Attachment ex parte

ex parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by GlobalStar

ex parte

2005-12-13

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

IBFS_SATMOD2005030100054_473815

T weems" EX PARTE OR LATE FILED Globalstar mc« bewne RECEIVED December 13, 2005 EC 13 2008 Ms. Marlene H. Dortch l commuicaton onniasn Secretary imesotsecntay Federal Communications Commission 445 Twelth Street, SW Washington, DC 20554 Re: Ex Parte Submission in File No. SAT—MOD—20050301—00054 Dear Ms. Dortch: On December 13, 2005, the undersigned, along with Tosh Roland and Paul Monte, spoke by telephone with Richard Engelman and Williem Bell ofthe Commission‘s Intemational Bureau (‘TB") staffregarding the status ofthe above—referenced application. During those conversations, e TB staffrequested farther information regarding Globalstar‘s compliance with Section 25.149(b)(2)() of the Commission‘s rules, 47 C.FR. § 25.149()@)(). Section 25.149(b)(2)G) requires that "Operational NGSO MSS ATC systems shall maintain an in—orbit spare satelite." In Exhibit B, p. 2,ofi ancillary terrestrial component ("ATC®) application, filed March 1, 2005, Globalstar explained how it met this rle requirement. The TB staffhas inquired whether, in light ofthe more recent information contained in Globalstar‘s Annual MSS Report for S2115, filed October 17, 2005 ("Annual Report"), Globalstar continues to mmaintain an in—orbit spare capable ofuse to maintain the geographic and temporal coverage required by the Commission‘s ATC rules. ‘As noted in the Amwel Report, significant number of Globalstar‘s satellites have experienced S—band antenns subsystem anomalies and have had to be taken out ofservice cither temporarily or permanently, Because ofrecent additional anomalies, Globalstar has placed its three in—orbit spares into operation. The company hopes to bring some or all ofthe recently failed satellites back into service; however, the process of doing so takes many months because changes in payload operating parameters must be commanded slowly over time before commercial use can begin again. Accordingly, while at this time Globalstar does not have an in—orbit spare, t is likely that satelltes temporarily out ofservice will be recovered. prior to the planned initition ofATC service during the latter part o2006. Furthermore, Globalstar will Inunch at least four, and perhaps all eight, ofits ground spares beginning in the first or second quarter of 2007,) at which time it expects to have multiple in—orbit spares once again. * Globalsta is curenty negotatinglawnch serviees agreements with o vendors prsuantto Technical Assitance Agreement and TechnologyTransfir Control Agrecments ecenty approved by,respectively, the Directorate ofDeftase Trade Contols ofe U.S. DepertmentofSate, and the Defense Tecinology Securty Administation.

Ms. Marlene H. Dortch December 13, 2005 Page 2 of2 Ifthe Commission determines that the in—orbit spare requirement must be satisfied at the time that an ATC authorization is granted, rather than at the time that ATC service is initlated, and that Globalstar does not meet the in—orbit spare requirement imposed by section 25.149()2)), then Globalstar respectfully requests a waiver ofthat provision for tlimited period oftime before Globalstar retums to full compliance. Grant of Globalstar‘s request fora waiver ofthe in—orbit spare requirement for a limited period of time following grent ofts ATC appliation, but prior toits initition of ATC service, is fully consistent with the TB‘s MSV ATC Order," which waived the analogous spare satelite requirement applicable to L—band MSS systems for a imited period oftime. Respectfully submitted, Mbaul" Cole) William BAdler Vice President—Legal & Regulatory Affairs CC: Roduey Porter Robert Nelson Richard Engelmen William Bell * See Mable Stelte Ventures Subsidiry LLC—— Applicatio for Minor Modification of Space Staon Licease for AMSC—1, CC File Now.SATMOD—20031118—00233, SAT—AVD20031118.00337, ses— MOD—20031118—01879, 19 FCC Red 22144 (Noventber $, 2004)at 125.


Document Created: 2005-12-30 11:49:12
Document Modified: 2005-12-30 11:49:12
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