Attachment ex parte

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

IBFS_SATAMD2003111800332_415585

FINTERNATIONAL ESERVICES SATELLITE jA:; 1 0 ‘2005 January 6,2005 Via Federal Express 9RIGINAL Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S.W. EX PARTE OR LATE FILED Washington, D.C. 20554 Re: Mobile Satellite Ventures Subsidiary LLC Ex Parte 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) Dear Ms. Dortch: International Satellite Services, Inc. (ISS) hereby urges the Commission to afford L-band Mobile Satellite Service (“MSS”) operators greater flexibility in their provision of an Ancillary Terrestrial Component (“ATC”), as requested by Mobile Satellite Ventures LP (“MSV”) in the above-captioned proceedings. The increased flexibility requested by MSV will ensure that next-generation MSS systems in the L-band can finally achieve the ubiquitous coverage, capacity, and economies of scale needed for a time consumer service. In contrast, the restrictions on L-band ATC advocated by Inmarsat Ventures plc (“Inmarsat”) will only ensure that MSS forever remains a niche service catering to price-insensitive users operating in remote areas. ISS has provided MSS since 1996 using the L-band satellites of MSV/ Mobile Satellite Ventures (Canada) Inc. We currently provide voice and data services to end user customers throughout the United States and the Caribbean. Our customers base spans a variety of vertical markets including mining and exploration, first responders, law enforccmeiit agencies at virtually all levels of government, military, park forest rangers, public utilities, sports and recreation, shipping and fishing industries as well as recreational boating, just to name a few. While ISS has developed a viable business using current-generation MSS satellites to serve niche markets, we are excited about the future potential for MSS when supplemented with .4TC. To date, MSS has been characterized by suitcase-sized user terminals, limited coverage, low data rates, and equipment and service prices far exceeding that offered by terrestrial wireless operators. Because the market for this type of service is small, the economies of scale needed to drive down equipment and service prices have not developed. With ATC, however, MSS has the potential to evolve into a true consumer service. ATC will provide the coverage, capacity, and economies of scale needed to bring MSS equipment and service prices to affordable levels. Moreover, by 1004 Collier Center Way Suite 205 Naples, Florida 341 10 www.issi-usnet T: 239.598.2241 F 239.598.9343 TF: 888.51 1.3403

overcoming satellite signal blockage in urban areas, ATC *ll allow MSS to become a truly ubiquitous service, allowing service providers to market their products to customers not only in rural and remote areas but to customers in the most densely populated urban cores as well. It comes as no surprise to ISS that Inmarsat opposes MSV’s efforts to make MSS into a more attractive service. If MSV does not succeed in its development of a next- generation MSS system, Inmarsat will have a monopoly in the L-band MSS market in the United States. Competition is always healthy. With no competitive pressure to discipline Inmarsat’s rates, terms, and conditions, L-band MSS service providers will struggle to survive, resulting in bankruptcies, job losses, and a step backward in the slowly rebounding telecommunications sector. Moreover, with only Inmarsat left standing, the prospects for innovation in L-band MSS technology will cease to exist. L-band MSS will remain stuck in time as a service useful for only a handful of users in remote areas. ISS understands that Inmarsat has used concerns of potential interference to oppose and delay MSV’s development of a next-generation MSS system. We believe these concerns are overstated and speculative. For example, our customers will continue to use their satellite-only terminals after MSV deploys ATC, but we are not concerned that these terminals will experience interference from MSV’s ATC base stations. This is because our customers do not use their satellite-only terminals in areas where MSV is expected to deploy base stations to overcome satellite signal blockage. By definition, if MSV needs to deploy an ATC base station to overcome signal blockage, our satellite- only terminals will not work effectively in those areas. The Commission is at a crossroads in the development of MSS technology. International Satellite Services, Inc. urges the Commission to follow the path of innovation and better consumer service by adopting MSV’s proposals for increased flexibility for ATC in the L-band. Operations International Satellite Services, Inc.


Document Created: 2005-01-21 12:17:55
Document Modified: 2005-01-21 12:17:55
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