Attachment Question 40 Exhibit

This document pretains to SAT-LOA-20170301-00028 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017030100028_1190238

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) THE BOEING COMPANY ) IBFS File Nos. SAT-LOA-20160622-00058 ) & SAT-AMD-20170301-00030 Application for Authority to Launch and ) Operate a Non-Geostationary Low Earth Orbit ) Call Sign: S2966 Satellite System in the Fixed-Satellite Service ) To: Chief, International Bureau OPPOSITION AND RESPONSE OF THE BOEING COMPANY Audrey L. Allison Bruce A. Olcott Senior Director, Frequency Management Services Jones Day The Boeing Company 51 Louisiana Ave. NW 929 Long Bridge Drive Washington, D.C. 20001 Arlington, VA 22202 (202) 879-3630 (703) 465-3215 Its Attorneys June 29, 2017

SUMMARY The Commission should dismiss the petition of CTIA and the opposition of T-Mobile USA, Inc. (“T-Mobile”) as irrelevant to the instant public notice process. As CTIA and T- Mobile both acknowledge, Boeing amended its application for the sole purpose of lowering the orbital altitude of its non-geostationary satellite orbit (“NGSO”) fixed-satellite service (“FSS”) system to resolve a potential conflict with the OneWeb NGSO FSS system. Neither CTIA nor T- Mobile provides any comments on this change of altitude. Therefore, their submissions are irrelevant. Instead, T-Mobile and CTIA devote almost their entire filings to repeating the arguments they previously made when the Commission originally placed Boeing’s NGSO FSS system application on public notice on November 1, 2016. At that time, Boeing provided a detailed response to T-Mobile and CTIA’s comments. 1 Rather than attempt to rebut Boeing’s detailed response, however, T-Mobile and CTIA make no reference to Boeing’s previous filing, apparently expecting the Commission staff to sort through their filings to identify and assess any new arguments that CTIA and T-Mobile have made in between the stale arguments that Boeing previously addressed. Such tactics, of course, do not contribute to the detailed record that is required for the Commission to further its public interest obligation to manage spectrum resources in an efficient manner to benefit all Americans. Although Boeing has addressed nearly all of T-Mobile and CTIA’s arguments previously, Boeing addresses them again briefly herein and provides references in this response to Boeing’s other filings in this proceeding and in the Spectrum Frontiers docket where these issues were 1 See Opposition and Response of The Boeing Company, IBFS File No. SAT-LOA-20160622- 00058 (Dec. 11, 2016) (“Boeing Response”). ii


Document Created: 2017-02-28 14:28:05
Document Modified: 2017-02-28 14:28:05
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