Attachment Request

This document pretains to SAT-STA-20110106-00003 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011010600003_859924

                           DrinkerBiddle&Reath                                                   Joe D. Edge
                                                                                                 Partner
                                                                                                 202—842—8809 Direct
                                                                                                 202—842—8465 Fax
                                                                                                 joe.edge@dbr.com

          Law Offices

    1500 K Street, N.W.
                                                                    January 6, 2011
      Washington, DC
            20005—1209

   202—842—8800 phone       VIA IBFS
      202—842—8465 fax
www.drinkerbiddle.com
                            Ms. Mindel De La Torre
             CALIFORNIA     Chief, International, Bureau
              DELAWARE

                ILLINOIS
                            Ms. Ruth Milkman
             NEW JERSEY
                            Chief, Wireless Telecommunications Bureau
              NEWYORK

          PENNSYLVANIA

         WASHINGTON DC
                            Mr. Julius Knapp
             WISCONSIN      Chief, Office of Engineering and Technology

                            Federal Communications Commission
                            445 Twelfth Street, S.W.
                            Washington, DC 20554

                                      Re:      Open Range Communications Inc.
                                               Request for Extension of Special Temporary Authority
                                               SAT—STA—20100625—00147


                            Dear Ms. De La Torre, Ms. Milkman, and Mr. Knapp:

                            Open Range Communications Inc. ("Open Range") hereby respectfully requests
                            extension of its existing Special Temporary Authority ("STA") for a period of 60 days
                            commencing February 1, 2011 to continue operating on the Globalstar spectrum (2483.5
                            to 2495 mHz) in accordance with the terms ofits existing authority to permit time for the
                            Bureaus to act on Open Range‘s request for a 180 day extension of its existing authority.
                            The facts and circumstances justifying the extension are set forth in Open Range‘s 180
                            day extension request. In summary, on September 14, 2010 the Commission denied
                            Globalstar‘s request for extension of the ATC gating criteria compliance dates, but
                            granted Open Range Special Temporary Authority to continue its operations on the
                            Globalstar ATC spectrum for a limited period.‘ The Bureaus, in the Open Range ST4

                            ‘ Globalstar Licensee LLC, Application for Modification ofLicense to Extend Dates for Coming Into
                            Compliance with Ancillary Terrestrial Component Rules, File No. SAT—MOD—20091214—00152 and Open
                            Range Requestfor Special Temporary Authority, File No. SAT—STA—20100625—00147, Order (DA 10—
                            1740)(IB, WTB, OET)(REL. September 14, 2010); Order on Reconsideration, Open Range Requestfor
                            Special Temporary Authority, File No. SAT—STA—20100625—00147, Released September 23, 2010 (DA 10—
                            1801) ("Reconsideration Order").


      Established 1849




                            DCQO1/ 2624125.1


DrinkerBiddle&Reath
 January 6, 2011
 Page 2


  and Reconsideration Order, granted Open Range Special Temporary Authority to
  continue to operate and expand its network to a defined list of markets through January
  31, 2011.

 The Open Range STA and Reconsideration Order require Open Range to submit monthly
 reports on the status of its efforts to secure alternative spectrum and to comply with the
 other commitments made by Open Range in seeking an STA. These commitments
 include limiting its build—out to a defined list of markets, compliance with all limitations
 and restrictions in its RUS loan agreement relating to the payment of dividends and
 distributions, payment of lease payments that would otherwise be due to Globalstar under
 the parties‘ spectrum lease instead to the U.S. Treasury as a voluntary contribution, and
 the submission of monthly reports on the status of its efforts to secure alternative
 spectrum.

 As detailed in its 180 day extension request, Open Range has complied with all of the
 conditions and undertakings set forth in the Bureaus‘ STA grant and in the letters
 submitted by Open Range. In light of Open Range‘s compliance and its substantial
 efforts to date in securing alternative spectrum, an extension of the Special Temporary
 Authority to permit time for action on Open Range‘s 180 day extension request is
 justified.




                                                   e
                                                   Respectfully submitted,




                                                   Opfi{a Range Compunications Inc.
                                                   by its attorney
                                                   Joe D. Edge



Document Created: 2019-04-23 17:57:47
Document Modified: 2019-04-23 17:57:47

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