Attachment letter

letter

LETTER submitted by MSV

letter

2005-12-02

This document pretains to SAT-PPL-20050926-00184 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2005092600184_472357

MSV DUPLICATE Mobile Satelite Ventures uo December 1, 2005 RECEIVED Via Hand Delivery and Electronic Filing Ms. Marlene H. Dortch, Secretary DEC ~ 2. 2005 Federal Communications Commission e 445 12th Street, S.W. en ooooreeneGonnisen Washington, D.C. 20554 Re: File No. SAT—PPL—20050926—00184 1B Docket No. 05—220 1B Docket No. 05—221 Dear Ms. Dortch: Mobile Satellite Ventures Subsidiary LLC (*MSV") hereby responds to Inmarsat‘s most recent letter in the above—referenced docket claiming that the L band is not suitable for broadband services." As MSV has demonstrated previously, and Inmarsat again fails to rebut, Inmarsat‘s true motivation for criticizing the utlity ofthe L band seems to be based on the realization that its new L band stelliteslack the power to provide acceptable service to small handheld user equipment. This issue prevents Inmarsat from developing and deploying a commercially viable hybrid satellt/terrestril network. Inmarsat‘s November 16th letter never even claims, let alone demonstrates, that it will be able to provide such "transparency class" service to handheld terminals. Inmarsat‘s etter also fails to explain why its selfstyled "application" for a 2 GHz system shows satellites with five times the power of ts new L band satelltes, eaving unchallenged MSV‘s assertion that this is further evidence that Inmarsat recognizes tsL band satelltes are essentially useless for hybrid service. Inmarsat also fails to respond to MSV‘s showing that Inmarsat‘s L band operations are spectrum inefficient and that Inmarsatistrying to rely on this spectrum inefficiency as an exeuse to forestall competition in the L band. While Inmarsat claims that the new satellites are an order ofmagnitude more spectrum efficient that ts previous spacecraf, this ignores the gap that remains between Inmarsat‘s new satellites and state of the art satellites such as MSV—1..Inmarsat also omits thatit has no plans toretire its old spacecraft or to aggressively reduce the inefficient global beam traffic that dominates its spectrum requirements. Moreover, Inmarsat makes the misleading claim that its new satellie is spectrum efficient because it has the capacity to operate with 200 narrow spot beams (nmarsat Nov. 16 Letter at 8); in fact, the new satellite puts only 12 ‘ See Letter from John Janka, Counsel for Inmarsat, to Ms. Marlene H. Dortch, FCC, File No. SAT—PPL—20050926—00184, IB Docket No. 05—220, IB Docket No. 05—221 (November 16, 2005) (‘Imarsat Nov. 16 Leter®\.

Ms. Marlene H. Dortch Deceber 1, 200 Page2 spot beams over the United States and constal waters, at a look angle that i lkely tosignificantly reduce their ability tdeliver maximum power to these areas. See Exhibit 1In contrast, MSV‘s new, much higher—power satelites each will have roughly 280 spot beams over the United States and coastal waters,at a look angle that will pernit delivery ofmaximum power. See Exhibit2." As a result, forthe same amount of spectrum and providing the same services, MSV using its next—peneration satelltes will be sble to deliver atleast 20—30 times more satellte capscityto United States customers then Inmarsat using its new satellite Finally, famersat blames MSV for unresolved intemational coordination issues in the L band (Imarsat Nov. 16 Letter 19). Inmassat‘s argumentignores the many efforts MSV has initlated over recent years and months to negotiate a new coordination agreement with Inmarsat, even in the face ofInnorsat‘s fallure to sbide by earlier agreements by refusing to eturm spectrum that MSV loaned to t on temporary basis, The record ofthose negotiations speaks for ielfand demonstratesthat MSV, not Inmersat, has taken good fith steps to reach a coordination agreement that optimizes the use of the L band to offer advanced wireless cormunications services. Very trily yours, Randy S. S Senior Vice President, General Counsel, and Secretary MopiLe SATELLITE vENTUREs SUBSIDIARY LLC 10802 Parkeidge Boulevard Reston, Virginia 20191 * Exhibit 1 is excerpted from a recent application to use Inmrsat 4F2 to provide BGAN service in t United States, See Stzatos Communications, Inc., Application for Title 1II Blanket License, File No. SES—LFS—20050826—01175 (August 26, 2005), Attachment A at 6 (Figure A.3— 1. * Exhibit 2 is an illustrtive depiction ofthe spot bear coverage area ofMSV‘s next—generation sutelites. While this Exhibit does not demonstrate actual beam deformation, it is an sceurate representation ofthe number of beams each next—generation setelite will have over the service area ofthe United States.

Ms. Marlene H. Dortch December 1, 2005 Page 3 ce Chairman Kevin J. Martin Commissioner Kathleen Q. Abernathy Commissioner Michael J. Copps Commissioner Jonathan S. Adelstein Fred Campbell Emily Willeford John Branscome John Giust Barry Ohlson Donald Abelson Gardner Foster Anna Gomez Karl Kensinger Roderick Porter Steve Spacth Cassandra Thomes

Exhibit 1

Figure A3—1 — BGAN L—band service link spot beams covering U.S.territry In addition to the service link beams, the BGAN User Terminals will also receive signaling communications in the L—Band via the global beam or the regional beams for the purpose of registering and unregistering communieation sessions over the service link spot beams, ‘The regional beams covering the U.S. teritories in the satelte‘s coverage area are depicted in Figure A3—2 below. The regional beam locations are nominally identical for both the uplink and downlink directions.

Exhibit 2

Proposed Next—Generation L Band Coverage wikn row


Document Created: 2005-12-12 17:37:25
Document Modified: 2005-12-12 17:37:25
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