Attachment ex parte

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

IBFS_SATMOD2003111800333_415561

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 Bizub Communications, Inc.                                                 Enat ecitsi@ntsitcomm.can
 #ateilite      Communications             $ofutions                              URC: mortintcommcom

January 12, 2005

Chairman Michael K. Powell
Federal Communications Commission
Office ofthe Secretary
445 12th Street, SW
Washington, DC 20554


        Re:     ATC Rulemaking, IB Docket No. 01—185
                Applications ofMobile Satellite Ventures Subsidiary LLC
                       File No. SAT—MOD—20031118—00333
                       File No. SAT—AMD—20031118—00332
                       File No. SES—MOD—20031118—01879
               Exparteprescaiation

Dear Chairman Powel:

                Bizub Communications, Inc. is writing to express is concerns about issues mised in
two related proceedings: ) reconsideration of the Commission‘s Order authorizing "ATC" as an
extension ofMobile Satelite Service (MSS) networks, and (1) the Commission‘s review ofthe first
authorization to implement ATC.
               As a suppler of Inmarsat equipment and airtime services to the United Nations and
US. based humanitarian organizations, Bizub Communications urges the Commission to ensure that
MSS services in the L—Band remain protected from ATC interference, and to preserve the ablity
to deploy new and innovative MS services i 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 assailt on two
fronts.. Fist, Mobile Satelite Ventuzes (MSV) has asked the Commission to revise is rules and allow
MSV to significantlyincrease ATC interference in a manner that would substantialy increase the zones
around ATC base stations where Inmarsat terminals will no longer work, and in a manner that also could
degrade orinterupt communications over Inmarsat spaceceaft. Second, in granting the very fist ATC
lcense, the International Burea granted waivers ofcermin ofthese rues and also placed a new burden on
MSS operators to demonstrate, in a very short time frame, hat they will be hurt by the deployment ofan
ATC base staion.


        The fict is that no one has identified a way to fily prevent ATC from genenating interference
into Inmarsat moble terminals or Inmarsat spaceeraft. The Commission‘s current ATC rules go a long
way toward constraining ATC interference into MSS services, and it is essentil that the Commision
maintain and enforce those rules. Moreover, it is critcal that the Commission maintain is current polices
that deviations from its ATC rules will be alowed only t is demonstrated that the deviations will not
increase ATC interfeence into MSS, @) ATC in the L—Band is to be phased in to allow time to study its
real world effects, and @i) if ATC does eause interference into MSS service an ATC operator must
immedately modify or discontinue its operations.. There are two main reasons these protections and
poliies must be maintained.
        Firs, the continued relabilty of Inmarsat services is essentil to the safety and security—related
communications of many federal, sate and local govenmenta agencies. Inmansat MSS terminals were
telied on in New York Gity folowing the September 11 atticks,and the Fire Department of New York
has recently chosen Inmarsat terminals to support its emergency response communications.. Inmamat
MSS service is elied on for these purposes because the system is independent oftheterestraland cellular
communications networks that may be unavalable or overshelmed in an emergency. MSS—based safety
and securigezelated communications simply cannot be at risk of ATC interference in the time of an
emergency, when polic, firfighters and other rescue personnel need reiable communications the most.
                Second, we are just beginning to realize the potental for MSS to support broadband
service across America, in urban, suburban, and rural areas alke. The Inmarsat—4 spacecraft that are
about to be launched will support transmission rates of432 kilobits per second—a rate competitve
with planned 3G networks. It therefore is not difficultto imagine the new types of land mobile,
aeronautial, 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 facltate
the provision of high qualiy live video feeds and news gathering in urban areas. In addition,
Inmarsat‘new broadband acronautical capablities will provide the opportunity to augment the
congested ai trific control system in the U.S, as well as offer communications services to the
general aviation industry———commercial and private aircraft of allsizes. Inmarsat—t thus provides a
unique opportunity—in fact, the only opportunity——to provide "always—on" broadband services to
airplanes, land mobile, and mariime users, regardless of their location.
         ‘The fill potential of MSS broadband services can come to fruiion onlyif the Commission looks
forward, and develops ATC rules and polices that protect the future, rather than simply protecting past
MSS technology.. For these reasons, it is criicl that Inmarsat land mobil, acronautical and maiime
terrninals are protected from interference whenever they are operated in the viiniy ofATC base staions.
         ATC, as a secondary, nominterfering service, should not be allowed to constmin the
continued. deployment of NMSS throughout the United Stas. Unfortunately the. FCC. has
mistakenly assumed that ) ATC wl be deployedonly in undefined urban areas, and (, Inmanat and
mobile and aeronmutical terminals will not be operated over or near those base stitins. If
                                                   2


Inmarmat or one of its US. distibutors wants to protect its operations in the vicinity 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
thiry day window that it ikely will have a mobie user in the viiniy ofthe base station, and () coordinate
with MSV to ty to avoid the effects of ATC interference. If those effonts are not successful, Inmansat
MSS service might not be possible in the viiniy ofthat base staion 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 opentionsin the vicinity ofan ATC base sttion.
         These proceedings raie very important policy issues and we urge the Commissionto give them
its filest atention and protect MSS service as described above.



EdwardJBizub, S— President



Document Created: 2005-01-25 17:19:57
Document Modified: 2005-01-25 17:19:57

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