Attachment letter

letter

LETTER submitted by Globalstar

letter

2006-04-13

This document pretains to SAT-A/O-19910603-00010 for Authority to Operate on a Satellite Space Stations filing.

IBFS_SATAO1991060300010_497931

/\ commene w wn mss wso mmewn in uonnsne Globalstar | ... | rnpiitinn April 12, 2006 RECEIVED Mr. Donald Abelson aPr 2 6 200 A" L $ 4# * Chicf,Interational Bureau rutun Communiatons Conniason . , Federal Communications Commission areect Semin aFR 2 9" 445 Twelfth Street, S.W., Room 6—C750 Washington, D.C. 20554 Re:=— Call Sign 2115 — Globalstar 1.6/2.4 GHz: Mobile—Satellite System File No. SAT—A/O—19910603—00010 Dear Mr. Abelson: Globalstar began launching its satellites on February 14, 1998, and successfully launched twenty—four satellites (with one aunch failure) by June 10, 1999. Globalstar reported these developments to the Commission in its Annual Report pursuant to 47 C.F.R. § 25.143(e), dated June 30, 1999. Globalstar has subsequently provided timely Annual Reports to the Commission as required by Section 25.143(c) ofthe Commission‘s rules, 47 C.F.R. § 25.143(c). In addition to the annual reporting requirement of Section 25.143(e), Section 25.121(d)(2) of the Commission‘s rules, 47 C.F.R. § 25.121(d)(2), provides that For non—gcostationary satellte orbit stellites, the license term will begin at 3 a.m. EST on the date that the lcensce certifies to the Commission that is initial space station has been successfully placed into orbit and that the operations ofthat satellte fully conform to the terms and conditions ofthe space station system authorization. We have recently undertaken a review of our records of FCC flings for another purpose and discovered that we do not have a record ofsubmiting the certification required by Section 25.121(d)(2). This certification determines the date on which the fifteen (formerly ten) year non— geostationary satellite constellation license term begins. Uncertainty about the meaning ofthe phrase "the operations ofthat satellte fully conform to the terms and conditions ofthe space station system authorization" may have led to a failure to make the certification. The FCC authorization for the Globalstar System was not specific about terms and conditions but rather incorporated by reference "the technical specifications set forth in [Globalstar‘s] application and consistent with our rules unless specifically waived herein."" Under our construction contract with Space Systems/Loral, Inc.the satellites were not formally accepted by Globalstar until the in—orbit testing of at least twenty—four satelltes was completed. This occurred in June 1999. Globalstar did not place the constellation into commercial service until late—1999 when thirty—two satellites had been launched and tested, because thirty—two satellites were the minimum needed to provide an acceptable quality of service to paying customers. ! LoralQualcomm Parmership P Order and Auborization, DA »5—128, 10 FCC Red 2333 (Jan. 31, 1995), 9 24

Mr. Donald Abelson April 12, 2006 Page 2 of 2 In any event, in light of tlanguage of Section 25.121(d)(2), and in order to cure the apparent absence of an unambiguous license term initiation date, Globalstar hercby certiies thatits first four satelltes, launched together on February 14, 1998, began to operate in conformance with the terms and conditions ofthe authorization on April 21, 1998, the date on which Globalstar determined that these four satellites met the technical specifications ofthe satellite construction contract. Pursuant to Section 25.121(d)(2), Globalstar‘s operating authority for the 1.6/2.4 GHz Mobile—Satellte System will expire on April 20, 2013. We sincerely regret any confusion that our possible failure to certify the beginning ofthe license term may have caused. Please contact the undersigned if you have any questions or require any additional information. Respectfully submitted, GLOBALSTAR, INC. Vie President—Legal & Regulatory Affairs (d08) os3—4a01 williomadler@globalstar.com ce: Robert Nelson Karl Kensinger


Document Created: 2006-04-28 11:18:47
Document Modified: 2006-04-28 11:18:47
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