Attachment O&A

This document pretains to SAT-AMD-20031205-00347 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2003120500347_412822

Federal Communications Commission DA 05—50 Before the Federal Communications Commision Washington, D.C. 20584 In the Matter of ) ) Mobile Satellite Ventures ) File No. SAT—LOA—20030827—00174 Subsidiary LLC ) File No. SAT—AMD—20031205—00347 ) File No. SAT—AMD—20040227—00021 Application for Authority to Launch ) Call Sign 82487 And Operate an L—band Mobile ) Satellte Service Satelliteat 63.5° ) wiL ) Order and Authorization Adopted: January 10, 2005 Released: January 10, 2005 By the Chief, Intemational Bureau: 1 INTRODUCTION 1. By this Order, we authorize Mobile Satellite Ventures Subsidiary LLC (MSV) to launch and operate an L—band‘ Mobile Satellite Service (MSS) satellite, known as MSV—2, at 63.5° W.L. to provide service within South America and between South America and the United States." Grant of this application will allow MSV to expand its MSS offerings to include South America, increasing competition in the global MSS markeiplace to the benefit of US. consumers. 1. BACKGROUND 2. MSV is the successor to Motient Services, Inc. (Motient, formerly known as AMSC Subsidiary Corporation)." It is authorized to operate the U.S—licensed L—band MSS satellit, ! The "L—band" ia general desigation fo requenciesfrom 1 to 2 GiHz. Inthis Order and Authorizarion, however, the term "L—band" denotesonly the 1583—1559 itz and 16%6.5—1660.5 MHz frequency bands (upper L—band) and the 1525—1544 MH and 16265—1645.5 Mfequency bands (ower L—band). * MSV amended is pplicationto operateatthe 63.5° W.L. orbit location instead of the $2° W.L. orbt ocation originally proposed. See Anendnent, File No. S47AMD—20031205—00347, MSV furter amended ts application to make thfllowing changes to thetechnical parametersofthsatelite: () increase the ize of the L—band service link antenna;(i) increase equivalent isoropically radited power (.p.) ofthe satelite;(i) increase the porental mumber of Lband spot beame; and (i) modify the bascline air inerface protocol from GMR only to GMR—2 (satelite adaptation of GSM), S—dma2000 (stelte adapration of edma2000), and SW—CDMA (sutelite adaptaion of W—CDMA)}. MSV sttes thatit has included revised nk badgetsto reflct the changes. According to MSV, these changes will make th technicl parameters of ts proposed satelite for service to South America consistent with the technical parameters of its proposed replacement satelite for service to North America. See MSV Applicaion File No. SAT— AMD—20040227.00021 at 1—2 > AMSC is the only entiy the Commisson authorized to aunch and opertea U.S. MSS sytem operitingin the L~ band. In November 2001, the Commissionapproved tapplication ofMotint and TMI Communicationsand Company, Limited Pariership (TML) to consolidte ther U.S.L—band MSS opertions in new company called

Federal Communications Commission DA 05—50 AMSC—1.‘.It also holds a blanket license for mobile earth terminals (METs) that access both AMSC—1 and MSAT—1 (the Canadian—authorized L—band MSS satellite)" Through these facilities, MSV provides land, maritime, and acronautical MSS, including voice and data service, throughout the contigyous United States, Alaska, Hawail, the Virgin Islands, and coastal areas up to 200 miles offshore." 3. MSV proposes to launch and operate its MSV—2 satellte to serve South America from the 63.5° W.L. orbital location, utilizing the L—band frequencies at 1525—1559 MHz (space—to— Earth) and 1626.5—1660.5 MHz (Barth—to—space) for service links.. Italso proposes to operate feeder links, tracking, telemetry, and control (TT&C), and gateway—to—gateway communication links in the 10.7—10.95 GHZ and 11.2—11.45 GHz bands (space—to—Earth) and the 12.75—13.25 GHz band (Earth—to—space)." MSV proposes to use MSV—2 to provide basic voice and data MSS and high—speed packet data MSS to South America, including public safety services." According to MSV, permitting it to launch and operate MSV—2 will increase competition to consumers in South America and will enable it to better compete in the global MSS marketplace. MSV notes that Inmarsat,Irdium, and Globalstar are among the MSS providers that provide MSS in both North and South America. 4. Although MSV—2 will be placed in a geostationary satellite orbit (GSO), MSV acknowledges that the L—band portion ofits satelite will provide MSS, and thus its satellte is considered "non—gcostationary—satellte—orbit—like" (NGSO—like) for processing purposes.. This means that its L—band request would be considered in a modified processing round. where competing appliations are invited andconsidered concurrently, under the rules adopted in the Space Station Licensing Reform Order." MSV states that ts application should not be subject to a modified processing round because it proposes to provide service to South America using only the L—band frequencies that the Commission has already coordinated and authorized for MSV‘s North American system. To the extent deemed necessary, MSV requests a waiver of the Mobile Satelite Ventires LP (MSV LP}. See Motiet Sevices Inc, TMI Communications and Company LP,and Mobile Stelite Ventires LLC, Order and duthorizaion,16 FCC Red 20469 (it. Bu. 2001). + Amendment of Pat 2,22, 25 ofthe Commisson‘s Rulesto Allocte Spectrum forand to Establish Rules and Polices Periaining to the Useof Frequencis a Land Mobile Satelite Srviceforthe Provisionof Various Common Carier Sevices4 FCC Red 6041 (1989) * AMSC Subsidiry Compontion 13 ECC Red 12316 (1999). *MSV Applcation File No. SAT—LOA—2000827.00174 a 3. " The term "Feede nk"refrs t fixed—stelit serviceradi inks caryingsignals in both directionsbetween a MSS stelitand gateway earth stations. The gateway carth sations connectthe MSS system with other netvorks, such as the public switched elephone network * MSV states that it will provide generic network services such as asset trcking, voice mail Short Message Serviees), cell broadcastservice(o,and mostother GSMICDMA supplementay servics,including support to Law Enforeement Agencies. Cstomer supportfeatures, such asdirectory and operatorassstanc, redit card caling, and emergency referalwll be provided asrequired. Mostnew sevicesto be provided by the ystem willbe bsed on highapeed packetdata mades,eapable ofproviding mult—media ntrconnection to the Itemeto other public and private dta networks, web surfing,telecommuting, ntesctive services, FTP, and other egional onational high— qualiy dats muli—castingservies. See MSV Application File No SAT—AMD—20040227—00021 at 9. * Amendment othe Commission‘s Space Sttion Licensing Rulesand Policies, Arst Report and Order and Further Notce ofProposed Rulemaking, TB Docket No. 02—34, 18 ECC Red 10760, 10782.90, paras 48—67 (2003)(Space Staron Licensing Reform Order} 2

Federal Communications Commission DA 05—50 Commission‘s processing round requirement for its L—band operations.. In contrast, MSV states that ts proposed feeder links are considered "GSO—like" since feeder links, by definition, involve transmissions to and from the satelite via a fixed central "gateway" earth station. Accordingly, MSV argues that its feeder link request should be considered under the Commission‘s first—come, first.served. process applicable to "GSO—like" satellites." MSV also requests a waiver of footnote NG104 of Section 2.106 ofthe Commission‘s rules, which requires the 10.7—10.95 GHz and 11.2—11.45 GHz frequency bands to be used for international service only, so that it can use these frequencies for both domestic feeder links and TT&C."" 5. MSV further requests a waiver of Section 25.165(a) of the Commission‘s rules,"" which requires the posting of a bond within 30 days of the grant of a satellite authorization. MSV notes that it plans to provide public safety services which the Commission said in the Space Station Licensing Reform Order could qualify for a waiver of the bond requirement. * Finally, MSV requests a waiver of our station keeping rules set forth in Section 25.210(),!! which requires that GSO space stations be maintained within 0.05° of their orbital longitude."" We placed MSV‘s application on public notice and no comments were fled. ui. DISCUSSION A. Processing Procedure 6.. In its Space Station Licensing Reform Order, the Commission established a modified processing round procedure for "NGSOlike" satellte systems. The Commission defined NGSO— like satellite systems as those in which the earth station has little or no directivity towards a satellite so that the earth station must track the satellite in all directions, such as hand—held satellite telephones.Based on this definition, we consider MSV—2‘s L—band service link as an NGSO—like system for the purpose ofdetermining whether a processing round is required. 7. Under a modified processing round framework, we place the first—filed application on public nouce and invite parties to file other potentially competing applications by a specified out— off date."" We consider all applications filed by the cut—off concurrently. The Commission then issues licenses by dividing the available spectrum equally among the qualified applicants."" " Space Station Licensing Reform Order, 18 ECC Red at10804—18, paas. 108—50. " MSV Application File No. SAT—LOA—20030827—00174 at 23. "arcr® 525.1650) "MSV Application File No. SAT—AMD—20031205—00347 at , itng Space Station Reform Onder, 18 FCC Red at 10825, paa. 169. "arcr® 5252100 ©* see Mitiation of Orbial Dcbris, Second Report and Order, 1B Docket No. 02—54, 19 ECC Red 11567 (2004) (Orkial Debris Order) " Space Station Licensing Reform Order, 18 ECC Red at 1073, par. 21. " Space Staion Licensing Reform Order, 18 FCC Red at10782—83, par. 48 " Space Surion Licensing Reform Onde, 18 FCC Red at 10782:43, par. 48. This is because omnidiectionl antemas such as those used in NGSO systems and GSO MSS systems, cannot servethe same geographic areas in the same frequencies without causing mutoal harmfilinterference. "The processing round approsch ths ensures 3

Federal Communications Commission DA 05—50 8. MSV, however, is not secking a license to use any additional L—band spectrum. Rather, MSV—2 will use the same L—band frequencies as those on which AMSC—1 is licensed. When the Commission receives NGSO—like applications that seck to use the same frequencies for which that applicant is already licensed, it processes that request immediately without instituting a modified processing round." We find that MSV‘s request to use MSV—2 to serve South America does not warrant a different result. We will not initate a modified processing round to award U.S.—L—band "South American" licenses in the same bands in which AMSC—I is operating. As a practical matter, any NGSO—like satellite serving South America in the bands licensed to AMSC—1 is likely to cause harmful interference to AMSC—I‘s North American operations. This is because, in this case, the large North American and South American coverage areas are in close proximity to each other and, indeed, are likely to overlap. Thus, geographic separation is not sufficient to limit co—frequency interference between multiple NGSO—like systems serving each of these areas. The Commission has said it will not consider applications for new systems where the new system‘s operations would cause interference to Hicensed systems."" Thus, we would not license another U.S. system to operate in the same frequencies as AMSC—1. Further, if we do not allow MSV to expand its coverage into South America, we would be preventing a U.S—licensed system from providing L—band service in this region altogether. In addition, operations by MSV in South America can be self:eoordinated to limit interference into MSV‘s North America service. Consequently, we will waive the modified processing round requirement for NGSO—like systems in this situation and will award MSV authority to construct and launch an NGSO—like satellite to serve South America in the L—band if it is otherwise qualified. 9. We agree with MSV that is request for Ku—band fixed—satellite service feeder links is governed by the first—come first—served policy for GSO—like satellites set forth in First Space Station Licensing Reform Order. There are no prior requests to use these Ku—band frequencies at the 63.5° W.L. orbit location and there are no nearby satellites using these frequencies with which MSV—2 might interfere.. Consequently, we will grant MSV license to operate on these frequencis ifit is qualiied B. Legal Qualifications 10. In considering applications to launch and operate a new satellite system, we must determine whether a grant will serve the public interest. In making this determination, we consider whether the applicant is legally, technically and otherwise qualified to launch and operate the satellite.. As the designated U.S. L—band licensee, the Commission has determined that MSV possesses the requisite legal qualifications to hold a Commission license. multiple competive systems. In contast, GSO—liksystems, which use directional antemnas, can provide co— frequency,co—coverageservice at orbitl spacings of25. This, in isef allows for muliple systems. © See, e , Applcation of EarthWatch, n., Order and Authorization, 12 FCC Red 21627 Catd Bur. 197) (Bureau wrated applcationto add two NGSO steles to an authorized two—satlite NGSO system, where no additonal frequencies were requested, asa modification o the ntal NGSO license). ® pace Staion Licensing Reform Order,18 ECC Red at10806,para. 113. a

Federal Communications Commission DA 05—50 €. Technical Qualifications 1. East—West Station Keeping Tolerance 11. MSV requests a waiver of Section 25.210() of the Commission‘s rules,"" which requires that GSO space stations be maintained within 0.05° of their assigned orbital longitude in the eastwest direction, unless specifically authorized by the Commission to operate with a different longitudinal tolerance, and except as provided in Section 25.283(b) (end—oflife disposal) of the Commission‘s rules." MSV secks to operate within 0.10° of its orbital longitude."" According to MSV, a waiver is justified because there are no nearby satellites to which MSV—2‘s operations could cause interference."* In addition, MSV states that the costs of complying with a £0.05° east—west station keeping tolerance (such as increased fuel to maintain a tighter tolerance) outweigh any purported benefits." 12. The Commission may grant a waiver for good cause shown."®. Waiver is appropriate if (1) special circumstances warrant a deviation from the general rule, and (2) such deviation would better serve the public interest than would strict adherence to the general rule."" Generally, the Commission may grant a waiver of its rulesin a particular case only if the relief requested would not undermine the policy objective of the ule in question, and would otherwise serve the public interest."" MSV states that a waiver is justified because there are no other satelltes at that location to which it could cause interference. MSV‘s analysis, however, is limited to those systems that are operating co—frequency with the MSV spacecraft and does not include other spacecraft that are not co—frequeney, but that may be impacted by the extended station keeping box. Without this additional information, we are not able to conclude that the public interest justifies a waiver, given the potential impact on the operations of other satellites. Accordingly, we deny MSV*s waiver request 13. Although we deny MSV‘s request, we do so without prejudice to MSV requesting a modification of its lcense to permit its satellte to be maintained within a 0.10° station keeping box. In support of such a modification request, MSV should provide information regarding the identty of known satellites located at, or planned to be located at the location proposed by MSV, or assigned a location in the vicinity such that the station—keeping volume of the respective satellites might overlap. MSV need not address every. filing. with. the Intemnational Telecommunication Union (ITU) that meets these criteria, but should assess and address any systems reflected in ITU filings that are in operation or that MSV believes may be progressing toward launch, eg., by the system being listed on a launch vehicle manifest. In the event an "arcrR. 5252100 " 47 CER. § 25283 (. See also Orbial Debris Order, 19 FCC Red 11567, "MSV Appleation File No. SAT—AMD—20040227—00021 at 41. We constru this request as on to maintain the MSV stelite within 0.1° ofts assigned orbitl longitude, asassessed atth nodal poinofhe orbit. °* MSV Applicaion File No. SAT—AMD—20040227—00021 ar d1 "MSV Application File No. SAT—AMD—20040227—00021 at 41—42. ®47 CER. § 13. See aso WATT Radiov. FCC, 418 R2d 1153 (D.C. Ci. 1969) (HAITRadio); NotheasCollar Co.v. RCG, 897 F2d 1166 (D.C. Cir. 1990) (Norheast Celtar) *"See Northast Celider,597 F.2d at166. * see WATTRadio, 418 F2d at 1157

Federal Communications Commission Da 05—50 overlap is indicated, MSV should identify the measures it would take to avoid in—orbit collisions with such satelites." 2. North—South Station Keeping Tolerance 14. To save station keeping fuel, MSV requests authority to operate MSV—2 with an initial north—south inclination®" of as much as six degrees."". This inclination would decrease under the influence of gravitational forces of the sun and moon, and then would begin to increase, thereby fluctuating between about one and six degrees during the expected life of the satellite. MSV states that its satellte will operate consistent with the requirements for inclined orbit satellites set forth in Section 25.280."" We will grant MSV‘s request. We note, however, that granting this request creates a potentil for harmful interference between MSV—2s Ku—band operations and Ku—band NGSO fixed—satellte service (FSS) satellites. Pursuant to TTU Radio Regulations GSO satellites, such as MSV—2, are protected against interference from NGSO FSS satellites operating in the same band provided that GSO satellite‘s north—south inclination is 4.5° or less."" Thus, during those periods in which MSV—2 will operate at an inclination ofup to 4.5°, MSV‘s network will be fully protected from interference from NGSO FSS networks."" During the periods in which MSV—2 will operate at an inclination more than 4.59, its operations will not be protected. We expect MSV to coordinate its operations at these higher inclinations with * Regardiess of wheher MSV secks such moifiction, we are following our standard practice of requiring submission of information regarding methods that willbe used to avoid colisions with other spacecrft operting within the = 08° sttion keeping volume. See pars. S3 i. " The incliation of an orbt is t angle between the orbial plane and the Earth‘s equtoril plane, measured counterelockaise. A zero inciation orbit would mean the stelite is orbiting directly over the equator; an inclinaton 090 degrees is a perfecty polarorbit * MSV Appleation File No. SAT—AMD—20040227—00021 ar 42 "arcrn 525280 "* See Article 22.51, Table 224A " see Amendment of ts 2 and 25 of the Commission‘s Rules to Permit Operation of NGSO FSS Systems Co— frequeneyWith GSO and Temestial Systems in the Ku—Band Frequency Range, Arst Report and Order and FurtherNotice ofProposedRulemaking, 16 ECC Red 4096 (2000), t 4143—44.

Federal Communications Commission DA 05—50 Hicensed NGSO ESS operators. Absent a coordination agreement, we require MSVs operation at inclinations between 4.5° and 6° to be on a non—interference basis." 3. L—band Operations a. Introduction 15. MSV—2 will have separate antenna systems for the service and feeder links. The L— band service link antenna will use a 24—meter reflector with approximately 400 spot beams for coverage of the South America. It proposes to operate in the 1525—1559 MH downlink and 1626.5—1660.5 MHz uplink frequency bands, with mobile units operating in South America. Under the Interational Table of Frequency Allocations, the 1525—1535 MHz band is allocated on a co—primary basis to MSS and the Space Operation Service in Region 2."" The 1535—1559 MHz and 1626.5—1660 MHz bands are allocated on a primary basis to MSS. ‘The 1660—1660.5 MHz band is allocated on a co—primary basis to MSS and the Radio Astronomy Service.". In addition to these co—primary allocations, there are a number of footnotes to the International Table of Frequency Allocations that place additional constraints on MSV‘s operation in portions of these bands.. We discuss these in tum b. Co—Primary Allocation for the Space Operations Service 16. As noted, both the 1.5 GHz downlink band and 1.6 GHz uplink band are allocated on a co—primary basis to MSS and the Space Operations Service in Region 2. Because, however,all L—band user terminals will transmit from South America and no user terminals within the United States will operate with MSV—2, we need not impose additional conditions on MSV—2 with respect to the 1626.5—1660.5 MHz receive bands on the satellite. Rather, we remind MSV that L—band terminals must operate in accordance with laws of the jurisdiction in which they will operate. We also remind MSV that it must coordinate with existing Space Operations Service stations in the 1525—1559 MHz band under the ITU Radio Regulations and that its operations are not entitled to any protection from interference unti t has completed coordination. c. Passive Research for Extraterrestrial Emissions 17. Further, according to Footnote 5.341 of the ITU Radio Regulations, some countries are conducting passive research in the 1525—1559 MHz band to search for intentional emissions of extraterrestril origin." The use of the 1525—1559 MHz band by the mobile—satellte service is subject to coordination under Article No. 9.11A of the ITU Radio Regulations."‘ Thus, we require MSV to coordinate its MSS operations in good faith with passive research operations " We also note that, tth extent MSV‘s planned operations i inclined orbitar impacted by deniao ts request for waiver of the eas—west station keeping requirement, MSV will need toseek modifiction of ts authoriztion to reflect any change in planned openations. "* For the allocation of requenciesthe Interational Telecommunication Union (ITU) has divded the world into three regions. Region includes Northand South America. See 47 CB.R. §2.104. "4rcrR 210 © Intemational Footote 5.341 to Section 2.106 ofthe Commission‘sules, 47 CF.R. §2.106. "* See Inermationl Footmote 5.354 t Section 2106 of the Commision‘s mles, 47 CER. §2.106 7

Federal Communications Commission DA 05—50 being conducted by other countries. Further, any radio station authorization for. which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments of other administrations."" d. Maritime and Acronautical Mobile—Satellite Distress Communications Services 18. International Footote 5.353A ofthe ITU Radio Regulations states that MSS systems operating in the 1530—1544 and 1626.5—1645.5 MHz frequency bands maynot interfere with maritime mobile—satellite (MMSS) distress, urgency, and safety communications that are also provided in these frequencies. Interational Footnote .353A protects MMSS distress, urgency, and safety communications, such as Global Maritime Distress and Safety System (GMDSS) by providing priority access and realtime preemptive capability for GMDSS communications. Domestically, to ensure MSS compliance with the provisions of Foomote US315, which is similar to Intemational Footnote 5.353A, the Commission established priority access and preemption standards and policies for the Mobile—Satelite Service in this band and incorporated these standards into its rules. °* 19. Further, mobile—satellite service operators must comply with Intemational Footnote 5.357A of the ITU Radio Regulations for operations in the 1545—1555 MHz and 1646.5—1656.5 MHz frequency bands and with Interational Footnote 5.362A" of the ITU Radio Regulations for operations in the 1555—1559 MHz and 1656.5—1660.5 MHz bands. These foomotes provide that the aeronautical mobile—satellite (R) service (AMS(R)S) shall have priority access and immediate availability over all other MSS operations. AMS(R)S is a mobile satellite service using mobile terminals on—board aireraft. This service can be used to support domestic and interational air traffc, including air traffic control. The (R) indicates that the spectrum is used for aeronutical communications related to the safety and regularity of flights primaily along national and intemational civil air routes. Further, MSS systems operating on these bands may not cause unacceptable interference to, or claim protection from, acronautical mobile—satelite (R) service communications with priority 1 to 6 in Article 44 of the TTU Radio Regulations."" 20. Although no METs in the United States will communicate with MSV—2, MSV must still comply with the Commission‘s rules regarding priority access and real—time preemption because MSV‘s Satellite Ground Station Subsystem (GSS) and Mobile Switching Center (MSC) © See 47 CER §25.1110) °* Estblising Rulesand Policiesfor the use ofSpectrim for Mobile Satelite Services in the Upper and Lower L— Band, Report and Order,17 BGC Red 2704 (2002). °* Inrerational Footrote .362A to Section2.106 ofthe Commission‘s ules sates: "In the United Sutesin the unds 1553—1550 Mitz and 1656.5—1660. Mitz,the acronautcal mobilsutelite(R) serviceshall have priority accessand immedite availailty,by pre—mption if necessary, over llother mobilesatlite communications operating withina network. Mobilesatelitesystems shullnot cause unacceptabl nterference o,o caim protetion from, seronsuticl mobile—satelit (R)service communications wth prionty 1 to in Aricle 44. Account shallbe taken ofthepriony osfet—related communications n the other mabile—steliteservces." Similar Janguage is containd in Footote US208 to Setion 2.106 ofthe Commisson‘s mles, 47 CF.R. §2.106. "* Article 44.1 of he ITU‘s Radio Repulations sets the order o prioiy for communication in the acronauticl mobile service and seronmutcal mobilesatelite srvice.. Priones 1—6 are as follows: 1) distess calls, distess messages and distess tafti; 2) communications preceded by the urgency signal; 3) communications rcting to 1adio direcionfinding; 4) ight safty messages; 5) meteorolopical messagesand 6) lightregularity messages 8

Federal Communications Commission DA 0s—50 will manage all satellite resources (%e., frequencies and power) and control the allocation of those resources to the mobile user terminals that use the satellite. ‘Thus, MSV will control the means of. preempting those mobile terminals operating with MSV—2 in South America.. MSV states that its satellte system will comply with all applicable requirements.. As with its current system, MSV will maintain a reserve pool o resources that will permit any additional demands of the AMS(R)S and GMDSS network to be met immediately. This AMS(R)S and GMDSS reserve pool will be maintained by retrieving resources from within the MSV network, We believe that the continuation of this practice, which has been successful on MSV‘s existing satellite, represents a. reasonable approach to mecting MSV‘s priority and. preemption requirements. 21. MSV does not request authority for U.S. fixed—gateway earth stations. Gateway carth stations Tocated in the United States will be licensed under separate application in accordance with Part 25 of the Commission‘s rules. Nonetheless, in 1993, the National Telecommunications and Information Administration (NTIA) and the Federal Aviation Administation (FAA) created a minimum set of capabilities to ensure that fixed—gateway earth stations operating in the 1545— 1559 MHz and 1646.5—1660.5 MHz bands comply with Foomote US308 and ITU Radio Regulation 5.357A and 5.362A." We will require that any U.S. fixed—gateway carth station communicating via MSV—2 meet the minimum set of capabilities set forth in the "1993 NTIA Recommendations." ¢. Distress and Safety Communications 22. MSV has requested authorty to use the 1544—1545 MHz and 1645.5—1646.5 MHz band segments. According to Intemational Footnotes 5.356 and 5.375 of the Table of Frequency Allocations, the use of these bands by the mobile—satellite service is imited to distress and safety communications."" MSV proposes to use MSV—2 to provide basic voice and data MSS services and high—speed packet data MSS services to South America. Although MSV‘s dispatch radio or "push to talk" feature may be used for distress and safety communications, MSV has not explained how it can limit transmissions in the 1544—1545/1645.5—1646.5 MHz bands to safety and distress communications only.. Given the broad range of commercial services available on the MSV system, we will not permit MSV—2 to operate in the 1544—1545/1645.5—1646.5 MHz bands and potentially disrupt emergency communications in these bands. £. Coordination with other L—band MSS Systems 23. In North America and nearby intemational airspace and maritimeareas, five satellte systems, which all operate in geostationary—satellite orbit (GSO), currently provide service in the L—band‘s 66 megahertz (33 megahertz in each transmission direction) MSS allocation. In 1996, the operators of the five North American L—band systems signed a Memorandum of Understanding (MoU). The MoU specified that "[sJpectrum allocations to individual operators will be reviewed annually on the basis of actual usage and short—term projections of future need." Unlike most international coordinations that create permanent assignments of specific spectrum, * See Lettr to Cheryl Trit, Chicf Common Carier Bureas, FCC, from Richard D. Parlow, Associate Administator, Office of Spectrim Management, NTIA, and Gerald Markey, Manager, Spectrum Enginecring Division, FAA, and atiachment to th leter (lan. 14, 1993)(/993 TLA Recommendations) * Inerational Foototes5.356 and 5.375 o Section 2106 ofthe Commission‘srles, 47 CB.R. $2.106. 9

Federal Communications Commission DA 05—50 the operators‘ assignments can change from year to year based on their marketplace needs. While the most recent annual operator—to—operator agreement has not been renewed since 1999, the five parties have continued to coordinate their operations informally and have been operating interference—free. We remind MSV that any L—band operations in South America must be coordinated with other MSS systems, and until such time that coordination has been completed these operations will be on a non—harmfil interference basis to other lawfully operating satellte or radio facilites and will receive no protection from interference caused by those faciities. 4. Ku—hand Operations a. International Plan 24. MSV‘s fixed—satellite service feeder link and TT&C operations will be conducted in the 10.7—10.95/11,2—11.45/12.75—13.25 GHfrequency bands. Feeder link and TT&C operations will be conducted from earth stations in the United States. According to International Footote 5.441 of the Table of Frequency Allocations,"" use of these bands by geostationary—satellite systems in the fixed—satellte service shall be in accordance with the plan prescribed in Appendix 30B of the ITU Radio Regulations. The FSS plan does not provide for operation of a U.S.— Hicensed satellte at 63.5° W.L.. The plan will have to be amended to take into account MSV—2‘s operation at that location. Appendix 30B specifies a procedure for amending the plan to permit additional FSS uses upon a showing of compatibilty with FSS allotments and assignments pursuant to the plan. MSV has submitted an analysis based on the published TTU MSPACE—s program"*and the ITU Appendix 30B Ku—band reference database."" This analysisindicates that MSV‘s proposed Ku—band operations would have no excess interference impact on other FSS systems implemented by other countries pursuant to Appendix 30B. If there is excess interference, MSV believes that it can be satisfactorily resolved through coordination agreements with affected administrations."*. We agree that such coordination seems feasible. ‘The operating authority we grant here for MSV‘s Ku—band operation is contingent, however, upon issuance of a favorable ITU finding pursuant to Appendix 30B, Article 6, and Section III of the ITU‘s Radio Regulations. b. Two—Degree Spacing 25. The Commission‘s FSS satellite licensing policy is predicated upon two—degree orbital spacing between geostationary satellites." This policy permits the maximum use of the " ImermationalFootote 5.441 to Section 2.106 ofthe Commission‘s rles, 47 CFR. §2.106. " TTU SottwarSuite, Space PlansSystem (SP5)Versio:2.12 (ncluding MSPACE) September 2002, Interational Telecommunication Union Radiocommunication Bureau (BR) Tformatis Adminstation and Publictions Department (LAP) ® Appendix 308 Ku—band reference database is ALOTHHAE made fom inputfile RS2SK_O20403xt and RS3SK_080403 reafer recrding in the Liofsub—repional systems EUTELSAT EXB—30.SB, EXB—R6B, EXB— 83.5%, EXB—88.55,"WARC ORB 88 FSS Plan in the 12/10—11 GH band, APPENDIX 308 ASCHIFil, hipo/hweein.intTTUR/space/planspJ0b/RS3SK.030403 zi. " MSV Applicaton File No. SAT—AMD—20040227—00021, Appendix A,at 53. ® For more information egarding the Commission‘s two—degreespacing policy,see Licensing Space Station in the Domestic Fixed—Satelite Sevice, Reportand Order, 48 F.R. 40233 (Sept.6, 1983). 10

Federal Communications Commission DA 05—50 geostationary satellite orbit."* MSV has submitted the technical information specified in the Commission‘s rules."" Upon review of thi information, we find that MSV—2‘s FSS feeder link and TT&C operations are two—degree compliant and meet all other technical requirements. 26. We note, however, that although there are no power—flux—density (PFD) limitsin the Commission‘s rulesfor emissions from a GSO satelite in MSV‘s proposed FSS downlink bands, the ITU has established PFD restrictions to prevent interference with terrestrial wireless services."" MSV‘s PFD specifications are consistent with these restrictions." . Waiver of Footnote NG104 27. Footnote NG104 of Section 2.106 of the Commission‘s rules states that use of the 10.7—11.7 GHz and 12.75—13.25 GHe bands in the United States by the Fixed—Satellite Service in the geostationary—satellte orbit shall be limited to intemational systems." MSV requests a waiver of this rule for its feeder link and TT&C operations, which will be conducted from an earth station in the United States. Inlight of the intemational nature of MSV‘s proposed service, which involves both service links and feeder links to complete the communications link, a waiver request of Footnote NG1O4 for feeder link operations is unnecessary. 28. However, we grant MSV‘s request for waiver of Footnote NGIO4 for its TT&C operations, which will be conducted in the 11.45 GHz and 13.25 GHz bands. MSV states that it may co—locate new feeder link/TT&C earth stations with existing MSV earth stations already operating in Reston, Virginia and Alexandia, Virginia. Comsearch®" has commenced a coordination analysis on MSV‘s behalf t determine whether MSV‘s proposed TT&C operations will interfere with co—primary fixed—service (FS) operations in those bands. This analysis has identified a small number of potential interference cases that MSV believes can be resolved through the use of shielding and other mitigation techniques and by coordination with the affected operators.®" Moreover, two co—located TT&C earth stations should not significantly increase the coordination burden on FS applicants. Thus, we grant MSV a waiver of Footnote NGIO4 to allow it to provide TT&C in the 1145 GHz and 13.25 GHz bands to MSV—2 from earth stations in Reston, Virginia and Alexandria, Virginia. MSV must still apply for license modifications of those two earth stations to request authority to communicate with MSV—2 in the 11.45 GHz and 13.25 GHfrequency bands. " See, eg, Assinment of Orbial Locationsto Space Stations in the Domestic Fixed—Satlite Service, L1 ECC Red 13788, Order and Authorizatin,(199),at13790, Prir o the Commisson‘s adoption ofthe two—degrec spucing policy, sitelites in the geostationary stelite orbit were ustally spaced three or four degrecs spart By adepting roles that enabledstelite operators to plac thei space stations two degreesapar, the Commision was ableto accommodate more geostaionary satlites "" See 47 CFR§§ 25.114 and 25.210. * See Section V of Aricle 21 of he TTU Radio Repulatons. * MSV Applcation SAT—AMD—20040227—00021 at43. ‘The Commision has etablshed identcal PFD limits for dowalins in the adiacent 10.95—11.2 GHiz band. See47 CER. § 25.208(). 47 CER §2.106, Feomore NGIOL © Comsearch is a privately owned commercalfequency coontinator ®MSV Applicaton File No. SAT—AMD—20040227—00021 at 26. 11

Federal Communications Commission DA 05—50 d. Protection of other services 29. The Commission has allocated the 10.7—11.7 GHz band to FSS (space—to—Rarth) on a co—primary basis with the Terrestrial Fixed Service.©. The Commission has allocated the 12.75— 13.25 GHz band to FSS (Earth—to—space) on a co—primary basis with the Terrestrial Fixed and Terrestrial Mobile Services." > MSV will have to comply with Section 25.203(c) of the Commission‘s rules, which sets forth coordination and other procedures designed to ensure that there is no harmful interference between stations operating in co—primary services."" MSV states that it will protect terrestrial fixed and terrestrial mobile services currently operating in the bands through several measures. First, MSV states it will coordinate its feeder link stations with terrestrial Fixed and Mobile systems as required by Section 25.203(c). In addition, MSV states it will have a coordination study conducted on its earth stations to determine their suitability for operation and will apply mitigation techniques to ensure adequate protection ofthe earth stations and terrestrial systems. To ensure that ts feeder link operation will not impede implementation of the Commission‘s spectrum—relocation policy for Fixed Service licensees currently operating in the 18.3—19.3 GHz band, MSV states that it will demonstrate when applying for feeder link earth station licenses that the proposed uplink operation would not interfere with, or require protection from, the operation of any existing Fixed service station at its current site in the event that the Fixed Service station‘s assigned frequencies were to be shifled pursuant to Section 101.85, Section 101.89, Section 101.91, or Section 101.95 ofthe Commission‘s rules." 30. In addition to protecting Fixed and Mobile services, MSV says that it will protect other services operating in the bands it will be using. Footnote US2S1 to Section 2.106 of the Commission‘s rules states that the 12.75—13.25 band is allocated to the Space Research Service (deep space) (space—to—Earth) for reception only at Goldstone, California."" MSV states that it will take "all practicable steps" to ensure that is feeder link transmissions will not interfere with the space research service at Goldstone, Califomnia.® Additionally, Footnote NGS3 of Section 2.106 of the Commission‘s rules reserves the 13.15—13.20 GHz band for television pickup and Cable Television Relay Service (CARS) inside a 50 kilometer radius of the top 100 television markets identified in Section 76.51 of the Commission‘s rules."" To avoid interference with these services, MSV says it will not transmit in the 13.15—13.2125 GHz band from a site within 50 kilometers of a top 100 television market identified in ofthe Commission‘s rules."" 31. Last, Footnote US211 of Section 2.106 of the Commission‘s rules states that space station operators in the 10.7—11.7 GHz band should take all practicable steps to protect radio 947CR 52.106. "n ©arorm grs2m0 #ar c5s 10185, 101 89, 101.91, t0.95. "47 CR §2.106,Foomote Usas1 * MSV Appliation ile No. SAT—AMD—20040227—00021ar2s. " 47 CFR. § 2.106,Footote NGS3. MSV states ht it understands that authorityfor uplink transmission in any pottion ofthe 12.75—13.25 Gitz band for which MSV does not alteady have authority will be withheld pending adeption of iles for cordination of such opention with Broadeast Auxilizy Service (BAS) and CARS mobile pickup operatins. MSV Applicaion File No. SAT—AMD—20040227—00021 at 28. ® MSV Applicaion Fil No. SAT—AMD—20040227—00021 at 28 12

Federal Communications Commission Da 05—50 astronomy observations from harmful interference in adjacent bands."". According to MSV, 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 dBWim‘."" MSV has agreed to equip its replacement satellites with a transmitter output filter to limit the emissions in the 10.6—10.7 GHz band at or below this level. Existing in—orbit satelites in this band employ such a filter as part of past agreements between the MSS and radioastronomy communities. Consequently, subject to this agreement, we allow MSV to operate its feeder links and TT&C functions in the 10.7—10.95 GHz and 11.2—11.45 GHz bands on a non—harmful interference basis to radio astronomy operations in adjacent bands. D. Bond Requirement 32. In its Space Station Licensing Reform Order, the Commission eliminated the financial requirements then in place and replaced them with a bond requirement."" The bond requirement is intended to ensure that licensees are financially able and committed to implementing their Hicensed. systems in a timely manner. Under this requirement, any entity awarded a satellte license must execute a performance bond, payable to the U.S. Treasury, within 30 days of the date of the license grant. The bond is payable upon failure to meet any of the implementation milestones included in every license, where adequate justification for extending that milestone is not provided. Licensees may reduce the amount of the bond upon mesting each milestone."" 33. MSV requests a waiver of the bond requirement because it intends to provide public safety services on MSV—2, noting that it has a proven track record of providing critical public safety services with its current MSS system. Specifically, MSV states that AMSC—1‘s unique dispatch radio or "push—to—talk" feature has proven critical in times of emergency because it allows communications to be broadcast to a large group of users simultancously, thercby allowing coordination of rescue efforts. MSV states that it will expand this and other public safety service offerings to South America on MSV—2. 34. In its Space Station Licensing Reform Order, the Commission stated that it would entertain requests for complete or partial waivers of this bond requirement, but limited its discussion to waivers "for satellite operators proposing satellites designed to provide public safety services." "* The Commission noted that it would consider things "such as public safety intent in deciding whether a waiver is warranted.""" In assessing "public safety intent," the Commission intended that the proposed satellite be wholly or partially designed for the specific purpose ofproviding public safety services." " 47 CER. §2.106, Feomore US211. " Letter fom Lon Levin, Mobie Satlite Ventures to Ms. Marlene H. Dortch, Secretuy, Rederl Communications Commission (May 12, 2000 " SpaceStaton Licensing Reform Orde, 18 ECC Red t 10822—24, pars. 161—65 "*Space SaionLicensing Reform Order, 18 ECC Red t 10826—27, par. 172. "* Space Sation Licensing Reform Orde, 18 ECC Red t 10825, para.1690 *n "" Altough not drecly appliable to space sutions, the Communications Act, for purposes of allocting and assipning spectrum between 746 megaberte and 806 megahort, defines "Public Safey Services" asservices "he sole or principl purpase of which is to protect the sufity of life, health, or property, that are provided 13

Federal Communications Commission DA 05—50 35. We look to the public interest benefit assessment contained in MSV‘s application to determine whether it expresses the requisie "public safety intent." MSV states that "grant of this application will serve the public interest by allowing MSV to better compete in the global MSS marketplace and providing the benefits of competition and new public safety services to the public in South America.""" We conclude that this statement of purpose falls short of the type of public safety intent contemplated by the Commission. This statement indicates that MSV‘s primary goal in launching and operating its proposed satellite is to compete on a global scale and make its service more attractive to MSS users. MSV‘s "push to talk" feature does not justify a waiver of the bond requirement. All MSS systems are inherently useful in providing public safety service because the user terminals are small and transportable. MSV does not identify any specific "safety" services besides the dispatch radio service. Thus, nothing in MSV‘s proposal to provide basic voice and data and high—speed packet data mobile satellite services persuades us that MSV has demonstrated "good cause" for waiving the bond requirement. We must now determine the appropriate bond for MSV—2. 36. In the Space Station Licensing Reform First Reconsideration Order," the Commission revised the bond requirements adopted in the Space Station Licensing Reform Order. Specifically, the Commission reduced the bond amounts from $7.5 million to $5 million for NGSO licensees, and from $5 million to $3 million for GSO licensees."". In addition, the Commission determined that GSO MSS licensees should be subject to the GSO bond requirements, even though they are considered "NGSO—like" for purposes of determining the appropriate application review procedures."". Consequently, we require MSV to post a $3 million bond within 30 days of the release date of this Order. If MSV does not submit this bond by the required date, this authorization shall be null and void. IV. ORDERING CLAUSES 37. Mobile Satellite Ventures Subsidiary LLC‘s (MSV‘s) application File No. SAT— LOA—20030827—00174, Call Sign $2487, as amended by SAT—AMD—20031205—00347 and SAT— AMD—20040227—00021, 18 GRANTED, in part,and MSV is authorized to launch and operate its MSV—2 satellite at 63.5° W.L. in the 1525—1544 MHe (space—to—Rarth), the 1545—1559 MHz (space—to—Barth), the 1626.5—1645.5 MHz (Earth—to—space) and. the 1646.5—1660.5 MHz frequency bands for. service links, and the 12.75—13.25 GHz (Earth—to—space), 10.7—10.95 GHz and 1.2—11.45 GHz (space—to—Rarth) frequency bands for feeder links, in accordance with the terms, conditions, and technical specifications set forth in its application, this atachment and the by...overnmental entiies or by nongovemmental. orpanizations that are authorized by a governmental entiy whose primary mission is the provision of such services and thatare ot made commercially availableto the public y the providec® 47 U.S.C.§ 238 (D(1) " MSV Application File No. SAT—LOA—20030827—00174 at 3. * Amendment of the Commissin‘s Space Suition Licensing Rulesand Poliies, Arst Onder on Aeconsideration and Fifh Report and Order, TB Docket No 02:34, 19 FCC Red 12637 (2003) (Space Staion Licensing Reform First Reconsideration Order) " Spoce SutionLicensing Reform First ReconsiderationOrder, 19 ECC e at 13654, pars 43. "Space SaionLicensing Reform First Reconsideration Order, 19 ECC Red at 13655,prs. 46. 14

Federal Communications Commission DA 05—50 Commission‘s rules. 38. IT IS FURTHER ORDERED that MSV‘s request to operate in the 1544—1545/1645— 1646.6 MHz band, which is limited to disress and safety communications, IS DENIED 39. IT IS FURTHER ORDERED thatin the absence of a coordination agreement, MSV‘s operation in the L—band will be on a non—harmful interference basis to other mobile—satellite service systems operating in the L—band. Consequently, MSV shall not cause harmful interference to any other lawfully operating L—band satellite or radio facility and shall cease operations upon written notification of such interference. MSV shall also inform the Commission in writing of such notification. Furthermore, MSV must notify all other operators in these frequency bands that it will be operating on a non—harmul interference basis.. MSV must also notify its customers that its operations are on a non—harmful interference basis. 40. IT 18 FURTHER ORDERED that MSV‘s operation in the upper L—band, 1545—1559 and 1646.5—1660.5 MHz bands, shall comply with the real—time access and priority preemption requirements seforth in International Footnotes 5.357A and 5.362A, to protect AMS[RJS. 41. IT IS FURTHER ORDERED that MSV‘s operation in the lower L—band, 1530—1544 and 1626.5—1645.5 MHz bands shall comply with the real—time access and prionity preemption requirements set forth in Intemational footnote 5.353A to protect the Global Maritime Distress Satellte Service. 42. IT 18 FURTHER ORDERED that MSV‘s use of the 12.75—13.25 GHz frequency band shall comply with the terms of Foomote US251 to 47 C.F.R. § 2.106 to ensure that MSV— 2‘s Ku—band transmissions will not interfere with space research (deep space)(space—to—Rarth) service at Goldstone, Califomia. 43. IT IS FURTHER ORDERED that MSV may not transmit in the 13.15—13.2125 GHz band from a site within 50 kilometers of a top 100 television market identified in Section 76.51 of the Commission‘s rules. 44. IT 18 FURTHER ORDERED that the authority for uplink transmission in any portion of the 12.75—13.25 GHz band from any specified site not previously authorized will be withheld pending adoption of rules for coordination of such operation with Broadeast Auxiliary Service (BAS) and Cable Television Relay Service (CARS) mobile pickup operations. 45, IT 18 FURTHER ORDERED that Footnote NG1O4 to 47 C.F.R. §2.106 IS WAIVED to allow MSV to provide TT&C in the 11.45 GHz and 13.25 GHz bands to MSV—2 from gateway earth stations located Reston, Virginia and Alexandria, Virginia. 46. IT 18 FURTHER ORDERED that the suthorization for feeder link operation conditionally granted herein pertains only to feeder link and tracking, telemetry, and control transmission between a single GSO satellite at 63.5° W.L. and a maximum of two fixed carth stations within the continental United States. 47, IT IS FURTHER ORDERED that MSV‘s authority to operate in the 10.7—10.95 GHz, 11.2—11.45 GHz and the 12.75—13.25 GHz bands is on a non—interference basis contingent upon the issuance of an ITU finding permitting such additional use pursuant to Appendix 30B of the ITU‘s Radio Regulations. 15

Federal Communications Commission Da 05—50 48. IT 18 FURTHER ORDERED that MSV‘s use of the 10.7—10.95 GHz and 11.2—11.45 GHz frequency bands shall comply with the terms of Footnote US211 to 47 CFR. § 2.106 which urges applicants for airbome or space station assignments to take all practicable steps to protect radio astronomy observations in the adjacent bands from harmful interference, and, in accordance with the MSV agreement, limit emissions in the 10.6—10.7 GHz band to —160 dBW/m‘ or less. 49. IT 18 FURTHER ORDERED that MSV shall coordinate with co—primary Space Operations Service stations in the 1525—1559 MHz band and will not be entitled to protection from interference until it has completed coordination. 50. IT 1S FURTHER ORDERED that MSV shall coordinate with those countries conducting passive research in the 1525—1559 MHz band and will not be entitled to any protection from interference from passive research radio. stations unless: it completes coordination. 51. IT IS FURTHER ORDERED that MSV shall coordinate with co—primary Terrestrial Fixed Service providers in the 10.7—11.7 GHz band. 52. IT 18 FURTHER ORDERED that MSV shall coordinate with Terrestrial Fixed and Terrestrial Mobile Services in the 12.75—13.25 GHz band. 53, IT 18 FURTHER ORDERED that MSV‘s request to waive Section 25.210() of the Commission‘s rules to permit MSV to operate its MSV—2 satellite with an East—West station keeping tolerance of+0.1° 1S DENIED without prejudice. 54. IT 18 FURTHER ORDERED that MSV must provide a written statement to the Commission within 60 days of the date of this grant that identiies any known satelites located at, or planned to be located at, MSV‘s assigned orbital location, or assigned in the vicinity ofthat location such that the station keeping volume of the respective satelltes might overlap, and that states the measures that will be taken to prevent in—orbit collisions with such satellites.. This statement should address any licensed FCC systems, or any systems applied for and under consideration by the FCC. The statement need not address every filing with the ITU that meets these criteria, but should assess and address any systems reflected in TTU filings that are in operation or that MSV believes may be progressing toward launch, e.g. by the appearance of the system on a launch vehicle manifest. If MSV elects to rely on coordination with other operators to prevent in—orbit collisions, it shall provide a statement as to the manner in which such coordination will be effected. 55. IT IS FURTHER ORDERED that MSV‘s operation at inclinations between 4.5° and 6.0° shall be on a non—interference basis until it completes coordination with license NGSO FSS operators. 56. IT 18 FURTHER ORDERED that MSV‘s request for a waiver of Section 25.165(a) of the Commission‘s rules 18 DENIED. 57. IT IS FURTHER ORDERED that MSV must construct, launch and place its authorized satelite into operation in accordance with the technical parameters and terms and conditions of this authorization by these specified time periods following the date of authorization: 16

Federal Communications Commission DA 05—50 A: Enter into a binding non—contingent contract to construct the licensed satellite system by January 11, 2005. B: Complete the Critical Design Review of the licensed satellite system by January 11, 2006. Begin the construction ofthe satellte by January 11, 2007 D: Launch and begin operations of the satellte by January 11, 2009. Licensee must file a bond with the Commission in the amount of $3,000,000.00, pursuant to the procedures set forth in Public Notice, DA 03—2602, 18 FCC Red 16283 (2003), within 30 days of the date of this GRANT. Failure to meet any of these dates shall ender this authorization NULL and VOID. 58. MSV shall prepare the necessary information, as may be required, for submission to the Intemnational Telecommunications Union (ITU) to initiate and complete the advance publication, international coordination, due difigence, and notification process of this space station, in accordance with the TTU Radio Regulations. MSV shall be held responsible for all costrecovery fees associated with these ITU filings. We also note that no protection from interference caused by radio stations authorized by other administrations is guaranteed unless coordination and notification procedures are timely completed or, with respect to individual administrations, by successfilly. completing coordination agreements, Any: radio. station authorization for which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments of other administrations. See 47 CFR. § 25.111(b). 59. MSV is obliged to comply with the applicable laws, regulations, rules, and licensing procedures ofany countries it proposes to serve. 60. IT 1 FURTHER ORDERED that the license term for the MSV—2 satellite, Call Sign: $2487, is fifeen years and will begin to run on the date that MobilSatellite Ventures Subsidiary LLC certifies to the Commission that the satellte has been successfully placed into orbit and its operation fully conforms to the terms and conditions of this authorization. 61. This Order is issued pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 C.FR. § 0.261, and is effective upon adoption. Petitions for reconsideration under Section 1.106 or applications for review under Section 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date of the Public Notice announcing that this action was taken. FEDERAL COMMUNICATIONS COMMISSION %fi: elsot e a/4 Chief, International Bureau 17


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