Attachment letter

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

IBFS_SATAMD2003111800332_412325

s Communications WithoutLimits December 16, 2004 DEC 2 8 2004 Chairman Michael K. Powell Federal Communications Commission Office of the Secretary 445 12th Street, SW Washington, DC 20554 Re: ATC Rulemaking, TB Docket No. 01—185 Applications of Mobile Satellite Ventures Subsidiary LLC File No. SAT—MOD—20031118—00333 File No. SAT—AMD—20031118—00332 File No. SES—MOD—20031118—01879 Ex parte presentation Dear Chairman Powell: Global Communications Solutions, Inc. (GCS)is writing to express its concems about issues raised in two related proceedings: (i) reconsideration of the Commission‘s Order authorizing "ATCas an extension of Mobile Satellite Service (MSS) networks, and (i)the Commission‘s review of the firstauthorization to implement ATC. GCS is one of Inmarsat‘s top Service Providers, worldwide. We generate approximately 70% of our revenue from Inmarsat hardware and airtime sales. Our strategic plan for the next 5 years relies heavily on the suecessful Iaunch and operation of the Inmarsat BGAN system in the United States. GCS urges the Commission to ensure that MSS services in the L— Band remain protected from ATC interference, and to preserve the abilityto deploy new and innovative MSS services in all parts of the United States, urban, suburban and rural, now and in the future, "The rules that the Commission adopted to constrain ATC interference are under assault on two fronts. First, Mobile Satellite Ventures (MSV) has asked the Commission to revise its rules and allow MSV to significantly increase ATC interference in a manner that would substantially increase the zones around ATC base stations where Inmarsatterminals will no Jonger 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 7640 Omnitech Place winglobalcoms.com Tel+1.585.9244840 Victor NY 14564—9782 Fac+1.585.9248332

Orcenber nz00 Proea waivers of certain ofthese rules and also placed a new burden on MSoperators to demonstrate, in a very short ime frame, that they will be hurt by the deployment of an ATC base station. The factis that no one has identified a way to fully prevent ATC from generating interference into Inmarsat mobile terminals or Inmarsat spacecraft. The Commission‘s current ATC rules go a long way toward constraining ATC interference into MSS services, and it is essential that the Commission maintain and enforcethose rules. Moreover, it is critical that the Commission maintain its current policies that () deviations from its ATC rules will be allowed only if it 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 its real world effects, and (ii)if ATC does eause 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. Fizst, the continued reliability of Inmarsatservices is essential to the safety and security—related communications ofmany 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 terminals to support its emergency response communications. Inmarsat MSS service is relied on for these purposes because the system is independent of the terrestrial and cellular communications networks that may be unavailable or overwhelmed in an emergeney. MSS—based safety and security—related communications simply cannot be atrisk of ATC interference in the time of an emergency, when police, firefighters and other rescue personnel need reliable communications the most. Second, we are just beginning to realize the potential for MSS to support broadband service across America, in urban, suburban, and rural areas alike. The Inmarsat—4 spacecraft that are about to be launched will support transmission rates of432 kilobits per second——a rate competitive with planned 3G networks. It therefore is not difficult to imagine the new types of land mobile, acronautical, and maritime MSS services that soon will be offered. Inmarsat‘s new BGAN land mobile service will support the extension of corporate communications networks, as well as facilitate the provision ofhigh quality live video feeds and news gathering in urban areas. In addition, Inmarsat‘s new broadband aeronautical 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 aircraft ofall sizes. Inmarsat—4 thus provides a unique opportunity———in fact, the only opportunity———to provide "always—on" broadband services to airplanes, land mobile, and maritime users, regardless oftheir location. The full potential of MSS broadband services can come to fruition only ifthe Commission looks forward, and develops ATC rules and policies that protect the future, rather than simply protecting past MSS technology. For these reasons, it is critical that Inmarsat land mobile, aeronautical and maritime terminals are protected from interference whenever they are operated in the vicinity of ATC base stations. ATC, as a secondary, non—interfering service, should not be allowed to constrain the continued deployment ofMSS throughout the United States. Unfortunately, the FCC has

orcenbe i1e Paas mistakenly assumed that (x) ATC will be deployed only in undefined urban areas, and (4) Inmarsatland mobile and acronautical terminals will not be operated over or near those base stations, IfInmarsat or one of its U.S. distributors wants to protectits operations in the vicinity of an ATC base station that will operate at high power, it now has to do two things () make a showing at the FCC within a thirty day window that it likely will have a mobile user in the vicinity ofthe base station, and (i) coordinate with MSV to try to avoid the effects ofATC interference. If those efforts are not successful, Inmarsat MSS service might not be possible in the vicinity of that base station in the future. MSS subscribers reasonably expect that their terminals 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 of an ATC base station. These proceedings raise very important policy issues and we urge the Commission to give them ts fullest attention and protect MSS service as described above. An original and seven copies of this letter are enclosed. Respectfully submitted, Global Communications Solutions, Inc. 8y Gef_ Frank York President ce Commissioner Kathleen Q, Abernathy Commissioner Michael J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chief, Office ofEngineering and Technology Donald Abelson, Chict International Bureau Marlene Dortch, Secrctary


Document Created: 2004-12-28 16:04:27
Document Modified: 2004-12-28 16:04:27
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