Attachment comments

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COMMENT submitted by New ICO Satellite Services GP

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2008-09-22

This document pretains to SAT-MOD-20080718-00143 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008071800143_665724

Before the FEDERAL COMMUNICATIONS COMMISSION FILED/Ac~E~TEB Washington, D.C. 20554 SEP 2 2 2008 In the Matter of ) TerreStar Networks Inc. ) File No. SAT-MOD-2008071 8-00143 ) Application for Modification of 2 GHz ) Call Sign S2633 Mobile Satellite Service Letter of Intent 1 Authorization 1 1 COMMENTS New I C 0 Satellite Services G.P. (“ICO”), the holder of a 2 GHz mobile satellite service (“MSS”) letter of intent (“LOI”) authorization, supports the grant of the above- captioned application (“Application”) filed by TerreStar Networks, Inc. (“TerreStar”). In its Application, TerreStar requests an extension of the milestone deadlines for launching its satellite and certifying its system operational to June 30 and August 30, 2009, respectively.’ TerreStar states that construction of its satellite is nearly complete and that the underlying construction delay is due to unforeseeable circumstances beyond its control.2 The Commission has a longstanding policy of granting milestone extensions when the delay is due to “circumstances beyond the licensee’s control” and particularly when those circumstances involve “unanticipated technical problems with a satellite under con~truction.”~ 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 ~ ~~ ~~~~ 1 See TerreStar Application, Exh. 1, at 1 (July 18, 2008). Id. See New I C 0 Satellite Services G.P., 22 FCC Rcd 2229, T[ 15 (II3 2007).

milestone extension request^.^ Consistent with Commission’s established milestone policy and in light of the substantial completion of TerreStar’s satellite, the Commission should grant TerreStar’s milestone extension request. Respectfully submitted, NEW IC0 SATELLITE SERVICES G.P. By: Cheryl A. Tritt suz Phuokg N. Pham Senior Vice President, Regulatory Affairs Momson & Foerster LLP 815 Connecticut Avenue, NW, Suite 610 2000 Pennsylvania Ave., NW, Suite 5500 Washington, D.C. 20006 Washington, D.C. 20006 Its Counsel September 22,2008 Id, dc-534933 2

CERTIFICATE OF SERVICE I hereby certify on this 22ndday of September 2008, 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, gthFloor Reston, VA 20190 Jonathan L. Wiener Goldber Godles Wiener & Wright 8 1229 19' Street, NW Washington, DC 20036-241 3 Counsel to TerreStar Networks, Inc. Tfieresa Rollins


Document Created: 2008-09-23 11:15:16
Document Modified: 2008-09-23 11:15:16
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