Amendment to STA Request (Jan 24, 1997)

5633-EX-MR-1997 Text Documents

MARITIME TELECOMMUNICATIONS NETWORK, INC.

2001-10-03ELS_48968

ALLEN & HaroLp A PROFESSIONAL LIMITED LIABILITY COMPANY INCLUDING A PROFESSIONAL CORPORATION ROBERT G. ALLEN, P.C. ‘0610—A CRESTWOOD DRIVE SsuiTe 200 DOUGLAS W. MAROLD, JR 2000 L STREET, N.W z POST OFFICE BOX 2126 ‘ — ELDRED D. INGRAHMAM* WASHINGTON, D.C. 200 ———_ MANASSAS, VIRG!NIA 2210 36 W. BRUCE WEINROD®* J. GEOFFREY BENTLEY (O3) 361—2278 5413 MAIN STREET OF COUNSEL FAX (FO3) 361—0894 STEPHENS CITY, VIRGINIA 22655 *ADMITTED IN PENNSYLVANIA ONLY PRACTICE RESTRICTED TO mMaTTERS BEFORE FCC AwD PTO **AOMITTED in D C ONLY January 24, 1997 Steve Sharkey Chief, Satellite Engineering Branch Federal Communications Commission International Bureau, Earth Stations P.0. Box 358160 Pittsburgh, Pennsylvania 15251—5160 Re: Amendment to Request for Special Temporary Authority Maritime Telecommunications Network, Inc. A&H #$1300.13 Dear Mr. Sharkey: PLEASE NOTE THAT THIS FILING CONTAINS PROPRIETARY INFORMATION. PURSUANT TO SECTION 0.459 OF THE COMMISSION‘S RULES, SET FORTH IN DETAIL BELOW, THE APPLICANT HEREBY REQUESTS THAT CERTAIN OF THE ATTACHED INFORMATION AND MATERIALS BE WITHHELD FROM PUBLIC INSPECTION. Being transmitted, in duplicate, on behalf of Maritime Telecommunications Network, Inc. ("MTN"), is an Amendment to the Request For Special Temporary Authority ("STA Request") filed by MTN on June 28, 1996. That STA Request was filed pursuant to Section 25.119 of the Commission‘s rules and to the Joint Order of the Chief, International Bureau and Chief, Office of Engineering and Technology, In _re_ Mobile Satellite—Based Communications Sservices by Crescomm Transmission Services, Inc. and Qualcomm Incorporated, DA—9%6—650, issued April 29, 1996 ("Waiver Order"). The Amendment being tendered herein has been prepared as the result of conferences held by MTN with the Commission staff on August 29, 1996; October 9, 1996; November 14, 1996; December 12, 1996; and December 19, 1996. In principal part, the Amendment consists of interference coordination studies conducted in connection with proposed Digital Shipboard Earth Station ("DSES")

Steve Sharkey January 24, 1997 Federal Communications Commission Page 2 operations in and around Norfolk, Virginia; San Diego, California; Mayport (Jacksonville) Florida; and Port Canaveral, Florida. The Amendment materials are responsive to the points raised by the Commission‘s staff in the conferences conducted on the referenced dates. Also furnished is a White Paper describing the methodology employed in conducting the above four port area studies. The research resulted in findings that the proposed operations, both at pierside and underway, can be conducted by MTN without causing objectionable interference to other licensed users of the studied frequencies. With respect to dockside operations, the four studies employed the stringent clearance criteria applicable to Fixed Earth Stations. Accordingly, the Amendment proposes operations at pierside that may be conducted on a full—time basis. The Amendment further seeks authority to operate Digital Shipboard Earth Stations from up to 250 ships within the operating limitations already defined by the Commission in the Waiver Order. Attached hereto is a fee filing check in the amount of $130 (Fee Filing Code: CGB) to cover the requisite filing fee. Pursuant to Section 0.459 of the Commission‘s Rules, MTN seeks proprietary treatment of certain portions of this Amendment, specifically, Exhibits 1 and 2. The materials contained in those Exhibits represent a very substantial investment of time, research and capital by MTN. Additionally, Exhibits 1 and 2 contain commercial and technical data that would customarily be quarded by MTN from its competitors. The methodology employed by MTN to analyze interference issues, as well as the specific presentation and depiction of graphic materials and maps employed to demonstrate that methodology, constitute a trade secret and contain valuable commercial and technical information that is the unique work product of MTN. For these reasons, this request for proprietary treatment meets the standards set forth in Section 0.457(@d)(2)(i) of the Commission‘s rules, and MTN accordingly requests, pursuant to Section 0.459 of the rules, that the information and materials contained in Exhibits 1 and 3 be withheld from public inspection.

Steve Sharkey January 24, 1997 Federal Communications Commission Page 3 In accordance with the requirements of Section 0.459(a), the proprietary materials have been physically separated from the rest of this Amendment through the use of page markers clearly delineating the beginning and ending of the proprietary materials. If there are any questions with request to this Amendment, please communicate with the undersigned. Ve truly yours Robert G. Allen RGA:vn Attachment


Document Created: 2001-10-03 09:53:19
Document Modified: 2001-10-03 09:53:19
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