Attachment letter

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

IBFS_SATAMD2003111800332_413258

 Chairman Michael K. Powell
 Federal Communications Commission
Office ofthe Secretary
445 12th Street, SW
Washington, DC 20554                                RECEIVED — FGC
                                                         JAN — 62005
                                                   reteal Canmuricaten Conninn
                                                           Suserore                  Junuary 5, 2005
Re:     ATC Rulemaking, IB 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—01870
               Ex parte presentation

Dear Chairman Powell:

Thrane & Thrane Inc.is writing to express ts concems about issues raised in two related
proceedings: () reconsideration ofthe Commission‘s Order authorizing "ATC" as an extension
ofMobile Satellite Service (MSS) networks, and (i) the Commission‘s review ofthe first
authorization to implement ATC.
Thrane & Thrane is a leading manufacturer ofInmarsat compliant mobile satellite terminals of
which thousands have been supplied since 1992 primarily to various US Government entites for
use in miltary as well as non—miltary applications on USsoil as well as abroad. As a
fundamental feature ofour products is the ability to do instant deployment ofthe terminals at any
location in the world our company urge 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 rules that the Commission adopted to constrain ATC interference are under assault on two
fronts. First, Mobile Satellte Ventures (MSV) has asked the Commission to revise ts rules and
allow MSV to significantlyincrease ATC interference in a manner that would substantially
increase the zones around ATC base stations where Inmarsat terminals will n longer work, and
in a manner that also could degrade or interrupt communications over Inmarsat spacccraft.
Second, in granting the very first ATC license, the International Bureau granted waivers of
certain ofthese rules and also placed a new burden on MSS operators t demonstrate, in a very
short time frame, that they will be hurt by the deployment of an ATC base station.

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                                                                               Thrane &Thrane

The factis that no one has identified a way to fully prevent ATC from generating interference
into Inmarsat mobile terminals orInmarsat spacecraft. The Commission‘s current ATC rules go
a long way toward constraining ATC interference into MSS services, and it is essentia that the
Commission maintain and enforce those rules. Moreover, it i 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 ts real world effects, and (i ) ifATC 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, the continued reliability of Inmarsat services is essential to 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 ofNew York has recently chosen Inmarsat terminals to support its emergency
response communications. Inmarsat MSS service is relied on forthese purposes because the
system is independent ofthe terrestrialand cellular communications networks that may be
unavailable or overshelmed in an emergeney. MSS—based safety and sccurity—related
communications simply cannot be at risk of ATC interference in the time of an emergeney, when
police, frefighters 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— spacecraft that are
about to be Iaunched will support transmission rates of 432 kilobits per second——a rate
competitive with planned 3G networks. It therefore is not difficult to imagine the new types of
land mobile, aeronautical, and maritime MSS serviees that soon will be offered. Inmarsat‘s new
BGAN land mobile service will support the extension ofcorporate 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 aeronsutical capabilities will provide the
opportunity to augment the congested air taffic control system in the U.S.,as well as offer
communications services to the general aviation industry———commercial and private aircraft ofall
sizes. Inmarsat—thus provides a unique opportunity———in  fact, the only opportunity———to provide
"alwways—on" broadband services to airplanes, land mobile, and maritime users, regardless of their
location.

The full potential ofMSS broadband services can come to fuition only ifthe Commission looks
forward, and develops ATC rulesand policies that protect the future, rather than simply
protecting past MSS technology. For these reasons, tis critical that Inmarsat land mobile,
acronautical and maritime terminals are protected from interferencewhenever they are operated
in the vieinity ofATC base stations.

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                                                                           Thrane & Thranc


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. If
Inmarsator one ofts U.S. distributors wants to protect ts operations in the vicinity oan ATC
base station that will operate at high power, it now has to do two things ) make a showing at the
FCC within a thity day window that it liely willhave a mobile user in the vicinity ofthe base
station, and (i) coordinate with MSV to try to avoid the effects ofATC interference. Ifthose
efforts are not suecessfil, Inmarsat MSS service might not be possible in the vicinity ofthat base
station in the future.                                                             >
MSS subscribers such as Search and Rescue organizations, Intelligence organizations and Law
enforeement organizations which are all among the users ofThrane & Thrane mobile satellite
terminals 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 of an ATC base station.

These proceedings raise very important policy issues and we urge the Commission to give them
itsfillest attention and protect MSS service as described above.

An original and seven copies ofthis letter are enclosed.

Respectfully submited,
Thrane & Thrane Inc.



         lenrikc Novelykke
       President


ee:    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, Chief, International Bureau
       Marlene Dortch, Sccretary
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Document Created: 2005-01-12 12:11:55
Document Modified: 2005-01-12 12:11:55

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