Attachment Amendment

This document pretains to SES-AMD-20061214-02179 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2006121402179_547503

                             Federal Communications Commission
                                      Washington, D.C. 20554



                                               January 29, 2007

Joseph A. Godles, Esq.
Goldberg Godles Wiener & Wright
    1229 19 Street, N.W.
Washington, DC 20036—2413

                                                    Re:     Call Sign: E060430
                                                           File No.: SES—LIC—20061206—02100
                                                           File No.: SES—AMD—20061214—02179


Dear Mr. Godles:

        On December 6, 2006, TerreStar Networks, Inc. (TerreStar) filed the above—captioned
application, as amended, seeking authority to operate up to 2 million portable handset mobile
earth terminals (MET‘s) in the 2 GHz band‘ that will communicate with the Canadian satellite,
TerreStar—1. In order to facilitate processing of the application, we request additional
information.

        The MET application requests authority consistent with a spectrum reservation issued to
TMI Communications and Co., Limited Partnership, in response to its Letter of Intent filing
("LOP")." We also note that certain information provided in the MET application concerning
TerreStar—1 and the related network appears to have changed since the Commission decided to
reserve spectrum for the satellite system. In particular, we note the following:

           1)          In response to item E46 of Schedule B in its MET application, TerreStar
                       indicates that the polarization of the antenna is horizontal. However, in
                       Section 5 of Attachment 2 (Engineering Exhibit) of its LOI application," TMI
                       stated that the polarization would be right hand circular for both service bands.

           2)          In response to item E47 of Schedule B, in its MET application, TerreStar
                       indicates that the emission designators are 1 M25G7W, 26KOG7W,
                       6K50G7W, 313KG7W, 31K3G7TW, 156KG7W, 200KG7W, and 50KOG7W.



    2180.0—2200.0 MHz and 2000—2020 MHz.

> See TMI Communications and Company, Limited Partnership, Letter of Intent to Provide Mobile—Satellite Service in
the 2 GHz Bands, Order, DA O01—1638, 16 FCC Red 13808 (Int‘l Bur. 2001) (TMI Authorization), TMI
Communications and Company, Limited Partnership, Memorandum Opinion and Order, 18 FCC Red 1725 (Int‘l Bur.
2003) ("TMI Milestone Order"), TMI Communications and Company, Limited Partnership and TerreStar Networks
Inc., FCC 04—144 (June 29, 2004), and Use of Returned Spectrum in the 2 GHz Mobile Satellite Service Frequency
Bands, 20 FCC Red 19696, 19726 (2005) ("2x 10 MHz Order").

*    See TMI Communications and Company, Limited Partnership application, File No. SAT—LOI—19970926—00161.


                                     Federal Communications Commission



                      However, in Section 5 of Attachment 2 of its LOL,* TMI stated that the
                      emission designator is 5K00G1W.

          3)          In File No. SES—AMD—20061214—02179, TerreStar indicates that
                      Terrestar—1 will be located at the 111.1° W.L. orbital location, rather than
                      at the 107.3° W.L. orbital location specified in the spectrum reservation.

TerreStar indicates that information concerning the Terrestar—1 satellite has already been
provided, and that it intends to seek modification of its spectrum reservation to address these
matters. However, we believe the filing of a full Schedule S for the Terrestar—1 satellite would
facilitate processing of the MET application. Accordingly, please submit an amendment
including a full Schedule S for the Terrestar—1 satellite. Please include in the Schedule S
information concerning all frequency bands on which the satellite will be capable of operating.

          We also note two additional matters that you may wish to address in any amendment.
First, in response to question E17 of Schedule B, TerreStar indicated that the MET‘s will not be
controlled remotely. While this method of operation is permitted for MET‘s, we note that Section
25.271 of the Commission‘s rules requires that, unless remotely controlled, such MET‘s must be
under the direct control of a trained operator at the site from which it operates. This method of
operation may not be practical for a large number of METs. We also note that in Exhibit 3 of the
application, TerreStar states that it will have the ability to shut down its mobile earth terminals 24
hours a day, seven days a week, from its network operations center. We therefore seek
clarification of whether, in fact, TerreStar intends to remotely control its MET‘s. If so, TerreStar
should answer "yes" to question E17 and provide a response to questions E61 through E68 of
Schedule B. Second, in response to items E54 and E55 of Schedule B, TerreStar provides a range
of satellite arc for the Terrestar—1 satellite. The listing of a range is appropriate only for ALSAT
designated earth stations. Accordingly, please correct items E54 and E55 to reflect the intended
orbital location of the satellite.

         TerreStar should submit the requested information within thirty calendar days from the
date of this letter. Failure to submit the requested information will result in dismissal of the
application.

                                                           Sincerely,




                                                                i / } } @ f f i Km
                                                              ;
                                                           *@ A. Kotler
                                                           Scott
                                                           Chief, Systems Analysis Branch
                                                           Satellite Division
                                                           International Bureau




*   See TMI Communications and Company, Limited Partnership application, File No. SAT—LOI—19970926—00161.



Document Created: 2019-04-09 20:02:04
Document Modified: 2019-04-09 20:02:04

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