Attachment Exhibit C

This document pretains to SAT-MOD-20100405-00064 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010040500064_808941

                                         Exhibit C

                                  Application Description

       Pursuant to Section 25.117(c) of the Commission’s rules, 47 C.F.R. § 25.117(c),

SkyTerra Subsidiary LLC (“SkyTerra”), the licensee of SkyTerra 1, a Mobile Satellite

Service (“MSS”) satellite, hereby requests a five-month extension, up to and including

October 31, 2010, to meet its “launch and begin operations” milestone. As explained

more fully below, in July 2009 the spacecraft manufacturer, Boeing Satellite Systems,

Inc. (“Boeing”), projected a potential delay in satellite construction due to unforeseeable

circumstances beyond SkyTerra’s control. This delay required SkyTerra to reschedule

the launch window for SkyTerra 1 to the August to October 2010 period. Construction of

the SkyTerra 1 satellite is now nearly complete but launch is not possible before the May

26, 2010 milestone. Extending the milestone is thus necessary to accommodate the new

delivery schedule and will allow SkyTerra to deliver the significant public interest

benefits of a next-generation MSS system. Once deployed, SkyTerra’s next-generation

satellite-terrestrial network will extend broadband access to rural areas, enhance reliable

public safety communications, increase wireless competition and spectrum efficiency,

extend United States technology leadership, and stimulate job creation; all of which are

consistent with key FCC and United State priorities. The International Bureau

(“Bureau”) has granted milestone extensions under similar circumstances, and it should

reach the same conclusion here.

       SkyTerra also modifies, in part, its orbital debris mitigation statement and

requests waiver of that portion of Section 25.283(c) of the Commission’s rules, 47 C.F.R.


§ 25.283(c), requiring the relief of pressure vessels at satellite end-of-life. As explained

more fully below, good cause exists for waiver of this requirement. 47 C.F.R. § 1.3.

I.        Grant of the Milestone Extension Request is Warranted

          A.       The Construction Delay Was Unforeseeable and Beyond SkyTerra’s
                   Control

          Delay in the completion of the satellite construction was principally caused by

development and integration issues associated with the advanced satellite system design,

notably the state-of-the-art 22-meter L-Band reflector and spacecraft test programs.

Several design iterations in the mesh management system were required during

deployment evaluation testing. As a result, additional evaluation testing was performed

to mitigate downstream risk prior to the reflector being released into single line flow of

the satellite program.

          In March 2009, the reflector was projected to be delivered to Boeing by July

2009. By July 2009, however, Boeing’s projected delivery of the reflector slipped from

July 2009 to the first quarter of 2010, as reflected in SkyTerra’s disclosures in its SEC

filings.1 Ultimately, the reflector was delivered to Boeing in January 2010. While the

enhanced test program resulted in the reflector delivery delay to Boeing by its

subcontractor, both SkyTerra and Boeing technical teams are pleased with the results and

the ensuing confidence gained by conducting the additional tests.

          Accordingly, while SkyTerra developed what it believed to be a reasonable

delivery schedule with its vendors, the above events occurred delaying the delivery of a

spacecraft suitable for testing and launch before the relevant milestone deadline. These

1
     See SkyTerra L.P., SEC Form 8-K (July 24, 2009), available at http://www.sec.gov/Archives/
     edgar/data/756502/000075650209000049/form8k.htm (last visited March 16, 2010) (delivery of the
     spacecraft is scheduled for the second quarter of 2010). Contemporaneously with the SEC filing,
     SkyTerra informally notified the Bureau that a waiver request would be forthcoming.

                                                     2
401367814v5


events were not within the control of SkyTerra, and together resulted in a delivery delay

that SkyTerra could not reasonably foresee.

        Based on the potential spacecraft delivery delay projected by Boeing in July 2009,

SkyTerra negotiated with its launch vehicle provider, International Launch Services, Inc.

(“ILS”), to reschedule the launch of SkyTerra 1 on the launch manifest for a launch

window of August to October 2010. At the time, this launch window was the earliest

reasonable period, consistent with launch vehicle availability, providing some minor

schedule margin in the event of further unanticipated delays.

        B.        The Construction and Delivery of the Satellite is Nearly Complete

        All components and subsystems have been completed and integrated on the

SkyTerra 1 satellite. Accordingly, construction of the main body of SkyTerra 1 is 100%

complete and the satellite is in Final Integrated System Test (“FIST”). Attached are

several photographs of the completed spacecraft body. See Attachment A.

        SkyTerra 1 has successfully completed the following major test milestones, and

there are no significant outstanding technical issues at this time:

              •   Spacecraft-level Thermal Vacuum Testing;

              •   Spacecraft-level Mechanical Environmental Testing;

              •   Spacecraft compatibility testing with the Ground Based Beam Forming

                  (“GBBF”) Network;

              •   Spacecraft compatibility testing with the Spacecraft Control System;

              •   L-Band Reflector Pre- and Post-Environmental Deployment Testing; and

              •   Final Reflector Tests.

          The remaining major milestones for the program include:



                                               3
401367814v5


              •   Final L-Band Reflector Stowage and shipment to Boeing; and

              •   Final Integrated System Testing.

          Boeing’s projected ready-for-shipment date is May 2010. SkyTerra has paid 90%

of the contract price for the satellite, and the contract is in full force and effect. Attached

is a letter from Boeing verifying the progress of the satellite construction and testing and

the status of the manufacturing contract. See Attachment B.

          ILS has agreed to a launch window of August to October 2010. SkyTerra has

paid ILS 100% of the price of the launch services contract, and the contract is in full

force and effect. Attached is a letter from ILS verifying the launch window and the status

of the launch contract. See Attachment C.

          SkyTerra has also made significant progress with other elements of its next-

generation system, further evincing its commitment to deploy the satellite system. In

September 2008, SkyTerra and Qualcomm signed an agreement pursuant to which

Qualcomm will integrate SkyTerra’s satellite protocol into tens of millions of its chipsets

for a wide variety of next-generation user devices.2 More recently, SkyTerra signed

agreements with Hughes Network Systems, LLC and Infineon Technologies AG, a

leading semiconductor manufacturer, for the development of a software-defined radio

MSS/ATC chipset,3 and with Alcatel-Lucent, for development of ATC base station



2
    See SkyTerra Press Release, SkyTerra’s Mobile Satellite Ventures, ICO Global Communications, and
    Qualcomm Sign Groundbreaking Technology Agreement Enabling First-Ever Integration of Satellite
    Communications into Mass Market Cellular Handsets and Devices (September 22, 2008), available at
    http://www.skyterra.com/media/press-releases-view.cfm?id=187&yr=2008 (last visited February 9,
    2010).
3
    See SkyTerra Press Release, Infineon, SkyTerra and TerreStar Announce Agreement to Develop the
    World’s First Satellite-Cellular Mobile Platform Based on SDR Technology (April 1, 2009), available at
    http://www.skyterra.com/media/press-releases-view.cfm?id=204&yr=2009 (last visited February 9,
    2010); Hughes Press Release, (April 2, 2009), available at http://www.hughes.com/HUGHES/Doc/0/
    K9D9RKIS7134DA5A60IIO1O69C/04-02-09_Hughes_Announces_Agreement_

                                                     4
401367814v5


technology.4 Construction of the ground infrastructure (i.e. buildings, generators, UPS,

and HVAC) at the four gateway facilities for the satellite network is complete; all of the

radiofrequency equipment has been installed; and the GBBF equipment has been

installed for both SkyTerra 1 and SkyTerra 25 at the four gateway facilities (Cedar Hill,

Napa, Ottawa and Saskatoon).

          C.       FCC Precedent Supports Grant of the Milestone Extension

          The Commission imposes milestone deadlines for satellite system implementation

in order to ensure that licensees proceed with construction and launch of their satellites in

a timely manner and that valuable spectrum will not be held, to the exclusion of others,

by those who are unwilling or unable to proceed.6 Extensions may be granted when the

delay is due to unforeseeable circumstances beyond the applicant’s control, or when there

are unique and overriding public interest concerns that justify an extension.7

          Bureau precedent unambiguously supports grant of the milestone extension

requested here.8 For example, in New ICO Satellite Services G.P., the Bureau granted


    with_SkyTerra_and_TerreStar_to_Implement_GMR1-3G_Satellite_Air_Interface_on_Chipset
    _for_Wireless_Handsets.htm (last visited February 9, 2010).
4
    See SkyTerra Press Release, Alcatel-Lucent to Develop Satellite Base Station Sub-Systems for SkyTerra
    and TerreStar to Support 3G Satellite Communications (April 1, 2009), available at
    http://www.skyterra.com/media/press-releases-view.cfm?id=205&yr=2009 (last visited February 9,
    2010).
5
    The space segment of the next-generation system will also include SkyTerra 2, which is authorized by
    Industry Canada. SkyTerra does not in this application seek Commission authority to access SkyTerra 2.
6
    See, e.g., Amendment of the Commission’s Space Station Licensing Rules and Policies, First Report and
    Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd 10760, at ¶ 173 (2003); In the Matter
    of TerreStar Networks, Inc., 22 FCC Rcd 17698, at ¶ 6 (Int’l Bur. 2007).
7
    See 47 C.F.R. § 25.117(c); see also, In the Matter of TerreStar Networks, Inc., 22 FCC Rcd 17698, at ¶ 6
    (Int’l Bur. 2007); In the Matter of New ICO Satellite Services, G.P., 22 FCC Rcd 2229, at ¶ 14 (Int’l
    Bur. 2007).
8
    See, e.g., WB Holdings 1 LLC, 20 FCC Rcd 10846 (Int’l Bur. 2005) (12-month launch and operate
    milestone extension granted; construction of satellite complete except for final testing); Loral SpaceCom
    Corporation, DIP, 18 FCC Rcd 21851 (Int’l Bur. 2003) (15-month construction completion and 16-
    month launch milestone extensions granted; satellite construction was 80% complete and 60% funded;
    satellite incorporated technology used for the first time, resulting in difficult and numerous engineering
    challenges).

                                                       5
401367814v5


the licensee five-month construction completion and launch milestone extensions because

of technical problems identified by the satellite manufacturer regarding the satellite’s

capacitors, composite waveguides, and precision oscillators integral to its GBBF

technology.9 In doing so, the Bureau explained that the manufacturing problems were

circumstances beyond the licensee’s control and found significant the fact the licensee

had completed over 85% of the satellite construction and paid approximately 93% of its

total satellite contract price and 75% of its total launch costs.10

           In TerreStar Networks, Inc., the Bureau concluded that there were overriding

public interest considerations warranting a 10-month launch milestone extension. 11

According to the Bureau, the licensee had demonstrated a substantial and continuing

commitment to construction and system implementation.12 The licensee had completed

84% of the satellite construction and paid 97% of the satellite contract price and 70% of

the launch contract price. The Bureau also noted that grant of the extension would serve

the public interest because it would allow the licensee “that has demonstrated diligence

and commitment . . . to expeditiously complete implementation of a satellite system with

advanced capabilities for homeland security, rural connectivity, and other critical

communications purposes.”13




9
     In the Matter of New ICO Satellite Services, G.P., 22 FCC Rcd 2229 (Int’l Bur. 2007).
10
     Id.
11
     In the Matter of TerreStar Networks, Inc., 22 FCC Rcd 17698 (Int’l Bur. 2007). Technically, the
     applicant for the milestone extension in this case held a reservation of spectrum and was not an FCC
     “licensee.” This distinction, however, is not material to the milestone extension analysis, and for
     convenience and consistency, the applicant is simply referred to as a satellite licensee.
12
     Given the satellite construction progress, the Bureau concluded that it was not necessary to determine
     whether the alleged manufacturing difficulties were beyond the licensee’s control, as one party had
     challenged in that proceeding. Id. at ¶ 7.
13
     Id. at ¶ 10.

                                                       6
401367814v5


           In Intelsat LLC, the Bureau granted a six-month construction completion and an

eight-month launch milestone extension request.14 The satellite was the first of its kind

manufactured and tested by the spacecraft manufacturer, resulting in a number of

unanticipated technical problems and leading to the redesign, reworking, and retesting of

various components. The satellite was also 85% complete, and the licensee had provided

a concrete plan for completing construction and launching within several months.

           As explained above in Part I.A, the satellite program delay was beyond

SkyTerra’s control. Unanticipated manufacturing issues with the design and construction

of the state-of-the-art, 22-meter L-band reflector resulted in delay in the satellite

construction and the rescheduling of the launch window for the August to October 2010

period.

           SkyTerra has demonstrated a substantial and continuing commitment to satellite

construction and system implementation. The main body of the spacecraft is fully

constructed and the primary tasks remaining before launch are testing of the reflector and

the fully integrated system. SkyTerra has paid approximately 90% of the satellite

contract price. The spacecraft is scheduled for launch during the August to October 2010

window, and SkyTerra has paid approximately 100% of the launch contract price.

           Additionally, there are unique and overriding public interest reasons for granting

the milestone extension request. SkyTerra and Boeing have labored for over four years

to complete construction of a state-of-the-art next-generation MSS satellite, and soon it

will be ready for launch. Many of the benefits the new system has to offer, including




14
     Intelsat LLC, 19 FCC Rcd 5266 (Int’l Bur. 2004).

                                                        7
401367814v5


extending rural broadband access,15 providing reliable public safety communications,16

increasing wireless competition17 and spectrum efficiency,18 expanding United States

technology leadership and stimulating job creation,19 are fully consistent with key FCC


15
     See, e.g., Federal Communications Commission Strategic Plan for Fiscal Years 2009 to 2014, DOC-
     283196A1, at p. 5 (2008) (“2009-2014 Strategic Plan”) (“The commission shall continue to encourage
     and promote broadband development, deployment, and availability, particularly to those in rural, low-
     income, or underserved areas.”); In the Matter of a National Broadband Plan for Our Future, Notice of
     Inquiry, FCC 09-31, GN Docket 09-51, at ¶ 1 (2009) (“Broadband NOI”) (“[U]biquitous broadband can
     help to restore America’s economic well-being and open the doors of opportunity for more Americans,
     no matter who they are, where they live, or the particular circumstances of their lives.”). The
     deployment of broadband services to rural areas is also supported strongly by Congress and this
     Administration. See American Recovery and Reinvestment Act of 2009, Pub. L. No. 111-5, 123 Stat.
     115 (2009) (“The Recovery Act”) (establishing billions of dollars in loan and grant money to expand
     broadband deployment in rural areas); see also http://www.whitehouse.gov/issues/rural/ (“President
     Obama supports a comprehensive plan and substantial investments in the expansion of rural broadband
     so that all areas of the country have access to the tools for fair competition in a 21st century economy.”)
     (last visited March 1, 2010).
16
     See, e.g., 2009-2014 Strategic Plan, at p. 3 (“Communications during emergencies and crises must be
     available for public safety, health, defense, and emergency personnel, as well as all consumers in
     need.”); In the Matter of Service Rules for the 698-746, 747-762 and 777-792 MHz Bands, Second
     Report and Order, 22 FCC Rcd 15289, at ¶ 464 (2007) (imposing requirement for D block licensee to
     make available to public safety users at least one handset that includes an integrated satellite solution in
     order to bolster the availability, robustness, and survivability of public safety communications
     networks).
17
     See, e.g., 2009-2014 Strategic Plan, at p. 7 (“The Commission shall seek to establish a consistent and
     transparent regulatory framework across all communications platforms (e.g., wireline, wireless, satellite,
     cable) to encourage both intra-modal and inter-modal competition.”); In the Matter of Service Rules for
     the 698-746, 747-762 and 777-792 MHz Bands, Second Report and Order, 22 FCC Rcd 15289, at ¶¶
     290-91 (2007) (establishing package bidding for certain 700 MHz licenses in order “to facilitate the
     entry of a new nationwide competitor”); Promoting Efficient Use of Spectrum Through Elimination of
     Barriers to the Development of Secondary Markets, Report and Order, 18 FCC Rcd 20604 (2003)
     (establishing flexible policies regarding secondary markets for wireless spectrum in order to increase
     wireless competition and efficiency in spectrum use).
18
     See, e.g., 2009-2014 Strategic Plan, at p. 9 (“The Commission shall develop policies that promote
     efficient and effective use of spectrum.”); Unlicensed Operation in the TV Broadcast Bands, Second
     Report and Order, 23 FCC Rcd 16807, at ¶ 2 (2008) (“[A]llowing use of the TV white spaces by
     unlicensed devices will have significant benefits for both businesses and consumers and thereby promote
     more efficient and effective use of the TV spectrum.”); Promoting Efficient Use of Spectrum Through
     Elimination of Barriers to the Development of Secondary Markets, Report and Order, 18 FCC Rcd
     20604 (2003) (establishing flexible policies regarding secondary markets for wireless spectrum in order
     to increase wireless competition and efficiency in spectrum use).
19
     See, e.g., 2009-2014 Strategic Plan, at p. 5 (“The Commission shall encourage and facilitate an
     environment that stimulates investment and innovation in broadband technologies and services.”);
     Broadband NOI, at ¶ 9 (The Commission “must include a plan for use of broadband infrastructure and
     services in advancing a broad array of public interest goals, including … private sector investment,
     entrepreneurial activity, job creation and economic growth, and other national purposes.”); see also The
     Recovery Act, at Sec. 3 (“The purposes of this Act include . . . [t]o preserve and create jobs and promote
     economic recovery.”); see also “The Economic Impact and Associated Employment of SkyTerra’s
     Network Deployment,” Appendix D, File Nos. SES-MOD-20090429-00536, SAT-MOD-20090429-

                                                         8
401367814v5


and United States priorities. Accordingly, the Bureau should grant SkyTerra’s request for

extension of its launch and begin operation milestone.20

II.        Grant of the Request for Waiver of the Commission’s Requirement to
           Relieve Pressure Vessels at Satellite End-Of-Life is Warranted

           Section 25.283(c) specifies that satellites must discharge all stored energy sources

at end-of-life of the space station, including “by venting excess propellant, . . . relieving

pressure vessels, and other appropriate measures.” 47 C.F.R. § 25.283(c). As part of the

orbital debris mitigation statement submitted with its satellite application, SkyTerra had

stated that once SkyTerra 1 “reaches its final disposal orbit, all on-board sources of stored

energy will be removed by depleting all propellant tanks, venting all pressurized systems,

discharging batteries, and turning off all active units.”21 However, SkyTerra 1 is a

Boeing Model 702 satellite, which is not designed to allow for the discharge of all

pressurant upon satellite end-of-life. Rather, consistent with Boeing’s practice with

respect to a number of its spacecraft buses, the helium tanks are isolated at the end of

transfer orbit and the amount of the remaining gas and the low pressurization in the tanks

result in minimal potential for accidental explosions during and after completion of




     00047, SAT-MOD-20090429-00046 (April 29, 2009) (indicating that SkyTerra’s next-generation system
     will have an important positive impact on the creation of high-paying American jobs).
20
     In the event that the Commission finds that SkyTerra has not satisfied the standard for a milestone
     extension, SkyTerra requests partial waiver of the launch and begin operations milestone requirement to
     permit the requested additional time to comply with the requirement. 47 C.F.R. § 1.3 (Commission may
     waive its rules for good cause); see also WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969), cert.
     denied, 409 U.S. 1027 (1972); Northeast Cellular Telephone Co., LP v. FCC, 897 F.2d 1164 (D.C. Cir.
     1990). As explained above, the evidence of substantial construction demonstrates good cause for a
     waiver in this case. SkyTerra could neither foresee nor control the cause of the construction delay, and a
     waiver would not undermine the purpose of the milestone requirements, to deter spectrum warehousing.
     See, e.g., Echostar Satellite Corp., 18 FCC Rcd 15875, at ¶ 9 (Int’l Bur. 2003); Astrolink International
     LLC, 17 FCC Rcd 11267, at ¶ 6 (Int’l Bur. 2002).
21
     See Application, File No. SAT-MOD-20070117-00012, at pp. 47-48 (filed January 17, 2007) (“2007
     SkyTerra Application”).

                                                        9
401367814v5


mission. Accordingly, SkyTerra modifies its orbital debris mitigation statement and

requests waiver of the Commission’s rule.22

         The statement regarding minimizing accidental explosions is revised as follows:23

         MSVSkyTerra has assessed and will limit the probability of accidental
         explosions during and after completion of mission operations. The MSV-
         1 SkyTerra 1 satellite is designed to minimize the potential for accidental
         explosions through propellant leakage and fuel and oxidizer mixing or
         other means. Propellant tanks and thrusters are isolated using redundant
         values, and electrical power systems are shielded in accordance with
         standard industry practices. During the mission, batteries and various
         critical areas of the propulsion subsystem will be monitored to avoid
         conditions that could result in explosion. After MSV-1 SkyTerra 1
         reaches its final disposal orbit, all on-board sources of stored energy will
         be removed, with the exception of the pressurized vessels discussed
         below, by depleting all propellant tanks, venting all pressurized systems,
         discharging batteries, and turning off all active units. SkyTerra 1 uses a
         Boeing 702 spacecraft bus that has a liquid propulsion system design that
         includes two helium (pressurant) tanks plus two pairs of fuel and oxidizer
         tanks. Venting of the excess propellant in the fuel and oxidizer tanks is
         performed as part of the end-of-life shutdown operations. The helium
         tanks provide proper propellant tank pressurization for apogee engine
         firings during transfer orbit. Both helium tanks are isolated at the end of
         transfer orbit by firing pyrotechnic valves, and there is no venting
         provision for these helium tanks at the satellite end-of-life. SkyTerra has
         estimated that approximately 507 grams of Helium will be sealed in each
         tank when they are isolated resulting in a final pressure of 662 psi, which
         is extremely low relative to the design burst pressure of 5,249 psi. Due to
         the low blanket pressure in the Helium tanks at the satellite end-of-life, an
         explosive event is unlikely, even in the event of a tank rupture (e.g. a
         meteorite strike). Accordingly, the satellite design results in minimal
         potential for the release of orbital debris.

         Under Section 1.3 of the Commission’s rules, 47 C.F.R. § 1.3, the Commission

has authority to waive its rules for good cause. Good cause exits if “special

circumstances warrant a deviation from the general rule and such deviation will serve the


22
   The Bureau recently concluded that the orbital debris mitigation practice used for the Boeing 702 bus
   does not comply with the FCC’s orbital debris mitigation requirements regarding venting of excess
   propellant. See Stamp Grant, File No. SAT-LOA-20090807-00085 (dated December 15, 2009).
23
   See Section Z.2 of the 2007 SkyTerra Application. The modified text is emphasized using standard
   blackline edits.

                                                    10
401367814v5


public interest.”24 In determining whether a waiver is appropriate, the Commission

should “take into account considerations of hardship, equity, or more effective

implementation of overall policy.”25

           Waiver is appropriate in this case because grant would not undermine the purpose

of the rule, to reduce the risk of accidental explosion. The amount of the remaining gas

in the helium tanks and the low blanket pressure in those tanks at the satellite end-of-life

result in minimal potential for accidental explosions during and after completion of

mission, consistent with the FCC’s rules. Indeed, the Boeing 702 spacecraft bus (and

other spacecraft buses with similar designs)26 has been in commercial service for more

than 10 years without incidents involving accidental explosions. Grant of the waiver is

also supported on hardship grounds. Construction of the SkyTerra 1 satellite is nearly

complete and launch is imminent.27 Accordingly, any design change cannot be

accomplished at this time without extraordinary cost and without jeopardizing the

satellite’s projected launch date and ITU priority. Under similar circumstances, the

Bureau has held that waivers are warranted, and consistent with that precedent, it should

grant SkyTerra’s request for waiver of the venting requirement.28



24
     Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
25
     WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972).
26
     See infra note 28.
27
     See supra Part I.B.
28
     See Stamp Grant, File No. SAT-LOA-20090807-00085 (granted December 15, 2009) (granting waiver
     of venting requirement for DIRECTV 12/RB2-A, a Boeing 702 satellite, given its imminent launch); see
     also Stamp Grant, File No. SAT-LOA-20071221-00183 (granted March 12, 2008) (granting a waiver of
     venting requirement for AMC-14, a Lockheed A2100 satellite, in light of late stage of satellite
     construction); Stamp Grant, File Nos. SAT-MOD-20070628-00090, SAT-AMD-20070731-00108
     (granted November 30, 2007) (granting waiver of venting requirement for Horizons 2, an Orbital
     Sciences Star satellite, in light of late stage of satellite construction); Stamp Grant, File Nos. SAT-MOD-
     20070207-00027, SAT-AMD-20070716-00102 (granted October 4, 2007) (granting waiver of venting
     requirement for INTELSAT-11, an Orbital Sciences Star-2 satellite, in light of late stage of satellite
     construction).

                                                       11
401367814v5


                                 Technical Certification

        I, Jeff Snyder, Vice President of Satellite Engineering for SkyTerra Subsidiary

LLC, certify under penalty of perjury that:

        I am the technically qualified person with overall responsibility for preparation of

the technical information contained in this application. I am familiar with the

requirements of Part 25 of the Commission’s rules, and the information contained in the

application is true and correct to the best of my knowledge and belief.

                                                      /s/
                                               Jeff Snyder

Dated: April 5, 2010




                                              12
401367814v5


            Attachment A

Photographs of the SkyTerra 1 Satellite


Diagram 1 – Fully Assembled Satellite. The stowed solar arrays are on the right, and

the stowed L-band reflector is the cylindrical spindle just right of the flag. The Ku-band

reflector is the dish located at the bottom part of the satellite.


Diagram 2 –L-Band Reflector. The L-band reflector is fully deployed in a face-down

configuration at the vendor’s site.


  Attachment B

Letter from Boeing


          23 March 2010

          Reference: 10(19)94403

          SkyTerra LP
          10802 Parkridge Boulevard
          Reston, VA 20191
          Aftention: Michael Cannice
          Subject: Contract MSV—ATC—01

AHHEING   Dear Mr. Cannice:

          As you are aware, Bosing has completed 100% of the construction of the main body
          of SkyTerra 1. The testing of the fully integrated spacecraft is nearly complete
          Specifically, Bosing has successfully completed the following major test milestones
                    * Spacceraft—level Thermal Vacuum Testing:
                    * Spacecraft—level Mechanical Environmental Testing;
                    * Spacecraft compatibility testing with the Ground Based BeamForming
                        (°GBBF*) Networks
                    * Spacecraft compatibility testing with the Spacecraft Control S
                    * L—Band Reflector Pre— and Post«Environmental Deployment Testing: and
                    * Final Reflector Tests.
          The remaining major milestones for the programinclude:
                    * Final L—Band Reflector Stowage and shipment to Bocing; and
                    * Final Integrated SystemTesting
          We have received all of the payments due under the contract, ttaling approximately
          90% ofthe contract price for the satellite, andthe contract is in full forceand effect
          Throughout the course of the satellite build, as we encountered schedule challenges,
          we have worked in conjunction with your teamto manage those challenges so as to
          mitigate any schedule impact. However, as youare aware, in July 2009, we projected
          a potential delay in satellite construction, due to factors beyond the direct control of
          Bocing andSkyTerra, which would result in the delivery of the SkyTerra 1 spacecraft
          in the second quarter of 2010.
          We currentlyestimate the deliverydate for the SkyTerra 1 spacecraft to be May2010,
          and we are committed fully to meeting that deliverydate. We will keep youapprised
          of any changes, and any other issues, as we complete the integration and testing of
          the spacecraft.
          Sincerely,

          Dennis R. Beeson
          Contract Manager


Attachment C

Letter from ILS





Document Created: 2010-04-05 11:11:15
Document Modified: 2010-04-05 11:11:15

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