Attachment ex parte

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

IBFS_SATMOD2003111800333_415327

                                                                                                                     L.L.P.
                                                                                                              & DEMPSEY
                                                                                                SQUIRE, SANDERS
                                  EX PARTE OR LATE FILED                                        1201 Pennsylvania Avenue, N.W.
                                                                                                P.O. Box 407
                                                                                                Washington, D.C. 200440407

                                                                                                Office: +1.202.626.6600
                                                                                                Fax: +1.202.626.6780



                                                                                                     Direct: +1.202.626.6615
                                                                         RlGlNAL                            bolcott@ssd.com



January 12,2005


VIA HAND DELIVERY
                                                                           RECEIVED
Marlene H. Dortch                                                             JAN 1 2 2005
Secretary                                                              Federal Communications Commission
Federal Communications Commission                                               Office of Secretary
445 12th Street, S.W.
Washington, D.C. 20554

        Re:      Mobile Satellite Ventures Subsidiary LLC
                 Ex Pavie Presentation
                 IB 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)
                                                                                                N ~of.c jes r&d
                                                                                                Ua &$E
                                                                                                                          of<.

Dear Secretary Dortch:

        The Boeing Company (“Boeing”), by its counsel, herein reiterates its support for the
Commission’s decisions in the referenced proceedings to permit the introduction of Ancillary Terrestrial
Component (“ATC”) as an important complement to the Mobile Satellite Service (“MSS”). As the
holder of a 2 GHz MSS license and as the world’s largest satellite manufacturer, Boeing has a keen
interest in decisions taken in this area. The Application for Review filed by Inmarsat Ventures, Limited
(“Inmarsat”), seeks to reverse important precedents decided by the Commission.’ Boeing is firmly
convinced that MSS licensees at L-band and S-band need the increased flexibility afforded by recent
Commission decisions to ensure that next-generation MSS systems can finally achieve the ubiquitous
coverage, capacity and economies of scale needed for a valuable, truly competitive consumer service.

        Until recently, MSS has been generally characterized by suitcase-sized user terminals, limited
coverage, low data rates, and equipment and service prices far exceeding that offered by terrestrial
wireless operators. Boeing-led developments - exemplified by the Thuraya Mobile Satellite System -

I
 In the Matter of Mobile Satellite VenturesSubsidiary LLC, Application for Review of Inmarsat Ventures Ltd., File
Nos. SAT-MOD-200311 18-00333, SAT-AMD-20031 1 18-00332, and SES-MOD-20031118-01879 (filed Dec. 8,
2004) (“Application for Review”).

                              .
          CINCINNATI ’ CLEVELAND COLUMBUS HOUSTON’ LOS ANGELES ’ MIAMI* NEWYORK ’ PALO ALTO ’ PHOENIX * SAN FRANCISCO
         TAMPA  * TYS0h-S CORNERWASHINGTONDC Rlo DE JANEIRO 1 BRATISLAVABRUSSELS* BUDAPEST ’ LONDON* MADRIDMILAN
           MOSCOW PRAGUE 1 BElJlNG * HONGKONG’ SHANGHAI * TOKYO
                   a                                                       OFFICES: BUCHAREST DUBLIN
                                                                 1 ASSOCIATED                         * KYIV TAIPEI
                                                                                                           a


                                                                                      SQUIRE,
                                                                                           SANDERS      L.L.P.
                                                                                                 & DEMPSEY
Secretary Marlene Dortch
January 12,2005
Page 2


demonstrate the potential for offering MSS to a broadly dispersed user community using small handheld
phones. Our evaluation of the U.S. market, taking into account the diverse requirements of both rural and
urban users, indicates that ATC will be key to ensuring that the service meets the goals of competitiveness
and ubiquity. This unmistakably supports the similarly-stated goals of the Commission.

        Moreover, Boeing understands that the Commission includes in its goals an uncompromising
support of efforts that promote effective communications for homeland security. In that regard, we note
that the integration of an MSS network with ATC offers one of the best mechanisms to ensure robustness
and wide-spread inter-operability necessary to meet homeland security requirements. The rules and
licensing provisions adopted thus far are supportive of that goal and we encourage you not to revisit
matters already adequately addressed. Furthermore, the Commission should continue to facilitate the
introduction of MSS/ATC through the adoption of the improvements in its ATC rules urged by Boeing in
its pending petitions for reconsideration of the rulemaking proceeding.2

        This country is now at the threshold of being able to realize the full benefits of MSS technology.
Boeing urges the Commission to hold the course that will permit continued introduction of innovation and
better consumer service by continuing to support the MSS industry in its introduction of ATC services
and by leaving unaltered the International Bureau’s decision to authorize MSV’s provision of MSS/ATC
services.




                                                       Counsel for The Boeing Company




 2 See Flexibiliw for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L-
Band, and the I . 6/2.4 GHz Bands, Petition for Reconsideration of The Boeing Company, FCC 03-162 (Sept. 11,
2003) (urging the Commission to reconsider some of the changes in the ATC application procedures that were
adopted by the Commission in its July 3, 2003 Order on Reconsideration); Flexibility for Delivev of
Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L-Band, and the 1.6‘2.4 GHz Bands,
Petition for Reconsideration of The Boeing Company, FCC 03-162 (July 7, 2003) (requesting the Commission to
harmonize its geographic cover requirements for MSS networks providing ATC services).



Document Created: 2005-01-21 11:47:35
Document Modified: 2005-01-21 11:47:35

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC