Attachment ex parte

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

IBFS_SATMOD2003111800333_415804

                                        January 5,2005

Via Hand Delivery                                                    RECEIVED
Ms. Marlene H. Dortch, Secretary
Federal Communications Commission                                      JAN 1 4 2005
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-MOD-20031118-00333 (ATC application)
               File No. SAT-AMD-20031118-00332 (ATC application)
               File No. SES-MOD-20031118-Ol879(ATC application)

Dear Ms. Dortch:

         Liberty Communications of Tallahassee, Florida, hereby urges the Commission to afford
L-band 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 above-captioned proceedings. The increased flexibility requested by MSV will
ensure that next-generation MSS systems in the L-band 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-insensitive users operating in remote
areas.

         Liberty has provided MSS since 1996 using the L-band satellites of MSV and Mobile
 Satellite Ventures (Canada) Inc. Liberty currently provides voice and data services to end user
customers throughout the United States. We serve the First Responder market with emphasis on
providing critical incident communications to the essential support functions, such as health,
transportation, environmental control, agriculture, and law enforcement. We have, in fact,
established a statewide emergency back-up communications system that connects local
responders to critical state and national agencies. During the recent hurricanes, this system was
often the only one that survived the immediate impact fiom the storms. While the availability of
a few operating handsets was laudable, an ATC component would have expanded

                3419 APALACHEE P K W , TALLAHASSEE, FL 3231Mo. of Copies rec’d
         850.877.7329OFFICE, 800 852 7544 TOLL FREE, 850.877.&$#@
                                                                                              nsS


Ms. Marlene H. Dortch
January 5,2005
Page 2

communications to all sectors in dire need - public and private. Ubiquitous coverage, capacity,
and instantly available would meet the communications needs of our first response customers.

        While Liberty has developed a viable business using current-generation MSS satellites to
serve niche markets, we are excited about the future potential for MSS when supplemented with
ATC. To date, MSS has been characterized by suitcase-sized user terminals, limited coverage,
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 down 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.




concerns of potential interferen                            SV's development of a next-generation

continue to use t                                             loys ATC, but we are not concerned
                                                              's ATC base stations. This is because
our customers


                                   rtain that our first responders




                                                 a4Q!lhv     trulyyours



                                                  /' Jon A. Hill
                                                 d a n a g e , Satellite Division



                3419 APALACHEE PKWY, TALLAHASSEE, FL 3231 I
         850.877.7329 OFFICE, 888.497.0592 TOLL FREE, 850.877.8362FAX



Document Created: 2005-01-31 17:20:19
Document Modified: 2005-01-31 17:20:19

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