Attachment Narrative

This document pretains to SES-AMD-20101025-01328 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2010102501328_847136

                                   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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