Attachment ex parte

This document pretains to SAT-AMD-20031118-00332 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2003111800332_412314

Mobile    Satelite Ventures to



                                                December 16, 2004

         Via Hand Delivery
         Ms. Marlene H. Dortch
         Secretary
         Federal Communications Commission
         445 12th Street, S.W;
         Washington, D.C. 20554
                 Re:    Mobile Satellite Ventures Subsidiary LLC
                        Ex Parte Presentation
                        1B Docket No. 01—185
                        File No. SAT—MOD—20031118—00333 (ATC application)
                        File No. SAT—AMD—20031118—00332 (ATC application)
                        File No. SES—MOD—20031118—01879 (ATC application)
         Dear Ms. Dortch:

                On December 13, 2004, Peter Cowhey, Dean ofthe UC San Diego Graduate School of
         International Relations and Pacifie Studies and an advisor to Mobile Satellite Ventures LP, met
         with Donald Abelson, Jim Ball, Richard Engelman, Anna Gomez, Sharina Smith, David
         Strickland, and Thomas Tycz ofthe International Bureau to discuss the above—referenced
         rulemaking. Dean Cowhey discussed how appropriate policies in this proceeding would promote
         consumer welfare through innovation and competition (including compettive entry), promote
         efficient spectrum use, prevent harmful interference, and be consistent with United States
         obligations internationally.
                 Dean Cowhey shared his assessment that there is a substantial opportunity for the
         development of wireless systems that offer hybrid satellte—errestrial capacity. This opportunity
         is supported by the evolution of wireless broadband air interfaces, the ability ofthese air
         interfaces to support all—IP transport, and the desire by large ‘non—wireless" operators to expand
         their service bundle to include two—way wireless services. A satellte—terrestrial network would
         provide instant ubiquity via satelite, advantages for overcoming the digital divide and
         improving public safety, and continent—wide broadcast/multi—cast capability for certain content.
         Economies of seale in the production of equipment and economics of scope in coverage would
         reduce consumer costs and enable much bigger vertical applications than would be the case with
         a satelite—only service. The terminal devices would be in the price range ofthe full spectrum of
         choices in the current market for errestrial mobile devices, ranging from the lower end to the
         Migher end. For these economies to exist,the system must have sufficient capacity. The
         existence ofa sunk cost in satellites will provide sufficient incentive for the development of
         services that integrate the satellte and terrestrial capabilities.


        To protect others from harmful interference, Dean Cowhey encouraged the
Commission‘s use tothe extent possible of innovative spectrum management approaches rather
than overly—restrctive ex ante technical rules. Reasonable spectrum management should not be a
barrier to entry. The Commission has a variety of policy tools available i it needs to address
residual risks ofinterference.

       Please contract the undersigned with any questions regarding this matter.
                                            Very truly yours,

                                            Lon C. Levia        *
ce    Donald Abelson
      Jim Ball
      Richard Engelman
       Anna Gomez
       Sharina Smith
      David Strickland
      Thomas Tyez
      John Janka, Counsel to Inmarsat



Document Created: 2004-12-28 14:34:47
Document Modified: 2004-12-28 14:34:47

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