Continued Nationwide Authority Justification

0086-EX-RR-2006 Text Documents

ORBCOMM License Corp

2006-09-28ELS_78111

                                                                                   Supplement
                                                                   ORBCOMM License Corp.
                                                                FCC File No. 0086-EX-RR-2006
                                                                           Call Sign WB2XGL

                                                                     FCC Corresp. Ref No. 4441

                                                                                       Page 1 of 1



                                        SUPPLEMENT


       ORBCOMM License Corp. (“OLC”) respectfully submits this Supplement to FCC
Application File No. 0086-EX-RR-2006 (Renewal of FCC Call Sign WB2XGL). This
Supplement is in response to a request for additional information from the Experimental Radio
Branch regarding the need for continuing experimental operation throughout CONUS in
connection with the requested authorization renewal. For the reasons stated below, there is
ample justification to renew the authorization maintaining the full CONUS operating area.
Accordingly, ORBCOMM requests that the renewal be granted without change of the previously
authorized full CONUS operating area.

¾   There is No Possibility of Harmful Interference to Any Third Party. OLC’s parent
    company ORBCOMM Inc. is the owner and operator of the ORBCOMM NVNG mobile
    satellite service system (FCC Call Sign S2103). The ORBCOMM System is the only
    operational commercial satellite system authorized by the FCC that utilizes the channels in
    the 137-138 MHz band on which the experimental equipment authorized under Call Sign
    WB2XGL operates. ORBCOMM’s commercially authorized use of the subject channels
    (which are employed for satellite downlink operations) is exclusive in the United States, and
    is coordinated and notified internationally in accordance with ITU procedures. Accordingly,
    the experimental use of these frequencies for the subject terrestrial transmitter cannot cause
    harmful interference to any third party with interference protection rights.

¾   There are a Limited Number of Experimental Units. The equipment authorized under
    Call Sign WB2XGL for which experimental license renewal is requested consists of a
    developmental terrestrial transmitter that operates on ORBCOMM downlink channels in the
    137-138 MHz band. This unit (sometimes referred as the “satellite on a stick”) is capable of
    simulating the space segment transmit portion of an ORBCOMM subscriber link. It is being
    developed for several possible uses, including an indoor test device for new user terminal
    development, and a repeater for mobile units on vehicles that are stored in warehouses or
    other buildings, or are otherwise located in areas that lack satellite coverage. At any given
    time, there are no more than about ten of these units that are operationally capable.

¾   Experimental Operation is of Limited Duration. Use of the devices covered by Call Sign
    WB2XGL is typically of very limited duration. No permanent installations or operations
    exist, or are contemplated during the proposed continuation of the experimental program.



Document Created: 2006-09-28 13:29:45
Document Modified: 2006-09-28 13:29:45

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