Attachment CTIA Ex Parte

CTIA Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by CTIA

Ex Parte Presentation Letter

2008-06-25

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

IBFS_SESAMD2007090701253_650954

CTlA The Wireless Association ” Expanding rhe Wireless f r o f m v Ex PARTE OR LATE FILED June 25,2008 FILELS/ACcEP-r’EU JUN 2 5 2008 Federal Communications Commission Ms. Marlene H. Dortch, Secretary Office of the SBcretnry Federal Communications Commission 445 12th Street, SW 12th Street Lobby, TW-A325 Washington, D.C. 20554 Re: Ex Parte Presentation, IBFS File No. SAT-MOD-200805 16-00106; SES-AMD-20070907-0 1253; SES-LIC-INTR-2007-02866; SES-LIC-2006- 1206-02 100, SES-AMD-20070508-00582, SES-AMD-20070309-00336, SES-AMD-2006 1214-02 179 Dear Ms. Dortch: CTIA - The Wireless Association@ (“CTIA”) takes this opportunity to express its concerns with recent requests by Globalstar Licensee LLC (“Globalstar”), TerreStar Networks L.P. (“TerreStar”) and New I C 0 Satellite Services G.P. (“ICO”) for waiver of certain rules pertaining to the mobile satellite services (“MSS”) ancillary terrestrial components (“ATC”). Specifically, CTIA is concerned that Globalstar, TerreStar and I C 0 are requesting authorization to begin providing ATC service without satisfying specific, important “gating criteria” established by the Federal Communications Commission (the “Commission”). CTIA urges the Commission to carefilly consider the MSS operators’ factual showings with regard to satisfying the gating criteria before authorizing ATC service. In establishing rules for the provision of ATC service by MSS licensees, numerous parties raised concerns that a grant of ATC authority would give MSS operators the incentive to rely primarily on terrestrial service and infrastructure. To ensure that MSS ATC remains truly ancillary to the provision of substantial satellite service, the Commission required that certain threshold “gating criteria” be met prior to beginning ATC service.’ Those gating criteria include: (1) geographic and temporal MSS service requirements; (2) maintenance of an “in-orbit’’ or “ground spare” satellite, as appropriate; (3) availability of commercial service; (4) offering of an integrated MSS/ATC service; and (5) operation of ATC in the same bands as the MSS service.* Globalstar, TerreStar and I C 0 now ask the Commission to grant them authority to provide ATC service before meeting particular gating criteria. CTIA I See, e.g., In re Flexibilityfor Delively of Mobile Satellite Service Providers in the 2 GHz Band, the L-Band, and the 1.6/2.4 GHz Bands, Report and Order and Notice of Proposed Rulemaking, 18 FCC Rcd 1962,166 (2003). * See id. See also 47 C.F.R. 0 25.149(b)(1)-(5).

urges the Commission to closely evaluate the MSS licensees’ compliance with the gating criteria prior to granting any ATC authorization. Pursuant to the Commission’s rules, copies of this letter are being hand filed with your office. Should you have any questions, please do not hesitate to contact the undersigned. Sincerely, /s/ Christopher Guttman-McCabe Christopher Guttman-McCabe 2


Document Created: 2008-07-01 15:21:59
Document Modified: 2008-07-01 15:21:59
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