Attachment 1991Comments of Radi

This document pretains to SAT-LOA-19900518-00036 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1990051800036_1060548

Before the FEDERAL COMMUNICATIONS COMMISSIQNCEyYED Washington, D.C. 20554 NOV 13 1991 In re Application of FCC MAIL BRANCH File Nos. SATELLITE CD RADIO, INC. 49/50—DSS—P/LA—90. =~ 58/59—DSS—AMEND—90 For Authority to Construct, 44/45—DSS—AMEND—92 Launch . and. Operate — a Digital x Audio Radio Service COMMENTS OF RADIO_SATELLITE CORPORATION Radio Satellite Corporation ("RSC") hereby submits its Comments on the above—referenced application of Satellite CD Radio, Inc. ("SCR"), pursuant to the Commission‘s Report No. DS—1244, DA 92—1408, released October 13, 1992. RSC believes that all DAR systems should be capable of operating at variable data rates and should provide for return (mobile—to—ground station) links. | RSC designed the RadioSat system in 1989 to provide a wide array of integrated communications and navigation services to consumers‘ through MSAT.2 RSC first publicly described the RadioSat system on May 7, 1990.3 and filed a RadioSat ground station application on May 22, 1990. The RadioSat application showed how MSAT, the mobile satellite system under construction by Telesat Mobile, Inc. ("TMI) in Canada and the American Mobile Satellite Corporation ("AMSC") in the U.S., could provide DAR services. It showed how multiple data rates could be 1 See attached flier, "Car Radio of the Future." Also, see the attached article from Microwave Journal, "Mobile Satellite Communications for Consumers," November 1991. Radio Satellite Corporation will send its Car Radio of the Future video describing the RadioSat system free to anyone requesting it. 2 Zuliani, Michael J. and Gary K. Noreen, "Mobile Satellite Service: A North American Perspective," 39th IAF, Bangalore, India, October 1988. 3 Noreen, Gary K., "Mobile Satellite Broadcast System Design," pp. 233—236, Proceedings of tfie 40th IEEE Vehicular Technology Conference, May 6—9, 1990, Orlando, Florida.

Page 2 accommodated — a key development, since talk channels require less than a quarter the data rate of stereo music channels. The RadioSat application was highly innovative in several key ways: 1) It was an application for a Mobile Satellite Service in an existing band using an authorized satellite, so it required neither a new allocation nor the processing of mutually exclusive applications. 2) It would provide a wide array of integrated services of much greater value to consumers than just a few more radio channels. 3) It would use satellites already under construction that should be in service at least 6 years before any new DAR satellite system. The original SCR application lacked these features. Instead, it was limited to audio entertainment distribution only — just a small subset of mobile satellite services — and to a single data rate. It required an investment of hundreds of millions of dollars and the launch of a new geostationary satellite limited to digital audio broadcasting. It required a new allocation, thus a new rulemaking by the FCC. It would require the FCC to process mutually exclusive applications. In its notable limitations, the SCR proposal was remarkably similar to that of Geostar. This was not surprising, since many of SCR‘s principals and attorneys played the same roles for Geostar: the Chairman of SCR, Martin Rothblatt, was formerly President of now—defunct Geostar Corporation, and Robert Briskman, President of SCR, was also from Geostar. Like SCR, Geostar proposed to launch a network of satellites to provide an artificially limited set of services to mobiles — in the case of Geostar, it was position determination; with SCR, it was digital audio broadcasting. Both Geostar and SCR requested enormous amounts of spectrum for their limited services. Both Geostar and SCR characterized their services as "new" ones requiring special action from the Commission, but in both cases, the services were subsets of geostationary Mobile Satellite Service. Both Geostar and SCR were represented by Richard Wiley. Not surprisingly, the Commission rushed in near—record time to award a license to Geostar,4 and now appears about to do the same to SCR. Geostar went bankrupt last year. After racking up a debt of $100 million, and going through $80 million of equity financing, its assets were sold in auction for $397,000, and its license was "sold" for $100,000.5 4 ‘The Commission‘s rulings on Geostar were characterized by hallucinatory statements about the "advanced state" of Geostar‘s proposal and by an extreme aversion to consider any rational alternatives. 5 Mobile Satellite News;, January 1992.

Page 3 The Geostar fiasco scared potential investors away from the mobile satellite industry, making it difficult for legitimate ventures to raise money. It was entirely avoidable. The severe deficiencies of Geostar‘s approach were well documented early in the Commission‘s proceedings on Geostar.5 SCR limited the services it proposed to provide so that it could claim a Pioneer‘s Preference. This is an approach that defies logic outside the FCC, but a similar strategy worked for Geostar. Geostar managed to define itself as something other than MSS, and managed to get the Commission to process its application separately in spite of the obvious fallacy of the claim. SCR is taking the same approach, and apparently getting away with it. By artificially limiting the services it will provide, SCR is limiting its potential market. A similar artificial limitation in the current DOMSAT industry would have prevented most operators from shifting their operations from long distance telephony to video distribution when they were preempted by fiber optic networks. It would have destroyed the DOMSAT industry. This approach is also contrary to everything the Commission did in the geostationary MSS proceeding, where it said it wanted to encourage innovative use of the spectrum. It appears to have been taken simply to qualify SCR for Pioneer‘s Preference. | SCR has amended its application to include some of the data broadcast services originally proposed by RSC; However, it is now limited to just satellite—to—mobile transmissions at one data rate — a severe handicap in the marketplace. To avoid another fiasco, RSC recommends that DAR systems have two key additional features: 1) Variable data rates. If a talk channel requires just 16 kbps while stereo music requires 64 kbps, it would be quite wasteful to force voice channels to use 64 kbps channels. Similarly, if 64 kbps channels prove adequate for many stations, it would be foolish to force all users into 256 kbps "CD quality" channels. ‘ 2) A return link (from mobiles to a network center) allows many useful new services. Given the Commission‘s plan for a one—way DAR service, this deficiency will be more difficult to correct. The return link could be provided by an "MSS" operator, though in a different frequency band. 6 Comments of Transit Communications, Inc., Gen. Docket No. $4—689, RM—4426, December 17, 1984. TCI noted that the services proposed by Geostar could be provided through a single satellite mobile satellite system with integrated GPS receivers, while using just 3% of the spectrum required by Geostar. This is, in fact, how TMI, Inmarsat and AMSC are now providing all the services Geostar promised.

Page 4 RSC believes that DAR systems incapable of operating at variable data rates would be highly wasteful of spectrum (as well as of satellite power) and should not be permitted. It is understandable that neither SCR nor the Commission want to include return links in DAR because that would remove any remaining facade over the fiction that DAR is a new service. RSC believes additional geostationary MSS operators are desperately needed in any event" — even if it means giving SCR an undeserved Pioneer‘s Preference. Respectfully Submitted, RADIO SATELLITE CORPORATION By: Darve M. /L/L@WW\/ Gary K Noreen Chairman & CEO 1167 North Holliston Avenue Pasadena, CA 91109 (818) 791—3951 November 12, 1992 7 ‘TMI and Inmarsat have been supportive of the RadioSat proposal. Unfortunately, AMSC — the monopoly geostationary MSS operator licensed by the FCC — blocked RSC from developing the RadioSat system. As a result, RSC was forced to suspend operations at the end of 1991. RSC filed a lawsuit against AMSC in Federal court in the District of Columbia in February 1992 charging numerous violations of communications and antitrust law; the suit is currently in mediation. Gary Noreen, the founder of RSC, was forced to leave the mobile satellite industry and now leads telecommunications design and development for an advanced mission to Mars at the Jet Propulsion Laboratory.

Car Radio of the Future Radio Satellite Corporation designed the RadioSat system to provide integrated com— munications and navigation services to consumers, including: * nationwide interactive digital audio entertainment; * data broadcasts, including traffic advisories, weather reports, travel databases, and stock and sport updates; * precision navigation; and * two—way voice and data communications. The RadioSat system requires an MSAT satellite, to be launched in 1994, and GPS, the satellite—based navigation system used in Desert Storm. Classical | Educational Kidi Talk| |News| Rock| |Jazz Country |CSMm |SPORTS By integrating complementary services into low—cost car radios, the RadioSat system provides utility far beyond the simple addition of functions. * Integration of two—way data communications with audio broadcasting enables direct response to broadcast solicitations, permitting consumers to order adver— tised products and services or to respond to polls simply by pushing a button. * Integration of precision navigation with data broadcasting enables the display of vehicle location and current traffic hazards and congestion on a digital map, which the driver can use to optimize travel plans. * Integration of precision navigation with two—way communications permits users to request emergency assistance from their vehicles and to automatically mform emergency agencies precisely where their vehicles are located. * Integration of two—way data and voice communications permits transmission of voice pages to and from mobiles, along with positive acknowledgments. With its highly flexible design, the RadioSatsystem can easily accommodate new services conceived and developed in the future. For more information about the RadioSat system and a free video showing a computer simulation of the car radio of the future, call Radio Satellite Corporation| at (818) 791—3951 or write us at 1167 N. Holliston Ave., Pasadena, CA 91104.

v ue x h im:¢ a i/ §PEGCIAL REPORT "I Mobile Satellite Communicati forConsumers Gary K. Noreen Radio Satellite Corp. Long Beach, CA Introduction system (GPS), which is a US gov— congestion on a digital map, which This paper reviews the capabili— ernment satellite—based navigation the driver can use to optimize travel ties of MSAT and describes the system. It will provide the smart car plans. Integration of two—way com— RadioSatt system. The RadioSat of the future with extensive, flexible munications with precision naviga— system, which is currently under de— communication capabilities. tion will permit users to request velopment, will provide integrated RadioSat services are provided emergency assistance from their communications and navigation with a single, low cost user—friendly vehicles and will allow them to in— services to consumers, including mobile radio at a cost far below that form emergency agencies automat— nationwide digital audio broadcasts; of providing each service indepen— ically of the precise location of their data broadcasts, such as traffic ad— dently and with utility far beyond the vehicles. Integration of two—way data visories, weather reports, travel simple addition of functions. For ex— and voice communications will per— databases, and stock and sports ample, integration of two—way data mit transmission of voice pages to updates; precision navigation; and © communications with audio broad— and from mobiles, along with pos— two—way voice and data communi— casting will enable direct response itive acknowledgements. cations. Low cost mobile satellite ra— to broadcast solicitations, permit— dios will be designed to replace ex— ting consumers to order advertised isting car radios and are expected products and services or to respond to become a popular mass market to polls simply by pushing a button. product. The RadioSat system will Also, integration of precision navi— use MSAT satellites," shown in Fig— gation and data broadcasting will ure 1 and scheduled for launch in enable the display of vehicle loca— 1994, and the global positioning tion and current traffic hazards and p—~ wose ome mas com ome es mee cme Bs wrnr mm m sans come tuss ooen mae mame tate mane mm mre ons aum d RSC NETWORK gom in n man men oo ons on mt m sn es m mee ce men FIXED STATIONS | —B —8 —B—B VOICE GATEWAY DISPATCH BASE STATION BROADCAST BASE STATION AMSC NETWORK RADIO SATELLITE CONTROL CENTER NETWORK CENTER Fig. 1 The RadioSat system. Fig. 2 The MSAT satellite. {RadioSat is a trademark of Radio Satellite Corp. ©1991 by Horizon House Publications, Inc. Reproduced by permission. MICROWAVE JOURNAL «e NOVEMBER 1991

[« [ MSAT entire capacity of an Inmarsat II could support only a single such MSAT (1994) _ The MSAT satellite system will channel; each MSAT satellite is INMARSAT II1 (1994) yrelay communications between capable of supporting 100 chan— AUssaAt (1991) mobiles throughout North America INMARSAT 1 (1990) and fixed earth stations. One nels. MSAT receive system perform— INTELSAT MCS (1982) MSAT satellite is under construc— MARECS (1981) tion for Telesat Mobile, Inc., which ance also is much better than pre— vious satellites, permitting addi— MARISAT (1976) will operate MSAT in Canada. A second satellite is under construc— tional new services. Receive sys— 0 05 _i 1.5 _2 tion for the American Mobile Satel— tem performance of commercial L— Fig. 5 MSAT Receive System performance lite Corporation, the US MSAT op— band satellites, expressed as mo— (G/T) (17K. erator. Each MSAT satellite can bile antenna gain (G) divided by provide coverage throughout receive system temperature (T), is Mobile Satellite Economics North America. They will back up shown in Figure 5. The high re— ceive system performance of The economics of MSAT can be each other. best understood by considering Each MSAT satellite employs a MSAT permits the transmission of voice using an omnidirectional mo— each MSAT satellite as a repeater pair of 6 by 5 m elliptical reflectors 22,300 miles high. The extreme to concentrate coverage over bile antenna and a two W amplifier. Each MSAT satellite can send height of MSAT satellites has two North America, as shown in Figure dozens of audio broadcasts using key economic consequences. 2. Separate transmit and receive First, it is much more expensive to antennas are used to minimize only a fraction of its total capacity. It can also support a wide array of construct and operate a repeater passive intermodulation, a fre— other new mobile satellite ser— 22,300 miles high, than a repeater quent problem with this class of 100 ft high, a typical terrestrial satellite. Each satellite uses a vices. Which services ultimately come to fruition depends largely tower height. Thus, the cost per Hughes 601 three—axis stabilized channe! of MSAT is far greater bus with a design life of 15 years. on their relative economic menits. than the cost per channel of a Allcommunications between typical terrestrial repeater. Each satellites and mobiles are at L— MSAT service must earn much band. All communications to mo— TABLE I higher revenue per channel than biles are sent through fixed Ku— MSAT FREQUENCIES that required to pay for terrestrial band earth stations to the satel— repeaters. Secondly, a repeater lites, which transpond the signals Satellite—to—Mobile 11530.0—1559.0 MHz 22,300 miles high can cover hun— to L—band, amplify them and re— Mobile—to—Satellite [1631.5—1660.5 MHz Satellite—to—Fixed (10.75—10.95 GHz dreds or thousands of times the transmit them to mobiles. Similarly, Fixed—to—Satellite (13.0—13.15 area of a repeater 100 ft high. This all mobiles transmit at L—band to attribute of MSAT provides the and 13.2—13.25 GHz the satellite, which transponds L— means for generating the high band signals to Ku—band, amplifies revenue per channel required for them and retransmits them for re— mobile satellite communications. ception by fixed Ku—band earth To justify the high cost of MSAT stations. Table 1 lists the MSAT channels, it is necessary either to frequencies. charge a higher price per mobile or Four beams cover the contigu— to support far more mobiles per ~ous US and Canada, correspond— channel than terrestrial systems. ing roughly to one beam per time Two—way voice services require zone, as shown in Figure 3. A the first of these approaches. separate beam covers Mexico and Such services support a relatively the Caribbean. Other beams cover small number of users, typically Alaska and Hawaii. 100 or less, on each channel. The radiated power of a satellite Therefore, users of two—way system is expressed as Effective MSAT voice services must pay Isotropic Radiated Power (EIRP). much more per unit airtime for the The aggregate EIRP of each Fig. 3 MSAT L—band coverage. use of MSAT than for terrestrial— MSAT satellite is 500 kW, as based systems, except in areas shown in Figure 4, three orders of with low population densities. MSAT (1994) magnitude higher than Marisat, INMARSAT III (1994) The second of these ap— the first commercial satellite de— AUSSAT (1991) proaches can result in the creation INMARSAT If (1990) signed for mobile communica— INTELSAT MCS (1982) of mass—market consumer prod— tions. MARECS (1981) MARISAT (1976) i—— > ucts and services. Point—to—multi— MSAT has the unique ability to o 100 200 300 400 ~ point services and point—to—point broadcast commercial audio pro— data communications exemplify gramming through satellites direct— this approach. Fig. 4 Effective isotropic radiated power ly to mobiles with small, inexpen— (kW). Point—to—muiltipoint mobile ser— sive antennas. This requires an vices, such as audio and data broad— EIRP of 5 kW per channel. The casts, are effectively provided MICROWAVE JOURNAL e NOVEMBER 1991

iotmont: You can order Beethoven: The 9 AM/FM Symphonies for forty doltars by AMPLIFIER AM/FM/DAB RECEIVER ANTENNA pressing the Order button or by SPEAKERS saying Order. l Speak l information Order_] : AUDIO DIGITIZER, SATELLITE F4 Stop 1eees Auto COMPRESSOR, CODER & SECTION Redioset"" J¥ OPTIONAL Radio F3 Map Data imweers MODULATOR (OPTIONAL) teamse ts Power co 5R ca«mdcnlon:&\ Emugem.y-} AUDIO DECOM— DATA Fig. 8 Interactive radio. TRANSMITTER PRESSOR & D/A CODER & (OPTIONAL) CONVERTER CONTROLS/ GPS DATA MICROCHIP To: Daddy. KEYBOARD PROCESSING {OPTIONAL) From: Celeste. & CONTROL L—BAND Please pick up milk, cheese, ice cream, and turkey on your way home. OPTIONAL ANTENNA DISPLAY ASSEMBLY RADIOSAT TDM DEMODULATOR ANTENNA Stop OPTIONAL & DECODER Data DIGITAL SATELLITE SWITCH, INTERFACE ASSIGNABLE RF FILTER & Communications DEMODULATOR ELECTRONICS LNA & DECODER Fig. 9 Alphanumeric paging with positive acknowledgment. Fig. 6 A schematic diagram of RadioSat‘s mobile radio. processing and control functions. mental cost of adding channels to The RSM also includes a data coder individual sites. and modulator for use with an op— Classical! 1 CSN | \News® | Talk tional transmitter. The RadioSat System A global positioning system mi— [Country, Rock ; Sports FM crochip (GPSM) can be added to the The RadioSat system was opti— [fiid's' .Educationefl Jazz AM mized for services that support radio for precision navigation. This enormous numbers of mobiles on chip uses GPS broadcasts and nav— Radiosat" T Stop Auto each MSAT channel.? This system igation information sent through the Map Data musle sures exemplifies how the capabilities of company‘s TDM channel to esti— Communications MSAT can be used to produce new mate mobile position with 5 m accu— consumer services and products. racy. The GPS frequency at Fig. 7 User interface radio display. The design objective was to inte— 1575.42 MHz is between the MSAT grate all mobile satellite services satellite—to—mobile and mobile—to— through MSAT. Since MSAT covers with consumer potential into one satellite frequency bands. This an area hundreds of times larger low cost mobile radio. Low cost is proximity makes it possible for a than terrestrial broadcast systems, achieved by integrating all the re— GPS receiver to share the antenna tens of millions of mobiles in quired electronics into a few inte— and front end with a RadioSat mo— hundreds of markets can potentially grated circuits, permitting mass pro— bile radio. receive each channel. Thus, the duction. By providing many inte— much larger potential audience of grated services to consumers in one User Interface MSAT offsets its relatively high cost radio, the attractiveness of the radio The capabilities of the RadioSat per channel. to consumers is maximized, result— system are best understood by con— MSAT can also provide point—to— ing in large potential market size. sidering how it will operate in a typ— point data communications at a low— With a large market, production ical car. A computer model is shown er cost than terrestrial networks. Al— costs are minimized. that simulates a satellite radio in— phanumeric paging and two—way stalled into a double—height dash— ‘messaging services support very RadioSat Mobile Radios board stot. The model features a set large numbers of mobiles on each in addition to the AM/FM receiver of fixed buttons on the bottom and channel. Terrestrial systems cannot sections of a conventional radio, a touch screen on top. The model take advantage of this efficiency; the each satellite radio incorporates an can be operated on a hands—and— limited range of terrestrial repeaters L—band satellite RF section and a eyes—off basis. It accepts voice limits the number of mobiles custom RadioSat microchip (RSM), commands in place of pressing but— reached by each repeater. Thus, the as shown in Figure 6. The RSM in— tons and can speak through voice high cost of supporting large ~cludes demodulators and decoders synthesis to convey messages re— numbers of repeater sites domi— for both channels and an audio de— ceived. nates the cost of terrestrial mobile compressor, and provides data Figure 7 shows the model display data systems, rather than the incre— after pushing the radio button. _MICROWAVE JOURNAL e NOVEMBER 1991

tance that includes precise location information as shown in Figure 12. ] . Travel ; — o7 | Stocks | | Weather | Acknowledgments can be sent back C_J ____J to the driver, advising that the mes— ' Sports : Road Advisories : sage has been received and telling how long it will take for assistance arteene to arrive. TD .eP Stop Eie Auto & The RadioSat system is designed Radio Map Data RETSNINOCR to enable easy use of data commu— F3 Power co Communications KEEmergency nications because data is much less expensive than voice through the Fig. 10 Data broadcast options. Fig. 11 Tornado alert showing car satellite. Voice, cellular telephone and tornado on map. through the satellite, can be pro— Channels broadcast over the satel— vided with add—on equipment, as lite system are identified by format [ | shown in Figure 13. Drivers will have | Police | Ambulance rather than call letters. Selecting AM c____] the ability to send short canned data or FM results in a sereen with tuning messages, as shown in Figure 14, or controls. | Fire | AAA with an attached computer key— The two—way RadioSat system al— board, will have the ability to send lows users to respond directly to Auto more complicated messages. broadcast solicitations. For exam— Map Data ©mw ple, after playing a piece of music, Communications Emergency Conclusion the announcer can state that a CD The launch of the first MSAT sat— containing that music can be pur— Fig. 12 Emergency communications. ellite in 1994 will open dramatic new chased by pressing the order button opportunities to communications on the radio. A data transmission equipment manutfacturers. The Ra— accompanying the statement would Volce Data dioSat system will use MSAT to pro— ez generate the display shown in Fig— Telephone Canned Messages [ vide a low cost, highly flexible two— ure 8. By simply pressing the button, way communications capability for the driver sends a short data signal !Dlspatch ISubscribe Compos;] consumers that can be adapted to back through the satellite to the many new applications. M ground facilities, which provides in— ~ Stop Auto Rediosat‘ formation identifying the driver and Cim the advertisement that promoted the cCO Emergency References 1. Gary K. Noreen, "MSAT: Mobile Commu— response. This feature can be used nications Throughout North America," to order products, services, infor— Fig. 13 Two—way communications options. 39th IEEE Vehicular Technology Confer— mation and samples; contribute ence, San Francisco, CA, May, 1989. funds to public radio programmers 2. Gary K. Noreen, "Mobile Satellite Broad— or other organizations; and to re— cast System Design," 40th IEEE Vehic— i‘ Address | Send Message ular Technology Conference, Orlando, spond to listener polls. Gmy_____O) {fwilbeilSmntesisae May 7 to 10. 1990. Also, see Gary K. All radios are individually ad~— J [Xine 1 will be 15 minutes early /* l} Noreen, "An Integrated Mobile Satellite BL_—CB dressable, so alphanumeric paging 1 will be 30 minutes early ‘ § Broadcast, Paging, Communications $7 messages can be sent to drivers, as I will be 15 minutes late :s and Navigation System," 40th IEEE t will be 39 minutes fate Ig| E2 Broadcast Symposium, September 7, shown in Figure 9. Pages sent over chrwressumon "'""""M’% 1990. Ts g:‘ Stap E Auto BE the RadioSat system can be ac— I F Radio l MapE omj i1 knowledged, unlike any other pag— Gary K. Noreen p F2 co R Communications iémergencyj 7 & ing system. received his BS and Satellite radios can receive a va— MS degrees in elec— Fig. 14 Canned message screen. trical engineering riety of data broadcasts, some inte— from the University of grated into the navigation or emer— Washington and gency alert systems. Some simply Carnegie—Mellon with uncorrected GPS. Second, the provide information that may be of University, respec— RadioSat system can broadcast tively. In 1989 he interest, such as selected stock warnings of natural disasters, organized Radio quotations or sports scores, as Satellite Corp. and chemical spills and traffic accidents shown in Figure 10. currently he is chair— to motorists. Each radio can alert The data broadcast capabilities of man and CEO. Radio Satellite Corp provides the driver if the warning concerns integrated mobile satellite communications the RadioSat system enhance GPS receivers in two distinct ways. First, something in the driver‘s area. The services to consumers. Since 1983, Noreen warning can be displayed on a map, has been president of Transit Communica— by using GPS differential correc— tions Inc. (TCl). Prior to forming TCI, Noreen as shown in Figure11, similar to tions sent through the RadioSat sys— designed communications systems for ad— tem, each radio can determine its those provided today in car naviga— vanced interplanetary space missions and for position to within a couple of meters, tion systems, so that the driver can MSS at NASA‘s Jet Propulsion Laboratory, consider alternative routes to avoid where he was leader of the land mobile sat— as opposed to 100 m uncertainty hazards. In the event of trouble, the ellite service study team. He is an AMSC driver can send a request for assis— board member and a member of Tau Beta Pi, IEEE and AIAA. MICROWAVE JOURNAL e NOVEMBER 1991



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