Attachment Comments

Comments

COMMENT submitted by ICO

Comments of New ICO Satellite Services G.P.

2008-04-25

This document pretains to SES-AMD-20070907-01253 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2007090701253_636994

                                                                         ORIGINAL
                                       Before the



In the Matter of                             1                              Federal Communicationscommission
                                             1                                     office of the Secretary
TerreStar Networks, Inc.                     )      File Nos. SES-LIC- 2006 1206-02100
                                             )      SES-AMD-20070723-00978
                                             )      SES-AMD-20070907-01253




             COMMENTS OF NEW I C 0 SATELLITE SERVICES G.P.




       New IC0 Satellite Services G.P. (“ICO”) submits these comments in support of

the above-captioned application, as amended, for ancillary terrestrial component (“ATC”)

authority (“Application”) and the associated waiver request (“Waiver Request”) filed by

TerreStar Networks, Inc (“TerreStar”).’ IC0 believes that the public interest is best

served by permitting the most flexible use of the 2 GHz band for MSS/ATC.2 IC0

agrees with TerreStar that many of the existing rules from which TerreStar seeks relief

were designed to protect Boeing’s planned, but ultimately abandoned, Aeronautical

Mobile Satellite (Route) Service, and that waiver is therefore warranted. Waiver of the

rules would permit more efficient use of 2 GHz MSS spectrum and more effective
1
 On March 26,2008, the Commission issued a Public Notice, seeking comment on
TerreStar’s Application and Waiver Request. FCC Public Notice, Satellite
Communications Services, Re: Satellite Radio Applications Accepted For Filing, at 1-2.
Report NO. SES-01018 (Mar. 26.2008).
  IC0 holds a Letter of Intent Authorization to provide MSS in the 2 GHz band. IC0 has
recently notified the Commission that it has met one of its final milestones with the
successful launch of its IC0 G1 geosynchronous satellite on April 14thof this year. See
Letter from Suzanne H. Malloy, Sr. Vice President, Regulatory Affairs, ICO, to Marlene
H. Dortch, Secretary, FCC (Apr. 18,2008). ICO’s ATC application and associated
waiver requests are currently under consideration by the Commission.


                                                                                             1


deployment of 2 GHz MSS systems, thereby enabling the many benefits to consumers

that MSS/ATC service will bring.


                                         Respectfully submitted,

                                         NEW IC0 SATELLITE SERVICES G.P.


                                         By:
                                         suz
                                         Peter Corea
                                         8 15 Connecticut Avenue, NW, Suite 610
                                         Washington, D.C. 20006
                                         (202) 330-4005




                                                                                   2


                                 CERTIFICATE OF SERVICE


       I hereby certify on this 25thday of April 2008, a copy of the foregoing COMMENTS has

been served via first class mail, postage pre-paid to the following:


    Joseph A. Godles
    Goldberg, Godles, Wiener & Wright
    1229 Nineteenth Street, N.W.
    Washington, DC 20036

     Counsel for TerreStar Networks, Inc.




                                                Theresa Rollins



Document Created: 2008-04-28 13:04:13
Document Modified: 2008-04-28 13:04:13

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