Attachment letter

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

IBFS_SATMOD2003111800333_413235

NERA enabling a wireless future Hers, e December 23, 2004 4875 Proston Park Blvt sure eo0 Piae,mxrsons Chairman Michael K. Powell m arassens Federal Communications Commission i ett Office of the Secretary i2 en 445 12th Street,SW Washington, DC 20554 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—01879 Ex parte presentation Dear Chairman Powells Nera Inc. based in Plano, TX, is writing to express ts concerns aboutissues aised in two related proceedings: ()) reconsideration of the Commission‘s Order authorizing "ATC"as an extension of Mobile Satellite Service (MSS) networks, and (i) the Commission‘s iew ofthe first authorization to implement ATC. Nera Inc. is a manufacturer and system integrator of a wide array of satelite and terrestrial wireless communications systems, and a global leader in Inmarsat systems and networking, with a wide variety of U.S. government, military, and commercial customers. Nera Inc. 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 of the 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 Satellite Ventures (MSV) has asked the Commission to revise itsrules and allow MSV to significantly increase ATC interference in a manner that would substantially increase the zones around ATC base stations where Inmarsat terminals will no longer work, and in a manner that also could degrade or interrupt communications over Inmarsat spacecraft. Second, in granting the very first ATC license, the International Bureau granted waivers of certain of these rules and also placed a newburden on MSS operators to demonstrate, in a very short time frame, that they will be hurt by the deployment of an ATC base station. The fact is that no one has identified a way to fully prevent ATC from generating interference into Inmarsat mobile terminals or Inmarsat spacecraft. The Commission‘s current 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 is critial that the Commission maintain its current policies that (i) 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 toallow time to study its real world effects, and (it) if ATC 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 emergeney response communications., Inmarsat MSS service is relied on for these purposes because the system is independent ofthe terrestrial and cellular communications networks that may be unavailable or overwhelmed in an emergeney. MSS—based safety and security—related communications simply cannot be atrisk of ATC interference in the time of an emergency, when police, firefighters 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—4 spacecraft that are about to be launched will support transmission rates of432 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 services that soon will be offered. Inmarsat‘s new BGAN land mobile service will support the extension of corporate 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 aeronautical capabilities will provide the opportunity to augment the congested air raffic 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 their location. The full potential ofMSS broadband services can come to fruition only if the Commission looks forward, and develops ATC rules and policies that protect the future, rather than simply protecting past MSS technology. For these reasons, it is citical that Inmarsat land mobile, aeronautical and maritime terminals are protected from interference whenever they are operated in the vicinity ofATC base stations. ATG, as a secondary, non—interfering service, should not be allowed to constrain the continued deployment of MSS 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 aeronutical terminals will not be operated over or near those base stations. If Inmarsat or one of ts U.S. distributors wants to protect its operations in the vicinity offan ATC base station that will operate at high power, it now has to do two things ()) make a showing at the FCC within a thirty day window that itlikely will have a mobile user in the vicinity of the base station, and (i) coordinate with MSV to try to avoid the effects of ATC interference. If those efforts are not successful, Inmarsat MSS service might not be possible in the vicinity of that base station in the future.

MSS subscribers reasonably expect that their 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 its fullest attention and protect MSS service as described above. An original and seven copics ofthis letter are enclosed. Respectfully submitted, Nera Inc. silly C President ce Commissioner Kathleen Q, Abemathy Commissioner Michael J. Copps Commissioner Kevin J. Martin Commissioner Jonathan S. Adelstein Ed Thomas, Chief, Office of Engineering and Technology Donald Abelson, Chief, International Bureau Marlene Dortch, Secretary


Document Created: 2005-01-12 12:14:20
Document Modified: 2005-01-12 12:14:20
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