Attachment certification

certification

CHANGE OF ADDRESS submitted by Globalstar

certification

2006-11-21

This document pretains to SAT-MOD-20030606-00098 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2003060600098_538176

                                GLOBALSTAR, INC.                  Tel: (408) 933—4000

                                461 SO. MILPITAS BLVD.            Fax: (408) 933—4100

G|0bal5tar                      MILPTAS, CA 95035                 www.globalstar.com


                                                           Received                           FILED/ACCEPTED
   November 20, 2006                                          *                ‘                   Nov 2 1 2006
                 Do                                        NOV 2 8 2006                             |
   Mr. John Giusti, Acting Chief                                                            Federal Communications Commission
   International Bureau                                     Policy Branch                         Office of the Secretary
   Federal Communications Commission                     "‘M°"MatonaiZurgay
   445 12th Street, S.W.
   Washington, D.C. 20554
           Re:      CERTIFICATION PURSUANT TO 47 C.F.R. § 25.143(c)
                    Call Sign $2115 — Globalstar 1.6/2.4 GHz Mobile—Satellite System
                    File Nos. SAT—AMD—20050105—00003 and SAT—MOD—20030606—00098

   Dear Mr. Guisti:

           Pursuant to Sections 25.143(c) and (d) of the Commission‘s Rules, 47 C.F.R. § 25.143(c)
   & (d), Globalstar Licensee LLC and its parent company, Globalstar, Inc. (collectively,
   "Globalstar"), hereby certify to the Commission that they intend: (1) to launch eight space
   stations into the Globalstar satellite constellation that are technically identical to the existing
  space stations; and (2) in connection therewith, to adjust the constellation to change the number
  of operating satellites, the number of in—orbit spares and the number of in—orbit test bed satellites
  and the relative positions of the satellites within the authorized orbital planes. These changes
  will not cause the Globalstar nongeostationary ("NGSO") satellite constellation to exceed the
  total number of authorized operating space stations within the meaning of Sections 25.143(c) and
  (d) of the Rules.‘ The orbital parameters will remain the same as those previously authorized,
   and all existing in—orbit satellites will remain in their planes.

         In its Annual Report, filed on October 6, 2006 pursuant to Section 25.143(e) of the Rules,
  Globalstar reported that as its satellites approached the end of their design life, they had begun or
  would eventually begin to exhibit a degree of reduced call capacity attributable to degrading S—
  band antenna amplifiers. Globalstar stated that it would be able to ameliorate this performance
  shortcoming by launching its eight on—ground spares and making adjustments to its constellation
  configuration in advance and in support of the launch of the spares.

          Globalstar‘s launch contractor, Starsem, has recently provided tentative launch windows
  of March 26 — April 24 and May 14— June 12, 2007, for the two launches of four spares each. In
  order to prepare the constellation for placement of the eight spares in the optimal slots,
  Globalstar must begin drifting certain of the existing operational and temporarily out—of—service
  satellites into different locations in their planes. The repositioning will take two to three months.

           To maintain the highest possible capacity and best possible quality of service, Globalstar
  will modify its current 40—satellite Walker NGSO configuration. The constellation will combine


         ‘ Globalstar is currently authorized to operate 40 in—orbit space stations plus spares. Public Notice Rpt. No.
  SAT—00270, DA 05—316 (Feb. 5, 2005).


Mr. John Guisti
November 20, 2006
Page 2 of 2

two different Walker configurations but will remain a single operating constellation of forty
satellites plus in—orbit spares. The modified constellation does not reduce the system‘s
worldwide coverage and meets all requirements of Section 25.143(b)(2) the Commission‘s rules
for the 1.6/2.4 GHz MSS service as well as the approved orbital debris mitigation plan.
Subscriber service will continue, and there will be no reduction in geographic coverage during
the transition to the modified configuration. The modified constellation will not increase
interference to other services and will meet all requirements of Section 25.213 of the Rules.
There will be no change in operations of the satellites, gateway earth stations or mobile earth
terminals.                                                                                  j

        The modified constellation will accommodate sharing of spectrum with other NGSO
systems in the feeder links as the current configuration does today." Sharing the service links
with other CDMA systems, if required, will be accomplished just as easily as with the current
configuration. The techniques that exist to mitigate interference between multiple NGSO
systems can still be applied as can the parameters that allow multiple CDMA systems to
coordinate with one another. Such interference mitigation techniques and parameters include
polarization diversity, spread spectrum, power control, downlink power flux density, aggregate
uplink EIRP spectral density and satellite diversity, which allows links between users and/or
gateways to be established through one or more satellites.

       As the launch dates approach, Globalstar will determine the precise positions for the eight
new satellites. It is presently contemplated that two will be placed in each of Planes C, F and H
and that one will be placed in each of planes D and E.‘ Satellites that are replaced in the
operating constellation by newly—launched satellites will be kept as in—plane spares, and failed
satellites, if any, will be moved from the orbital altitude in accordance with the approved orbital
debris mitigation plan.

       Please contact the undersigned if you have any questions or require additional
information.

                                                     Respectfully submitted,

                                             GLOBALSTAR LICENSEE LLC &
                                             GLOBALSTAR, INC.




                                   o MbnaUb William F. Adler
                                            Vice President & Assistant Secretary


          > Globalstar and ICO Global have entered into a feeder link frequency coordination agreement that is
effective through 2007.
        * The Right Ascension of the Ascending Node (RAAN) and argument of perigee (ARGP) for the eight
planes were provided in File No. SAT—MOD—20030606—00098, Exhibit A, p. 5 of 7, filed June 3, 2003.



Document Created: 2006-11-28 15:39:58
Document Modified: 2006-11-28 15:39:58

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