Attachment reply

reply

REPLY submitted by Inmarsat

reply

2006-03-01

This document pretains to SAT-AMD-20051116-00221 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2005111600221_486627

Before the RECEIVED FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 MAR — 1 2008 In the matter of ) reden CommunatonConsin ) Offee o Sertay Use ofReturned Spectrum in the 2 GHz ) B Docket Nos. 05—220 and 0—221 MSS Frequency Bands ) 5. ) Re Inmarsat Global Limited ) File Nos. SAT—PPL—20050926—00184 Petiion for Declaratory Ruling ] SAT—PDR—20050926—00184 ) SAT—AMD—20051116—00221 CoNsoLIDATED REPLY Inmarsat replies to the pleadings filed in response to the Petitions for Reconsideration ofthe two Orders in which the Commission: (1) assigned the entie 2 GHz band to TMI and ICO (the "2 GHz Order®); and (2) dismissed Inmarsat‘s Petition for Declaratory Ruling (°PDR") to provide MSS at 2 GHz. In its Petition for Reconsideration, Inmarsat demonstrated that the decision to assign the entire 2 GHe band to TMI and ICO was based on the following flawed and unsubstantiated assumptions: (})other MSS operators do not need access to 2 GHz because they can use other bands to provide the services possible at 2 GHz; (i) TMI should have access to more 2 GHz spectrum because it does not have other MSS interests; and (i) awarding the entire 2 GHz band to TMI and 1CO will produce public safety and rural broadband benefitsdifferent from those that competing applicants would be able to provide. Moreover, Inmarsat showed that the Commission failed to address altemative solutions that would serve the public interest better than licensing to duopoly at 2 GHe today. Globalstar‘s Petition for Reconsideration reiterated manyof these same themes, emphasizing that the public interest determinations in the 2 GH: Order were "both premature and unsubstantiated."" CTIA and T—Mobile support Inmarsat‘s and Globalstar‘s calls for * Globalstar Petition for Reconsideration at 8.

reconsideration. As T—Mobile states: "the 2 GHz MSS Order cannot withstand APA serutiny, as it relies upon unrealistic assumptions, fails to fully consider rational suggestions, and arrives at an unsupported conclusion that is contrary to any reasonable interpretation ofthe record evidence."" Only two parties oppose reconsideration:. TMI and ICO, the recipients ofthe 2 GHz spectrum windfall. Significantly, TMI and 1CO fail t refute the identiied deficiencies of the 2 GHz Order. Instead, TMI and 1CO rely on arguments that the Commission expressly declined to consider, and on factors that would apply equallyto all potential 2 GHz MSS operators. Moreaver, TMI and ICO fail to address how it better serves the public interest to assign the entire 2 GHz band tthem, rather than to authorizeadditional MSS providers, and thereby provide for increased competition in the band. Forthe reasons provided in Inmarsat‘s Petition for Reconsideration, and those set forth below, the Commission should reconsiderits decisions and reinstate Inmarsat‘s PDR to provide MSS to the United States at 2 GHz. 1. TMT‘s Axp ICO‘s Justirications Do Nor Cure Ti Dericiencits in Ti 2 GHZ Ororr Inmarsat‘s and Globalstar‘s Petiions show that the 2 GHz spectrum award to TMI and 1CO was unsubstantiated. Namely,there is no rational basis on which to conclude that greater public safety and rural broadband services would accrue by increasing 1CO‘s and TMI‘s spectrum assignments by 250 percent, rather than by allowing a third (or possibly a fourth) competitor in the band." This is particularly true when two qualified MSS operators—Inmarsat * Comments of T—Mobile at 4 (foomotes omitted). * The relevant issue on reconsideration is whether there is a substantiated and reasoned basis for deciding to award TMI and ICO more spectrum instead of licensing additional operetors in the band.. O 1CO Opposition at 8; TMI Opposition at i, 17. 2

and Globalstar—were on record with proposals to meet those very same public safety and rural broadband needs by the end of the decade." Instead of addressing these legal shortcomings, TMI and ICO argue that a number ofdifferent considerations could support the Commission‘s decision: (1) their plans for an ATC network; (2) the technical capabilities ofTMI‘s proposed spacecraft;and (3) the speed at which TMI and 1CO could deploy their hybrid MSS/ATC networks." As Inmarsat demonstrated inits Petition for Reconsideration, in reaching its decision, the Commission expressly rejected each of these factors as not relevant. Moreover, these considerations would not support the decision to award the entire 2 GHz band to TMI and 1CO in any event. ATC: Commission policy is clear that ATC is nota legitimate justification for secking additional spectrum. Moreover, the Commission emphasized in the 2 GH Order that it did not "reach() tissue ofwhether ICO and TMUTerreStar need additional spectrum to provide ATC, as they claim."". For this reason, the virtually identical letters from state and local public safety officials that TMI and ICO tout in their Oppositions® are not "compelling," or even remotely probative: those letters support the award ofspectrum so that TMI and 1CO can provide ATC? Even if the Commission were to change its policy and rely on ATC plans to justify the spectrum award, there would be no reason to provide ICO‘s or TMUTerreStar‘s 2 * TMI‘s eriticism of Inmarsat‘s plans to deploy ATC in conjunction with a qualiied terrestrial partner, TMI Opposition at 11—12 & n.42, ring particularly hollow in light ofpress reports that TMT‘s affiliate, MSV, does not intend to deploy ATC alone. Jesse Drucker, Catching a Wave, As Satellte Firms Move to Add Cellular Service, Critics Cry Foul, Wall St.1., Feb. 9, 2006, at A1. * See TMI Opposition at 2—7; ICO Opposition at 3—5. ® See Comments of Inmarsat in 1B Docket No. 0$—220 at 18—20 (citing Flexibilitfor Delivery ofCommunications by MSS Providers, 18 FCC Red 1962, 1974 4 20, 2067 4 215 (2003)). 72 GHz Order at 1281.76; see also id. 1 42,n.116 ("we ... do not rely on contentions that TM! needs additional spectrum deploy a network using ATC®). * TMI Opposition at 3—4; 1CO Opposition at 3. * See 2 GHz Order at§ 28,n.74.

GHz ATC plans any greater weight than Inmarsat‘s or Globalstar‘s. Neither ICO nor TerreStar has ever provided commercial satelite service, submitted an application to provide ATC, or committed to a specific ATC deployment schedule. Spacecraft Design: ‘TMI‘s reliance on the technical capabilities ofts proposed spacecraftlikewise is unavailing.." The Commission appropriately placed no weight on TMI‘s spacecraft design."" Commission policy is clear that TMI cannot "bootstrap"" itway into more spectrum by building a larger spacecraft than the Commission has authorized."" Even if the Commission were to change that policy, the 2 GHz Order does not address why TMI‘s and 1CO‘s stil—evolving 2 GHz networks would provide greater public interest benefitsthan Inmarsat‘s (or Globalstar‘s) 2 GHz spacecraft design. Deployment; 1CO attempts tojustify its spectrum award by claiming that the decision "would ensure that the spectrum would be broughtinto use more quickly than if the spectrum were assigned to others.""". 1CO ignores the Commission‘s express rejection of "speed"as the basis for increasing 1CO‘s and TM!‘s spectrum assignments,and the clear finding that increased speed ofdeployment would not outweigh giving other entities an opportunity to compete at 2 GHz."* In this regard, it bears emphasis that Inmarsat and Globalstar provided the Commission with proposals for expeditiously authorizing competing MSS providers, and each indicated that it could deploy is 2 GHz system by the end of the decade. Thus, even if speed of deployment were considered, others could be in a position to bring the returned spectrum into use soon after ICO and TMI are required to commence commercial 2 GHservice. ‘° TMI Opposition at 4. 72 GHe Order 1 42,n.116. !* See Inmarsat November 16 £t Parte at 3; Inmarsat Reply Comments in TB Docket No. 05— 221 at 37—40. . 1CO Opposition at 4—5. " 2 GHz Order at 1 57,n.173.

Other than these three factors (which do not justify the spectrum windfally, 1CO‘s and TMI‘s Oppositions offer only vague platitudes about how MSS generally can provide public safety and rural broadband benefits. Again, there is no reason to believe that TMI and 1CO are better suited to provide those benefitsthan the two other entities who stand ready to deploy at 2 GHz—Inmarsat and Globalstar. Moreover, as both Globalstar and CTIA aptly note, neither I1CO nor TMI is required to serve the needs of first responders or to provide broadband services in rural areas.." Thus, there can be no basis to conclude that awarding more spectrum to ICO and TMI would better advance those goals than authorizing additional competitorsin the band. To the contrary, as Inmarsat has explained, courtsare clear in waring that the creation ofa duopoly raises the risk that consumers will not receive the benefits that result from healthy competition.® 11. ThCoission Dip Nor Anoarss Reuevant Arcuments anp Prorosats In addition to the absence of substantiated reasoning, the 2 GHz Order is legally deficient because it failed to address several relevant ssues and altemative proposals. First, the Commission failed to address the aspects ofthe 2 GHz band that make it uniquely suited among MSS bands to support high—data—zate, next—generation multimedia MSS offerings over mobile handheld devices, and that highlight the dangers of licensing to duopoly at 2 GHz."" Although the Commission concluded that 2 GHMSS providers will be able to compete with MSS operators in other bands, the Commission simply did not address the converse: whether other MSS bands can support the same product offerings as those proposed at "* CTIA Comments at6 (citing Globalstar Pettion at 9). 1CO‘s citation to the geographic coverage rules that apply to MSS providers, ICO Opposition at 3—4 (citing 47 C.FR. §—25.143(b))Giv)), is unavailing. There is no requirement that 1CO and TMI actually provide broadband service, nor any specification ofthe data rates they must achieve or the other salient conditions on which they are to provide "broadband service" to "rural areas." !* Inmarsat Petition at 5—7. ‘" See Reply Comments of Inmarsat in IB Docket No. 05—221 at 17—22; Leter from John P. Janka to Marlene H. Dortch, IB Docket Nos. 05—220 and 05—221, at 8 (iled Sep. 28, 2005). 5

2 GHz, or whether MSS providers in other bands can compete with the MSS offerings possible a2 oHe." 1CO‘s cursory responses to these competitive issues do not bear scrutiny. The fact that Inmarsat will soon introduce BGAN service at L—Band in the United States does not obviate the need for further competition at 2 GHz. The future opportunitiesto deploy 2 GHz multimedia services to handheld MSS devices are far different than any of the services that Inmarsat is able to offer at L—Band today or in the near term. TMI admits as much."" Nori it relevant, as 1CO asserts, that the Commission has not chosen to extend to the 2 GHz band the same licensing reform rulesthat apply in other bands."" The policy underlying those rules,firsarticulated in the DIRECTY/EchoStar Hearing Designation Order, applies with equal force here. In that case, the Commission recognized that the anticipated provision of broadband services in a nascent frequency band presents issues that warrant a much more sophisticated look at the definitions of markets and market participants than those assumed by 1CO‘s and TMI‘s broad—brush assertions thatall MSS frequency bands are fungible. In fact, one ofthe very reasons the Commission designated for hearing the proposed DIRECTV/EchoStar merger was a concem about the transaction‘s impact on the provision of broadband services by satellite in the nascent Ka band."" Nor is there any record basis here to conclude that the broadband MSS services to be provided in the nascent 2 GHz: Band would be reasonably interchangeable with MSS services possible in other bands."" Nothing in the various "* Cf. TMI Opposition at 8. "* 14. at 6 (describing how TMI‘s 2 GHz system will provide services not available from Inmarsat or any other satellite provider). ® 100 Petition at 6—7. *‘ See EchoStar Communications Corp., 17 FCC Red 20559, 20665—66 3 289 (2002). Much as the 2 GHz band should be treated here, the Commission treated the nascent FSS Ka band as different from the existing, congested FSS bands in which satellte services already were being provided. See id. at 20650 4 241. * See id. at 20651 1244.

submissions of Professor Cowhey or Dr. Bruce Owen that TMI has submitted fills these gaps in: the record." Second, the Commission ignored the fact that TMIis an incumbent MSS provider with close business ties t, and substantial overlapping ownership with, MSV. In fact, MSV does not dispute Globalstar‘s documentation of that relationship in its Petition.®" Thus, the Commission‘s stated inclination to award the returned spectrum to "new entrants,"rather than to existing MSS operators, is fatly inconsistent with the decision to award more 2 GHz spectrum to TM.*" In fact, despite the stated desire to facilitate new entrants, as a result ofthe 2 GHz Order, the MSV/TMI ventures have approximately twice the amount ofMSS spectrum over the Americas as any other provider."" Contrary to what TMI assers, the Commission did not "find" that TMI, TerreStar, and MSV‘s MSS businesses are "independent." The Commission‘s sifence on this issue cannot be construed as a conclusion that TerreStar and MSV "are separately owned and managed,... will operate separate MSS systems, and thatthe two companies plan to compete against one another.""" Nor could the Commission have assumed that the 2 GHz spectrum awarded to TMI wltimately would be held by an independent, new entrant. TMI stll holds its 2 GHz authorization, and, as recent press releases reflect, the possible restructuring ofthe relationship between and among TM, MSV, and TerreStar remains in Nux." "* See TMI Opposition at 9. "*. Globalstar Petition at 18—21 (providing a detailed account of the interrelationship between TMI and MSV); Letter Comments ofMSV at 1. "*. See 2 GHz Order i1356 & 1.173. * Inmarsat Petition at $:9. * TMI Opposition at 12—13. * See Press Release, Motient Corp., Motient Corp. Updates Shareholders on MSV Roll—Up (Feb. 2, 2006); Press Relcase, SkyTerra, StyTerra Issues Update on Proposed MSand TerreStar Consolidation (Feb. 2, 2006). Thus, his issue is not "mooted," as TMI assents, by 7

Third, the Commission simply failed address several ofInmarsat‘s proposals that would both (i) avoid prematurely constraining access to the 2 GHz band to two entities who remain years away from deploying their systems, and (i) allow the entry of a third (and possibly a fourth) 2 GHz competitor, without undue delay."" Inmarsat proposed incentives to ensure additional competitors would commence service as quickly as possible, and offered a way to increase TMI‘s and ICO‘s spectrum assignments to 2 x 6.67 MHz (as the Commission originally proposed) while also licensing additional competition in the band."" While TMI debates the merits of one of these proposals for the first time now," 1CO erroncously argues that the Commission was not required to address them at all." TM! criticizes Inmarsat‘s proposal wherchy the award of 2 GHz spectrum rights would go to the first of several competitors t actually deploy a satelite system in the band."" Contrary to what TMI would have the Commission believe, this type of market—based solution already has proven effective in facilitating innovation in the satelite industry. Entreprencurs have funded a number of inititives that have competed for (and won)the $10 Million prize in the X Prize Cup, which was established to spur technological innovation in space."" If funding is available for speculative space ventures that seek to claim such a prize, there is no reason to assume that funding would not be readily available to pursue the spectrum "prize" that is 2 GHz. Motient‘s recent announcement thatit does not intend to increase its ownership in MSV. TMI Opposition at 13, n.51. * See Inmarsat Petition at 12—13. ®*. See id. at 12—14. *‘ TMI Opposition at 15. * 1C0 Opposition at 11. * TMI Opposition at 15 (citing Inmarsat Petition at 13). * See hitp:/wwxprizefoundation.com; SpaceShipOne captures X Prize, Privarelyfunded craft reaches altitude requirement (Oct. 4, 2004), available at hitps//www.cnn.com2004TECH/space/10/04/spaceshipone.attempt.cnn/index.htm1. 8

1CO is wrong that the Commission was not obliged to consider these types of proposals that Inmarsat submitted in response to the Commission‘s express soliciation* Inmarsat proposals were "front—and—center" in its pleadings," and were made in numerous ex parte presentations detailing altematives to providing the entire 2 GHz band to 1CO and TML."" Inmarsat‘s alternatives are not, as ICO implies, the type of "rather subtle suggestion{s]" that the Commission may not be obligated to address."" HiI. OrnerIssurs A. Inmarsat Has Standing 1CO is wrong that, in order to establish "standing," Inmarsat must show that it is an aggrieved party within the meaning of Section 316 ofthe Communications Act."" First, because the Commission recognized that Section 316 does not squarely apply to the 2 GHz Order, the statutory strictures of Section 316 do not apply cither."" Second, the Public Notices in these proceedings expressly solicited comment from a wide range ofinterested partis,"" pursuant to which Inmarsat and a host ofothers actively participated, and Inmarsat submitted a competing proposal forits own 2 GHz MSS system. Finally, the 2 GHe Order specifically allowed further challenges to be lodged pursuant to two different avenues — one for any licensce or permittee that believed that ts license would be modified by the decision, and one for any **. See Public Notice, FCC 0—133 (rel. Jun. 29, 2005); Public Notice, FCC 05—134 (rel. Jun. 29, 2003). * See, eg, Comments of Inmarsat in IB Docket No. 05—220 at 25—32; Reply Comments of Inmarsat in IB Docket No. 05—221 at 10—29. *‘ See, eg, Leter from John P. Janka to Marlene H. Dortch, File No. SAT—PPL—20050926— 00184, TB Docket Nos. 0—220 and 05—221, at 2 (filed Aug. 24, 2005); Leter from John P. Janka to Marlene H. Dortch, IB Docket Nos. 05—220 and 08—221, at 10—12 (filed Sep. 28, 2005); Letter from John P. Janka to Marlene H. Dortch, SAT—PPL—20050926—00184, IB Docket Nos, 05—220 and 0—221, at 1 (filed Nov. 16, 2008) **: See 1CO Opposition at 11 (citing MCT Worldeom. v. FCC, 209 F.3d.760 (D.C. Cir. 2000). * f4 at1143. © 2 GHz Order at12, n3 & 118 * Seeid. at 99 3—4.

entity thatis entitled to seek reconsideration under Section 1.106 ofthe Commission‘s rules."" Inmarsat chose the latter procedural vehicle, which it has standing to pursue by virtue of its active participation in this proceeding and its PDR." B. Reconsideration of Inmarsat‘s Petition for Declaratory Ruling Is Warranted In its Petition, Inmarsat urged, to the extent the Commission revisitsits 2 GHz decision, that the Bureau reconsider the dismissal ofInmarsat‘s PDR to provide 2 GHz MSS service to the United States.‘ That resultis warranted because the only reason Inmarsat‘s PDR was dismissed was that the entire 2 GHz band already had been awarded to TMI and 1CO. Neither TMI nor 1CO disputes that reconsideration of Inmarsat‘s PDR would be appropriate in these circumstances."" Thus, Inmarsat reiterates its request that the Commission reinstate Inmarsat‘s PDR and grant Inmarsat authority to compete as a third provider of2 GHz MSS. For the foregoing reasons, the Commission should reconsider its 2 GHz Order and reinstate Inmarsat‘s Petition for Declaratory Ruling to provide 2 GHz MSS. Respectfully submitted, Diane J. Comell Vice President, Govemment Affairs INvarsar, Inc. 1100 Wilson Blyd, Suite 1428 enth Street, N.W., Suite 1000 Arlington, VA 22209 Washington, D.C. 20004 March 1, 2006 * 1d. ar t 68—69. ® 47 CFR. §1.106@)0). * Inmarsat Petition at 16. * TMI argues only that a decision nor to reconsider the 2 GHz Order would negate the need to reconsider dismissal of Inmarsat‘s market access petiion. TMI Opposition at 15, n.56. 10

CERTIFICATE OF SERVICE 1, Jeffrey A. Marks, hereby certify that on March 1, 2006, I caused to be served a copy of the foregoing Consolidated Petition for Reconsideration by first—class U.S. mail (unless otherwise indicated) upon the following: Chairman Kevin J. Martin Michael J. Copps Federal Communications Commission Commissioner 445 12" Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW By Electronic Mail Washington, DC 20554 By Electronic Mail Jonathan J. Adelstein Deborah Taylor Tate Commissioner Commissioner Federal Communications Commission Federal Communications Commission 445 12" Street, SW 445 12" Street, SW Washington, DC 20554 Washington, DC 20554 By Electronic Mail By Electronic Mail Fred Campbell Emily Willeford Legal Advisor to Chairman Martin Deputy Chief of StafF and Federal Communications Commission Advisor to Chairman Martin 445 12" Street, SW Federal Communications Commission Washington, DC 20554 445 12"Street,SW By Electronic Mail Washington, DC 20554 By Electronic Mail John Giust Barry Ohison Legal Advisor to Commissioner Copps Legal Advisor to Commissioner Adelstein Federal Communications Commission Federal Communications Commission 445 12" Street, SW 445 12"Street,SW Washington, DC 20554 Washington, DC 20554 By Electronic Mail By Electronic Mail Asron Goldberger Donald Abelson Legal Advisor to Deborah Taylor Tate Chicf, International Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, SW 445 12"Street,SW Washington, DC 20554 Washington, DC 20554 By Electronic Mail By Electronic Mail

Roderick Porter Richard Engelman Deputy Bureau Chicf, International Bureau ChiefEngineer, Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street,SW 445 12" Street, SW Washington, DC 20554 Washington, DC 20554 By Electronic Mail By Electronic Mail Sam Feder Cassandra Thomas Acting General Counse! Acting Chief Federal Communications Commission Satellite Division, Intemational Division 445 12"Street, SW Federal Communications Commission Washington, DC 20554 445 12Street, SW Ry Electronic Mail Washington, DC 20554 By Electronic Mail Gardner Foster Karl Kensinger Legal Advisor, Interational Bureau Associate Division Chief Federal Communications Commission Satellte Division, Intemational Bureau 445 12" Street,SW Federal Communications Commission Washington, DC 20554 445 12° Street, SW By Electronic Mail Washington, DC 20554 By Electronic Mail Fem Jarmulnck William Bell Deputy Chief Policy Branch Satelite Division, International Bureau Satellite Division Federal Communications Commission International Division 445 12® Street, SW Federal Communications Commission Washington, DC 20554 445 12" Street,SW By Electronic Mail Washington, DC 20554 By Electronic Mail Steve Spacth Christopher Guttman—McCabe Assistant Division Chief CTIA The Wireless Association Satelite Division, Intemational Bureau 1400 16" Street, NW Federal Communications Commission Suite 600 445 12" Street, SW Washington, DC 20036 Washington, DC 20554 By Electronic Mail i

Dale Branlund Thomas Clemons Chief Technical Officer President BRN Phocnix, Inc. Aleska Association of Chiefs of Police 329 N. Bemardo Avenve P.0. Box 167 Mountain View, CA 94043 Seward, AK. 99664 Loren Leman Suzanne Hutchings—Malloy Chairman 1CO Satelite Services, G.P. Aerospace States Association 2000 Pennylvania Avenue, NW 2200 Wilson Boulevard Suite 4400 Suite 102—249 Washington, DC 20006 Arlington, VA 22209 William T. Lake Carl R. Frank William Cutler Pickering Hale and Dorr Jennifer D. Hindin 2445 M Street, NW Amy E. Bender Washington, DC 20037 Kelin N. Kasler Counselfor Globalstar, LLC Wiley Rein & Ficlding 1776 K Street, NW Washington, DC 20006 Counselfor Sirius Satellite Radio, Inc. Nils Rydbeck, MSEE, PhD., Professor Kathleen O‘Brien Ham Rydbeck Consulting Managing Director, Federal Regulatory Affairs 943 Flagship Drive T—Mobile USA, Inc. Summerland Key, FL 33042 401 9° Street, NW Suite 550 Washington, DC 20004 Thomas J. Sugrue J. R. Carbonell Vice President, Government Aairs Carol L. Tacker T—Mobile USA, Inc. David G. Richards 401 9° Street, NW Cingular Wireless,LLC Suite 550 5565 Glenridge Connector Washington, DC 20004 Suite 1700 Atlanta, GA 30342 Robert A. CalafF Peter Pitsch Director, Federal Policy Communications Policy Director T—Mobile USA, Inc. Intel Government Affairs 401 9° Street, NW Intel Corporation Suite 550 1634 1 Street, NW, Washington, DC 20004 Suite 300 Washington, DC 20006 i

Dennis J. Bumett Andrew Tang Vice President Director Wireless Systems Analysis EADS North America Defense Company Broadband Wireless Division 1616 North Fort Myer Drive Intel Corporation Suite 1500 1634 1 Street, NW Arlington, VA 22209 Suite 300 Washington, DC 20006 Marjorie J. Dickman Jonathan D. Blake Senior Attomey Kurt A. Wimmer Intel Government Affairs Matthew S. DelNero Intel Corporation Covington & Burling 1634 1 Street, NW 1201 Pennsylvania Avene, N.W. Suite 300 Washington, DC 20004—2401 Washington, DC 20006 Counselfor TerreStar Networks, Inc. Gregory C. Staple Wayne V. Black Vinson & Elkins Keller and Heckman LLP 1455 Pennsylvania Avenue, NW 1001 G Street, NW Washington, DC 20004—1008 Suite 500 West Counselfor TMI Communications and Company Washington, DC 20001 Limited Parmership Counselfor American Petroleum Institute Oliver Badard Joseph P. Markoski Vice President Bruce A. Olcott Alcatel North America Squire, Sanders & Dempsey LLP 11600 American Dream Way 1201 Pennsylvania Avenue, NW 9° Floor P.0. Box 407 Reston, VA 20193 Washington, DC 20044—0407 Counselfor The Boeing Company Thomas M. Walsh Henry Ruwiedel Spectrum Planning & Regulation Rubwiedel The Bocing Company — IDS/S&IS ssir w iss® Satellte Development Center Crown Point, IN 46307 P.0. Box 92919 we w—si0—s343 Los Angeles, CA 90009—2919 iv

ChiefDan Flmn Raymond G. Bender, Jr. Savannah Chatham Mctropolitan Police John S. Logan P.0. Box 8032 Dow, Lohnes & Albertson, PLLC Savannah, GA 31412 1200 New Hampshire Avenue, NW Suite 800 Washington, DC 20036 Counselfor Hughes Network Systems, LLC Gerald C. Musarra Laurence D. Atlas Vice President, Trade & Regulatory Affairs Leoral Space & Communications Lockheed Martin Corporation 1421 Jefferson Davis Highway 1500 Crystal Drive Suite 810 Suite 300 Arlington, VA 22202—3290 Arlington, VA 22202 Carl Hofferberth Lany Hatch Microwave Circuits, Inc. Advanced Manufacturing Technology, Inc. 1611 Kemper Street 28 Millrace Drive Lynchburg, VA 24501 Lynchbure, VA 24501 David A. Cavossa Christopher D. Imlay Executive Director General Counsel SatelliteIndustry Association Society of Broadcast Engineers, Inc. 1730 M Street, NJW. c/o Booth, Freret, Imlay & Tepper Suite 600 14356 Cape May Road Washington, DC 20036 Silver Spring, MD 20904 Fred Fellmeth, Esq. James R. Jenkins 777 American Drive Vice President, Legal and External Affairs Bensalem, PA 19020 United States Cellular Corporation Counselfor Toral RF Marketing, Inc. 8410 West Bryn Mawr Chicago, II 60631 George Y. Wheeler, Esq. Bert W. King Holland & Knight LLP 24 Jones Avene 2099 Pennsylvania Avenue, NW Greenville, SC 29601—4332 Suite 100 Washington, DC 20006 Counselfor United States Cellular Corporation ChiefJoseph G. Estey ChiefHarold L. Hurt President President International Association of Chiefs ofPolice Major Cities Chiefs Association 422 Winthrop Drive 422 Winthrop Drive Tthaca, NY 14850—1739 Tthace, NY 14850—1730

SheriffJames A. Kames SheriffTed Sexton President President Major County Sherifis‘ Association National Sheriffs‘ Association 422 Winthrop Drive 422 Winthrop Drive Ithaca, NY 14850—1730 Tthaca, NY 14850—1739 William K. Coulter, Esg. Kumar Singarajsh DLA Piper Rudnick Gray Cary LLP Chairman 1200 19th Street, N.W. Satelite Action Plan Regulatory Group Washington, DC 20036 Brussels Counselfor Mobile Satellite Users Association BELGTUM, DC 01040 By International Mail Aarti Holla—Maini Robert A. Mazer, Esg. Secretary General R. Edward Price European Satellite Operators Association Vinson & Elkins, LLP Brussels 1455 Pennsylvania Avenue, NW BELGIUM, DC 01040 Washington, DC 20004—1008 By International Mail Counselfor StyTerra Communications, Inc. Lawrence R. Krevor Robert S. Foosaner Vice President, Spectrum Strategy Vice President and ChiefRegulatory Officer Sprint Nextel Corporation Sprint Nextel Corporation 2001 Edmund Halley Drive 2001 Edmund Halley Drive Reston, VA 20191 Reston, VA 20191 J11 M. Lyon Vice President and General Counsel Trey Hanbury United Telecom Council Senior Counsel, Spectrum Strategy 1901 Pennsylvania Avenue, NW Sprint Nextel Corporation 5" Floor 2001 Edmund Halley Drive Washington, DC 20006 Reston, VA 20191 Kenneth L. Morekel Lee Cobb Director Executive Director Ohio Department of Public Safety Virginia‘s Region 2000 Economic 1970 West Broad Street Development Council P.0. Box 182081 P.0. Box 937 Columbus, OH 43218—2081 Lynchburg, VA 24505 Cecilia Bemier Lester B. Baird, Sr. Town Manager County Administrator P.0. Drawer 669 Hendry County, Florida Windermere, FL 34786 P.0. Box 2340 LaBelle, FL 33975—2340 vi

SheriffRobert J. McCabe ChiefA.M. Jacocks,Jr. Norfolk Sheriff‘s Office Chicfof Police 811 E. City Hall Avenue Building 11 Norfolk, VA 23510 Municipal Center 2509 Princess Anne Road Virginia Beach, VA 23456 Cartton Stallings Randy S. Segal President Senior VicePresident, General Counsel and Georgia Fratemal Order ofPolice Secretary 772 Maddox Drive MobilSatellite Ventures Subsidiary LLC Suite 104 10802 Parkridge Boulevard Ellijay, GA 30540 Reston, Virginia 20191 A A.Z— vii


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