Attachment Narrative

This document pretains to SES-AMD-20101025-01326 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2010102501326_847134

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) GLOBALSTAR LICENSEE LLC, GUSA ) LICENSEE LLC, AND GCL LICENSEE ) LLC ) ) Application for Modification of ) File No. SAT-MOD-20080904-00165 Nongeostationary Mobile Satellite Service ) System License (S2115) to Launch a Second- ) Generation System ) ) Application for Modification of Mobile ) File No. SAT-AMD-20091221-00147 Satellite Service Earth Station Licenses and ) Mobile Earth Terminal Licenses to Authorize ) Communications with Second-Generation ) System and to Incorporate Previously-Granted ) Ancillary Terrestrial Component Authority ) ) Application For Space And Earth Station ) File Nos. SES-MFS-20091221-01616 ) SES-MFS-20091221-01617 ) SES-MFS-20091221-01618 AMENDMENT TO APPLICATION FOR MODIFICATION OF MOBILE SATELLITE SERVICE EARTH STATION AND MOBILE EARTH TERMINAL LICENSES Globalstar Licensee LLC (“Globalstar”)1 hereby amends the above captioned application filed on December 21, 2009 (“Application”) that seeks to modify its earth 1 Globalstar Licensee LLC is the authorized licensee of the Globalstar satellite constellation (call sign S2115). An affiliated company, GUSA Licensee LLC, holds licenses for Globalstar’s earth station gateways located in the United States and a blanket license for the operation of Globalstar mobile earth station terminals, and is responsible for the provision of Globalstar MSS services to end users in the United States. For purposes of this application, Globalstar Licensee LLC and GUSA Licensee LLC are referred to collectively as “Globalstar.”

station and mobile earth terminal licenses to permit communication with its French- registered second generation satellites, as well as ongoing modifications to the operations of its U.S.-licensed satellites that are necessary to provide for the transition to its second- generation constellation. In this amendment to the Application, Globalstar seeks authority for all of the antennas at Globalstar’s earth station in Sebring, Florida to communicate with its first- and second-generation satellites for telemetry and command (T&C) purposes. In its December 2009 application, Globalstar only requested authority for its Clifton, Texas site to conduct T&C operations. Since the filing of that application, to achieve maximum efficiency in both maintenance and launch operations, Globalstar added T&C capability to its Sebring, Florida site to monitor current and new replacement Globalstar satellites. On October 12, 2010, Globalstar amended its December 2009 application to enable one of its antennas at Sebring to engage in such communications.2 In this amendment, Globalstar seeks authority for the remainder of its antennas at Sebring to engage in T&C of its first- and second-generation satellites.3 This authority will allow Globalstar to utilize multiple antennas at this site for T&C purposes, which will allow it to communicate with and control multiple satellites in view simultaneously from the site. The information required by sections 25.114(d) and 25.143 of the Commission’s rules in order to obtain authority for U.S.-based earth stations to 2 File No. SES-AMD-20101012-01278. 3 File Nos. SES-MFS-20091221-01616 (Call Sign: E050098 (SBRG-2)), SES- MFS-20091221-01617 (Call Sign: E050099 (SBRG-3)), SES-MFS-20091221-01618 (Call Sign: E050100 (SBRG-4)). 1st Generation Constellation ITU Designation: HIBLEO-4FL; 2nd Generation Constellation ITU Designation: HIBLEO-X. -2-

communicate with the foreign-registered satellites4 is provided in the December 2009 application.5 The Sebring earth station complies with all applicable Commission rules for earth station operation. *** For the reasons stated above, Globalstar requests that the Commission grant its application, as amended herein. Respectfully submitted, /s/ Samir C. Jain ________________________ L. Barbee Ponder IV General Counsel and Vice President – Legal and Regulatory Affairs GLOBALSTAR LICENSEE LLC 300 Holiday Square Blvd. Covington, LA 70433 (985) 335-1503 Samir C. Jain Elvis Stumbergs WILMER CUTLER PICKERING HALE AND DORR LLP 1875 Pennsylvania Ave., NW Washington, D.C. 20006 (202) 663-6000 Counsel for Globalstar Licensee LLC October 25, 2010 4 See Report and Order, Amendment of the Commission's Regulatory Policies to Allow Non-U.S. Licensed Space Stations to Provide Domestic and International Satellite Service in the United States, 12 FCC Rcd 24094, 24175-76 ¶¶ 189-192 (1997); First Report and Order and Further Notice of Proposed Rulemaking in IB Docket No. 02-34, and First Report and Order in IB Docket No. 02-54, Amendment of the Commission's Space Station Licensing Rules and Policies, 18 FCC Rcd 10760, 10872-73 ¶¶ 300-302 (2003). 5 See File No. SAT-AMD-20091221-00147, Narrative at 13-21. -3-

Engineering Certification I hereby certify under penalty of perjury that I am the technically qualified person responsible for preparation of the engineering information contained in the foregoing “Amendment To Application For Modification Of Mobile Satellite Service Earth Station And Mobile Earth Terminal Licenses” (“Application Amendment”); that I am familiar with the relevant sections of the FCC’s rules referred to in the Application Amendment; and that the technical information set forth in the Application Amendment is true and correct to the best of my knowledge and belief. Signed this 25th day of October, 2010 /s/ Paul A. Monte ______________________ Paul A. Monte, Vice President, Engineering & Product Development Globalstar, Inc. -4-


Document Created: 2010-10-25 15:10:42
Document Modified: 2010-10-25 15:10:42
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