Rule 1 65 Letter.pdf

SUPPLEMENT submitted by Sheppard Mullin LLP

1.65 Letter

2014-07-11

This document pretains to SAT-LOI-20140617-00070 for Letter of Intent on a Satellite Space Stations filing.

IBFS_SATLOI2014061700070_1053881

                                                                   Sheppard, Mullin, Richter & Hampton LLP
                                                                   1300 I Street, N.W., 11th Floor East
                                                                   Washington, D.C. 20005-3314
                                                                   202.218.0000 main
                                                                   202.218.0020 fax
                                                                   www.sheppardmullin.com




July 11, 2014


VIA ELECTRONIC FILING

Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Room TW-A325
Washington, DC 20554

Attn: Satellite Division, International Bureau


                        Re:     Satmex Market Access Application
                                File No. SAT-LOI-20140617-00070


Dear Ms. Dortch:

Pursuant to Section 1.65 of the Commission’s rules, 47 C.F.R. § 1.65, Satélites Mexicanos, S.A.
de C.V. (“Satmex”) wishes to update the record with respect to the above-mentioned application
(the “Market Access Application”). Satmex is submitting this update at the request of Raytheon
Corporation (“Raytheon”).

In the Market Access Application, Satmex provided background information to the Commission
concerning the Wide Area Augmentation System, or WAAS.1 Satmex included this background
information in order to provide context for the Commission to appreciate that the hosted payload
that will fly on the Satmex 9 spacecraft for Raytheon Company will be part and parcel of the
WAAS system going forward. In doing so, the Market Access Application stated as follows:
“Satmex 9 is intended as a replacement for the Galaxy-XV, which is nearing its operational end-
of-life.”2




1
    See Market Access Application at p. 3.
2
    Id. at p. 4.


                                                                     Sheppard, Mullin, Richter & Hampton LLP
                                                                     1300 I Street, N.W., 11th Floor East
                                                                     Washington, D.C. 20005-3314
                                                                     202.218.0000 main
                                                                     202.218.0020 fax
                                                                     www.sheppardmullin.com


July 11, 2014
Page 2


Following further discussions about this statement between Raytheon and the Federal Aviation
Administration (the “FAA”), Raytheon contacted Satmex with a request to clarify the statement
as recommended by the FAA. In particular, the FAA indicated to Raytheon as follows:

During our recent conversations we became aware that the application for the license submitted
contains factual background that could be misconstrued without greater context for the FAA’s
long range plan for maintaining the WAAS Geostationary Constellations. Of concern is the
statement of facts suggesting:

       1)       That the FAA will replace Galaxy XV with SatMex 9;
       2)       That Galaxy XV is nearing its end of life.

The FAA is not replacing Galaxy XV with SatMex 9. SatMex 9 is part of FAA’s long range
planning to provide continued WAAS coverage. Furthermore, Galaxy XV, to the FAA’s
knowledge, is not at the end of life.

Satmex wishes to submit the foregoing information into the record in order to provide a fuller
context for the Commission’s analysis and processing of the Market Access Application.

Please do not hesitate to contact the undersigned should you need any additional information.


                                             Sincerely,

                                             /s/ Brian D. Weimer

                                             Brian D. Weimer
                                             Counsel for Satélites Mexicanos, S.A. de C.V.



Document Created: 2014-07-11 17:24:18
Document Modified: 2014-07-11 17:24:18

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