Attachment 20140327161942.pdf

20140327161942.pdf

LETTER submitted by Wiley, Rein & Fielding

Correction

1991-11-11

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

IBFS_SESLIC1989122000086_1040290

WILEY, REIN & FIELDING 1776 K STREET, N. w. WaASHINGTON, D. C. 20006 (202) 429—7000 FACSIMILE JOHN L. BARTLETT (202) 429 —7049 (202) 429—7070 TELEX 2483498 WYRN UR November 11, 1991 Mr. James R. Keegan Chief, Domestic Facilities Division Common Carrier Bureau Federal Communications Commission Room 6010, 2025 M Street, N.W. Washington, D.C. 20554 Re: American Mobile Satellite Corporation Request for Special Temporary Authority File No. 420—DSE—P—L—90 Dear Mr. Keegan: The letter from Mr. Lon Levin, General Counsel of American Mobile Satellite Corporation (AMSC) dated November 5, 1991, requires a brief response to correct erroneous statements. In that letter, Mr. Levin attempts to distinguish the conditions placed upon grant of a waiver to Aeronautical Radio, Inc. (ARINC), United Air Lines and Northwest Airlines by the Chief, Private Radio Bureau, to operate aeronautical mobile terminals in conjunction with INMARSAT‘s space seqgment by factually incorrect statements. See Memorandum Opinion and Order, released May 9, 1990 (DA 90—691) . First, Mr. Levin attempts to distinguish the waiver given to aircraft terminals on the basis of "type acceptance" of AMSC‘s terminals by INMARSAT. However, the aircraft earth stations involved in the Bureau Chief‘s waiver are subject to the same access approval by INMARSAT as AMSC‘s terminals will be. Both AMSC‘s terminals and the aircraft earth stations currently lack FCC type acceptance, but such type acceptance eventually will be required to minimize the likelihood of interference. If the AMSC terminals are to be used after the final service rules and type acceptance criteria are adopted, they must comply with such new rules, just as the aircraft earth stations will comply. Second, Mr. Levin states that ARINC was proposing service in a band not allocated for aeronautical service. The frequencies in the maritime mobile satellite service may

Mr. James R. Keegan November 11, 1991 Page 2 be used by aircraft stations for aeronautical communications (see 47 C.F.R. § 87.185(c)) and the Commission‘s Rules give express priority in the maritime mobile satellite bands to aircraft distress, urgency and safety communications. See 47 C.F.R. § 80.91. ARINC is entitled to assurance from the Commission that such protection will be afforded. The simple fact of the matter is that the stringent conditions imposed by the Chief of the Private Radio Bureau on aeronautical use of the maritime mobile satellite spectrunm are appropriate, and the public interest requires that these conditions also be imposed on any authorization to AMSC to use INMARSAT facilities to provide service in that spectrun. Very Aruly yours, cce: Lon C. Levin Phillip Schneider James E. Landry Warren Y. Zeger William E. Zimnsky Elizabeth H. Hayes J. Geoffrey Bentley Bruce D. Jacobs


Document Created: 2019-05-30 12:09:40
Document Modified: 2019-05-30 12:09:40
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC