Attachment supplement

supplement

SUPPLEMENT submitted by Globalstar

supplement

2005-08-26

This document pretains to SAT-AMD-20001103-00154 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2000110300154_452935

RECEIVED Before The FEDERAL COMMUNICATIONS COMMISSION AUG 2 6 2005 Washington, DC 20554 Fedenl Conmunaters Comnion Offeeot Secmiy In the Matter of ) ) File Nos: GLOBALSTAR LLC i/a GLOBALSTAR, LP. ) 183718471857186—SAT—PLA—97 ) 182.SAT—PMLA—97(64) ) For Modification of License for a Mobile ) TBFS File Nos. Satellit Service System in the 2 GHz Band ) SAT—LOA—19970926—00151—154 ) SAT—LOA—19970026—00156 For Waiver and Modification of J SAT—AMD—20001103—00154 Implementation Milestones for ) SAT—MOD—20020717—00116—119 2 GHz MSS System ) SAT—MOD—20020722—00107—110 ) SAT—MOD—20020722—00112 ) Call Signs $252002172723724 To: The Commission SUPPLEMENT TO PETITION FOR RECONSIDERATION Globalstar submits this supplement to its petition for reconsideration*"of the Commission‘s decision not to reverse the International Burean‘s cancellation of Globalstar‘s 2 GHz mobile satellite service (MSS) authorization»" As Globalstar‘s petition remains pending before the Commission, Globalstar now desires to update the Commission with its specific plans for construction and launch of a 2 GHz MSS system if the Commission grants its petition and reinstates ts authorization." 2 Globalsr, Ption for Reconsidention,File Nos. SAT—LOA—19970926—00151/52!53!54!56, t al.(iled Juy 26, 2000 £ Memorandure Opinionand Order, Applicarion of Globalstr, LP, For Modifcation of License for a Mobile—Sareite Service System in the 2 GHiz Band, 18 ECC Red 1249 (2003). » To the extenttht Globalstar‘spertionfor reconsideration mightbe viewed as akinto a pending applicaton, Globalstar blieves that submissionofthe information contained in the supplement to is peiton for reconsideration is necessary t ensurethe contnuing accuracy and completenessof that application, as required by section 1.65othe Commission‘s rules, 47 CER. $ 1.65.

Globalstar is now in itssixth year of providing MSS voice and data services. Globalstar service is available in all areas of the world except central and southemm Africa, Southeast Asia, and the Indian subcontinent, regions in which Globalstar is currently negotiating to expand coverage. As of June 2005, Globalstar had 153,000 subscribers in more than 120 countries, which reflects an average annual growth rate of 45 percent during Globalstar‘s first five years of service, and an astounding increase of 50 percent in the last 18 months alone. Globalstar is committed to meeting the needs ofits current and future customers for satellite—based voice and data telecommunications services anywhere at any time. Consistent with this vision, in April 2005, Globalstar applied for ancillary terrestrial component ("ATC") authority in order to enable it to make more efficient and intensive use ofits assigned spectrum, and to expand and broaden its customer base.* Upon grant of its applications for ATC authority, Globalstar is poised immediately to accelerate development of ATC phones. Globalstar currently provides MSS service using its constellation of 40 non—geostationary orbit ("NGSO®) satelites at the 1.6/2.4 GHz band and 4 in—orbit spares."‘ The number of new customers and the bandwidth demands of new services necessitate that Globalstar seek additional capacity to expand its service offerings to meet customer needs. To offer broadband service effectively, as well as to continue to provide reliable voice and narrowband data services to its growing subscriber base, Globalstar needs additional spectrum. The 2 GHz MSS spectrum is presently, and is likely to remain, the only available allocated MSS spectrum, and it is ideally situsted to provide a means for Globalstar to increase its broadband voice and data services and # See Globalstar LLC Request for Authortyto Implement an Ancillary Terresrial Componentfo the Globalsr Above 1 GHtz, oBig LBO, Mobile Satelte Servic(MSS) System (Call Sign ES2115);Globalsar USA. LC ApplicationforModifcation of Blanket License Authorizaton for Mobile Eath Station Terminals (Call Sign E970381); RCC File Nos. SAT—MOD—20050301—00054 and SES—MOD—20050301—00261. # "Three of the four in—orbispares are temporarily outof service.

address additional vertical markets, such as aviation, while continuing to meet the demands of its existing customers. It will be difficult, if not impossible, for Globalstar to serve more customers and support innovative products without the 2 GHz authorization. Globalstar reiterates that it stands ready and financially able to design, launch and operate an MSS system at 2 GHz. As is now apparent, however, private investors will no longer finance NGSO systems. They are simply too expensive in light of the revenue that MSS systems are capable of generating over the useful life of the constellation.®‘—In keeping with the realities of the satellite services marketplace, Globalstar intends to abandon the NGSO portionor its hybrid NGSO/GSO constellationand instead deploy a single geostationary orbit ("GSO") satellite to serve the United States at 2 GHz. Globalstar also intends to construct a second on—ground spare satellite and intends over time to add two additional operational satelltes to provide global coverage in accordance with the GSO portion ofits original 2 GHz application. A next« generation 2 GHz GSO MSS system can provide significant service expansion and meet increasing marketplace demands ata fraction of the cost of a NGSO system and in less time. No question can remain about Globalstar‘s ability to build out ts modified proposed 2 GHz system or about the public interest benefits that will flow from that system. Globalstar, now over one year removed from its Chapter 11 proceeding, is infused with necessary capital to pursue opportunities to grow its service offerings. For example, in addition to its plans to # "The Commissionrecenty granted th application of ICO Satlite Services G.P.to modify ts reservation of spectrum for a NGSO system toa geostationary system. See Memorandum Opinion and Order, ICO Sarelite Services G.P. Applicationfor Modifeation of2 Git L1 Authorization, Fle No. SAT—MOD200501 10—00004, DA 08—1504 (rel. May 24,2005). SkyBridge LLC. whichin Jaly 2005 received an authorization to constrect a NGSO system, surrendered is lcense only one month lter. See Public Notce, Report No. SAT—00314, DA No. 05—2327, Aug. 19, 2005. Seealso, The Bocing Company. Order and Authorization, DA 03—2073 (re. June 24, 2003), wherein the Commission granted Bocing‘s appictionto modify ts roposed 2 GHtz sytem from a 16stelite NGSO contigurtion toa single GSO satellte. Bocingsubsequenty surrendered ts icense # Globaltr Appliation for Modification of License, Fle Nos. SAT—00115/16/17/18/19; SAT—MOD: 20020722—0010710809/10/12 (lty 17, 2002)

implement ATC, Globalstar recently has entered into a $140 million contract with QUALCOMM to develop enhanced features and second—generation products, has acquired the physical assets and business of its former service provider in Venezuela, and is adding two new Gateways in the U.S. in Florida and Alaska." s The Commission has a clear presumptive preference for a minimum of at least three competitors in a given frequency band. Specifically, in its Space Station Licensing Reform decision, the Commission stated, "we find that the factors that have led courts to disfavor mergers to duopoly also support establishing a procedure that will maintain at least three competitors in frequency band, unless an interested party can rebut our presumption that three is necessary to maintain a competitive market.""" Globalstar‘s experience in the MSS marketplace gives it a distinct edge that will enable it become a strong 2 GHz competitor and market leader. If the Commission reinstates Globalstar‘s license, Globalstar is willing to commit to the same construction schedule and the same implementation timetable that the International Bureau imposed on ICO in its order modifying ICO‘s spectrum reservation""" If the Commission were to reinstate the license by November 30, 2005, Globalstar would require about three months to enter into a non—contingent contract for construction and launch ofthe satellte. We hope and expect that the developmental work done between July 2002 and January 30, 2003, when the Hicense was cancelled, can be recovered and can reduce the time necessary to achieve Critical » Giobaltr recently eceived an STA o operatea new gateway in Scbrig, Horida to meet prowingservice needs, including hurricane emergencyservices. See Globalstar LC Applicationfor Earth Station Special Temporery Auhoriy,File No SES—ST2005062000784 (gramted July 13, 2005). # Amendents ofthe Commission‘s Space Station Licening Rules and Polices, 18 PCC Red 10760, 10789 9 64 2002 W Noedisupre

Design Review of the GSO satellite. If so, then Globalstar will meet the same schedule that ICO intends to meet from commencement of coordination ofthe physical operation of the satellte as follows: Proposed Implementation Milestone Proposed Deadline Non—contingent contract March 1, 2006 Critical design review September 1, 2006 Commence coordination of the physical October 15, 2006 operation of the sstellite Place order for TWTAs December 15, 2006 Complete bus wire hamess fabrication April 15, 2007 Start communications paneUpayload June 1, 2007 integration Complete propulsion integration August 1, 2007 Complete bus integration October 1, 2007 Complete coordination ofthe physical October 15, 2007 operations of the satellte, and file any modification applications necessitated thereby Complete main body integration January 1, 2008 Complete reference performance test April 1, 2008 Complete thermal vacuum test June 1, 2008 Launch satellte October 1, 2008 Centify that entire system is operational October 15, 2008 Based on the foregoing, Globalstar urges the Commission to act prompily to grant its pending petition for reconsideration.. Immediate action is particularly warranted in light of the

Commission‘s pending proposals regarding the possible redistribution and reallocation of 2 GHz MSS spectrum Respectfully submitted, Richard S. Roberts William T. Lake William F, Adler Wilmer Cutler Pickering Hale Globalstar LLC and Dorr LLP 461 Milpitas Blvd. 2445 M Street, NW. Milpitas, Califomia 95035 Washington, D.C. 20037 (408) 933—4401 (202) 6e3—6000 August 26, 2005 d See Comment of Globalsar LLC in TB Docket No,05—220 (Aled July 13, 2005); Comment and Reply Comments ofGlobalsar LLC in 1B Docket No.0%—221 (iled Jly 29,2005 and Aupust 15, 2008)

CERTIFICATE OF SERVICE 1, Nathen T. Mitchler, hereby certify that T have on this 26th day of August, 2005 caused to be served true and correct copies of the foregoing "Supplement to Petition for Reconsideration" upon the following persons via hand delivery (marked with an asterisk (*)) or via United States mail, first—class postage prepaid: Marlene Dortch * Kathryn A. Zechem Secretary L. Andrew Tollin Federal Communications Commission Wilkinson Barker Knauer, LLP 445 12th Street, SW 2300 N Street, NW, Suite 700 Washington, DC 20554 Washington, DC 20037 (202) 783141 Douglas L. Brandon J. R. Carbonell AT&T Wireless Services, Inc. Carol L. Tacker 1150 Connectiout Avenue, NW David G. Richards Washington, DC 20036 Cingular Wireless LLC (202) 223—9222 5565 Glenidge Connector Suite 1700 Atlanta, GA 30342 (404) 236—5543 Pe Nathan T. Mitchier


Document Created: 2005-08-30 16:09:11
Document Modified: 2005-08-30 16:09:11
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