Attachment ex parte

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

IBFS_SATAMD2003111800332_415613

UX aovmns ts oo 157 Fnii s cas. wuoross Toe eozeazeatne Fec srzestermm Bizub Communications, Inc. Enat ecitsi@ntsitcomm.can #ateilite Communications $ofutions URC: mortintcommcom January 12, 2005 Chairman Michael K. Powell Federal Communications Commission Office ofthe Secretary 445 12th Street, SW Washington, DC 20554 Re: ATC Rulemaking, IB Docket No. 01—185 Applications ofMobile Satellite Ventures Subsidiary LLC File No. SAT—MOD—20031118—00333 File No. SAT—AMD—20031118—00332 File No. SES—MOD—20031118—01879 Exparteprescaiation Dear Chairman Powel: Bizub Communications, Inc. is writing to express is concerns about issues mised in two related proceedings: ) reconsideration of the Commission‘s Order authorizing "ATC" as an extension ofMobile Satelite Service (MSS) networks, and (1) the Commission‘s review ofthe first authorization to implement ATC. As a suppler of Inmarsat equipment and airtime services to the United Nations and US. based humanitarian organizations, Bizub Communications urges the Commission to ensure that MSS services in the L—Band remain protected from ATC interference, and to preserve the ablity to deploy new and innovative MS services i 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 assailt on two fronts.. Fist, Mobile Satelite Ventuzes (MSV) has asked the Commission to revise is rules and allow MSV to significantlyincrease ATC interference in a manner that would substantialy increase the zones around ATC base stations where Inmarsat terminals will no longer work, and in a manner that also could degrade orinterupt communications over Inmarsat spaceceaft. Second, in granting the very fist ATC lcense, the International Burea granted waivers ofcermin ofthese rues and also placed a new burden on MSS operators to demonstrate, in a very short time frame, hat they will be hurt by the deployment ofan ATC base staion.

The fict is that no one has identified a way to fily prevent ATC from genenating interference into Inmarsat moble terminals or Inmarsat spaceeraft. The Commission‘s current ATC rules go a long way toward constraining ATC interference into MSS services, and it is essentil that the Commision maintain and enforce those rules. Moreover, it is critcal that the Commission maintain is current polices that deviations from its ATC rules will be alowed only t is demonstrated that the deviations will not increase ATC interfeence into MSS, @) ATC in the L—Band is to be phased in to allow time to study its real world effects, and @i) if ATC does eause interference into MSS service an ATC operator must immedately modify or discontinue its operations.. There are two main reasons these protections and poliies must be maintained. Firs, the continued relabilty of Inmarsat services is essentil to the safety and security—related communications of many federal, sate and local govenmenta agencies. Inmansat MSS terminals were telied on in New York Gity folowing the September 11 atticks,and the Fire Department of New York has recently chosen Inmarsat terminals to support its emergency response communications.. Inmamat MSS service is elied on for these purposes because the system is independent oftheterestraland cellular communications networks that may be unavalable or overshelmed in an emergency. MSS—based safety and securigezelated communications simply cannot be at risk of ATC interference in the time of an emergency, when polic, firfighters and other rescue personnel need reiable communications the most. Second, we are just beginning to realize the potental for MSS to support broadband service across America, in urban, suburban, and rural areas alke. The Inmarsat—4 spacecraft that are about to be launched will support transmission rates of432 kilobits per second—a rate competitve with planned 3G networks. It therefore is not difficultto imagine the new types of land mobile, aeronautial, and maritime MSS services that soon will be offered. Inmarsat‘s new BGAN land mobile service will support the extension of corporate communications networks, as well as facltate the provision of high qualiy live video feeds and news gathering in urban areas. In addition, Inmarsat‘new broadband acronautical capablities will provide the opportunity to augment the congested ai trific control system in the U.S, as well as offer communications services to the general aviation industry———commercial and private aircraft of allsizes. Inmarsat—t thus provides a unique opportunity—in fact, the only opportunity——to provide "always—on" broadband services to airplanes, land mobile, and mariime users, regardless of their location. ‘The fill potential of MSS broadband services can come to fruiion onlyif the Commission looks forward, and develops ATC rules and polices that protect the future, rather than simply protecting past MSS technology.. For these reasons, it is criicl that Inmarsat land mobil, acronautical and maiime terrninals are protected from interference whenever they are operated in the viiniy ofATC base staions. ATC, as a secondary, nominterfering service, should not be allowed to constmin the continued. deployment of NMSS throughout the United Stas. Unfortunately the. FCC. has mistakenly assumed that ) ATC wl be deployedonly in undefined urban areas, and (, Inmanat and mobile and aeronmutical terminals will not be operated over or near those base stitins. If 2

Inmarmat or one of its US. distibutors wants to protect its operations in the vicinity 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 thiry day window that it ikely will have a mobie user in the viiniy ofthe base station, and () coordinate with MSV to ty to avoid the effects of ATC interference. If those effonts are not successful, Inmansat MSS service might not be possible in the viiniy ofthat base staion in the future. MSS subscribers reasonably expect that their 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 opentionsin the vicinity ofan ATC base sttion. These proceedings raie very important policy issues and we urge the Commissionto give them its filest atention and protect MSS service as described above. EdwardJBizub, S— President


Document Created: 2005-01-25 17:19:57
Document Modified: 2005-01-25 17:19:57
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