Attachment 20140327162007.pdf

20140327162007.pdf

RESPONSE TO REPLY COMMENTS submitted by American Mobile Satellite Corporation

Reponse

1991-11-11

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

IBFS_SESLIC1989122000086_1040292

American Mobile Satellite Corporation 1150 Comeciest Avenve, NW Woshingion 0C Fourth Floor Lon C. tavin Novembe:,51'1§9iw” James R. Keegan Chief, Domestic Facilities Division Common Carrier Bureau Federal Communications Commission Room 6010 2025 M Street, N.W. Haskhinc—oan m _ aaAnm wasaiillnigcoli, 1.U. 40334 Re: American Mobile Satellite Corporation Request for Special Temporary Authority File No. 420—DSE—P/L—90 Dear Mr. Keegan: I am writing on behalf of American Mobile Satellite Corporation ("AMSC"), in response to an October 18, 1991 letter to you from John L. Bartlett, counsel to Aeronautical Radio, Inc. ("Arinc"). Arinc requests that the Commission impose various restrictions on any grant of AMSC‘s above—referenced request for authority to operate up to 750 land mobile terminals. AMSC proposes to deploy these terminals in connection with its early service, which will use space seqgment leased from Inmarsat. Arinc, which operates its own ground—based communications system for the airlines, for several years now has consistently opposed AMSC‘s efforts to develop a domestic Mobile Satellite Service system. That effort frequently includes the interjection of specious technical arqguments. See, e.g., Consolidated Opposition and Response of AMSC, Gen. Docket No. 84—1234 (July 26, 1988). Mr. Rartlett‘s October 18 letter continues this pattern. There is no basis for Arinc‘s concern that AMSC‘s terminals might interfere with aviation operations. AMSC‘s terminals will use space seqgment leased from Inmarsat. Inmarsat is the only entity currently operating space segment in these bands. Inmarsat has tested AMSC‘s terminals and certified that the terminals cannot cause interference to other users of Inmarsat‘s space segment. In addition, Inmarsat has designed its system so that AMSC‘s network will have its own dedicated frequencies that do not overlap with those used by any other networks operating on Inmarsat space seqgment, including the networks used by Arinc and other aeronautical service providers. There are thousands of

other terminals using Inmarsat‘s space seqgment already operating in the band; there is no evidence that any of these has caused interference to Arinc‘s operations. Arinc cites the conditions the Commission placed on Arinc when it granted temporary authority to Arinc for aeronautical satellite operations and contends that the same conditions must be placed on AMSC. Memorandum Opinion and Order, DA 90—691 (May 9, 1990). Arinc, however, completely ignores the fact that the Commission placed those conditions on Arinc because Arinc‘s terminals were not type—accepted and because Arinc was seeking to provide aeronautical service in a band not allocated for such service. By contrast, AMSC‘s terminals are type—accepted for non—interference by Inmarsat and will operate in a band that has an appropriate allocation. Arinc also seeks to tie AMSC‘s application to the Commission‘s proceeding to establish technical standards for aeronautical mobile terminals. PR Docket No. 90—315. But, because AMSC‘s application does not include aeronautical terminals, it does not raise any of the issues under consideration in PR Docket No. 90—315. There also is no basis to Arinc‘s position that any grant of AMSC‘s application requires the Commission to grant a separate waiver that Arinc has requested. The two matters are totally unrelated. Moreover, AMSC has demonstrated previously that Arinc‘s waiver request is contrary to the public interest. See Opposition of AMSC to Request for Waiver, File No. I—S—P—90—002 (January 8, 1990); Letter from Lon Levin to Donna Searcy (November 21, 1990); Letter from Brian Pemberton to Hon. Alfred Sikes (October 24, 1991). We will not repeat those views here. Based on the foregoing, AMSC urges the Commission to act expeditiously to reject Arinc‘s request and grant AMSC application. Very truly yours, {/"'\ C * L’""‘“‘&M Lon C. Levin cc: John L. Bartlett Phillip Schneider James E. Landry wWarren Y. Zeger William E. Zimsky Elizabeth H. Hayes J. Geoffrey Bentley Bruce D. Jacobs


Document Created: 2019-05-23 13:51:57
Document Modified: 2019-05-23 13:51:57
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC