Attachment Narrative

This document pretains to SAT-PPL-20160111-00001 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2016011100001_1121030

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of INMARSAT PLC IBFS File No. ______________________ Request to Modify the ISAT List to Reflect the Replacement of the Inmarsat-3 F4 Satellite by the Inmarsat-3 F5 Satellite at the 54º W.L. Orbital Location PETITION FOR DECLARATORY RULING Inmarsat plc (“Inmarsat”) hereby requests, pursuant to the Commission’s ISAT List Order1 and Section 25.137 of the Commission’s rules, that the Commission modify the “ISAT List” to reflect the replacement of the Inmarsat-3 F4 satellite (the “I3F4” satellite) with the Inmarsat-3 F5 satellite (the “I3F5” satellite) at 54 W.L. The I3F4 satellite was added to the ISAT List at this location in 2009,2 and has been operating there for over six years without incident. The I3F4 and I3F5 satellites were the last two of a series of third-generation Inmarsat satellites built by Lockheed Martin and Matra Marconi Space, and thus have virtually identical designs. Accordingly, the new satellite will operate with the same parameters, and provide the same types of “existing and evolved” Inmarsat services, as the one it is replacing.3 I3F5 recently 1 See Inmarsat, Inc. Request to Streamline Licensing of L-Band Mobile-Satellite Service Terminals Using Inmarsat Satellites as Points of Communication, 23 FCC Rcd. 15268 (Int’l Bur. 2008) (“ISAT List Order”). 2 See Grant Stamp, IBFS File Nos. SAT-PPL-20090107-00003 and SAT-APL-20090115-00005 (Apr. 6, 2009) (“I3F4 ISAT List Authorization”). 3 The I3F4 satellite will be moved slightly to a storage orbit at 45.3º pending deorbit later this year. 1

began the process of relocating from the 24.6º E.L. orbital location, and can be expected to arrive at its new location in mid-February 2016. For the reasons set forth herein, this change to the ISAT list will serve the public interest and should be implemented expeditiously. I. BACKGROUND In October 2008, the Commission adopted an order establishing a list of Inmarsat satellites approved to serve the United States in using L-band frequencies (the “ISAT List”), which includes those Inmarsat satellites that have been found to meet the Commission’s legal, technical, and policy requirements for access to the U.S. market.4 The ISAT List allows earth station licensees and applicants to seek authority to communicate in the L-band with satellites listed on the ISAT List, rather than having to seek authorization to communicate with Inmarsat satellites on a satellite-by-satellite and orbital-location-by-orbital-location basis.5 The Commission also provided that new and relocated Inmarsat satellites could be added to the ISAT List through a petition for declaratory ruling, such as this one, demonstrating that the proposed operations satisfy the Commission’s legal, technical, and policy requirements.6 II. SECTION 25.137(f) INFORMATION The Commission previously granted market access for the I3F4 satellite at the nominal 54º W.L. orbital location.7 In that context, information necessary to satisfy the requirements of Section 25.137 of the Commission’s rules, which sets for the required contents of a request for 4 See ISAT List Order, ¶ 1. The I3F4 and I3F5 satellites are licensed by the United Kingdom. 5 Id. 6 Id., ¶ 8. 7 See I3F4 ISAT List Authorization, supra. 2

market access, was provided.8 Consistent with Section 25.137(f), Inmarsat includes as Appendix A hereto (in addition to the information provided on the accompanying FCC Form 312) a technical description of the I3F5 satellite that reflects the operating parameters of the spacecraft at 54º W.L.9 That technical description is virtually identical to the one provided in connection with the market access application filed for the I3F4 satellite,10 with two non-material exceptions: (1) slight variances in the launch mass, satellite dry mass, and mass of AKM expendables set forth in Section A.16-2; and (2) the amount of fuel being allocated and reserved for the final orbit raising maneuvers (5.4 kg for I3F5 compared to 3.5 kg for I3F4) set forth in Section A.19. III. GRANT OF INMARSAT’S REQUEST WILL SERVE THE PUBLIC INTEREST Grant of the requested modification of the ISAT List to reflect the replacement of the I3F4 satellite by the I3F5 satellite at 54º W.L. would serve the public interest. The Commission has already granted market access to one 3-series Inmarsat satellite at this location, and Inmarsat proposes to replace it with by another satellite of nearly identical design that will operate with the same parameters as are currently authorized. Inmarsat will operate I3F5 under the same conditions applied to the current I3F4 ISAT List Authorization. The public interest findings underlying the prior grant of market access remain fully applicable with respect to Inmarsat’s 8 Inmarsat does not currently have any pending or granted spectrum reservation requests for unlaunched spacecraft to which the limits of Section 25.137(d)(5) of the Commission’s rules apply. See 47 C.F.R. § 25.137(d)(5). 9 Inmarsat also hereby incorporates by reference the Schedule S information provided in connection with its application to place I3F4 on the ISAT List. The relevant applications can be found in IBFS File Nos. SES-MFS-20071011-01413, SAT-PPL-20090107-00003, and SAT-APL-20090115-00005. 10 See IBFS File No. SAT-APL-20090115-00005, Appendix A (Technical Description). 3

ongoing operations at this orbital location. Continuing market access using the I3F5 satellite would enable Inmarsat to ensure uninterrupted provision of services to, from, and within the United States as Inmarsat reconfigures its in-orbit fleet. Further, the requested modification of the ISAT List to reflect the replacement of the I3F4 satellite is consistent with the Commission’s conclusion that the ISAT List “will serve the public interest by eliminating duplicative and repetitive filings and by facilitating the more rapid deployment of satellite services to U.S. consumers.”11 CONCLUSION For the foregoing reasons, Inmarsat respectfully requests that the Commission modify the ISAT List to reflect the replacement of the I3F4 satellite by the I3F5 satellite at the 54º W.L. orbital location. Respectfully submitted, __/s/______________________________ Donna Bethea-Murphy William M. Wiltshire Senior Vice President of HARRIS, WILTSHIRE & GRANNIS LLP Global Regulatory 1919 M Street, N.W. INMARSAT PLC The Eighth Floor 1101 Connecticut Avenue, N.W. Washington, DC 20036 Suite 1200 (202) 730-1300 Washington, DC 20036 Counsel for Inmarsat plc 11 ISAT List Order, ¶ 1. 4


Document Created: 2019-04-08 12:39:48
Document Modified: 2019-04-08 12:39:48
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