Attachment letter

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

IBFS_SATAMD2003111800332_413254

h jy 405 Ex Pafte on Late FiLep December 20, 2004 ORIGINAL RECEIVED Chairman Michael K. Powell Federal Communications Commission DEC 2 8 zo0 Office of the Secretary 445 12th Street,SW Fateal oomnuneatonConnissin Washington, DC 20554 Somnne Re: ATC RulemakingIB Docket No. Ol—185 Applications of Mobile Satelite Ventures Subsidiary LLC File No. SAT—MOD—20031118—00333 File No. SAT—AMD—20031 118—00332 File No. SES—MOD—20031118—01879 Ex parte presentation Dear Chairman Powell: A0S, Ic. is writing to express its concems aboutissues raised in two related proccedings: () reconsideration of the Commission‘s Order authorizing "ATCas an extension ofMobile Satelite Service (MSS) networks, and (i) the Commission‘s review ofthe first authorization to implement ATC. AOS, Inc.is a Texas based Inmarsat Service Provider that provides Inmarsat services to a broad range of Inmarsat satellite equipment users. AO8, Inc urges the Commission to ensur 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 rules thatthe Commission adopted to constrain ATC interference are under assiult on two fronts. First, Mobile Satellte Ventures (MSV) has asked the Commission to revise ts ules and allow MSV to significantly increase ATC interference in a manner that would substantilly increase the zones around ATC base stations where Inmarsat terminals will no longer work, and in a manner tat also could degrade or interupt communications over Inmarsat spacectaft. Second, in granting the very first ATC license,the International Bureau granted waivers ofcertain of these rulesand also placed a new burden on MSS operators to demonstmte, in a very short time frame, that they willbe hurt by the deployment of an ATC base station. 11017 temnsor ose 0 Suezs No,of Goples recd onstaasrsase L ABCDE weorzzsore pesrinsous meeaosscon na

The factis that no onhas identified a way tofully prevent ATC from generating interference into Inmarsat mobile terminals oInmarsat spacecraft. The Commission‘s current ATC rules go a long way toward constraining ATC interference into MSS services, essentil that the Commission maintain and enforce those rules. Moreover,it is critical that the Commission maintain is current policies that () deviations from its ATC rules will beallowed only iit is demonstrated that the deviations will not increase ATC interference into MSS, (i ATC in the L—Band is o be phased in to allow time to study its real world effects, and ) if ATC does cause interference into MSS service, an ATC operator mustimmediately modify or dliscontinue ts operations. There are two main reasons these protections and policies must be maintained. First, the continued reliability ofInmarsatservices is essential to the safety and security—related communications ofmany federal, state and local governmental agencies. Inmarsat MSS terminals were elied on in New York City following the September 11 attacks, and the Fire Department ofNew York has recently chosen Inmarsat terminals to support ts emergency response communications. Inmarsat MSS service is relied on for these purposes because the system is independent ofthe terestril and cellular communications networks that may be unavailable or overwhelmed in an emergency. MSS—based safety and security—related communications simply eannot be atrisk of ATC interference in the time of an emergeney, when police, frefighters and other rescue personnel need relisble communications the most. Second, we are just beginaing to realize the potential for MSS to support broadband service across America, in urban, suburban, and rural areas alice. The Inmarsat—t spacceraft that are about tobe launched will support trnsmission rates of 432 kilobits per second—a rate comperitive with planned 3G networks. It therefore is not difficaltto imagine the new types ofland mobile, acronsutical, 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 faciltate the provision ofhigh quality live video feeds and news gathering in urban areas. In addition, Inmarsat‘s new broadband acronautical capabiities will rovide the opportunity to augment tcongested air trific control system in the U.S.as well as offer communications services to the generalaviation industry——commercialand private aireraft 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 ofMSS 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 citical that Inmarsat lnd mobile, aeronautical and maritime terminals are protected from interference whenever they are operated in thvicinity of ATC base stations. nasmoe

oreminem asse Fans 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 mistakenly assumed that (x) ATC will be deployed only in undefined urban areas, and (y) Inmarsat land mobile and acronautical terminals will not be operated over or near those base stations. IfInmarsat or one of ts U.S. distributors wants to protect ts operations in the vicinity of an ATC base station that will operate at high powe,it now has to do two things ) make a showing atthe FCC within a thirty day window that it ikely will have a mobile user in the vicinity of the base station, and (i) coordinate with MSV to try o avoid the effects of ATC interference. Ifthose efforts are not successfil, Inmarsat MSS service might not be possble 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 ofan ATC base station. These proceedings raise very important policy issues and we urge the Commission to give them its fullest attention and protect MSS service as described above An original and seven copies ofthis lette are enclosed. Respectfully submitted, By: Sue Robinson President, AOS,Inc. ce Commissioner Kathleen Q. Abemnathy Commissioner Michae! J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chi, Office ofEngincering and Technology Donald Abelson, Chicf, International Bureau Mariene Dortch, Secretary nasaos


Document Created: 2005-01-12 12:16:54
Document Modified: 2005-01-12 12:16:54
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