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




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

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