Narrative Statement

0240-EX-PL-1999 Text Documents

BT North America

1999-09-10ELS_16590

EXHIBIT 1

Experimental Application of BTNA

BT North America, Inc. (“BTNA”) requests experimental authority in order to test the
suitability and commercial viability of Inmarsat Mini-M terminals for use in emergency
backup communications. A great deal of attention has been focused on the possibility of
telecommunications network outages as a result of such concerns as the upcoming Year
2000 conversions, hurricanes and other weather disturbances that are predicted to
increase in severity, and several notorious system failures (such as the shut down of
paging networks due to satellite problems and MCI’s recently publicized data network
crash). Several of BTNA’s customers require a network backup plan that will support
mission-critical communications even in the event of a major problem that shuts down
the public telecommunications network.

BTNA believes that the new Inmarsat Mini-M terminals may provide an effective
means of providing continued communications in the event of network disasters. Thus,
BTNA seeks a blanket experimental authorization to deploy up to 200 Mini-M terminals
in the United States so that it can test the Mini-M terminals under varying conditions and
for differing types of communications needs. In addition, in order to gauge the
marketplace viability of such a backup capability, BTNA seeks authority to provide
commercial services to its customers as part of a limited market study pursuant to
Sections 5.202(j) and 5.206 of the Commission’s Rules. BTNA also requests that it be
permitted to sell the Mini-M terminals to its customers in order to gauge effectively the
impact on demand of the pricing of equipment and services.1 BTNA will, however,
inform the customers of the experimental nature of the authorization (and the
concomitant limits on operation and the absence of protection from interference resulting
from such temporary, secondary operation).

The Commission, on numerous occasions, has allowed experimental operation of
Inmarsat terminals. 2 In addition, as noted previously, BTNA will inform its customers
that the service is being provided pursuant to experimental authority, so that there will be
no reliance or expectation that permanent authority will be granted.3 Thus, such a license
will be without prejudice to whatever action the Commission ultimately may take with

1
Notwithstanding that the customers may own the terminals, BTNA will retain the
ability to shut down transmissions from any of its customers’ terminals if there is any
report of interference or if otherwise requested by the Commission. In this regard, BTNA
will maintain a 24-hour point of contact.
2
E.g., Experimental Actions, Report No. 315, released March 18, 1999; Experimental
Actions, report No. 314, released September 23, 1998; Experimental Actions, Report No.
309, released March 26, 1998.
3
In addition, the limited size of the market study will eliminate any possibility of
“bootstrapping” the experimental program into permanent authority.

respect to granting Inmarsat authority to provide domestic services within the United
States.4

Finally, BTNA will incorporate safeguards to ensure that the limited experimental
program proposed here will not cause harmful interference to any licensed operations in
these bands. Prior to being placed into service, the subscriber terminals will have gone
through an Inmarsat commissioning process, thus ensuring that their technical parameters
conform to the requirements of the Inmarsat satellite system. In addition, as mentioned
previously, BTNA will maintain a 24-hour point of contact in case there are any
malfunctioning terminals or any other interference concerns, and BTNA’s operations
center will have the ability to shut down immediately any terminal that is causing harmful
interference.

BTNA believes that grant of the requested experimental authorization will well serve
the public interest. BTNA will gain valuable knowledge regarding the potential use of
Inmarsat Mini-M terminals for backup telecommunications needs. In addition, BTNA’s
subscribers will enjoy added peace of mind that network disasters will not completely
shut down their communications networks.

4
E.g., Amendment of the Commission's Regulatory Policies to Allow Non U.S.
Licensed Space Stations to Provide Domestic and International Satellite Services in the
United States, Report and Order, 12 FCC Rcd 24094 (1997) at ¶¶ 118, 126 and 127.

Document Created: 2001-08-16 12:12:46
Document Modified: 2001-08-16 12:12:46

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