Attachment ex parte

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

IBFS_SATAMD2003111800332_415605

                                                                     EX PARTE OR LATE F!LEJ

                                                                              ORIGINAL

                                  221 North Greenbush Road
                                       Troy, NY I2180                    RECEIVED
January 6,2005
                                                                           JAN   - 7 2005

Via Hand Delivery
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
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:

       Wells Communications 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 true 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.

       Wells Communications has provided MSS since 1995 using the Gband satellites of MSV
and Mobile Satellite Ventures (Canada) Inc. Wells Communications currently provides voice
services to Public Safety, Utilities and Businesses throughout New York and Vermont.

        While Wells Communications has developed a viable business that includes current-
generation MSS satellites to serve niche markets, we are excited about the future potential for
MSS when supplemented with ATC. 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
                                                                            No. of Co ies
                                                                            List AB&


Ms. Marlene H. Dortch
January 6,2005
Page 2


provide the coverage, capacity, and economies of scale needed to bring MSS equipment and
service prices to affordable levels. Moreover, by overcoming satellite signal blockage in urban
areas, ATC will 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.

       Wells Communications understands that concerns of potential interference could delay
MSV's development of a next-generation MSS system. 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. Wells
Communications 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.


                                                     Very truly yours,

                                                     Q v i n P %an

                                                     Kevin P Ryan
                                                     Sales Manager



Document Created: 2005-01-21 12:16:49
Document Modified: 2005-01-21 12:16:49

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