Attachment 1990Request for Waiv

1990Request for Waiv

REQUEST submitted by STARSYS

Request for Waiver

1990-05-04

This document pretains to SAT-MSC-19900504-00019 for Miscellaneous on a Satellite Space Stations filing.

IBFS_SATMSC1990050400019_1059895

                                 BEFORE THE

   Federal Communications Commission
                           WASHINGTON, D.C. 20554




                                                                                  199U

In the Matter of the Application of




                                                 No N N N N N NP
STARSYS, INC.                                                      File No. 36b—DSS—MI5C—IO
For Authority to
Construct a Low Earth Orbit Mobile
Satellite System


                           REQUEST FOR WAIVER OF                            4
               SsECTION 319(d) OF THE COMMUNICATIONS ACT


            STARSYS,   Inc.    ("STARSYS"),   by its attorneys and

pursuant to Section 319(8)         of the Communications Act of 1934,

as amended,    47 U.S.C.      § 319(8),   hereby requests a waiver of the

requirement that STARSYS obtain a construction permit before it

commences construction of its proposed "STARNET"                       low earth

orbit mobile satellite system.            Concurrently with this waiver

request,    STARSYS is also filing an application for authority to

construct    its   proposed STARNET system.           Pending         the

Commission‘s decision with respect to the application,                          STARSYS

is willing and prepared to assume the risk involved in

commencing the construction process.            In support of this waiver

request,    the following is shown.

            By allowing STARSYS immediately to begin design,

pre—construction,      and limited construction of its STARNET

system,    a Section 319(8) waiver would permit it more


expeditiously to provide the American public with a wide array

of beneficial services,   including the following:


         e     two—way messaging from ultra—low—cost
              calculator—size terminals;

         e    position determination anywhere in the
              worlda ;

         e    emergency alert services,   for safety of
              life or property;

         e    environmental monitoring services,   to
              reduce pollution;

         e    mobile property management services,      for
              anti—theft purposes;

         e    automatic vehicle pollutant emission
              level monitoring;

         e    electronic license plate functions for
              intelligent vehicle—highway systems; and

         e    biosensor monitoring for telemedicine
              applications .


         STARSYS and its affiliates have more experience than

any other entity in the world in designing,     constructing,        and

operating low earth orbit mobile satellite payloads.          Now,

STARSYS is prepared to bring these services to the public

through a spectrally—efficient commercial low earth orbit

satellite system that capitalizes both on the experience of

STARSYS‘s affiliates and on advances in the state of

technology.   A waiver of the Section 319(8)   construction permit

requirement will enable STARSYS to commence system construction

at its own risk,   and thereby advance the date when the STARNET


system enters into service.   As such,   the public interest will

be well served by the grant of this request.

           Therefore, for the reasons stated above, STARSYS

should be granted a waiver pursuant to Section 319(8)        of the

Communications Act.


                                 Respectfully submitted,

                                 STARSYS,   INC.



                                 By:
                                       Raul R. Rodriguez
                                       Stephen D. Baruch
                                       Marc G. Corrado

                                       Leventhal,    Senter & Lerman
                                       2000 K Street,     N.W.
                                       Suite 600
                                       Washington,   D.C.    20006—1809
                                       (202)   429—8970          '

May 4,   1990                    Its Attorneys .



Document Created: 2014-09-02 15:46:23
Document Modified: 2014-09-02 15:46:23

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