Attachment letter

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

IBFS_SATAMD2003111800332_415569

L.L.P. & DEMPSEY SQUIRE, SANDERS EX PARTE OR LATE FILED 1201 Pennsylvania Avenue, N.W. P.O. Box 407 Washington, D.C. 200440407 Office: +1.202.626.6600 Fax: +1.202.626.6780 Direct: +1.202.626.6615 RlGlNAL bolcott@ssd.com January 12,2005 VIA HAND DELIVERY RECEIVED Marlene H. Dortch JAN 1 2 2005 Secretary Federal Communications Commission Federal Communications Commission Office of Secretary 445 12th Street, S.W. Washington, D.C. 20554 Re: Mobile Satellite Ventures Subsidiary LLC Ex Pavie Presentation IB Docket No. 01-185 File No. SAT-MOD-20031118-00333 (ATC application) File No. SAT-AMD-20031118-00332 (ATC application) File No. SES-MOD-20031118-01879 (ATC application) N ~of.c jes r&d Ua &$E of<. Dear Secretary Dortch: The Boeing Company (“Boeing”), by its counsel, herein reiterates its support for the Commission’s decisions in the referenced proceedings to permit the introduction of Ancillary Terrestrial Component (“ATC”) as an important complement to the Mobile Satellite Service (“MSS”). As the holder of a 2 GHz MSS license and as the world’s largest satellite manufacturer, Boeing has a keen interest in decisions taken in this area. The Application for Review filed by Inmarsat Ventures, Limited (“Inmarsat”), seeks to reverse important precedents decided by the Commission.’ Boeing is firmly convinced that MSS licensees at L-band and S-band need the increased flexibility afforded by recent Commission decisions to ensure that next-generation MSS systems can finally achieve the ubiquitous coverage, capacity and economies of scale needed for a valuable, truly competitive consumer service. Until recently, MSS has been generally characterized by suitcase-sized user terminals, limited coverage, low data rates, and equipment and service prices far exceeding that offered by terrestrial wireless operators. Boeing-led developments - exemplified by the Thuraya Mobile Satellite System - I In the Matter of Mobile Satellite VenturesSubsidiary LLC, Application for Review of Inmarsat Ventures Ltd., File Nos. SAT-MOD-200311 18-00333, SAT-AMD-20031 1 18-00332, and SES-MOD-20031118-01879 (filed Dec. 8, 2004) (“Application for Review”). . CINCINNATI ’ CLEVELAND COLUMBUS HOUSTON’ LOS ANGELES ’ MIAMI* NEWYORK ’ PALO ALTO ’ PHOENIX * SAN FRANCISCO TAMPA * TYS0h-S CORNERWASHINGTONDC Rlo DE JANEIRO 1 BRATISLAVABRUSSELS* BUDAPEST ’ LONDON* MADRIDMILAN MOSCOW PRAGUE 1 BElJlNG * HONGKONG’ SHANGHAI * TOKYO a OFFICES: BUCHAREST DUBLIN 1 ASSOCIATED * KYIV TAIPEI a

SQUIRE, SANDERS L.L.P. & DEMPSEY Secretary Marlene Dortch January 12,2005 Page 2 demonstrate the potential for offering MSS to a broadly dispersed user community using small handheld phones. Our evaluation of the U.S. market, taking into account the diverse requirements of both rural and urban users, indicates that ATC will be key to ensuring that the service meets the goals of competitiveness and ubiquity. This unmistakably supports the similarly-stated goals of the Commission. Moreover, Boeing understands that the Commission includes in its goals an uncompromising support of efforts that promote effective communications for homeland security. In that regard, we note that the integration of an MSS network with ATC offers one of the best mechanisms to ensure robustness and wide-spread inter-operability necessary to meet homeland security requirements. The rules and licensing provisions adopted thus far are supportive of that goal and we encourage you not to revisit matters already adequately addressed. Furthermore, the Commission should continue to facilitate the introduction of MSS/ATC through the adoption of the improvements in its ATC rules urged by Boeing in its pending petitions for reconsideration of the rulemaking proceeding.2 This country is now at the threshold of being able to realize the full benefits of MSS technology. Boeing urges the Commission to hold the course that will permit continued introduction of innovation and better consumer service by continuing to support the MSS industry in its introduction of ATC services and by leaving unaltered the International Bureau’s decision to authorize MSV’s provision of MSS/ATC services. Counsel for The Boeing Company 2 See Flexibiliw for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L- Band, and the I . 6/2.4 GHz Bands, Petition for Reconsideration of The Boeing Company, FCC 03-162 (Sept. 11, 2003) (urging the Commission to reconsider some of the changes in the ATC application procedures that were adopted by the Commission in its July 3, 2003 Order on Reconsideration); Flexibility for Delivev of Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L-Band, and the 1.6‘2.4 GHz Bands, Petition for Reconsideration of The Boeing Company, FCC 03-162 (July 7, 2003) (requesting the Commission to harmonize its geographic cover requirements for MSS networks providing ATC services).


Document Created: 2005-01-21 11:47:35
Document Modified: 2005-01-21 11:47:35
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