Attachment Operate with the Unc

This document pretains to SES-LFS-20050930-01352 for License to use Foreign Satellite (earth) on a Satellite Earth Station filing.

IBFS_SESLFS2005093001352_1098718

. RECEIVED ORIGINAL Southwest Texas Regional _1 Advisory Council for Trauma JUL 2 0 2006 Satellite Division RECEIVED International—Bureau July 17, 2006 ] JUL 1 T 2006 Federal Communications Commission Via Hand Delivery Office of Secretary Ms. Marlene H. Dortch Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Applications to Operate with the Uncoordinated Inmarsat 4F2 Satellite SES—LFS—20050826—01175 (Call Sign 050249); SES—MFS—20051122—01614 (Call Sign EO00180) SES—STA—20060307—00374 (Call Sign E000180); SES—STA—20060310—00419 (Call Sign 050249) SES—LFS—20050930—01352 (Call Sign E050276); SES—MFS—20060118—00050 (Call Sign EO00280) SES—STA—20060308—00388 (Call Sign EO00280); SES—STA—20060313—00430 (Call Sign E050276) SES—LFS—20051011—01396 (Call Sign E050284); SES—STA—20060314—00438 (Call Sign EO50284) SES—MFS—20051207—01709 (Call Sign E030055); SES—STA—20060307—00372 (Call Sign E030055); SES—LFS—20051123—01634 (Call Sign E0O50348); SES—STA—20060316—00454 (Call Sign EO50348) SES—MFS—20051202—01665 (Call Sign E020074); SES—STA—20060307—00373 (Call Sign EO20074) SES—LFS—20060303—00343 (Call Sign E060076); SES—STA—20060315—00445 (Call Sign E060076) SES—LFS—20060522—00852 (Call Sign E060179); SES—STA—20060522—00857 (Call Sign EO60179) Dear Ms. Dortch: The Southwest Texas Regional Advisory Council for Trauma (STRAC) is a 501(c)3 Non—profit, tax—exempt organistions responsible for the development and implementation of the 22 county regional EMS/Trauma system. STRAC has 71 Public Safety EMS agencies and 53 hospitals and trauma centers in its region. STRAC organizes these agencies and hospitals during disaster and the MSV sitcom units are critical to that plan as it saves lives. STRAC relies on the Mobile Satellite Service ("MSS") system operated by Mobile Satellite Ventures LP ("MSV*") for public safety communications for communications over more than 26,000 square miles and 22 counties, covering over 2 million people. We have come to expect dependable service from MSV, which is crucial given the critical communications for which we rely on MSV‘s system. We are also excited about MSV‘s planned next—generation MSS system, which will allow us to use small, handheld terminals throughout the United States, including in the most rural and remote areas of our nation, for broadband services. Given the importance of the L band to our emergency operations, we are extremely concerned about the pending proposals to operate tens of thousands of Broadband Global Area Network ("BGAN®") terminals with an uncoordinated L band satellite. This satellite has not been coordinated among the L band MSS operators, and its technical characteristics are far different than any satellite that has been coordinated previously. Without a prior coordination agreement, there is a significant risk that the uncoordinated satellite and the services provided over it will interfere with our existing critical public safety operations. During normal operations, this is unacceptable; during times of emergency, it is life threatening. In addition, the operator of the

uncoordinated satellite proposes to use certain loaned frequencies that it refuses to return to MSV. We understand that these frequencies are required for MSV to develop new and innovative services for public safety users, including additional services that further improve interoperable communications. Before permitting any new operations in the L band, we urge the Commission to take action to ensure that the L band will continue to be able to support critical public safety services. For example, the Commission should encourage L band operators to coordinate more contiguous frequency assignments that will eliminate the need for spectrum inefficient guard bands, will reduce the potential for interference caused by carriers placed too closeto a band edge, and will allow for the introduction of truly broadband services. Moreover, the Commission should take firm action to preclude L band operators from usurping frequencies coordinated for and licensed to other operators. By taking these actions, the Commission can ensure that the L band is used in a more efficient manner and will continue to be able to support critical public safety services. Very truly yours, Eric Epley Executive Director


Document Created: 2015-08-06 12:50:04
Document Modified: 2015-08-06 12:50:04
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