Attachment ex parte

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

IBFS_SATMOD2003111800333_413202

         atcorn.                                            Ex pante on Late rieo
      DIRECT
                                                                    ORIGINAL
December 8, 2004                                                RECEIVED
                                                                  bec 1 4 zo0
Chairman Michael K.Powell                                                  ies
Federal Communications Commission                           Snd oniies
Office ofthe Secretary                                             étee agioney
445 12th Street, SW
Washington, DC 20554

        Re:    ATC Rulemaking, IB Docket No. 01—185
               Applications of Mobile Satelite Ventures Subsidiary LLC
                      File No. SAT—MOD—20031118—00333
                      File No. SAT—AMD—20031118—00332
                      File No. SES—MOD—20031118—01879
               Ex parte presentation
Dear Chairman Powell:

              Satcom Direct is writing to express its concerns about issues raised in two related
proceedings: () reconsideration ofthe Commission‘s Order authorizing "ATC" as an extension
of Mobile Satellte Service (MSS) networks, and (1)the Commission‘s review ofthefirst
authorization to implement ATC.

               Satcom Directis the preferred provider of Inmarsat Aeronautical services to the
US Militay. Sateom Direct urges the Commission to ensure that MSS services in the L—Band
remain protected from ATC interference, and to preserve the ability to deploy new and
innovative MSS services in all parts ofthe United States, urban, suburbon and rural, now and in
the future,

                The rules that the Commission adopted to constrain ATC interference are under
assault on two fronts. First, Mobile Satelite Ventures (MSV) has asked the Commission to
revise ts rules and allow MSV t significantly increase ATC interference in a manner that would
substantialy increase the zones around ATC base stations where Inmarsat terminals will no
onger work, and in a manner that also could degrade or intermupt communications over Inmarsat
spacecraft. Second, in granting the very first ATC license, the Intermational Bureau granted
waivers ofcrtain ofthese rules and also placed a new burden on MSS operators to demonstrate,
in a very short time frame, that they willbe hart by the deployment ofan ATC base station.
               The fict is that no on has identified a way to fully prevent ATC from generating
interference into Inmersat mobile terminals oInmersat spacecraft. The Commission‘s current
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ATC rules go a long way toward constraining ATC interference into MSS services, and it is
essential that the Commission maintain and enforce those rules. Moreover, it s riticl that the
Commission maintsin ts current policies that () deviations from its ATC raleswill beallowed
only ifit is demonstrated thatthe deviations willnot increase ATC interference into MSS, (i)
ATC in the L—Band is to be phased in to allow time to study its real world effects, and (
ATC does cause interference into MSS service, an ATC operator must immediately modify or
di;gom_j..:: its operations. There are two main reasons these protections and policies must be
maintained.
               First, the continued reliility of Inmarsat services is essentialto the safty and
security—related communications of many federal, state and local governmental agencies.
Inmarsat MSS terminals were relied on in New York City following the September 11 attacks,
and the Fire Department ofNew York has recently chosen Inmarsat terminals to support ts
emergency response communications, Inmarsat MSS service is relied on for these purposes
because the system is independent ofthe terestrial and cellular communications networks that
may be unavailable or overnhelmed in an emergency. MSS—based safety and security—related
communications simply cannot be atrisk of ATC interference in the time of an emergency, when
police, frefighters and other resue personnel need relisble communications the most
                Second we arejust beginning to relize the potentil for MSS to support
broadband service across America, in urban, suburban, and rural areas alike, The Inmarsat—t
spacecraft that are about to be launched will support transmission rates of432 kilobits per
second—a rate competitive with planned 3G networks. Ittherefore is not dificultto imagine the
new types of land mobile, acronautical, and maritime MSS services that soon will be offered
Inmarsat‘s new BGAN land mobile ervice will support the extension ofcorporate
communications networks, as well as failitte the provision ofhigh qualty live video feeds and
news gathering in urban areas. In addition, Inmarsat‘s new broadband acronautical capabilitics
will provide the opportunity to augment the congested air trafic control system in the U.S.,as
well as offer communications services to the general aviation industry———commercial and private
aireraft ofall sizes. Inmarsat—4 thus provides a unique opportunity——in fact,the only
opportunity—to provide "always—on" broadband services to airplanes, land mobile, and maritime
users, regardless of thir location.
               "The full potential ofMSS broadband services can come to fruition only ifthe
Commission looks forward, and develops ATC rules and policis that protect t future, ather
than simply protecting past MSS technology. For these reasons, it is criical that Inmarsat land
mobile, neronautical and mariime terminals are protected from interference whenever they are
operated in the viciity ofATC base stations.
               ATC, as a secondary, non—interfering service, should not be allowed to constrain
the continued deployment ofMSS throughout the United States. Unfortunately, the FCC has
mistakenly assumed that(x) ATC will be deployed only in undefined urban areas, and (¥)
Inmersatland mobile and aeronutical terminals willnot be operated over or near those base
stations. If Inmarsat or one of ts U.S. distributors wants to protect ts operations in the vicinty
of an ATC base station that will operate at high power, it now has to do two things () make a
showing at the FCC within a thitty day window that itlikely will have a mobile user in the


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vicinity ofthe base station, and (1) coordinate with MSV to ty to avoid the effects ofATC
interference. If those efforts are not successful, Inmarsat MSS service might not be possible in
the vicinity ofthat base station in the future.
               MSS subscribers reasonably expect that ther terminals will work anywhere they
need them to work. The Commission should not require MSS service providers to make advance
showings in order to protect their operations in the vicinity ofan ATC base station.
               These proccedings raise very important policy issues and we urge the
Commission to give them itsfullestattention and protect MSS service as described above.

              An original and seven copies ofthis ete are enclosed.

                                             Respectfully submitted,

                                             Satcom Direct


                                             By: _Q_M
                                                  d Greenhill
                                                    vp

ec:    Commissioner Kathleen Q. Abemathy
       Commissioner Michee! J. Copps
       Commissioner Kevin J. Martin
       Commissioner Jonathan S. Adelstein
       Ed Thomas, Chief, Office ofEngineering and Technology
       Donald Abelson, Chief, International Buresu
       Marlene Dortch, Secretary



Document Created: 2005-01-12 12:20:55
Document Modified: 2005-01-12 12:20:55

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