Attachment supplementing

This document pretains to SAT-MOD-20031118-00333 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2003111800333_399888

DUPLICATE MSV Mobile Satelite Ventures September 22, 2004 RECEIVED Via Hand Delivery p Ms. Marlene H. Dortch Sep 2 2 2004 redelCommunlcatonsCommission Federal Communications Commission geva: Oficeot Sreminy 445 12th Street, SW. Washington, D.C. 20554 Re: Mobile Satellite Ventures Subsidiary LLC Ex Parte Presentation 1B Docket No. 01—185 File No. SAT—MOD—20031118—00333 (ATC application) File No. SAT—AMD—20031118—00332 (ATC application) File No. SES—MOD—20031118—01879 (ATC application) Dear Ms. Dortch In response to questions raised by Commission staff at a mecting held on September 14, 2004, Mobile Satellte Ventures Subsidiary LLC ("MSV") hereby supplements its application with the attached information. Please direct any questions regarding this matter to the undersigned. Very truly yours, o. Lon C. Levin ce Richard Engelman Howard Gribo Kathym Medicy Roderick Porter Steven Spacth David Strickland Cassandra Thomas John Janka, counsel for Inmarsat Mobile Satalite Ventures LP 19802 Parvidge Bodard, Reston, Vignia, 20101—se1o

Atachment * On pages 22 and 26 of its ATC application, MSV certified that measurements used to determine compliance with out—of—band emission limits to protect GPS receivers will be made over a 20 millisecond averaging period. In light ofa Commission decision adapted in November 2003,‘ MSV hereby certifies that these measurements will be made over a 2 millisecond active transmission interval. * On page 22 of its ATC application, MSV certified to the out—of—band emission limits its base stations would meet t protect GPS. * Attached hereto is an exhibit explaining further how MSV‘s priority and preemptive access obligations will be satisfied for a CDMA protocol. See Attachment A. * Exhibit G ofMSV‘s ATC application explained the methodology whereby MSV concluded which satellite systems operate co—channel with MSV or MSV Canada in a waythat is meaningful for any interference analysis. The analysis focused on the potential that an MSV MT operating in North America might be visible to a widely separated satellite using the same frequency. Attached hereto is an Addendum to this showing which includes satellitesthat are visible from MTs operating in Hawail. See Attachment B. ‘ Second Report and Order, TB Docket No. 99—67, FCC 03—283 (Nov. 18, 2003).

Attachment A Addendum to Exhibit D of MSV‘s ATC Application Priority & Preemptive Access for CDMA A key aspect ofthe Commission‘s MSS L—band policy is its requirement that the licensee provide priority and preemptive access for acronautical sefety services in the upper L—band, and for maritime safety services in the lower L—band. 47 C.F.R. Section 2.106 foomotes US308, US315. "Priority" means that if a GMDSS or AMS(R)S system operating on MSV‘s satellite(s) needs additional spectrum, MSV will relinguish that spectrum to it "Preemption‘" is required when the requested MSV spectrum is occupied. In that case, MSV will terminate active channels to make spectrum available. The Commission has defined the system characteristics required to support priority and preemptive access in MSV‘s authorizations." MSV‘s understanding of these requirements is thatifa GMDSS or AMS(R)S system operating on MSV‘s satellite(s) needs additional spectrum for safety or emergency communications, MSV will relinguish that spectrum to it including preempting channels currently in use for lower priority communications, if required, to make spectrum available. MSV had previously demonstrated how this will be achieved for a GSM—based air interface. Here, the showing is made for 18—95B and CDMA2000 air interfaces. Both of the above air interfaces employ full—duplex terminals and continuously transmitted, forward, pilot channels. This greatly faciltates the preemption of a forward and return carrier pair. Here "preemiption" is taken to mean relinguishing spectrum, as discussed above.. Prionitzed access without vacating the entire spectrum occupied by a carrieris currently not feasible for 18—95B and CDMA2000, The CDMA Development Group (CDG), however, has recently approved a priority access scheme which will be published as TIA—917 in October 2004. MSV will provide priority access to GMSS and AMS(RJSusers according tothis standard, thereby providing substantilly similar prionitized access as available via GSM and previously described in MSV‘s Application. The concept of operation is as follows. Upon request to the MSV hub" from AMS(R)S or GMDSS control centers, via agreed upon preemption protocols, the forward pilot channel ofto— be—vacated carriers will be taken down. This will cause all MTs camped on those carriers to cease transmission almost immediately (within 40 ms). If the AMS(R)S or GMDSS scheme uses CDMA, a reserved System Identification ID (SID) and/or Network Identification ID (NID) will * See, eg., Application of AMSC Subsidiary Corporation for a Blanket License to Construct and Operate up to 200,000 L—band Mobile Earth Stations, Order and Authorization, File No. 2823— DSE—PL—93, 94 12, 18 (1993). * The hub is the Central Resource Manager and has control over both satellteand terrestrial frequencies for the entire hybrid network.

be used in the Sync Channel so that commercial MTs will be barred from re—logging on to that carrier.

Attachment B Addendum to Exhibit G of MSV‘s ATC Application If satellites visible from the longitude of Honolulu, Hawaii are included in MSV‘s analysis, the list osatellites visible to an MSV MT expands as follows. Aom satname LonG_Nom NTF_RsN vn vinasarane 152 Coordination J wrsar—t35e 135 Coordination 4 wTsaresse 195 Coordination cHN conrass—10€ 140 Coordination ma measare ti8 Coordination ns carupas 135 Coordination Aus Aussare isee mos 1s2 Goordination Aus Aussare tsz MXL 152 Goordination Aus Aussare issemos 155 Goordination aus Aussare 1see L 155 Coordination Aus Aussato tsserss 155 Coordination Aus Aussate isse mor 155 Notfication J wrsar—1408 10 Coordination J wrsare—108 10 Goordination J wrsar—ise 115 Coordination J wrsare—ise 115 Coordination urs vornias t2s Coordination urs vornas 110 Notfication c inmarsatspors tss Coordination "The first group of satellites, would clearly be line—ofsight to MSV*s system, but they have not yet requested coordination with MSV‘s system, leading MSV to conclude that they are not operating co—channel with MSV‘s existing operations. The Australian and Indonesian satellites are visible from the Hawail. Their coverage areas, however, are centered on Australia and Indonesia, respectively; as a result, their antenna gain toward Hawaii is small. Therefore, te effect of ATC transmissions from Hawail on these systems would be slight. MSV is coordinating with the operator of the satellits in the next group comprising the MTSAT satellites at 140°E and 145°E.

The only remaining systems are those that are operated by Partiesto the Mexico City Memorandum of Understanding. These Parties have developed a series of Agreements that provide for a substantial amount of spectrum to be used without any co—channel sharing. The Agreements clearly establish which frequencies are shared by which systems and which frequencies are used on an exclusive basis in the region.

Certification 1, Lon CLevin, Viee President of Mobile Satelite Ventures Subsidiary LLC (MSV certify under penalty ofperjurythat the information contained herein is true and correct. Excouted on September 22, 2004 .Levin Vice President


Document Created: 2004-10-06 18:14:32
Document Modified: 2004-10-06 18:14:32
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