Attachment 1993Motion for accep

1993Motion for accep

MOTION submitted by TRW

Motion For Acceptance of TRW's Opposition

1993-05-28

This document pretains to SAT-LOA-19900731-00044 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1990073100044_1061058

                                                                                            ECEIVED
                                     BEFORETHE

       Federal Communications Commission "* ""
                               WASHINGTON, D.C. 20554                               FEDERAL COMMUNICATIONS COMMISSION
                                                                                         OFFICE OFTHE SECRETARY



In the Matter of the Applications of    )
                                        )
NORRIS SATELLITE COMMUNICATIONS, INC.   )                   File Nos.         54—DSS—P/L—90
                                        )                                     55—DSS—P—90
Application for Authority to Construct, )                                       =
Launch and Operate Communications       )                                 QECE!VED
Satellites in the Ka—Band               )
                                                                            JUN      2 1995
To:    The Commission                                                  0OiMebLC FACILITIES DIVISION
                                                                         SATELLTE RADIO BRANCH
                   MOTION FOR ACCEPTANCE OF TRW INC.‘S
                      OPPOSITION ‘TO NORRIS SATELLITE
          COMMUNICATIONS,   INC.‘S PETITION FOR RECONSIDERATION


             TRW Inc.    ("TRW"), by its attorneys, hereby respectfully

requests the Commission to accept its Opposition to the Petition

for    Reconsideration          ("Petition")        filed    by    Norris            Satellite

Communications, Inc.         ("Norris") in the above—captioned proceeding.

Acceptance of TRW‘s Opposition is justified for two reasons:                                     (1)

Norris failed to serve its Petition on parties to the proceeding in

violation of Sections 1.47 and 1.106(f) of the Commission‘s Rules;

and (2)   TRW‘s Opposition raises matters of substantial importance

that    relate    directly     to    the   public    interest      determination                the

Commission must make with respect to Norris‘ request for additional

spectrum beyond that currently authorized under the Commission‘s

Order and Authorization,            7 FCC Red 4289     (1992)      ("Order").

             In    its   Order,      the    Commission       authorized            Norris         to

construct, launch and operate a domestic fixed—satellite system in

the    19.7—20.2   GHz   and    29.5—30.0    GHz    bands.        On     August       7,     1992,

Norris filed its Petition requesting the Commission to add 400 MHz


                                              —2 —


(i.e.,     19.5—19.7      GHz   and     29.3—29.5         GHz)     to   its   authorization.

However, because Norris‘           Petition was neither served on any party

to the proceeding nor placed on Public Notice by the Commission,

TRW was prevented from filing a timely response to Norris‘ request.

In fact, TRW only recently became aware of Norris‘                            Petition after

it   was   served with      copies       of   oppositions           filed     in    the       instant

proceeding by Motorola Satellite Communications, Inc." and Calling

Communications         Corporation.y            TRW       has     prepared         the    attached

Opposition to address Norris‘                 Petition and to voice its extreme

concern over Norris‘            request for additional spectrum in view of

current    circumstances.              Accordingly,        TRW respectfully urges                 the

Commission        to   accept    the    accompanying             Opposition        and    formally

consider the pleading on the merits.

                                                     Respectfully submitted,

                                                     TRW INC.




                                                     By          Mertle
                                                          Norman P. Leventhgl             *
                                                          Raul R. Rodriguez
                                                          A.B.    Cruz III

                                                            Leventhal, Senter & Lerman
                                                            Suite 600
                                                            2000 K Street, NW
                                                            Washington, DC           20006
                                                            (202)    429—8970

May 28,    1993                                      Its Attorneys



U     See Opposition of Motorola Satellite Communications,                                Inc.,
      filed March 22, 1993.

      See Opposition of Calling Communications Corporation,                                   filed
      May 13, 1993.                                                                           (


                        CERTIFICATE OF SERVICE


          I, Sharon Krantzman, hereby certify that true and correct

copies of the foregoing document were sent by first—class, postage

prepaid mail, this 28th day of May,         1993,   to the following:

          Wayne Hartke, Esquire
          Hartke & Hartke
          7637 Leesburg Pike
          Falls Church,     VA    22043

          Cicily C. Holiday, Chief
          Satellite Radio Branch
          Common Carrier Bureau—
          Federal Communications Commission
          Room  6324
          2025 M Street,     NW
          Washington, DC       20554

          Thomas Tycz, Deputy Chief
          Facilities Division
          Common Carrier Bureau
          Federal Communications Commission
          Room 6010
          2025 M Street,    NW
          Washington, DC       20554

          Lon C.   Levin,   Esquire
         American Mobil Satellite Corp.
          4th Floor
          1150 Connecticut Avenue,         NW
         Washington, DC        20036

         Alfred M. Mamlet, Esquire
          Steptoe & Johnson
          1330 Connecticut Avenue,         NW
         Washington, DC        20036

          Bruce D.   Jacobs,     Esquire
          Fisher, Wayland, Cooper & Leader
          Suite 800
          1255 23rd Street,       NW
         Washington, DC        20037

         Mitchell F. Brecher, Esquire
         Down & Cleary
         Suite 850
         1275 K Street,     NW
         Washington, DC        20005


Mr.   Charles T.   Force
Associate Administrator for
  Space Operations
National Aeronautics and Space
  Administration
400 Maryland Avenue,       SW
Washington, DC     20546




                                QA%O/W /ZC I 22274A__
                                Sharon Krantzman   C



Document Created: 2014-09-12 14:07:26
Document Modified: 2014-09-12 14:07:26

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