Attachment letter

letter

LETTER submitted by Mobile Satellite Ventures

letter

2004-05-24

This document pretains to SAT-AMD-20031118-00335 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2003111800335_376160

                                                                   EX PARTE OR LATE FILED


Mo biI e Sat e I I it e Ventures
                                                                                      ORIGINAL

                                                 May 12,2004

        Via Hand Delivery                                                      RECEIVED
        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
                         File No. SAT-AMD-20040209-00014
                         File No. SAT-AMD-20031118-00335

        Dear Ms. Dortch:

               Mobile Satellite Ventures Subsidiary LLC (“MSV”) files this letter to clarify that its
        replacement Mobile Satellite Service (“MSS”) satellite at 101“W will satisfy an emission limit of
        -160 dBW/m2into the 10.6-10.7 GHz band to protect radio astronomy from harmful interference.

                MSV has applied to operate its replacement satellite using the following downlink
        frequencies for feeder link operations: 10.70-10.95 & 11.2-11.45 GHz.’ This band lies
        immediately adjacent to the 10.6-10.7 GHz band which is allocated to radio astronomy on a
        primary basis. 47 C.F.R. 5 2.106, US277. US21 1 urges space stations operating in the 10.7-11.7
        GHz band to protect radio astronomy observations in the adjacent band from harmful
        interference. 47 C.F.R. 4 2.106, US2 11?


        ’See Mobile Satellite Ventures Subsidiary LLC, Amendment, File No. SAT-AMD-20040209-
        00014 (February 9,2004); Mobile Satellite Ventures Subsidiary LLC, Minor Amendment, File
        No. SAT-AMD-20031118-00335 (November 18,2003). On April 23,2004, the International
        Bureau dismissed MSV’s February 9,2004 amendment in which MSV requested authority to
        operate in the 10.70-10.75 GHz band because it purportedly failed to include an interference
        analysis. See Letter from Thomas S. Tycz, FCC, to Lon C. Levin, MSV, File No. SAT-AMD-
        20040209-00014, DA 04-1095 (April 23,2004). This amendment will be reinstated if the
        International Bureau’s decision is reversed on review.
        2
          US74 further clarifies that in the 10.68-10.7 GHz band, radio astronomy service is “protected
        from extraband radiation only to the extent that such radiation exceeds the level which would be
        present if the offending station were operating in compliance with the technical standards or
        criteria applicable to the service in which it operates.” 47 C.F.R. 5 2.106, US74.



                                                                                               ---------_
Mobile Satellite Ventures LP                                        10802 Parkridge Boulevard, Reston, Virginia, 201 91 -541 6


MA. Marlene H. Dortch
May 12,2004
Page 2


         The National Science Foundation has explained that the protection level required at radio
astronomy sites in the 10.6-10.7 GHz band is -160 dBW/m2. MSV certifies that emissions from
its replacement satellite will not exceed this emission limit in the 10.6-10.7 GHz band. As with
its current satellite, AMSC-1, MSV will equip its replacement satellite with a special transmitter
output filter to limit emissions in the 10.6-10.7 GHz band at or below this level to ensure that
radio astronomy observations are protected from harmful interference.

           Please direct any questions regarding this matter to the undersigned.

                                                Very truly yours,


                                              -~
                                                Lon C. Levin



cc:        Karl Nebbia, National Telecommunication and Information Administration
           Tomas E. Gergely, National Science Foundation
           Thomas Tycz, FCC



Document #: 140 17 17 v. 1



Document Created: 2004-06-01 12:01:58
Document Modified: 2004-06-01 12:01:58

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