Attachment 1995AMSC Reply to Co

1995AMSC Reply to Co

REPLY TO OPPOSITION TO PETITION FOR RECONSIDERA submitted by AMSC

Reply

1995-03-27

This document pretains to SAT-L/A-19941116-00074 for Launch Authority on a Satellite Space Stations filing.

IBFS_SATLA1994111600074_1081201

Before the FEDERAL COMMUNICATIONS COMMISSION ' P U E /—U e Washington, D.C. 20554 CLIOA, E. In 12 Application of MAR 3 0 1995 TRW Inc. File Nos. 20—DSS—&zO9k(12)— ~ ~ommunical ess—o101s! Wesfiis For Authority to Construct, Launch, and Operate 18—SAT—AMEND—95 a Low Earth Orbit Satellite System in the 1610—1626.5 MHz/2483.5—2500 MHz Band mEOEIvVEC REPLY TO CONSOLIDATED OPPOSITION TO MAR 27 '995 PETITIONS FOR RECONSIDERATION "EOERALCOMRMUNICATIONS CoMEESSION AMSC Subsidiary Corporation ("AMSC") hereby replies to the opposition filed by TRW Inc. ("TRW*") in response to AMSC‘s Petition for Reconsideration of the Commission‘s order granting TRW‘s above—referenced application. Order and Authorization, DA 95—130 (January 31, 1995). In its Petition for Reconsideration, AMSC asked the Commiuission to clarify that grant of the license to TRW would be conditioned on the outcome ofthe rulemaking in the proceeding, which was itself subject to reconsideration at the time the Commission granted TRW‘s license. Report and Order, CC Docket No. 92—166, FCC 94—261, 9 FCC Red 5936 (19945. AMSC is seeking reconsideration of the rulemaking on a number of grounds, including the Commission‘s exclusion of systems using geostationarysatellites. AMSC Petition for Reconsideration, CC Docket No. 92—166 (November 21, 1994), at 8—1 1. TRW opposes AMSC‘s Petition for Reconsideration ofits grant, arguing that it should not be "held hostage" to the future actions of those who pursued their rights in the rulemaking. AMSC is not attempting to hold TRW thostage." AMSC did not oppose the grant of TRW‘s application and AMSC does not oppose TRW‘s going forward with the construction of its system, subject only to whatever modifications might be mandated by the ultimate outcome of

2 the rulemaking. AMSC is merely asking the Commission to clarify that whatever rights TRW has as a result of the grant of its application those rights are subject to the outcome of the underlying rulemaking, which is not yet complete. Respectfully submitted, AMSC SUBSIDIARY CORPORATION oiPA Bruce D. Jacobs Lon C. I€vin Glenn S. Richards Vice President and Kevin M. Walsh Regulatory Counsel Fisher Wayland Cooper AMSC Subsidiary Corporation Leader & Zaragoza, L.L.P. 10802 Park Ridge Boulevard 2001 Pennsylvania Avenue, N.W. Reston, Virginia 22091 Suite 400 (703) 758—6000 Washington, D.C. 20006 (202) 659—3494 March 27, 1995

CERTIFICATE OF SERVICE I, Ana Julissa Ayala, a secretary in the law firm of Fisher Wayland Cooper Leader & Zaragoza L.L.P. do hereby certify that on this 27th day of March 1995, a copy of the foregoing "Reply to Consolidated Opposition to Petitions for Reconsideration" by AMSC . Subsidiary Corporation was sent by U.S. first class mail, postage prepaid to: Robert A. Mazer Rosenman & Colin 1300 19th Street, N.W. Suite 200 Washington, DC 20036 Counsel for Constellation Communications, Inc. Norman P. Leventhal Raul R. Rodriguez Stephen D. Baruch David S. Keir Walter P. Jacob Leventhal, Senter & Lerman 2000 K Street, NW. Suite 600 Washington, D.C. 20006 Counsel for TRW, Inc. Michael D. Kennedy Vice President/Director of Regulatory Relations Motorola Inc. Suite 400 1350 I Street, N.W. Washington, D.C. 20005

wees Philip L. Malet Alfred M. Mamlet Pantelis Michalopoulos Steptoe & Johnson 1330 Connecticut Avenue, N.W. Washington, D.C. 20036 Counsel for Motorola Satellite Communications, Inc. John T. Scott, III William D. Wallace Stephen M. Byers Crowell & Moring 1001 Pennsylvania Avenue, NW 10th Floor North Washington, DC 20004 Counsel for Loral/Qualcomm Partnership, L.P. Leslie A. Taylor Leslie Taylor Associates 6800 Carlynn Court Bethesda, MD 20817 Counsel for Loral/Qualcomm Partnership, L.P. Jill Abeshouse Stern Shaw, Pittman, Potts & Trowbridge 2300 N Street, N.W. Second Floor Washington, DC 20037 Counsel for Mobile Communications Holdings, Inc. AnaJulissa Ayala


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Document Modified: 2015-03-24 17:39:57
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