Attachment letter

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

IBFS_SATAMD2003111800332_413255

Tosocrescmamer rare OFcom ornce or communicmnons 20 December 2004 Mariene H Dortch en Secretary, Federal Communications Commission 445 Twoin Stroet SW reve. commout Washington DG 20554 ououe. cenatim usa +1 200 19 0107 wevintoimmonn Re:— ATG Rulemaking 1B Dockat No 01—188 Applcations of Moble Satelte Ventures Subsidiny LLC (Receven & novecred File No SAT—MOD—200st116—c0383 Fie No SAT—AVD—20031110—00802 bec 2 0 2004 Fie No SEs—M00—20031t1s.01870 Foo — MAILROOM Dear Mrs Dortch I am urting to express Ofcont‘sconcern aboutissues related to tforesaan aperation of Ancilary Terrastial Component (ATC)in e t—band, which are currenty under conideraton by the FGC. Ofcom is consemed., frsty that the recent Order and Authorisaton for MV to deploy ATC in I—band allowrs signticant increases n thlavel of ntorterence that may be recaived by the Inmarsat system, and secondy about proposals for even more dramatc eliwations tothe astablished ATC lin MSV‘s pending Pottion for Reconsideration. Ofeom has been following the ATC procsecings wi greatintrnet,since thay reise many important and difeut issuss. Ofcom agress with the prinisle of alowing fexbity in e use of spectrum uhere possile, and also agroes wih the oventding requirement to enaure that such fexibity daes not disrupt the operation of oter existng and planned services. With regard to L—band, Ofcom is acutely aware, tvough is operatorInmarsat,that spectrum for MSS is in shor supply. We tharefare agree wih tFCC‘s promise in the February 2008 ATC Orderthat ATG is a secondary servic that should not mpact on tho availabity of spectrum for MSS. Unfortinataly his promise has been compromised n the recent MSV ATG lcence grantby the decisiont alow the MSV ATC system to cause more intelerence 10 Inmarsat services than was foreseon in the 2003 ATG Order. The ATC Ordar was adaptad aftr at ieast wo yoars of debate and i is clear from the Order that tFGC spent consideraile effrt in balancing the domands ofthe ATC proponents with the requirement to protect ho expactations of MSS user and oatL—band. As mantioned aieady, Ofcom feais that the FCC was successfu in achioving is balance, and we are Tegtone + « ons mt 1o l tec |ficai cummoniions wecdomand We would be pleased to discuss thase matirs win you in more coran

en—cec— z00e 10041 rvom To: soaresessonser mere reasonably contant trat i the prescriptions ofthe ATC Order are adhered to,Inmarsats satelite systom wil not be unduly affected. However, he recent MSV ATC lcence grant upsets this dalcate balance by allwing signifeant increases in the amount ofintrference that may be caused to MSS batt in the upink and n the dowriink, Even if some aspects of the FCC inteference analysis may be conservative, we won‘t know is wih certainty untreal ATC oparatons have staried. We also noto hat Inmarsat has pointad out areas where the FCC analysis underostimatos the ameunt f Inteference that wil be caused to MSS. it would bo a mitake to alow relaxations o the carefly crfted ATC rulos at is time. it wl be easierto alow such relations n the futir,i experience shows that this is posslble wihout causing harm to nmarsat sarvices, than it would be to scale back ATC oporations that are found to cause excessve interference. This approach would also bo more in Inc wth the secondary nature of ATC. Consequenty, we requestthe CC to reconsider the dacision to alow MBV relaxations of the ATC protection limis. We also take this opportunty o express our very sttong concem wih the furtor relaxations proposed by MSV in ts Pattio for Reconsideration or the 2008 ATC Ordar. Thase relaxations go much furher than thase granted in the MSV ATC loanon and our contem with trese MSV proposals is amplifed in equal measure. We woult be pleased to discus those matters wih you in mare dotal. Yours sincoraly 202


Document Created: 2005-01-12 12:18:39
Document Modified: 2005-01-12 12:18:39
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