Attachment 20140327161927.pdf

20140327161927.pdf

LETTER submitted by AMSC

Requesst

1991-11-22

This document pretains to SES-LIC-19891220-00086 for License on a Satellite Earth Station filing.

IBFS_SESLIC1989122000086_1040289

                                                                                       DUPLICATE
‘AMS(     American Mobile Satellite CoOrpOration 1150 Comecieut Averve,  NW     Woshingion DC       202/8727¢2)
                                                                 Fourth Floor          20036     fax 202/331—721 2

          Lon C. levin      _                  §
          Vice President and Requlatory Counsel
                                                                                         RECEIVED
                                                   November 22,      1991

                                                                                           nov 2 5 1991

               an
  James R. Keegic                                                                FEDERAL COMMUNICATIONS$ COMMISSION
  Chief, Domest                  Facilities Division                                 OFFICE OF THE SECRETARY
  Common Carrier Bureau
  Federal Communications Commission
  Room 6010
  2025 M Street, N.W.
  Washington, D.C.                    20554


                  Re:         AMSC Request for Special Temporary Authorit
                               File No. 4+20—DSE—P—L=90———               |<~7—SS                )


  Dear   Mr.    Keegan:

       This letter is for the purpose of requesting expedited
  action on the above—referenced request for Special Temporary
  Authority.  AMSC has leased capacity on Marisat to provide an
  early Mobile Satellite Service in advance of the launch of its
  dedicated satellites.  Pending at the Commission is an
  application for authority to operate up to 30,000 mobile units
  using the Marisat capacity.                      To meet immediate needs,           however,
  AMSC has requested the instant STA for 750 mobile units.   These
  units have been type approved for non—interference by Inmarsat,
  and will operate on dedicated frequencies assigned by Inmarsat to
  AMSC in a manner that assures that they will not cause
  interference to other users of Inmarsat space segment.   In a
  November 11 letter to you, John S. Hannon, Vice President of
  Legal Affairs for Comsat Mobile Communications, confirmed that
  Inmarsat has concluded that the mobile units satisfy its non—
  interference requirements.

       Aeronautical Radio, Inc. is the only entity that objects in
  any way to grant of the STA.  Letter from John L. Bartlett to
  James R. Keegan (October 18, 1991).  Arinc requests that the
  Common Carrier Bureau place the same conditions on AMSC‘s grant
  as the Private Radio Bureau placed on Arinc‘s use of Inmarsat
  space seqgment. October 18 Bartlett letter, citing Memorandum,
  Opinion and Order, DA 90—691 (May 9, 1990).  Arinc initially
  contended that AMSC‘s mobile units could cause interference to
  aeronautical safety communications.  But in a recent letter to
  the Commission, Arinc no longer raises this issue.  Letter from
  John L. Bartlett to James R. Keegan (November 11, 1991).  AMSC


hopes that the focus of the more recent letter from Mr. Bartlett
reflects Arinc‘s acceptance of the proposition that a grant of
AMSC‘s STA request does not threaten aviation safety
communications.

     There is no reason to impose any conditions on AMSC‘s
deployment of mobile units.  AMSC is the authorized U.S. provider
of Mobile Satellite Service.        Its provision of interim service is
consistent with that authorization and furthers the Commission
goal of service being provided as soon as possible.        As discussed
above, there is ample evidence that the mobile units will not
cause interference to other users.  Because AMSC is providing
land mobile service,       it does not need any waivers of Part 87
rules that were applied to Arinc‘s request.

     Therefore, AMSC urges the Commission to act expeditiously to
grant the above—referenced request for Special Temporary
Authority.



                                   bmn C lering,
                                   very truly yours,



                                    Lon C.   Levin


cc:    John L. Bartlett
      Phillip Schneider
      James E. Landry
      Warren Y.    Zeger
      _William E. Zimsky
       Elizabeth H. Hayes
       J. Geoffrey Bentley
      Bruce D.    Jacobs



Document Created: 2019-05-31 01:44:26
Document Modified: 2019-05-31 01:44:26

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