Ex Parte Filing.pdf

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by WorldVu Satellites Limited

4 26 2018 Ex Parte

2018-04-26

This document pretains to SAT-LOA-20170726-00110 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017072600110_1382835

Sheppard, Mullin, Richter & Hampton LLP 2099 Pennsylvania Avenue, NW, Suite 100 Washington, D.C. 20006-6801 202.747.1900 main 202.747.1901 fax www.sheppardmullin.com Brian D. Weimer 202.747.1930 direct bweimer@sheppardmullin.com April 26, 2018 VIA IBFS Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street SW Washington DC 20554 Re: Notice of Ex Parte Presentation; IBFS File Nos. SAT-LOA-20161115-00118 (Call Sign S2983) and SAT-LOA-20170726-00110 (Call Sign S3018) Dear Ms. Dortch: On April 24, 2018, the undersigned, outside counsel to WorldVu Satellites Limited (“OneWeb”) spoke on the phone with Karl Kensinger, Deputy Division Chief of the International Bureau’s Satellite Division. The discussion focused on an apparent discrepancy in the Commission’s recent Memorandum Opinion, Order, and Authorization (the “MOO&A”) granting Space Exploration Holdings, LLC an authorization to construct, deploy, and operate its non- geostationary orbit (“NGSO”), fixed-satellite service system (“FSS”).1 The undersigned pointed out that although the MOO&A stated “SpaceX will be subject to the same conditions as OneWeb, Telesat Canada, and Space Norway, including the requirement that it coordinate its physical operations with space stations of NGSO systems operating at similar orbital altitudes[,]” the ordering clauses of the MOO&A do not impose any corollary physical coordination requirement.2 The undersigned noted that such clauses were contained in the 1 See Space Exploration Holdings, LLC, Application For Approval for Orbital Deployment and Operating Authority for the SpaceX NGSO Satellite System, IBFS File No. SAT-LOA- 20161115-00118 (Call Sign S2983); Application For Approval For Orbital Deployment And Operating Authority for the SpaceX NGSO Satellite System Supplement, IBFS File No. SAT- LOA-20170726-00110 (Call Sign S3018), Memorandum Opinion, Order and Authorization, FCC 18-38 (rel. Mar. 29, 2018). 2 MOO&A at ¶ 11 (citing the prior U.S. market access grants requiring OneWeb, Telesat Canada, and Space Norway to coordinate their respective physical operations with other nearby NGSO FSS systems); Id. at ¶¶ 39-56.

Marlene H. Dortch April 26, 2018 Page 2 Commission’s prior grants of U.S. market access for NGSO FSS systems and inquired as to whether the Commission would issue an errata addressing this issue.3 Please do not hesitate to contact the undersigned with any questions. Very truly yours, /s/ Brian D. Weimer Brian D. Weimer for SHEPPARD, MULLIN, RICHTER & HAMPTON LLP cc: Karl Kensinger, International Bureau, Satellite Division 3 See, e.g., WorldVu Satellites Limited; Petition for a Declaratory Ruling Granting Access to the U.S. Market for the OneWeb NGSO FSS System, Order and Declaratory Ruling, 32 FCC Rcd 5366, 5378 ¶ 25(d) (2017) (“OneWeb must coordinate physical operations of spacecraft with any operator using similar orbits, for the purpose of eliminating collision risk and minimizing operational impacts. The orbital parameters specified in this grant are subject to change based on such coordination.”).


Document Created: 2018-04-26 21:58:40
Document Modified: 2018-04-26 21:58:40
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