Attachment SURRENDER

SURRENDER

OTHER submitted by BOEING

SURRENDER

2005-03-29

This document pretains to SAT-MOD-20020726-00113 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2002072600113_425810

                                                                                Soums, Sucoms & Drurser LLP
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                                          March 28, 2008

                                                                         viA HAND DELIVERY
                                                     RECEIVED
  Marlene H. Dortch
  Secretary                                            maR 2 8 2005
  Federal Communications Commission
  445 12th Street, S.W.                          Fodeal Conmuncaton Conmlison
  Washington, D.C. 20054                              _ OfcrotBremtay


         Re:     The Bocing Company
                 Authority for Use ofthe 1990—2025/2165—2200 MHz and
                 Associated Frequency Bands for a Mobile—Satellite System
                 FCC File Nos. 79—8AT—P/LA—97(16), 90—SAT—AMEND—9820),
                 IBFS Nos, SAT—LOA—19970926—00149, SAT—AMD—19980318—00021,
                 SAT—AMD—20001103—00159, SAT—MOD—20020726—00113,
                 SAT—MOD—2003071 1—00128, SAT—AMD—20030827—00241,
                 and SAT—AMD—20040713—00132
                 Notice of Surrender of License and Withdrawal of Application


  Dear Ms. Dortch:

          The Bocing Company ("Bocing"), through its attomeys, hereby surrenders the above—
  referenced 2 GHz Mobile—Satellite Service (°MSS") license.. Boeing hercby also withdraws its
  pending application as amended to modify its 2 GHz MSS license, FCC file numbers SAT—
  MOD—20030711—00128, SAT—AMD—20030827—00241 and SAT—AMD—20040713—00132.
          Bocing‘s decision to surrender itslicense comes at a critical time for the MSS industry
  and should not be construed as indicating a lack of confidence by Bocing in the growing
  potential of MSS networks
         As a result of the Commission‘s foresight and Teadership, consumers will soon be able to
  benefit from MSS networks that employ an ancillary terrestrial component (°ATC"). The
  Commission‘s February 25, 2005 order that provides for ATC authorization during. the
  developmental phase of an MSS/ATC network is the key to financing the next generation


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                                                                                      Soum, Sixpins & DroserLLP.

Secretary Dortch                                                                         March 28, 2008
Page 2

satellites that will provide handheld mobile communications services on a transparent, integrated
and cost—effective basis.
         MSS networks have already greatly extended. the reach of mobile communications
services, making them available in rural and remote locations, including inhospitable and occanic
regions that will ikely remain beyond the reach of terrestrial networks. Next generation ATC—
enabled wireless satelite networks will begin to satisfy current expectations of the mass markets
for full, ubiquitous coverage and vastly improved quality of service. Complementary MSS/ATC
services will provide reliable communications in dense urban centers that are dificult to
penetrate using a satellite—only platform.. The inclusion of ATC will also enable MSS networks
to provide increased user capacity in congested locations, such as at the site of disaster relief
efforts. Integrated MSS/ATC networks will also be able to provide services at much lower
prices using the economics of scale that are available to mass market consumer devices.
         Following the Commission‘s decision two years ago to authorize MSS licensees to
employ ATC services, Bocing has worked diligently to design, finance and construct an MSS
satellite that incorporates the significant technical benefits of ATC. Bocing, however, has
concluded that it cannot reasonably expect to complete this process prior to the final milestone
deadline that was included in the July 17, 2001 order authorizing Boeing‘s 2 GHz MSS system.
         Although Bocing is surrendering its 2 GHz MSS license, Bocing stll hopes to participate
in the development of integrated MSS/ATC networks as a leading manufacturer of MSS
spacecraft.. In this regard, Bocing urges the Commission to afford other 2 GHz MSS licensces
adequate time to develop and construct ATC—enhanced MSS networks within a reasonable
milestone framework.. Bocing will also continue its leadership in making available satelite—
based aeronautical and other mobile communications services through its Connexion by
Bocing!"‘ service.




! See Flexibliy for Delivery of Communicatins by Mobile Satlite Service Providers in the 2 GHiz Rand, the L—
Band, andthe 1624 GHt Rands, Memorandim Opiion and Orderand Secand Order on Reconsidention, FCC 05—
30,9 89 (Fob, 25, 2005) (permiting 2 Giz MSS lcenseest secure ATC authorization prior to unching MSS
networks based on a demonstrtion that they wil comply with thir ATC gating requirements prioto providing
ATC services)


                                                                          Soum Sucoums & Dracrser LLP.

Secretary Dortch                                                            March 28, 2005
Page3

       Bocing thanks the Commission and its staff for their many years of support for the MSS
industry and for developing a regulatory environment that accommodates ATC—enhanced MSS
networks. Please let us know if you have any questions.



                                                  Murkosts
                                          Bruce A. Olcott
                                          Counsel for The Bocing Company



Document Created: 2005-03-30 12:03:05
Document Modified: 2005-03-30 12:03:05

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