Attachment letter

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

IBFS_SATAMD2003111800332_412316

December 20, 2004 RECEIVED FCC ‘The Honorable Michael K. Powel! Clainows DEC 2 0 2004 Federal Communications Commission Feige 445 12th Street, SW Pereimks Washington, DC 20554 Re: Applications ofMobile Satellte Ventures Subsidiary LLCFCO/V© File No. SAT—MOD—20031118—00333 File No. SAT—AMD—20031118—00332 DEC 2 8 2004 File No. SES—MOD—20031118—01879 Ex parte presentation Dear Chairman Powell: GMPCS Personal Communications Inc. ("GMPCS") is writing to express its concems about issues raised in two related proceedings: () reconsideration ofthe Commission‘s Order authorizing "ATC" as an extension ofMobile Satelite Service (MSS) networks, and () the Commission‘s review ofthe frst athorization to implement ATC. GMPCS, located in Pompano Beach, Floride, is one ofthe nation‘s largest resellers of mobile satellite ervices, including services offered via the Inmarsat, Iidium, and Globalstar satelite networks. GMPCS sells services directly to end users, including many customers who intend to use their terminals in the United States. GMPCS urges the Commission to ensure that MSS services in the L—Band remain protected from ATC interference, and to preserve the ability to deploy new and innovative MSS services in all parts ofthe United States, urban, suburban and rural, now and in the future. The uies that the Commission adopted to constrain ATC interference are under assault on two fronts. First, Mobile Satelite Ventures (MSV) has asked the Commission to revise its ules and allow MSV to significantlyincrease ATC interference in a manner that would substantially increase the zones around ATC base stations where Inmarsat terminals will no longer work, and in a manner that also could degrade or interrupt communications over Inmarsat spacecraft. Second, in granting the very first ATC license, the International Bureau granted waivers ofcertain ofthese rules and also placed a new burden on MSS operators to demonstrate, in a very short time frame, that they will be hurt by the deployment ofan ATC base station. ‘The fact is that no one has identifed a way to fully prevent ATC from generating interference into Inmarsat mobile terminals or Inmarsatspacecraft. The Commission‘s current

Oremnseas roe Proee ATC rules go a long way toward constraining ATC interference into MSS services, and it is essentil thatthe Commission maintain and enforce those rules. Moreover, it is ritial thatthe Commission maintain its current policiesthat () deviations from its ATC rules will be allowed only ifi is demonstrated that the deviations will not increase ATC interference into MSS, (i) ATC in the L—Band is to be phased in to allow time to study it real world effects, and (i) if ATC does cause interference into MSS service, an ATC operator must immediately modify or discontinue its operations. There are two main reasons these protections and policies must be maintained. First, tcontinued reliabilty of Inmarsat services is essentialto the safety and security= related communications of many federal, state and local governmental agencies.. Inmarsat MSS terminals were relied on in New York City following the September 11 attacks, and the Fire Department of New York has recently chosen Inmarsat terminalsto supportits emergency response communications. Inmarsat MSS service is relied on for these purposes because the system is independent of the terestrial and cellular communications networks that may be unavailable or overwhelmed in an emergeney. MSS—based safety and security—related communications simply eannot be atrisk ofATC interference in the time of an emergency, when police,frefighters and other rescue personnel need reliable communications the most. Second, we arejust beginning to realize the potential for MSS to support broadband service across America, in urban, suburban, and rural arcas alike. The Inmarsat—4 spacecraft that are aboutto be Iaunched will support transmission rates of 432 kilobits per second——a rate competitve with planned 3G networks. It therefore is not difficul to imagine the new types of land mobile, aeronautical, and maritime MSS services that soon will be offered. Inmarsat‘s new BGAN land mobile service will support the extension ofcorporate communications networks, es well as fcilitatethe provision ofhigh quality live video feeds and. news gathering in urban areas, In addition, Inmarsat‘s new broadband acronautical capabilities will provide the opportunity to augment the congested air traffic control system in the U.S.,as well as offer communications services to the general aviation industry——commercial and private aireraft ofall sizes. Inmarsat—4 thus provides a unique opportunity:——in fact, the only opportunity——to provide "always—on"" broadband services to ailanes, land mobile, and maritime users, regardless oftheir location. The fill potential ofMSS broadband services can come to fruition only i the Commission looks forward, and develops ATC rules and policies that protect tfuture, rather than simply protecting past MSS technology. For these reasons, it is crtical that Inmarsatland mobile, aeronautical and mariime terminals are protected from interference whenever they are operated in the vicinity ofATC base stations. ATC, as a secondary, non—interfering service, should not be allowed to constrain the continued deployment of MSS throughout the United States. Unfortunately, the FCC has mistakenly assumed that (x) ATC will be deployed only in undefined urban areas, and () Inmarsat land mobile and aeronauticalterminals will not be operated over or near those base stations. If Inmarsat or one ofts U.S. distibutors wants to protectits operations in tvicinty ofan ATC base station that will operate athigh power, it now has to do two things () make a showing atthe CC within a thirty day window that it licely will have a mobile user in the

Brernseem.asoe Pas vicinity of the base station, and (i) coordinate with MSV to try to avoid the effects ofATC interference. If those effortsare not successful, Inmarsat MSS service might not be possible in the vicinity oftat base station in the future. MSS subscribers reasonably expect that theirterminals will work anywhere they need them to work, The Commission should not require MSS service providers to make advance showings in order to protect their operations in the vicinity ofan ATC base station. These proceedings raise very important policy issues and we urge the Commission to give them its fillesatention and protect MSS serviceas described above. An original and seven copies of this letter are enclosed. Respectfully submitted, GMPCS Personal Communications Inc. By: Mat— fonF. Kiein General Manager ces Commissioner Kathleen QAbemnathy Commissioner Michael J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chicf, Office ofEngineering and Technology Donald Abelson, Chi, International Bureau Marlene Dortch, Sccretary


Document Created: 2004-12-28 14:44:56
Document Modified: 2004-12-28 14:44:56
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