Attachment application.pdf

This document pretains to SAT-STA-19980128-00010 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA1998012800010_1163947

hx SaafLCEl1 _( REAC:INSTRUCTIONS CAREFULLY | arcimemcome j BEFORE PROCEEDING CATIONS COHMISSION REANCE ADVICE ppe (1) 10cKBOX # fo Box 355 1} S’ raseNo.______ or _____ 4) STREET ADORESS LNE NG. 1 6560 Rock Spring Drive . g/ D 5) STREET ADDRESS LNE No. 2 x 7) sTare (a) cooe Bethesda Maryland l—;0817 (3) DAYTME TELEPHONE NUMBER (include area code} _ (10) COUNTRY CODE (if not in U.SA.} 3of 21Y¢ 33J5 IF PAYER NAME AND THE APPLICANT ~U’tME ARE DIFFERENT, COMPLETE SECTION B . IF MORE THANONE APPLICANT, USE CONTINUATION SHEETS(FORM159.—C)> . > 11) APP NAME(H paying by credit card, enter name exactly as it sppears on your card) 12) STREET ADDRESS LINE NO. 1 kfl) STREET ADDRESS LINE NO. 2 14) ony is stare ~ fie) ar cooe 'fifl DAYTWE TELEPHONE NUMBER (Include area code) (18) COUNTRY CODE (if not in U.S.A.) COMPLETE SECTION C FOR EACH SERVICE, IF MORE BOXES ARE NEEDED, USE CONTINUATION SHEETS (FORM 159~C) f[Zia)Fee i [ZaA) rcc cone 2 I | WWW (Zia) auaniy ~f228) ree bue on (PTC) w sL.ooK zo8 Cav [738)Fec cooe i [248) rcc cone 2 WW avarm rec . [_ [ | f[zic) rcc cooe 2 sIeroTHeR |(200) PAYNENT TYPE coOé (PTC) [zD) ouammty ~((220) FEE DUE FoR (PTC) N BLOCK 200 USE orat fmo)rec i [ | _| s 340) Foc cooe 2 CCE L PA_MMA Name a e esmm —am wree m mm re ie is

@MSAT Mobile Communications ORIGINAL Robert A.Mansbach 6560 Rock Spring Drive Bethesda, MD 20817 Telephone 301 214 9459 Fax 801 214 7145 Telex 197800 Internat robert.mansbach@comsat.com January 27, 1998 Ms. Magalie Salas, Secretary Federal Communications Commission 1919 M Street, N.W., Room 222 Washington, D.C. 20554 ATTN: Thomas S. Tycz, Chief, Satellite and Radio Communication Division Re: Request for Special Temporary Authority, pursuant to Section 214 of the Communications Act of 1934, as amended, to provide Mini—M services via the Inmarsat System in the U.S. and points beyond. Dear Ms. Salas: COMSAT Corporation, through its COMSAT Mobile Communications business unit ("COMSAT"), herein requests a grant of Special Temporary Authority pursuant to Section 214 of the Communications Act of 1934, as amended, from February 15, 1998 through August 14, 1998 to provide Inmarsat Mini—M service in the United States and beyond to certain customers in conjunction with Inmarsat land earth stations at Southbury, Connecticut and Santa Paula, California. In support of this request, COMSAT submits as follows: COMSAT has received an urgent request for service from Disaster Medical Assistance Corporation ("Disaster Assistance") which plans to incorporate a PLANET 1 terminal in disaster and medical assistance packages which it assembles for use by municipalities‘ emergency response teams in safety of life situations. PLANET 1 is the only satellite communications service that can meet the requirements of Disaster Assistance for domestic and international satellite links providing reliable, portable communications and 24—hour customer support during a time of natural disaster or other emergency. The Disaster Assistance packages, including a PLANET 1 terminal, will be placed in the custody of state and local authorities and maintained in a constant state of readiness, enabling instant access to survivable communications, in the event of a natural disaster or other emergency.

Disaster Assistance‘s packages have been designed in response to community action programs developed by a number of municipalities to rapidly coordinate search, rescue and relief efforts in safety of life situations. Since cellular and other terrestrial facilities may be rendered useless by disasters, Disaster Assistance has decided to incorporate satellite communications equipment in their disaster relief packages. They have chosen the Planet 1 terminal for these packages due to its small size and weight, in recognition of the fact that portability may be critical in a disaster or emergency situation. The use of PLANET 1 terminals will also reduce the cost of having to train disaster coordinating personnel in the use of multiple communications equipment, a cost efficiency which is key to local municipalities operating under budgetary constraints. Disaster Assistance has assured COMSAT that each state and local authority receiving a package including a PLANET 1 terminal will be instructed to apply to the Commission for a license to operate the PLANET 1 terminal(s) in its custody. COMSAT will provide space segment to enable the use of the PLANET 1 terminals used for disaster recovery in accordance with COMSAT Mobile Communications Tariff F.C.C. No. 1. COMSAT has developed its PLANET 1 terminal, a notebook—sized Mini—M terminal which provides digital communications via Inmarsat—3 satellites, in response to consumer demand and marketplace forces. The PLANET 1 terminal has won a "Best of What‘s New" popular Science award as one of the best new products of 1996 and a 1997 "Users Choice Award" from Communications News Magazine, which is presented annually to the company whose product attained the most positive response from the magazine‘s readership of telecommunications and data networking managers. In its recent Report and Order in the "DISCO—II" rulemaking proceeding, the Commission discussed the provision of Inmarsat services domestically by COMSAT.‘ The Commission stated that it would require COMSAT "to make an appropriate waiver of immunity from suit" before COMSAT would be allowed to provide domestic U.S. service via INTELSAT and Inmarsat, and also to show that such entry would promote competition and otherwise be in the public interest." These conditions were imposed by the * In re Amendment of the Commission‘s Reqgulatory Policies to Allow Non—U.S. Licensed Space Stations to Provide Domestic and International Satellite Service in the United States, IB Docket No. 96—111, FCC 97—399 (released Nov. 26, 1997), at TT 108—128 ("DISCO II Order") . ° DISCO II Order at C 126. S:\users\legaffidisasterasst.doc

Commission "[blecause of concern over potential harm to the U.S. market for satellite services . . . ."" COMSAT believes that, with regard to provision of service to Disaster Medical, there is ample cause for the Commission to waive the policy enunciated in the DISCO II Order and permit COMSAT to provide the service in the United States without requiring COMSAT to waive its "brivileges and immunities." The D.C. Circuit Court of Appeals has held that waiver of a particular policy is appropriate where special circumstances warrant a deviation from the general rule and such deviation would better serve the public interest than would strict adherence to the general rule." The urgent need for this communications capacity to support vital safety of life requirements clearly warrants a deviation from the general policy considerations in the DISCO II Order and a grant of Special Temporary Authority, as requested herein, in furtherance of the public interest. Respectfully submitted, COMSAT Corporation COMSAT Mobile Communications By Robert A. Mansbach Its Attorney cco:— James Ball Steve Sharkey ° DISCO II Order at T 125. i COMSAT notes that it has filed a Petition for Review of the DISCO II Order in the U.S. Court of Appeals for the D.C. Circuit. Although filing this application, COMSAT fully reserves all rights in connection with such appeal. ° Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990); see also WAIT Radio v. FPCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969), cert. denied, 409 U.S. 1027 (1972) . S:\users\legaff\disasterasst.doc

CERTIFICATION I hereby certify that COMSAT Corporation is not subject to a denial of Federal Benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988, 21 U.S.C. Section 853a. RSbert A. Mansbach COMSAT Corporation 6560 Rock Spring Drive Bethesda, Maryland 20817


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Document Modified: 2017-01-10 18:53:11
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