Attachment letter

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

IBFS_SATMOD2003111800333_413215

Chairman Michael K. Powell Federal Communications Commission Office ofthe Secretary 445 12th Street, SW Washington, DC 20554 RECEIVED — FGC JAN — 62005 reteal Canmuricaten Conninn Suserore Junuary 5, 2005 Re: ATC Rulemaking, IB Docket No. 01—185 Applications of Mobile Satellite Ventures Subsidiary LLC File No. SAT—MOD—20031118—00333 File No. SAT—AMD—20031118—00332 File No. SES—MOD—20031118—01870 Ex parte presentation Dear Chairman Powell: Thrane & Thrane Inc.is writing to express ts concems about issues raised in two related proceedings: () reconsideration ofthe Commission‘s Order authorizing "ATC" as an extension ofMobile Satellite Service (MSS) networks, and (i) the Commission‘s review ofthe first authorization to implement ATC. Thrane & Thrane is a leading manufacturer ofInmarsat compliant mobile satellite terminals of which thousands have been supplied since 1992 primarily to various US Government entites for use in miltary as well as non—miltary applications on USsoil as well as abroad. As a fundamental feature ofour products is the ability to do instant deployment ofthe terminals at any location in the world our company urge 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, suburban 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 Satellte Ventures (MSV) has asked the Commission to revise ts rules and allow MSV to significantlyincrease ATC interference in a manner that would substantially increase the zones around ATC base stations where Inmarsat terminals will n longer work, and in a manner that also could degrade or interrupt communications over Inmarsat spacccraft. Second, in granting the very first ATC license, the International Bureau granted waivers of certain ofthese rules and also placed a new burden on MSS operators t demonstrate, in a very short time frame, that they will be hurt by the deployment of an ATC base station. mecion omm ols c iesseetts

Thrane &Thrane The factis that no one has identified a way to fully prevent ATC from generating interference into Inmarsat mobile terminals orInmarsat spacecraft. The Commission‘s current ATC rules go a long way toward constraining ATC interference into MSS services, and it is essentia that the Commission maintain and enforce those rules. Moreover, it i critical that the Commission maintain its current policies that () deviations from its ATC rules will be allowed only if it is demonstrated that the deviations will not increase ATC interference into MSS, (i) ATC in the L~ Band is to be phased in to allow time to study ts real world effects, and (i ) ifATC does cause interference into MSS service, an ATC operator must immediately modify or discontinue its operations. There are two main reasons these protections and policies must be maintained. First, the continued reliability of Inmarsat services is essential to the safety 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 its emergency response communications. Inmarsat MSS service is relied on forthese purposes because the system is independent ofthe terrestrialand cellular communications networks that may be unavailable or overshelmed in an emergeney. MSS—based safety and sccurity—related communications simply cannot be at risk of ATC interference in the time of an emergeney, when police, frefighters and other rescue personnel need reliable communications the most. Second, we are just beginning to realize the potential for MSS to support broadband service across America, in urban, suburban, and rural areas alike. The Inmarsat— spacecraft that are about to be Iaunched will support transmission rates of 432 kilobits per second——a rate competitive with planned 3G networks. It therefore is not difficult to imagine the new types of land mobile, aeronautical, and maritime MSS serviees that soon will be offered. Inmarsat‘s new BGAN land mobile service will support the extension ofcorporate communications networks, as well as facilitate the provision ofhigh quality live video feeds and news gathering in urban areas. In addition, Inmarsat‘s new broadband aeronsutical capabilities will provide the opportunity to augment the congested air taffic control system in the U.S.,as well as offer communications services to the general aviation industry———commercial and private aircraft ofall sizes. Inmarsat—thus provides a unique opportunity———in fact, the only opportunity———to provide "alwways—on" broadband services to airplanes, land mobile, and maritime users, regardless of their location. The full potential ofMSS broadband services can come to fuition only ifthe Commission looks forward, and develops ATC rulesand policies that protect the future, rather than simply protecting past MSS technology. For these reasons, tis critical that Inmarsat land mobile, acronautical and maritime terminals are protected from interferencewhenever they are operated in the vieinity ofATC base stations. mecton s esd e‘ Wirgini Beachv7

Thrane & Thranc 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 (y)Inmarsat land mobile and acronautical terminals will not be operated over or near those base stations. If Inmarsator one ofts U.S. distributors wants to protect ts operations in the vicinity oan ATC base station that will operate at high power, it now has to do two things ) make a showing at the FCC within a thity day window that it liely willhave a mobile user in the vicinity ofthe base station, and (i) coordinate with MSV to try to avoid the effects ofATC interference. Ifthose efforts are not suecessfil, Inmarsat MSS service might not be possible in the vicinity ofthat base station in the future. > MSS subscribers such as Search and Rescue organizations, Intelligence organizations and Law enforeement organizations which are all among the users ofThrane & Thrane mobile satellite terminals 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 of an ATC base station. These proceedings raise very important policy issues and we urge the Commission to give them itsfillest attention and protect MSS service as described above. An original and seven copies ofthis letter are enclosed. Respectfully submited, Thrane & Thrane Inc. lenrikc Novelykke President ee: Commissioner Kathleen Q. Abernathy Commissioner Michael J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chief, Office ofEngineering and Technology Donald Abelson, Chief, International Bureau Marlene Dortch, Sccretary macson ooo s old esc


Document Created: 2005-01-12 12:11:55
Document Modified: 2005-01-12 12:11:55
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