Attachment letter

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

IBFS_SATAMD2003111800332_413256

atcorn. Ex pante on Late rieo DIRECT ORIGINAL December 8, 2004 RECEIVED bec 1 4 zo0 Chairman Michael K.Powell ies Federal Communications Commission Snd oniies Office ofthe Secretary étee agioney 445 12th Street, SW Washington, DC 20554 Re: ATC Rulemaking, IB Docket No. 01—185 Applications of Mobile Satelite 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: Satcom Direct is writing to express its concerns about issues raised in two related proceedings: () reconsideration ofthe Commission‘s Order authorizing "ATC" as an extension of Mobile Satellte Service (MSS) networks, and (1)the Commission‘s review ofthefirst authorization to implement ATC. Satcom Directis the preferred provider of Inmarsat Aeronautical services to the US Militay. Sateom Direct 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, suburbon 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 Satelite Ventures (MSV) has asked the Commission to revise ts rules and allow MSV t significantly increase ATC interference in a manner that would substantialy increase the zones around ATC base stations where Inmarsat terminals will no onger work, and in a manner that also could degrade or intermupt communications over Inmarsat spacecraft. Second, in granting the very first ATC license, the Intermational Bureau granted waivers ofcrtain ofthese rules and also placed a new burden on MSS operators to demonstrate, in a very short time frame, that they willbe hart by the deployment ofan ATC base station. The fict is that no on has identified a way to fully prevent ATC from generating interference into Inmersat mobile terminals oInmersat spacecraft. The Commission‘s current h 0 1901 Highay A1A # SatliteBeach FL 2937+ 321—777—3000

oveniertm ran ATC rules go a long way toward constraining ATC interference into MSS services, and it is essential that the Commission maintain and enforce those rules. Moreover, it s riticl that the Commission maintsin ts current policies that () deviations from its ATC raleswill beallowed only ifit is demonstrated thatthe deviations willnot 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 ( ATC does cause interference into MSS service, an ATC operator must immediately modify or di;gom_j..:: its operations. There are two main reasons these protections and policies must be maintained. First, the continued reliility of Inmarsat services is essentialto the safty 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 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 terestrial and cellular communications networks that may be unavailable or overnhelmed in an emergency. MSS—based safety and security—related communications simply cannot be atrisk of ATC interference in the time of an emergency, when police, frefighters and other resue personnel need relisble communications the most Second we arejust beginning to relize the potentil for MSS to support broadband service across America, in urban, suburban, and rural areas alike, The Inmarsat—t spacecraft that are about to be launched will support transmission rates of432 kilobits per second—a rate competitive with planned 3G networks. Ittherefore is not dificultto imagine the new types of land mobile, acronautical, and maritime MSS services that soon will be offered Inmarsat‘s new BGAN land mobile ervice will support the extension ofcorporate communications networks, as well as failitte the provision ofhigh qualty live video feeds and news gathering in urban areas. In addition, Inmarsat‘s new broadband acronautical capabilitics will provide the opportunity to augment the congested air trafic 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 airplanes, land mobile, and maritime users, regardless of thir location. "The full potential ofMSS broadband services can come to fruition only ifthe Commission looks forward, and develops ATC rules and policis that protect t future, ather than simply protecting past MSS technology. For these reasons, it is criical that Inmarsat land mobile, neronautical and mariime terminals are protected from interference whenever they are operated in the viciity ofATC 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 mistakenly assumed that(x) ATC will be deployed only in undefined urban areas, and (¥) Inmersatland mobile and aeronutical terminals willnot be operated over or near those base stations. If Inmarsat or one of ts U.S. distributors wants to protect ts operations in the vicinty 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 thitty day window that itlikely will have a mobile user in the

Arcinct,me Prms vicinity ofthe base station, and (1) coordinate with MSV to ty to avoid the effects ofATC interference. If those efforts are not successful, Inmarsat MSS service might not be possible in the vicinity ofthat base station in the future. MSS subscribers reasonably expect that ther 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 proccedings raise very important policy issues and we urge the Commission to give them itsfullestattention and protect MSS service as described above. An original and seven copies ofthis ete are enclosed. Respectfully submitted, Satcom Direct By: _Q_M d Greenhill vp ec: Commissioner Kathleen Q. Abemathy Commissioner Michee! J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chief, Office ofEngineering and Technology Donald Abelson, Chief, International Buresu Marlene Dortch, Secretary


Document Created: 2005-01-12 12:20:55
Document Modified: 2005-01-12 12:20:55
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