Attachment comment

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COMMENT submitted by New ICO Satellite Services G.P.

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2007-07-23

This document pretains to SAT-MOD-20070608-00080 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2007060800080_579729

Before the FEDERAL COMMUNICATIONS COMMISSION fii%féffi%%g???‘gg Washington, D.C. 20554 ‘ JUL 2 3 ropg Federg} Communiga As tons Commise: T rmSS Office of the Se;fifsiam; *J ton In the Matter of ) ) TerreStar Networks Inc. ) File No. SAT—MOD—20070608—00080 ) Application for Modification of 2 GHz ) Call Sign $2633 Mobile Satellite Service Letter of Intent ) Authorization ) ) COMMENTS New ICO Satellite Services G.P. ("ICO"), the holder of a 2 GHz mobile satellite service ("MSS") letter of intent ("LOIT") authorization, submits these comments regarding the above—captioned application ("Application") filed by TerreStar Networks, Inc. ("TerreStar"). In its Application, TerreStar seeks to modify its 2 GHz MSS LOI authorization by extending the milestone deadline for launching its satellite from November 2007 to September 2008.! TerreStar states that despite substantial progress made toward completing construction of its satellite, a 10—month milestone extension is required because of unforeseeable construction delays beyond its control. TerreStar attributes the construction delays to unanticipated technical problems in the construction and delivery of the S—band low noise amplifiers, oscillators, and S—band feed array.2 1ICO supports the grant of an extension of TerreStar‘s launch milestone deadline for unanticipated technical problems encountered during construction. The Commission ‘ See TerreStar Application, Exh. 1, at 1 (June 8, 2007). * Id. at 4. dc—496315

has a longstanding policy of granting milestone extensions when the delay is due to "circumstances beyond the licensee‘s control" and particularly when those cirecumstances involve "unanticipated technical problems with a satellite under construction."" Additionally, the Commission has considered "the extent of a satellite‘s construction and the amounts paid toward the total contract price" as factors in granting milestone extension requests." Imposing milestones while granting extensions under appropriate circumstances serves the Commission‘s policy of preventing satellite licensees from warehousing valuable spectrum and ensuring prompt delivery of service to the public.® ICO suggests that the Commussion evaluate TerreStar‘s milestone extension request under the Commission‘s established milestone policy and precedent and grant the request, subject to any modifications the Commission deems appropriate, if the Commission determines that TerreStar‘s delay is due to circumstances beyond its control. Respectfully submitted, NEW ICO SATELLITE SERVICES G.P. :_ oi WitiPay/Wué’j;fi Cheryl A. Tritt SuzanneHhichings Malloy Phuong N. Pham Senior Vice President, Regulatory Affairs Morrison & Foerster LLP 815 Connecticut Avenue, NW, Suite 610 2000 Pennsylvania Ave., NW, Suite 5500 Washington, D.C. 20006 Washington, D.C. 20006 Its Counsel July 23, 2007 * See New ICO Satellite Services G.P., 22 FCC Red 2229, 15 (IB 2007). 4 Id. © Id. 1 14. de—496315 9

CERTIFICATE OF SERVICE I hereby certify on this 23" day of July 2007, a copy of the foregoing Comments has been served via first class mail, postage pre—paid, to the following: Douglas Brandon TerreStar Networks, Inc. 12010 Sunset Hills Road, 9°" Floor Reston, VA 20190 Henry Goldberg Goldber% Godles Wiener & Wright 1229 19" Street, NW Washington, DC 20036—2413 l Tully Counsel to TerreStar Networks, Inc. Theresa Rollins de—496315


Document Created: 2007-07-25 12:10:25
Document Modified: 2007-07-25 12:10:25
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