Attachment ex parte

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

IBFS_SATMOD2003111800333_415773

January 6,2005 RECEIVED JAN 1 4 2005 Via Hand Delivery Ms. Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Mobile Satellite Ventures Subsidiary LLC Ex Parte Presentation IB Docket No. 01-185 File No. SAT-MOB20031118-00333 (ATC application) File No. SAT-AMD-20031118-00332 (ATC application) File No. SES-MOD-20031118-01879 (ATC application) Dear Ms. Dortch: W. T. Services Inc. (“WTS”)hereby urges the Commission to afford Lband Mobile Satellite Service (“MSS) operators greater flexibility in their provision of an Ancillary Terrestrial Component (“ATC‘), as requested by Mobile Satellite Ventures LP (“MSV”) in the abovecaptioned proceedings. The increased flexibility requested by MSV will ensure that next-generation MSS systems in the Lband can finally achieve the ubiquitous coverage, capacity, and economies of scale needed for a true consumer service. In contrast, the restrictions on L-band ATC advocated by Inmarsat Ventures plc (“Inmarsat”) will only ensure that MSS forever remains a niche service catering to price-insensitiveusers operating in remote areas. WTS has provided MSS since 1996 using the L-band satellites of MSV and Mobile Satellite Ventures (Canada) Inc. WTS currently provides voice and data services to end user customersthroughout the United States. WTS provides satellite voice and data services for customers in the oil BE gas industry, Federal Government, State Government, and Local Government markets. While WTS has developed a viable business that includes current-generationMSS satellites to serve niche markets, we are excited about the future potential for MSS when supplementedwith ATC. To date, MSS has been characterized by suitcase-sized user terminals, limited covemge, low data rates, and equipment and service prices far exceeding that offered by terrestrial wireless operators. Because the market for this type of service is small, the economies of scale needed to drive dawn equipment and service prices have not developed. With ATC, however, MSS has the potential to evolve into a true consumer service. ATC will provide the coverage, capacity, and economies of scale needed to bring MSS equipment and service prices to affordable levels. Moreover, by overcoming satellite signal blockage in urban areas, ATC will allow MSS to become a truly ubiquitous service, allowing service providers to market their Products to customers not only in rural and remote areas but to customers in the most densely populated urban cores as well. WTS understands that concerns of potential interference that could delay MSV’s development of a next-generation MSS system. These concerns are overstated and speculative. For example, our customers

will continue to use their satellitesnly terminals after MSV deploys ATC, but we are not concerned that these terminals will experience interference from MSV's ATC base stations. This is because our customers do not use their satellite-only terminals in areas where MSV is expected to deploy base stations to overcome satellite signal blockage. By definition, if MSV needs to deploy an ATC base station to overcome signal blockage, our satellite-only terminals will not work effectively in those areas. The Commission is at a crossroads in the development of MSS technology. W T S urges the Commission to follow the path of innovation and better consumer service by adopting MSV's proposals for increased flexibility for ATC in the L-band. very truly yours, W.T. Servicesm Jay Green CommunicationsConsultant JGlmat


Document Created: 2005-01-31 17:19:06
Document Modified: 2005-01-31 17:19:06
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