Attachment letter

letter

LETTER submitted by Mobile Satellite Ventures

letter

2005-09-29

This document pretains to SAT-MOD-20050301-00054 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2005030100054_458295

msV Mobile Satllte Ventures > sam w ansiscon Via Hand Delivery OCT 0 4 2005 Ms: Matione H. Dorieh, Secsetary Potey Branch RECEIVED Federal Communications Commission International B:rsau 445 12th Street, S.W. sep 2 9 2005 Washington, D.C. 20554 sconnision Eatun conmunicatinl Re: GlobalstarLLC se sties Application for Authority to Implement an Ancillary Terrestrial Component File Nos. SAT—MOD—20050301—00054; SES—MOD—20050301—00261 Dear Ms. Dortch: Mobile Satellite Ventures Subsidiary LLC (°MSV") urges the International Bureau (*Bureau") in acting on the above—captioned application to clarify that Globalstar LLC ("Globalstar®) requires additional authority from the Commission if it seeks to provide a poorer quality satellte service than that for which it has authority today. In the above—captioned proceeding, Globalstar is secking authority to implement an Ancillary Terrestral Component (*ATC®)in conjunction with its current—generation Big LEO Mobile Satellite Service (°MSS") system." One precondition for authority to implement ATC is a showing that the applicant will provide an "integrated service." 47 C.F.R. §.25.149(b)(4). The safe harhor for satisfying the integrated service requirement is to offer a dual—mode handset that can communicate with both the satellite and terrestral network. 47 C.FR. §25.149(b)(8)G). In its application, Globalstar certifies that it will offer a dual—mode handsct. See Globalstar ATC Application at Exhibit B—A. Globalstar states in its application that it has not yet concluded the design or production ofthe user equipment it expects to deploy for ts proposed service. See Globalstar ATC Application at Exhibit B—4. The application does, however, specify the output power (EIRP) and antenna gain of the user equipment. 1d. Moreover, based on its existing satellte license, Globalstar is authorized to provide satellite service at an average data rate of no less than 2.4 kbps." Ifthere is any reduction in the size and weight of its pictured user equipment,these key ‘ See Application of Globalstar LLC, File Nos. SAT—MOD—20050301—00054; SES—MOD— 20050301—00261 (March 1, 2005) ("Globalstar ATCApplication"). * See LoraliQualcomm, L.P., Authority to Construct, Launch and Operate Globalstar, Order and Authorization, 10 FCC Red 2333, § 24 (Int‘1 Bur. 1995). Globalstar‘s application was granted "in accordance with the technical specifications set forth n its application," meaning that Globalstar cannot offer consumers satellte service ata lesser data rate without secking prior Footote continued on next page

Ms. Marlene H. Dortch September 29, 2005 Page 2 parameters (EIRP, antenna gain,and data rate) are likely to change in ways that would affect the quality ofthe satellite service." As such, in acting on Globalstar‘s application, the Bureau should clarify that Globalstar must seek prior approval to the extent it modifies these parameters and, if Globalstar modifies these parameters, the Bureau also should require Globalstar to specify the services thatit plans to offer on ATC. Please direct any questions regarding this matter to the undersigned. Very truly yours, ce Don Abelson Cassandra Thomas Howard Gribof William Bell William Adler William Lake Doomers comnva Footnote continued from previous page Commission approval. See Application of Loral/Qualcomm Partership, L.P. For Authority to Construct, Launch, and Operate Globalstar, File No. SAT—AMD—19941 1 16—00077 (November 15, 1994),at Tables 4—2 to 4—5. * For this reason, MSV received authority to operate a link margin booster with dual—mode handsets used with ts current—generation MSS system. See Mobile Satellite Ventures Subsidiary LLC, Order andAuthorization, DA 04—3553 (Iut‘ Bur. 2004), at 28—33.


Document Created: 2005-10-04 18:27:57
Document Modified: 2005-10-04 18:27:57
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