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
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC