadians and preserved Canada’s scarce and valuable orbital resources), when

considered as a whole, fully satisfy the licensing criteria and advance the policy objectives set forth by the

Department.

With this overview of how Telesat’s applications have addressed and complied with every requirement and

evaluation criterion set forth by the Department, the balance of this submission will focus on the satellite

users who have submitted comments. Accordingly, Telesat is pleased to provide the following response.

i) Support of Canadian Satellite Users

With this Call the Department made a deliberate effort to include the views of Canadian satellite users

in the evaluation and award of satellite orbital licences. For their part, whether they utilize large or

3

relatively small amounts of satellite capacity, Canadian users have responded clearly and largely with a

common voice. They have by an overwhelming majority supported Telesat’s applications and the

adoption of the fundamental principle of spectrum aggregation which underlies those applications.

The spectrum made available pursuant to this Call is of particular interest to two markets: the

broadcasting industry and the emerging satellite broadband market. Participants in these markets are

the heaviest users of satellite capacity in Canada. Consistent with the licensing criteria, their opinions

and comments should therefore be given substantial weight.

The following table summarizes the significant support that satellite stakeholders have given Telesat

relative to each of the Company’s licence applications.

Table 1 – Support for Telesat’s Applications

Public Comments Licence 2 5 6 8 9 14 17 18 23 24

Spec

trum

Ag

greg

atio

n

72.5°

17 G

Hz B

SS

82° 1

7 GHz

BSS

86.5°

17 G

Hz B

SS

91° K

a FSS

91° 1

7 GHz

BSS

107.3

° 17 G

Hz B

SS

111.1

° Ext.

Ku F

SS

111.1

° 17 G

Hz B

SS

118.7

° Ka F

SS

118.7

° 17 G

Hz B

SS

Interested Parties Aboriginal Peoples Television Network √ √ √ √ √ √ √ √ √ √ √ Alliance Atlantis √ √ √ √ √ √ √ √ √ Astral Television Networks √ √ √ √ √ √ √ √ √ Barrett Xplore Inc. √ √ √ √ √ Bell ExpressVu √ √ √ √ √ √ Canadian Association of Broadcasters √ √ √ √ √ √ Canadian Cable Systems Alliance N/C √ √ Canadian Satellite Radio Investments Inc. √ √ √ √ √ √ √ √ √ √ √ Canadian Satellite Users Association √ √ √ √ √ √ √ √ √ CBC Radio Canada √ √ √ √ √ √ √ √ √ CHUM Television √ √ √ √ √ √ √ √ √ COM DEV Ltd. √ √ √ √ √ √ √ √ √ √ √ Corus Entertainment Inc. √ √ √ √ √ √ √ √ √ √ √ High Fidelity HDTV √ √ √ √ √ MDA √ √ √ √ √ √ √ √ √ √ √ SCN √ √ √ √ √ √ √ √ √ √ √ S-Vox √ √ √ √ √ √ √ √ Shaw √ √ √ √ √ √ Telus √ WildBlue N/C √ √ √ √ N/C - Interested parties made no comments on subject matter

4

The two strongest demand drivers for additional satellite capacity serving Canada are (1) high

definition television (HDTV) and (2) the rapid take-up by Canadians of satellite broadband services. It

is therefore important in this comparative licencing process that Telesat’s applications received such

broad and strong support from Canadian broadcasters, their associations, and Canada’s only national

broadband satellite service provider.

In addition to the strong support Telesat received from Canadian satellite users in general, it is

particularly significant that those entities that have to date made the largest financial investments in

satellite-delivered services have offered their exclusive support in this process for Telesat’s

applications. On the broadcast side, Telesat has received strong commitments from Canada’s two

largest satellite users, Bell ExpressVu and Star Choice. In light of Telesat’s strong track record in

deploying affordable, reliable and innovative satellite services, these important satellite users have

worked closely and exclusively with Telesat to ensure that we can collectively put in place the

expansion satellite capacity needed to accommodate their and their customers’ growing broadcast

requirements.

Telesat also has an understanding in principle for expansion satellite capacity from Canada’s largest

satellite broadband service provider, Barrett Xplore, as well as a commitment from WildBlue to

evaluate new plans for Ka-band capacity over North America. Telesat has invested hundreds of

millions of dollars and worked side-by-side with both Barrett and WildBlue over the past years to

bring innovative and competitive satellite-delivered broadband services to underserved communities

throughout Canada and the United States. In this regard, it is only logical that these pioneers would

seek to partner with Telesat in this process to ensure that we can obtain the necessary spectrum

resources to expand the offerings that we collectively introduced to the market in the first place.

These customer commitments fulfill one of the Department’s principal criteria that the satellite

business plans put forth by applicants are supported by genuine customer demand. The strong and

exclusive support by the very groups that today are procuring satellite capacity and serving the

broadcast and broadband markets in Canada is a strong endorsement of Telesat’s competitiveness and

track record as well as evidence of their trust in the Company’s ability to deliver on its commitments.

No other applicant was able to offer such concrete support from Canadian satellite users.

Moreover, the amount of information and level of detail provided in Telesat’s Canadian Satellite

Capacity and Service Plans provides tangible data upon which Canadian satellite users could assess the

suitability of Telesat’s proposals to their needs, as well as the commitment of Telesat to continue its

substantial investment program in the Canadian satellite services market. The high level of support

5

among Canadian satellite users is in large part a reflection of the confidence in the Company by

satellite users and the continued dialog and sharing of information Telesat consistently undertakes with

users concerning its and their future plans.

By contrast, it could not be determined from the brevity of the other applicant’s Canadian Satellite

Capacity and Service Plans any of the details of their proposed capacity, nor that any of its applications

were supported by actual customer commitments. Moreover, Telesat notes that of the handful of

comments supporting non-Telesat applications, that support was largely given for orbital locations at

which Telesat is not seeking to provide services.

When the actual buyers of capacity, user associations and the vast majority of individual broadcasters

and other satellite users exclusively support Telesat’s applications, it is clear that Canadian needs will

best be served by awarding Canadian spectrum resources to Telesat to execute its proposed

development plans. Moreover, it is consistent with Canada’s telecommunications policy objectives by

“satisfying the needs of Canadian satellite users ... while fostering the future introduction of new and

innovative broadcasting and telecommunications services”.

ii) Spectrum Aggregation

Fundamental to Telesat’s applications was that Canada be consistent with the approach taken by other

administrations around the world and the Department should in this and future proceedings adopt a

licensing approach that permits and encourages satellite operators to aggregate spectrum at a given

orbital location. As Telesat described in detail in its applications, such an approach will:

(1) lead to lower unit costs for transponders;

(2) encourage innovation;

(3) promote in-orbit redundancy and service reliability;

(4) minimize the likelihood for harmful interference;

(5) enhance the likelihood that spectrum is expeditiously brought into use;

(6) leverage the investments users already have made in terrestrial infrastructure; and

(7) foster competition by ensuring that Canadian satellite operators are not placed at a competitive

disadvantage relative to U.S. and European operators who benefit from the economies of scale

associated with launching larger satellites, economies they can capture as a result of their ability

6

to aggregate spectrum through their respective administrations licensing policies which favour

spectrum aggregation.

In short, a licensing policy that encourages spectrum aggregation fully advances all of the policy

objectives set out in section 7 of the Telecommunications Act.

Telesat notes that many of the comments received from Canadian broadcast and broadband

undertakings supported the need for Canada to adopt a spectrum aggregation policy in order to

maximize the services platform available to users at any one orbital location (i.e. the ability to create

‘neighbourhoods’), thereby enhancing the efficient use of valuable spectrum while minimizing harmful

interference between satellite systems. All of Telesat’s applications were based on interest and

expressed commitments from users for satellite capacity in Telesat’s existing orbital neighbourhoods.

These are locations which have been developed by Telesat through its investment in satellite facilities

and the offering of high-quality services which have attracted and retained Canadian customers. Some

of these neighbourhoods have long been established while others have been developed only in recent

years. In any event, all of these locations have been made useful as a result of the neighbourhoods

established by the substantial investments made (and risks taken) by Telesat, and not by any other

applicant in this process.

a) Support for Spectrum Aggregation

The following excerpts from comments illustrate the depth of support Canadian satellite users have

given for the adoption by the Department of spectrum aggregation in the current round of spectrum

licensing.

“To the extent practical, BXI agrees with Telesat’s position that Canadian satellite operators

should be allowed through the licensing process to develop a variety of spectrum at their orbital

platforms. This approach not only provides added choice to Canadian satellite users in developing

new spectrum but allows new spectrum to be introduced in a cost-effective and efficient manner.

Conversely, awarding different spectrum to several Canadian satellite operators at the same orbital

location defeats the economies of scale that could otherwise be realized by a single operator.

Therefore, BXI would urge the Department to award the licences in this Call with the intent of

developing these strategic Canadian orbital platforms.” Excerpt from comments by Barrett Xplore,

December 15, 2006, Page 2.

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“Industry Canada’s awarding of these licences to Telesat Canada is in line with CBC/Radio-

Canada’s support of growth in these satellite neighbourhoods.” Excerpt from comments by

CBC/Radio-Canada, December 15, 2006, Page 2.

“… CSUA has established a series of principles that it considers are critical to any assessment of

the public interest in applications for Canadian orbital slots…….the use of the Canadian orbital

positions should enhance users’ neighbourhoods as a way of promoting efficient distribution

platforms”…Pages 2 and 3.

“The development of neighbourhoods serviced by a single supplier creates significant efficiencies

in satellite distribution for users.” Excerpts from comments by CSUA, December 15, 2006, Page 4,

and endorsed by Alliance Atlantis and Astral Television Networks.

“It is the CAB’s view that the Department should place paramount consideration on the ability

of the chosen licensee to maximize opportunities for the expansion of Star Choice/Cancom and

Bell ExpressVu satellite services in the 17 GHz BSS and Extended Ku bands, within their existing

DTH orbital neighbourhoods….. this would best be ensured through an extension of the

relationships that Star Choice/Cancom and Bell ExpressVu currently have with Telesat……it is

preferable that the facilities required in the critical DTH neighbourhoods in the 17 GHz and

Extended Ku bands be capable of being integrated into future Telesat spacecraft…” [emphasis

added] Excerpt from comments by CAB, December 15, 2006, paragraph 13 and endorsed by

Alliance Atlantis and Astral Television Networks.

“Telesat’s white paper on Orbital Slot Development is credible [in] so much as CSRI believes that

a single satellite operator should have exclusive priority to develop all frequency bands at a

particular orbital position in which they are currently operating…” (text in parentheses is added.)

Excerpt from comments by Canadian Satellite Radio Investments, December 15, 2006, Page 1.

“In terms of contested licences, we believe it is important that we secure all orbital resources in the

existing DTH neighbourhoods and that, in general Canada and the industry would be best served if

Telesat were the single supplier in control of these resources.” Excerpt from comments by CHUM,

December 15, 2006, Page 2.

“….S-VOX is of the view that the needs of Canadian Broadcasters can best be met if Telesat is

awarded the …licences. This would allow Telesat to develop these orbital positions in order to

enhance Canada’s existing orbital broadcast neighbourhoods. It would give them the ability to

launch hybrid satellites, which reduces costs, and it would give them the ability to easily

coordinate traffic on those satellites, which will become increasingly important as Canada

8

transitions to HDTV and begins to roll out new services.” Excerpt from comments by S-VOX,

December 13, 2006, Page 1.

“Given that the construction and launch of a satellite represents a significant capital investment,

TELUS recognizes that driving economies of scale is an important aspect to the long-term

profitability of a satellite program. TELUS therefore supports the concept of assigning multiple

frequency licenses to the same operator at an individual orbital location, and feels this is valid for

both emerging and incumbent operators.”Excerpt from comments by TELUS, December 15, 2006,

Page 1.

b) Spectrum Aggregation & Competition

The current Call is an important juncture in licensing new spectrum and provides the Department a

one-time opportunity to affirm spectrum aggregation as the guiding principle going forward for

awarding Canada’s satellite spectrum. Spectrum aggregation will allow competing Canadian satellite

operators to maximize their development of a diversity of services and provide Canadian satellite users

with an efficient and cost-effective choice. In fact, only through the adoption of spectrum aggregation

can Canada enjoy a fair, open and competitive satellite market both domestically and at the

international level. To do otherwise will place Canadian satellite operators at a competitive

disadvantage relative to foreign satellite operators who are capable of offering services both in and

outside of Canada. These foreign operators, through the licensing policies favouring spectrum

aggregation applied by their respective administrations, have aggregated multiple frequencies at their

own orbital locations, a large number of which are well suited to providing services in Canada. As a

result, these operators can take advantage of the substantial economies of scale afforded by large

satellites operating over multiple frequency bands. Failure to license Canadian operators to multiple

frequencies at their existing slots will deny them, their customers and the Canadian public the vast

benefits associated with larger satellites and the creation of neighbourhoods, placing Canadian satellite

operators at a competitive disadvantage and distorting competition in Canada as a result.

In addition to competing with Canadian and foreign satellite operators, Telesat also encounters

vigorous competition from operators of terrestrial communications facilities, both within and beyond

Canada. Terrestrial facilities can provide certain types of services more cost efficiently than satellite-

based networks. In order to compete with terrestrial providers, therefore, satellite operators must be

able to take advantage of the cost savings and efficiencies that come from launching larger satellites

(savings that come from lower unit costs per transponder and the higher power afforded by larger

satellites buses, allowing operators to offer more throughput through a finite amount of spectrum).

The ability to launch larger satellites, however, is constrained by the amount of spectrum an operator

9

has access to at a given orbital location. Accordingly, spectrum aggregation is necessary to enable

Canadian operators to compete both with non-Canadian operators who can launch larger satellites

owing to their ability to aggregate spectrum as well as providers of terrestrial networks whose facilities

are typically less bandwidth constrained.

As seen in the users’ comments, spectrum aggregation delivers benefits to Canadian satellite users and

to all Canadians. Canadian satellite users benefit when each operator is able to develop an orbital

neighbourhood which incorporates multiple facilities, achieves significant economies of scale and

delivers an extensive portfolio of services. This was demonstrated in the case of Anik F2 where the

potential and the benefits of spectrum aggregation were successfully achieved. At the time Anik F2

was being designed and built, Ka-band was a new and unproven service in North America. Moreover,

the Canadian market for these services was unproven; thus, it would have been financially imprudent

to construct an expensive, stand-alone Ka-band spacecraft. As part of its innovative solution and

facilitated by spectrum aggregation, Telesat was able to leverage Anik F2’s C and Ku-band payloads

and add a new Ka-band component to the spacecraft. As a result, tens of thousands of Canadian users

are now benefiting from Ka-band high-speed broadband Internet services- users who would otherwise

not have access today to any broadband service at all.

In addition to these benefits, the Government’s policy objectives are further enhanced through

spectrum aggregation by ensuring that the use of Canada’s valuable satellite spectrum for Canadian use

is maximized, while reducing the burden of interference between systems and the attendant

coordination and administrative costs.

In addition to being consistent with the licensing policies followed by other administrations, the

benefits of spectrum aggregation have long been understood and accepted by the Department.

Consider the following excerpts from the Policy for the Use of the Geostationary Satellite Orbit by

Canadian Satellite Networks (RP-002), 1995:

“It is also noted that there may be a significant economy of scale in the implementation of the

space portions of satellite networks if there is sufficient traffic requirement to make effective use of

the larger spacecraft. This was experienced in the transition from the ANIK C and D series of

satellites to the ANIK E series…”

“If no account is taken of the possible future need for larger multi-band spacecraft when

determining the orbit location to be used by current spacecraft, events and ensuing arrangements

may preclude the future implementation of larger spacecraft. If a satellite in one frequency band

is located at a certain coordinated GSO location, and a second satellite operating in a different

10

frequency band is located at a nearby but different coordinated location, it may be difficult to

combine the systems at a later date by implementing a single larger multi-band system, because of

coordination constraints associated with the earlier networks. This difficulty can be avoided if the

earlier satellites are co-located even though the decision is not made at that time to implement the

two networks with a single larger spacecraft.”

“Thus…it is recommended that Canadian satellites be concentrated in a few specified orbit

locations wherever this is technically feasible. This will keep open the option of implementing

larger multi-band multi-service satellites if and when it is advantageous to do so.” Page 2

Later in Section 4.3, at Page 4 of the same Policy, the Department recommends the deployment of

additional bands at the same orbital locations as currently operational or planned satellites:

“The prime reason for the guideline is to make available the option of implementing larger multi-

band spacecraft if and when it is advantageous to do so. It is recommended that these orbit

locations be used in early generations of the networks even if larger multiband spacecraft are not

contemplated at that time, because the necessary process of coordinating and notifying them and

their successors in accordance with Article 11 of the Radio Regulations may make it more difficult

to change the orbit location later to enable construction of the multiband spacecraft.”

As a result of the Department’s policy, Canada enjoys today the benefits of this spectrum aggregation

principle on a limited scale, restricted to Canadian orbital positions that have hosted successive

generations of satellites. Those benefits have been notable: lower unit costing of capacity through

larger spacecraft (e.g. Anik E’s with C and Ku-band, Anik F1 with the South American payload), early

deployment of developing frequency bands to secure Canadian rights as well as to provide a market-

entry platform (e.g. Anik F1 Extended Ku-band, Anik F2 Ka-band), and first-flight opportunities for

the Canadian aerospace component industry in their product development work (e.g. Anik F2 Ka-band

Spacemux).

The post-WTO environment has opened borders and competitors have expanded their markets.

Furthermore, the satellite industry has undergone a phenomenal degree of consolidation which has

produced formidable competitors who enjoy vast economies of scale and scope in terms of financial

benefits (e.g. access to financing, multiple procurement programs, system redundancy and insurance

savings) and global geographic reach. These cost structure advantages are available to them not only

in foreign markets but also in the Canadian market, and Telesat has no alternative but to meet this

competitive challenge. Canada’s adoption of the spectrum aggregation philosophy is not just a “nice to

have”, it is a competitive necessity for Canadian operators, users, and the space industry.

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Adoption of the spectrum aggregation philosophy supports and is consistent with Canada’s

telecommunications policy objectives and the objectives of this Call by enhancing the competitiveness

of Canadian telecommunications at both the national and international levels and by fostering the

development of a Canadian satellite infrastructure which will advance Canadian satellite service

offerings in the domestic market and the larger market of the Americas.

Other Canadian licensed satellite operators will benefit from this philosophy too. Indeed, Ciel’s largest

shareholder, SES, has been a leader in aggregating frequencies at given orbital locations around the

world – including multiple orbital slots in the North American arc that are capable of serving Canada –

and building strong neighbourhoods at these slots for the benefit of its customers, shareholders, and

licensing administrations (principally the U.S. and Luxembourg). Perhaps the leading satellite

neighborhoods in the world are those operated by Ciel affiliate SES Astra in Europe at 19.2 ° WL and

28.2 °WL.

Ciel affiliate SES Americom, moreover, has been a leader in aggregating spectrum in the North

America arc. At 105 °WL, SES and its related companies have authorizations or applications pending

for spectrum in the C- and Ku-bands, Extended Ku-band, Ka-band as well as frequency bands at

17 GHz BSS and 12 GHz BSS. Similarly, Ciel’s application for 12 GHz BSS at 138°WL should be

considered in light of its ability to enhance SES Americom’s existing neighbourhoods at 137° and

139°WL. On the other hand, SES’s spectrum aggregation approach may have also played a role in

Ciel not filing a licence application for 17 GHz BSS at 111.1°WL, a frequency band in which Ciel has

shown considerable interest at other locations in this current process. The answer may be in the fact

that SES (through Luxembourg) holds the next ITU priority, after Canada, for this spectrum at

111.1°WL. That is, should Canada be unable to bring into use the 17 GHz BSS at 111.1°WL by the

ITU deadline, SES then gains the ITU priority to develop this spectrum. Ciel’s application in Industry

Canada’s Call at the 103ºWL location -- where AMC-1 operates today adjacent to AMC 4 at 101ºWL

-- is further evidence of SES’ justifiable interest in aggregating spectrum at existing orbital locations.

To be clear, Telesat endorses the highly successful manner in which SES has managed to aggregate

frequencies at multiple orbital locations around the world and to build strong satellite neighbourhoods

using these frequencies. Although SES has been a pioneer in this practice, Intelsat and Eutelsat – the

other large international satellite operators – also have built strong businesses through the development

of satellite neighbourhoods at orbital locations where they have the rights to use multiple frequencies.

Having invested substantial resources in developing these neighbourhoods, these operators and their

respective licensing administrations jealously and zealously guard against any incursion by other

operators seeking to gain access to frequencies at these slots.

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Telesat is hoping that it too, over time, can grow its business to compete more effectively with these

three much larger operators. As the Department is aware, on December 18, 2006 Telesat announced

that its parent BCE Inc. was selling the Company to a group consisting of Canada’s Public Sector

Pension Investment Fund (PSP Investments) and Loral Space and Communications Inc (Loral).

The new company will be named Telesat and will remain a Canadian-based satellite operator

headquartered in Ottawa. The Company’s focus on the growth of its Canadian core business will

remain a key business objective for the new Telesat. Furthermore, the transaction will include the

transfer of Loral Skynet’s satellite assets to the new Telesat, making the Company the fourth largest

operator in the world based on the number of operating satellites. This is an excellent outcome for

Telesat and Canadian satellite users. It allows the Company an opportunity to grow beyond the

Americas using the Skynet satellites, take advantage of increased economies that result from a larger

base of satellite facilities, continue the substantial investments made over the years in R&D and deploy

even more advanced and innovative services, all the while remaining Canadian.

However, the ‘new’ Telesat will continue to be much smaller than its global competitors, SES Global,

Eutelsat and Intelsat. Specifically, Telesat will have a combined fleet of 11 satellites, compared to 36

for SES, 22 for Eutelsat, and 52 for Intelsat. Although Telesat and its new shareholders will look for

opportunities to acquire smaller operators to gain scale and enhance the Company’s competitive

position, we remain committed to growing our business organically by continuing to develop our

existing neighbourhoods at our existing orbital locations, in the same manner that our much larger

competitors do at their respective orbital locations. Our ability to further develop these neighborhoods

and compete more effectively in the market, however, is wholly contingent on our ability to obtain the

incremental frequencies at our existing locations in connection with this proceeding.

c) Spectrum Aggregation & Current Uncontested Licence Applications

In expressing their support for spectrum aggregation, several parties also commented that with respect

to this Call, applications which are uncontested for spectrum at a specific orbital location should be

awarded to the applicants. Telesat generally agrees with this approach, subject to a determination that

the applicant meets the criteria established by the Department in the Call. These criteria must include

an assessment of whether it is warranted for the Department to award several orbital licences to Ciel at

this early and unproven stage of its existence. While Ciel may be accurate in stating that it has

brought-into-use the ITU modification at the 129ºWL BSS position using an interim satellite, it has yet

to be seen whether Ciel will serve a single Canadian customer, or proven that Ciel will follow through

on its commitment to deploy its new satellite, currently being constructed, and if so, to what extent it

13

will comply with any obligations or licence conditions to establish a Canadian presence and facilities,

as well as public benefit requirements. As these events will not occur until well beyond the

Department’s expected award of licences in the current Call process in the Spring of 2007, the

Department should carefully consider to what extent it is warranted to award multiple licences to an

unproven entity, particularly one whose parent company already has substantial orbital resources over

the Americas and around the world that may be developed in advance or in lieu of any frequencies

granted to Ciel in this process.

Table 2 below provides an overview of the satellite orbital slot applications that are in contention

between Telesat and Ciel but also highlights Telesat’s existing neighbourhoods.

Table 2 – Existing & Potential Orbital Neighbourhoods

F3

F2

F1, F1R

N1, N4i

N2, N3

N 5

Telesat Existing

BSS

Ciel 2

17 GHz BSS & Ka

Ext Ku

Ka**

17 GHz BSS

17 GHz BSS

17 GHz BSS & Ka

Ciel Appl.

17 GHz BSS v & Ka

17 GHz BSS & Ext Ku

17 GHz BSS

17 GHz BSS & Ka

17 GHz BSS

17 GHz BSS

17 GHz BSS

Telesat Appl.

107.3

138

129

118.7

114.9

113

111.1

109.2

103

99

95

91

86.5

82

78

72.5

Orbital Slots

F3

F2

F1, F1R

N1, N4i

N2, N3

N 5

Telesat Existing

BSS

Ciel 2

17 GHz BSS & Ka

Ext Ku

Ka**

17 GHz BSS

17 GHz BSS

17 GHz BSS & Ka

Ciel Appl.

17 GHz BSS v & Ka

17 GHz BSS & Ext Ku

17 GHz BSS

17 GHz BSS & Ka

17 GHz BSS

17 GHz BSS

17 GHz BSS

Telesat Appl.

107.3

138

129

118.7

114.9

113

111.1

109.2

103

99

95

91

86.5

82

78

72.5

Orbital Slots

100% support of ExpressVuStarChoice

BarrettExisting Neighbourhood

CSUA & CABSupport of Aggregation

With respect to Licence # 16 (Ka-band at 109.2°WL), Telesat notes that Mexico currently has ITU

priority for 500 MHz of the Ka-band spectrum, by virtue of the MEXSAT-109.2 KA filing. However,

the associated Mexican network must be brought into use no later than March 6, 2008. Licensing of

this spectrum has been the subject of a domestic proceeding in Mexico, which was initiated in part

because of interest from Quetzsat, the SES affiliate in Mexico. Telesat understands that this process

has been suspended and it is uncertain whether Mexico will be able to bring the MEXSAT-109.2 KA

14

network in to use prior to the ITU deadline. That being the case, Canada’s CANSAT-19 filing would

establish Canadian priority over the entire 1000 MHz of geostationary Ka-band spectrum.

Consequently it is likely that Ciel, either on its own or in conjunction with affiliate Quetzsat, will have

beneficial use of the full complement of Ka-band spectrum at this location.

d) Spectrum Aggregation & Current Contested Licence Applications

Licences # 14 and # 17, 17 GHz BSS at 107.3° and Extended Ku-band at 111.1° WL

Telesat and Ciel have both applied for these authorizations. However the comments filed by Canadian

satellite users in this proceeding, the support letters filed with Telesat’s application, and the

Company’s detailed applications for these two licences, provide a solid and compelling case for award

of these licences to Telesat. These two licences are of primary interest to Star Choice to enable

expansion of its existing DTH neighbourhood, specifically to include extended Ku-band capacity at

both the 107.3 and 111.1° WL positions. Star Choice’s letter of exclusive support for Telesat (as filed

November 15, 2006 with Telesat’s applications for Licences # 14, 17, 18 and 23) provided the business

rationale why Star Choice, the largest satellite user at the 107.3° and 111.1° WL orbital locations,

believes that Telesat’s proposed plans for this orbital DTH neighbourhood are the only ones that will

meet Star Choice’s expansion and backup requirements.

This support for Telesat’s plans was reinforced by all the major Canadian broadcasters who have filed

comments on December 15th, and was summarized by the following comments from the CSUA:

“… we strongly urge the department to ensure that Canada obtains all orbital resources in the

existing DTH neighbourhoods, to allow for growth and improved redundancy. Star Choice,

Telesat’s existing customer at this location, has stated its exclusive support for Telesat for these

licences [#14 and #17] ….CSUA agrees with, and fully supports, the rational provided by Star

Choice.” [text in parentheses added] CSUA’s comments, December 15, 2006, Page 4.

Telesat’s application clearly meets the criteria outlined in the Call requiring that applications meet the

needs of users, have credible business plans and are supported by letters of commitment from Telesat’s

partners. Ciel’s applications have not met these requirements of the Call. As a result, by the

application of the licensing criteria set forth by the Department, Telesat respectfully submits that the

Department should award these licences to Telesat.

15

Licences #23 and #24 for Ka-band and 17 GHz BSS spectrum at 118.7°WL

Telesat notes that its applications for Licences #23 and #24 are in keeping with the spectrum

aggregation principle. The C and Ku band spectrum at the 118.7°WL position was awarded to Telesat

in 2001. With the launch of Anik F3 later this year, these bands will anchor a new Canadian-licensed

Telesat orbital neighbourhood – a neighbourhood that Telesat wishes to grow to also include Ka-band

and 17 GHz BSS. In addition, Telesat has made significant efforts to ensure that Canadian priority has

been retained for the valuable Ka-band spectrum at this orbital location. Telesat’s efforts and

contributions associated with securing the 118.7°WL position have not wavered over the past six years.

Telesat remains committed to developing this licence application, which is critical to both Telesat and

Barrett Xplore Inc. in terms of the long-term viability of their satellite broadband services.

Telesat is pleased to have received the support of Barrett Xplore, Canadian Satellite Radio Investments

and CORUS Entertainment Inc. for its applications for these two licences. In addition, Star Choice and

APTN strongly endorsed Telesat’s Ka-band plans in their Letters of Support filed with Telesat’s

applications.

Moreover, we urge the Department to give particular credence to the comments of Barrett Xplore, the

only commenter that actually is procuring and delivering Ka-band capacity to Canadians today.

Working closely with Telesat, Barrett has built a successful broadband service used today by tens of

thousands of Canadian homes and small businesses across the country. While others talk about

bridging the digital divide, Barrett and Telesat have built that bridge and have been delivering

broadband services to otherwise unserved areas since 2005, using Ka-band on Anik F2. Indeed, this

service has been so successful that additional Ka-band capacity is now needed in certain geographic

areas.

Telesat has developed a three-stage plan to meet the growing needs of Barrett and other Ka-band

broadband service providers in Canada. The first stage involves provision of additional Ka-band

capacity in the geographic areas of highest demand, using Anik F3 at 118.7°WL, for which Telesat has

an interim Ka-band authorization. The second stage involves construction of a new satellite with

extensive, full Canada coverage Ka-band capacity, following grant of permanent authorization by the

Department to Telesat for Ka-band at 118.7°WL. This new satellite will involve a construction period

of about 44 months before it is able to supplement the service to be provided by Anik F3. The final

stage, following the grant of licence, will add new Ka-band capacity to Telesat’s existing orbital

neighbourhood at the 91°WL location.

16

Telesat’s Ka-band licence applications which form the basis of the Company’s comprehensive long

term Ka-band capacity plan are anchored by actual customer and end-user capacity demand and

interest, given credence by existing services and business plans. All of these elements, as well as

Barrett’s exclusive support, reinforce the strength and viability of Telesat’s Ka-band licence

applications at 118.7° as well as at 91 °WL.

By contrast, the public-domain portion of Ciel’s Ka-band applications for either the 118.7° or 91°WL

locations provided few details on the nature of their satellite plans, the basis for their Ka-band

business, Canadian commitments for Ka-band capacity, and the actual amount of Ka-band capacity

they plan to deliver to the Canadian market. The justification given for the limited support received by

Ciel was a desire to promote competition for the potential pricing and innovation benefits that might

result. However, this support and Ciel’s applications provided no commitment or even a strong

indication as to the level of Ka-band capacity needed, or that would actually be used, by these parties.

Finally, Telesat strongly contends that the most cost-effective and efficient manner of introducing new

frequency bands to the Canadian market is through applying spectrum aggregation. Having created an

orbital platform at the 118.7°WL location with Anik F3, Telesat is best positioned to augment the

Anik F3 services with the addition not only of Ka-band, but also of 17 GHz BSS capacity for Canadian

service providers. Barrett has referenced the potential growth of its service to include exploitation of

the 17 GHz BSS band. Telesat believes that the 17 GHz BSS band will be used for two purposes – to

augment existing capacity for DTH services, and to provide a platform for new and innovative services

such as interactive television, provided in concert with Ka-band broadband services. Logically, the

former will predominate in orbital neighbourhoods where DTH services are provided today, whereas

the latter is an obvious adjunct to the Ka-band services offered by Barrett and other Canadian service

providers, a synergy best realized at 118.7°WL. Hence, the Department should facilitate the

introduction of such innovative services by awarding not only the Ka-band, but also the 17 GHz BSS

authorizations at 118.7°WL to Telesat.

Licences #8 and #9, 17GHz BSS and Ka-band spectrum at 91°WL

Telesat notes that a strong majority of parties who chose to comment on these licence applications

supported Telesat’s applications. While these applications are largely broadband driven, Telesat was

especially pleased by CAB’s support of the Company’s Ka-band development plans at the 91°WL

location - “Since it is unlikely that a separate Ka-Band only satellite at 91°would be viable, the CAB

would also support Telesat’s proposal associated with Licence 8.” CAB comments December 15, 2006,

Page 4.

17

The basis for awarding a spectrum licence must include a number of essential elements including, but

not limited to: a sound business plan, financial and technical resources to execute the plan and the

realization of certain benefits to Canada, consumers, business and the Canadian satellite industry. The

Department’s evaluation criteria in its Call also reflects this view. In this context Barrett Xplore,

Canada’s only national Ka-band broadband service provider, has chosen to reiterate its exclusive

support for Telesat’s applications. Barrett has an existing satellite broadband business, its subscriber

growth is rising exponentially and it has a detailed business strategy on how it plans to roll out services

in this fledgling satellite broadband market. No other commenter in this process can make the same

statement. Barrett has shared its plans with Telesat and those plans form the key components of

Telesat’s applications to develop Ka-band capacity at the 118.7° and 91°WL orbital locations.

Here again, Telesat has met the criteria of the Call with a customer commitment for necessary

capacity, while Ciel has not. Barrett Xplore and other satellite broadband service providers have

existing Ka-band businesses that are growing rapidly and will require the Ka-band capacity at the

91°WL location to meet their future service requirements.

Barrett’s interest in 17 GHz BSS has also been included in Telesat’s licence applications # 9 and #24.

Most comments also recognized that previously unused spectrum, such as the 17 GHz BSS frequency

band, could best be assured of being brought into use by enabling Telesat to further develop its 91°WL

orbital neighbourhood to include this spectrum. For example as emphasized by the CAB, “the

Department should place paramount consideration on the ability of the chosen licensee to maximize

opportunities for the expansion of Star Choice/ Cancom and Bell ExpressVu satellite services in the 17

GHz BSS and Extended Ku bands, within their existing DTH orbital neighbourhoods.”

iii) Canadian Benefits

a) Canadian Broadcasting Industry

Telesat was very pleased with the solid support Canadian broadcasters have given Telesat and the

benefits that they see will be realized by Telesat’s further development of their DTH orbital platforms.

For example,

APTN stated on Page 1of its November 14th letter of support:

“Telesat’s long-standing commitment to provide service throughout Canada is critical to APTN.

Without Telesat’s commitments to provide coverage to remote, Northern and other underserved

18

communities, which includes many Aboriginal communities, the delivery of traditional satellite

broadcasting services, satellite telecommunication services and, more recently, newer satellite

broadband services to these communities would not have been possible. Telesat’s commitments

have helped the North and remote communities elsewhere to become connected to the national

broadcasting system in a way that would simply have been inconceivable otherwise.”

APTN reiterated its support in its comments of December 15, 2006, at Page 1:

“APTN has already indicated its support for Telesat in this process based on Telesat’s past record

in providing reliable satellite service to serve communities throughout Canada.”

Bell ExpressVu commented on the benefits in its letter of exclusive support dated November 14, 2006,

Page 2:

“In addition to the expansion benefits which Telesat’s plan will bring to us in terms of new

capacity, a multi-satellite procurement program as outlined by Telesat would provide us with

backup to safeguard our business against satellite failure as well as a myriad of alternatives for

future service offerings ….”

Corus Entertainment comments December 12, 2006, Page 1:

“Corus believes that… Telesat Canada can provide the Canadian system with the best service in a

manner that is in the public interest. Telesat Canada has the track record and existing plant to

ensure that this goal will be achieved.”

CSRI commented on December 15, 2006, Page 2:

“Based on our existing working relationship with Telesat…it makes sense for CSRI to work with

Telesat Canada for satellite and network management…”

SCN commented in their letter of support for Telesat on November 14, 2006, Page 1:

“Telesat has a long history of providing high quality, reliable satellite capacity to all regions of

Canada, and has demonstrated a willingness and desire to address SCN’s current and future

business needs. Your organization has helped SCN grow from a regional provider to a provider of

services on a national basis.”

19

S-VOX commented in its letter December 13, 2006, Page 2:

“Telesat has a proven track record of consistently delivering high quality service to all parts of

Canada which is fundamentally important to S-VOX reaching its audiences.”

Shaw’s letter of exclusive support November 15, 2006, page 2:

“Telesat is our supplier and we have benefited from the unified approach and economies of scale

of shaping our system around Telesat’s infrastructure, both in terms of the Anik satellites and also

with Telesat’s ground facilities.”

Clearly, Canada’s broadcasting industry fully recognizes the benefits that accrue to individual

members and the industry as a whole when new satellite capacity and spectrum, along with the

promise of new innovative services, can be brought on stream seamlessly and at a reasonable cost.

Added to this mix are the benefits Canadian consumers will realize from the growing number of new

programming undertakings that are being licensed by the CRTC on a regular basis, the launch of new

HDTV services and the associated DTV transition phase, in addition to future interactive services that

will continue to be delivered to all parts of Canada.

b) Canadian Satellite Broadband

Canadian consumers today are realizing the benefits of Telesat’s years of investment in the

development, planning and construction of Canada’s first Ka-band payload on Anik F2. Barrett

Xplore, the existing national Ka-band broadband service provider, has given its unequivocal support

to Telesat:

“BXI has chosen to offer its exclusive support to Telesat…BXI believes strongly that a quantum

addition to Ka-band satellite capacity is critical to delivering broadband or high-speed Internet

access and applications to Canadians living in rural and remote areas of Canada. We have made a

clear and important decision to partner with Telesat in order to achieve our business plan

objectives and to address this important social/economic goal for Canada. Satellite broadband has

become a reality in Canada due to Telesat’s pioneering vision, its innovation, and its investment in

developing a satellite and ground infrastructure that enables BXI to bring broadband access and

applications to Canadian consumers and business regardless of their location in Canada.” Barrett’s

comments December 15, 2006, Page 1

The introduction of a full-scale payload in the Ka-band aboard Anik F2 was possible only because it

could benefit from the cost sharing of aggregating this band with the C- and Ku-bands. Without this

20

strategy, neither Barrett nor Telesat would be experiencing the rapid market acceptance of this

innovative product.

Telesat’s long term Ka-band capacity plan will ensure that the benefits of delivering high speed

Internet access and applications to Canadians living in remote, rural and near urban areas will continue

to grow.

Star Choice specifically commented in its exclusive support letter for Telesat (November 15, 2006) at

Page 3:

“Star Choice is also interested in expanding its service offerings to include broadband via satellite.

We believe that this could be an excellent complement to the existing Star Choice DTH services

and the broadband services now offered terrestrially….Star Choice intends to review options for

capacity on the Telesat Ka-band satellite proposed to be deployed at the 118.7W.”

Telesat made significant contributions and took several risks to place Canada in the lead as the first

country to have deployed a national Ka-band broadband service. Telesat has an extremely strong

business case to develop these two orbital positions for broadband, consistent with the Department’s

criteria outlined in the Call. To deny Telesat and Barrett the ability to grow their business using the

118.7°WL and 91°WL positions would be unjustified considering the level of investment made by the

two parties in pioneering such a service which has delivered a number of benefits and has improved

the economic and social fabric of the country, but would be particularly unwarranted given that

Telesat’s applications have complied with the criteria set out by the Department while Ciel’s have not.

c) Canadian Satellite Industry

While the Call’s comments phase was specifically geared to solicit the views of Canadian satellite

users, Telesat was also delighted to receive letters of support from two of Canada’s giants in the

satellite manufacturing sector. For example, COM DEV in its support letter for Telesat dated

November 14, 2006, Pages 1-2, stated:

“Over the past 30 years, Telesat Canada has developed a close working relationship with other

members of Canada’s space team by working closely with the Canadian hardware industry as

follows:

• As a strong ally in the space telecommunications sector………

• As a cooperative provider of “first-flight” opportunities for new Canadian space

technologies…..

21

• As a strong advocate of Canadian space hardware for use on the satellites of other

countries….

Telesat has thus played a very direct role as catalyst fostering the success of Canada’s space

industry, and has contributed greatly to our success as the most export oriented space industry in

the world.”

MacDonald Dettwiler and Associates Inc. (MDA) provided its exclusive support to Telesat and

commented on the direct benefits Telesat has brought to the industry in MDA’s letter of November 13,

2006, Pages 1-2:

“Telesat Canada has had a close collaboration with our Quebec facility and in many respects, has

been our lead customer; providing valuable flight heritage for new technologies and a steady

stream of high value, high technology employment. Our solid relationship with Telesat has

allowed us to develop and maintain key technical expertise that has been successfully exported…..

MDA strongly supports Telesat’s efforts to expand its service offerings from its current orbit

allocations and wish to acknowledge the positive contributions that they have made to Canada’s

telecommunications infrastructure and our own success in international markets.”

In its support of Telesat, MDA also endorsed Telesat and its well-respected consulting group for export

of services around the world.

d) Canadian Coverage and Use

In supporting Telesat’s applications APTN urged the Department to ensure that the new licensed

satellites would “deliver reliable telecommunications and broadcasting services in all regions of

Canada, including the North”. In addition, APTN wanted assurances that capacity would remain

available for Canadian use and that the use of Canadian spectrum should also provide benefits to

underserved communities on an ongoing basis.

Telesat acknowledges the points made by APTN and reiterates that each of the satellites proposed by

Telesat in its applications will have full coverage of Canada, including the North. Secondly, Telesat

will continue its long-standing practice of making capacity on each of its proposed satellites available

first to Canadians. Telesat’s coverage of all of Canada has enabled the development of applications

and the delivery of broadband services to aboriginal communities across Canada.

22

e) Competition

Some interested parties commented on their support for satellite competition in the Canadian market.

Telesat notes that the Canadian satellite market has been open for competition since March 2000.

Since that time, the Department has authorized over 60 foreign satellites to operate in Canada.

Moreover, in 2004, Ciel was licensed by the Department as a Canadian geostationary satellite operator.

Competition is alive and thriving in the Canadian market which includes not only the many other

satellite offerings available but also any number of terrestrial solutions. The benefits of competition

are, among others, lower prices, innovative and leading-edge services, network reliability and quality

of service. Ultimately, however, the benefits of competition flow to the customer, and the indicator of

a successfully competitive market is customer satisfaction. The overwhelming support which Telesat

has received from the Canadian satellite user community, including those prepared to make capacity

commitments, clearly demonstrates the level of user satisfaction with Telesat services and should leave

no doubt that competitive forces are fully at work in the Canadian satellite market.

In their comments, several parties reiterated the existence of satellite competition in Canada. For

example, the CSUA in its December 15th comments validates the competitive nature of the market,

stating at Page 4:

“The service supplier at this neighbourhood, ExpressVu, used the Gazette call process much like a

competitive request for proposal. Both Telesat and Ciel have presented their proposals for slot

development to ExpressVu and ExpressVu has made a clear choice in favour of Telesat.”

The CSUA also made the identical observation with respect to Star Choice at Page 5 of its submission.

The “Canadian satellite market” does not, in fact, exist as a standalone and independent entity.

Satellites by their very nature cover several geographic areas and thus multiple jurisdictions. Satellite

operators are positioning themselves as global and regional players, and as mentioned previously,

some have many years’ head-start and have been reaping the cost-efficiency benefits of spectrum

aggregation and large satellites. Competition in the Canadian market is subject to the forces of that

global consolidation, and Telesat is not immune in having had to meet that competition for several

years.

To illustrate this, Figure 1 shows the number of bands deployed in the North American arc on Telesat

satellites for which a permanent authorization has been granted by Industry Canada. They account for

twelve licences on seven satellites operating at six orbital locations. In contrast, Figure 2 shows the

number of satellites (19) operating in the same arc by the SES family of companies (including Ciel), as

well as the multitude of active coordination filings and APIs spanning five frequency bands at 64

23

orbital positions. The newly combined Intelsat/PanAmSat is also dramatically larger than Telesat,

with more satellites than even SES in the North American arc.

Clearly the Canadian satellite market is not immune to the significant presence of these operators and

the intense competitive pressure they place on Telesat. Canadian customers of Telesat are

sophisticated buyers of a variety of services, and they approach satellite services in the same way as

they do other products -- by shopping for the best value. They would not make a commitment to take

service from Telesat if the offering was not the best available in the market.

It is incumbent on the Department to recognize this state of competition in the market, and not to

constrain Telesat in its ability to operate on the same basis and under the same conditions as its

competitors. If Telesat is to compete effectively and if its users and the Canadian public are to enjoy

the benefits of a fully competitive market and the other manifold public interest benefits associated

with a spectrum aggregation licensing approach, the Department should grant each of the Company’s

applications. Telesat strongly believes that the application of the decision criteria set forth by the

Department in this proceeding requires such a result.

24

Figure 1 – Telesat’s North American Arc

Figure 2 – SES Family of Companies in the North American Arc

25

Conclusion

In every one of its applications, Telesat has met all of the criteria and adhered to all of the principles

established by Industry Canada in this Call.

• Telesat’s applications promote Canada’s telecommunications objectives. They propose

innovative and advanced services which respond to users’ needs- and those same users have

amply demonstrated their commitment and support. Telesat’s commitment to the principle of

spectrum aggregation is fully consistent with enhancing the competitiveness of Canadian

telecommunications at both the national and international levels – indeed it is a competitive

necessity - and will advance Canadian satellite service offerings in the domestic market and

the larger market of the Americas, all while continuing to deliver the highest quality of

service to all regions of Canada;

• Telesat’s proposals have been structured carefully to ensure that they are supported with a

solid business approach and support from partners, and that the use of spectrum is in

compliance with all ITU regulations and timing considerations;

• Telesat’s applications were developed with a Canada-first approach, and as a result they

maximize the level and breadth of benefits to Canadians;

• Telesat is, and will be, fully compliant with the Canadian ownership and control regulations.

All of its satellites are and will continue to be under Canadian direction and control and

operated from facilities located in Canada; and

• Telesat has proven itself to be a world-class satellite owner and operator, capable of the

planning, procurement, implementation and operation of these proposed satellite projects.

By contrast, the applications of Ciel that overlap with Telesat’s do not meet the Department’s criteria. Ciel

lacks commitments from users and, as a result, has been unable to put forward detailed commercial and

technical showings. Telesat urges the Department to acknowledge the supplications of the majority of the

Canadian user base to ensure their continued access to capacity by awarding Telesat its requested licences.

Finally, it is Telesat’s hope that the Department, having initiated this significant and enormous effort to

deliver new satellite spectrum in Canada, will now move towards finalizing the evaluation of applications

and the award of licences. As the Department is aware many of the applications submitted have inherent

deadlines. Any delays in the awarding of licences past mid-2007 could jeopardize Canada’s ability to

26

retain its ITU priority to orbital spectrum and also would curtail business expansion plans of existing

satellite users due to a lack of satellite capacity. Timely completion of the current Call process is therefore

in the national interest.

This concludes Telesat's comments to the Reply phase of the Call. The Telesat team is available at your

convenience should you have any questions concerning these comments or any other matters related to the

Company's licence applications.

Yours truly,

Ignacy

c.c Mr. Dave Lewis, Ciel

Interested Parties (Comments)

ANNEX 1

Page 1 of 2Press Release

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SESAAMERICOM<b,̂ .H%**& G--.„

AMC-18 Successfully Launched from Kourou Spaceport

Ariane 5 ECA Performs Perfectly

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December 8, 2006 - Princeton, N.J - SES GLOBAL (Euronext Paris and Luxembourg Stock Exchange: SESG)announces that the AMERICOM-18 (AMC-18) satellite which is to be operated by SES AMERICOM, an SES GLOBALcompany, was successfully launched onboard an Arianespace Ariane 5 EGA launch vehicle from the French GuianaSpaceport in Kourou today at 7:08 p.m. local time (5:08 p.m. EST.; 22:08 p.m. GMT). After 32 minutes, the spacecraftseparated from the Ariane Upper Stage and was placed into geostationary transfer orbit and within moments the satellrsent an initial signal which was received at Lockheed Martin's Uralla, Australia facility. (6:08 p.m. EST; 23:08 GMT).

Edward Horowitz, President and CEO of SES AMERICOM, said, "The launch of AMC-18 is a proud moment for theAMERICOM team. It is also a proud moment for the Lockheed Martin team who has built and delivered an exceptionalspacecraft, and for the Ariane team, which has just launched the 25th spacecraft for SES," He continued, "We now lookforward to bringing AMC-18 into service as we will be creating America's only three-satellite HDTV neighborhood, HD-PRIME™. At this tipping point in the development of the HD market, we're investing in critically needed bandwidth to futhis new channel growth."

Marshall Byrd, Vice President and General Manager, Lockheed Martin Commercial Space Systems, said, "LockheedMartin has a tremendous history with SES AMERICOM, starting with the launch of Satcom F1 in 1975. The first A2100spacecraft, AMC-1, was launched in 1996 for SES AMERICOM. Lockheed Martin recognizes and deeply appreciates tttrust that SES AMERICOM has placed in us throughout our 30-year business relationship and we are proud once agairto provide mission success for one of our most long-standing customers."

Jean-Yves LeGall, President and CEO of Arianespace, said, "I would like to thank SES AMERICOM for placing theirconfidence in Arianespace to deliver AMC-18 safely into orbit. AMC-18 is the twenty-fifth satellite that Arianespacelaunched for SES GLOBAL, representing 22 years of fruitful cooperation."

About AMC-18AMC-18 is an all C-band satellite, designed to offer full North American coverage including all 50 U.S. states, theCaribbean and Mexico from 105 degrees west longitude. It will become the third satellite in the HD-PRIME neighborhocjoining AMC-10 and AMC-11, which are near capacity. In addition, cable head ends are enjoying access easy-to-installtriple-feed antennas accessing AMC-18 plus two additional cable satellites, AMC-1 at 103 degrees West and AMC-4 at101 degrees West. Working with its customers and the cable industry, AMERICOM has installed triple-feed antennas acable head-ends serving the majority of the U.S. cable households to facilitate their reception of cable programming froall three spacecraft.

AMC-18 was procured by SES GLOBAL Satellite Leasing Ltd., an SES company located on the Isle of Man; thespacecraft will be operated and marketed by SES AMERICOM. The satellite, built by Lockheed Martin CommercialSpace Systems (LMCSS), will be the 13th A2100-based spacecraft in the AMERICOM fleet. LMCSS will perform thetransfer orbit operation and deliver AMC-18 to 80 degrees West; AMERICOM takes over the spacecraft to begin in-orbitesting on December 19th.

About SES AMERICOM

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The largest supplier of satellite services in the U.S., SES AMERICOM is recognized as a pioneer of global satellitecommunications services. Celebrating the 30th anniversary of the launch of its first satellite, the company today operatea fleet of 18 spacecraft in orbital positions predominantly providing service throughout the Americas. As a member of trSES GLOBAL family, SES AMERICOM is able to provide end-to-end telecommunications solutions to any region of theworld via a fleet of 44 satellites. In addition, AMERICOM Government Services, a wholly owned subsidiary, is dedicateeto providing satellite-based communications solutions to both civilian and defense agencies of the U.S. government. Wiits combined operations, SES AMERICOM serves broadcasters, cable programmers, aeronautical and maritimecommunications integrators, Internet service providers, mobile communications networks, government agencies,educational institutions, carriers and secure global data networks with efficient communication and content distributionsolutions.

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Monica Morgan, (1)609-987-4143monica.morgan@ses-americom.com

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