Attachment Suppl Filing 1/16/04

This document pretains to SES-LIC-20011130-02259 for License on a Satellite Earth Station filing.

IBFS_SESLIC2001113002259_353272

LEVENTHAL S ENTER & LERNAN PLLC January 16, 2004 RAUL R. RODRIGUEZ E-MAiL (202) 416-6760 RRODRIGUEZ@LSLLAW.COM VIA HAND DELIVERY Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Attn (via e-mail):William Howden Chief, Systems Analysis Branch Satellite Division International Bureau Dear Ms. Dortch: This letter responds to the request for information dated December 12, 2003 from William Howden, Chief, Systems Analysis Branch, Satellite Division, International Bureau, to Maritime Telecommunications Network, Inc. (“MTN”) concerning MTN’s application for operation ofearth stations onboard vessels (“ESVs”) in the Ku-band (the “Application”). Points of Communication With its Application, MTN requests authority to transmit in the band 14.0 14.5 GHz — and communicate with Satmex-5, a satellite operated by Sat~lites Mexicanos, S.A. de C.V. (“Satmex”) and located at 116.80 W.L. MTN uses stabilized antenna systems for ESVs that operate with ±0.20 pointing accuracy of the exact position of the satellite through which the ESV is communicating. There are only a few exceptional conditions, described below, under which the antenna could be mispointed by more than 0.5g. Even under these highly unusual conditions, the ESV antenna controller can detect within 100 ms if the pointing error should ever exceed 0.5 0and cease transmissions immediately. The controller would then suppress transmissions until the pointing accuracy is within ±0.2g. ~uT i’uITCN DC ~½VOQO~

Ms. Marlene H. Dortch January 16, 2004 Page -2- The stabilized antenna systems used by MTN employ closed-loop servo systems and highly accurate sensors to continuously monitor the antenna’s position in inertial space. When operating properly, the servo mechanism will keep the antenna pointing within ±0.10 RMS, 0.20 peak. There always exists the possibility that unforeseen conditions can cause the antenna to be mispointed outside ofthese specifications. Examples of some of these possible conditions are: 1. Unexpected mechanical disturbance from an external source; 2. Operation in an unbalanced mechanical configuration; 3. Operation subjected to tangential accelerations beyond the pedestal specifications (e.g., extremely heavy sea conditions); 4. Failure of one or more sensors; or 5. Failure of one or more drive motors. Even under any of the failure conditions cited above, the antenna controller can detect a pointing error that exceeds 0.50 within 100 ms and cease transmissions immediately. As noted above, the controller will not allow transmissions to resume until the pointing error has diminished to within ±0.20. The sensors mounted on the antenna measure antenna position with a resolution ofbetter than 0.0 10. The key to robust systems operation and reliable error reporting is that the antenna position data is processed before being used to drive an error comparator. In addition to antenna position, many sources of data are available to the system to make a robust decision about the accuracy ofthe antenna pointing. They are: 1. Satellite modem synch lock; 2. Short-term integrated rate sensor antenna position: 3. Long-term accelerometer and heading reference sensors readings; 4. AGC level data; and 5. Calculated azimuth and elevation positions based on ship latitude, longitude and desired satellite longitude. If for any reason the satellite modem should lose synch with the satellite down-link, the system will cease transmission immediately, regardless of the pointing accuracy, and not re- transmit until it has re-synchronized with the satellite and the pointing accuracy is within ±0.20. At all times the antenna controller compares a running average of the measured azimuth and elevation to the desired azimuth and elevation positions. If the results exceed the 0.50 threshold, then transmissions will cease immediately and not resume until the pointing accuracy is within ±0.20. The threshold detection algorithm has been used successfully for more than 10 years to insure that the stabilized antenna system is operating within the desired limits.

Ms. Marlene H. Dortch January 16, 2004 Page -3- Notice to Adiacent Satellite Operators MTN has notified the operators of satellites operating in the band 14.0 14.5 GHz and — whose orbital location is within ±60 of the location of Satmex-5 that its ESV terminals are operating in compliance with the inter-system coordination agreement. The following table lists the satellites that could be potentially affected and whose operators have been notified. Name Orbital Degrees from Operator Location Satmex-5 Galaxy 3R 111.100 W ~5.700 PanAmSat Solidaridad F2 113.000 W -3.80~ Satmex Satmex-S 1l6.80~ W 0.000 Satmex Anik E2 118.700 W + 1.900 Telesat Copies of the notifications sent to each affected satellite operator are attached to this letter. 24-Hour Contact MTN maintains a Network Operations Center (“NOC”) at its headquarters in Miramar, Florida on a 24-hours-a-day, 365-days-a-year basis. All systems of MTN’s clients are monitored and their emissions are controlled from this center. Any client can obtain information about its system and problem resolution by calling the personnel on-duty in the NOC at +1(954) 538- 4074. An appropriate regulatory authority can also call the NOC to inquire about potential interference. If it is determined that the interference is coming from a system under MTN’s control, the on-duty personnel can cease emissions from that unit immediately. There are standard escalation procedures in place for all types of incidents that the on- duty personnel use to notify and involve the appropriate MTN staff members to resolve a problem. In the most extreme cases, MTN’s Vice-President of Operations will be called in to take charge of the situation and resolve the problem. Acknowledgment of Subiectivity to Rule Making MTN hereby acknowledges that any license that it receives pursuant to its Application will be subject to the outcome of any future rule making concerning ESV operations.

Ms. Marlene H. Dortch January 16, 2004 Page -4- Should the Commission require any additional information regarding MTN’s Application, please contact the undersigned counsel. Raul Counsel to Maritime Telecommunications Network, Inc. Attachments

LEVENTHAL SENTER & LERMAN PiX January 16. 2004 VIA FEDERAL EXPR~ESS Mr. Kalpak Gude PANAMSAT CORPORATION 1801 K Street, NW Suite 440 Washington. DC 20006 Re: Application of Maritime Telecommunications Network, lnc. Call Sign E010332 FCC File Number SESL1C2001113002259 Dear Mr. e. I am writing to you on behalf of Maritime Telecommunications Network, Inc., (“MTN”) concerning its earth station application pending before the U.S. Federal Communications Commission (“FCC”). MTN plans to use this earth station to communicate with Satmex-5, which is located at 116.8 degrees W.L. Your company operates the Galaxy 3R satellite, which is located at 111.10 degrees W.L. Because Galaxy 3R is located within six degrees of Satmex-5, the FCC requires that we provide you with the enclosed technical assessment. You have the right to reply to the enclosed materials. If you do not reply within 30 calendar days from the date of notice, the FCC will construe your not replying as an assent to the grant of MTN’s earth station application. Sincerely, cu>~ R Rodriguez . Counsel to Maritime Telecommunications Network, Inc. RRRIrjc Attachments cc: Mr. William Howden International Bureau Federal Communications Commission by e-mail: Mr. Harry Ng Joseph Godles, Esq.

Maritime Telecommunications Network, Inc. Adjacent Satellite Operator Notification Earth Station Onboard Vessel Performance As part of a license application filed by Maritime Telecommunications Network. Inc. (“MTN’) to operate earth stations onboard vessels (“ESVs”) in the band 14.0 -14.5 GHz, the Federal Communications Commission (“FCC”) is requiring that MTN notify all operators of satellites that are within 6~ of the orbital location of Satmex-5, the satellite through which MTN’s ESVs communicate when operating. You are receiving this notification as the operator of Galaxy 3R, which is located at 111.100 W.L. approximately 5.70~ from Satmex-5 at 116.8 W.L. This document provides the technical basis for adjacent satellite operators to determine that MTN’s ESV systems are operating in compliance with the terms of the inter-system coordination agreement and, therefore. do not pose any more potential for interference than a land-based earth station with the same performance characteristics. MTN uses stabilized antenna systems for ESVs that operate with ±0.2~ pointing accuracy of the exact position of the satellite through which the ESV is communicating. Any loss of synch with the satellite downlink or any mispointing error greater than ±0.50 will cause the terminal to cease transmission and not resume until the pointing accuracy is within ±0.2~. Therefore, these ESV terminals have the same or greater pointing accuracy than land-based VSATs operating on the same satellite. The attached table provides the transmission parameters and related data nccessary to characterize the performance of the ESV systems operated by MTN. In addition. antenna radiation patterns have been attached that show the pole and cross-pole performance of the complete antenna system in the plane of the geo-stationarv satellites. As can be seen from the data, these ESV terminals are operating within the performance requirements established by the FCC for all N/SAT earth stations and within the limitations established in the inter-system coordination agreement. If you have any questions on this notification, please contact: Robert Hanson N/ice President Regulatory Affairs — Maritime Telecommunications Network. Inc. 3044 N. Commerce Parkway Miramar. FL 33025 United States of America Telephone: 720-635-8162 Facsimile: 303-449-1272 E-mail: robert_hanson@mtnsat.com Raul R. Rodriguez Leventhal Senter & Lerman PLLC 2000 K Street. NW. Suite 600 Washington. DC 20002 United States of America Telephone: 202-429-8970 Facsimile: 202-293-7783 E-mail rrodriguez@lsl-law.com Failure on your part to reply within 30 calendar days from the date of this notice will be construed as assent to the grant of MTN’s ESV application. Replies should be filed directly with the Federal Communications Commission, with copies to the individuals above .

Satmex-5 Value Orbital location 116.80W Beam Ku-2 Transponder 18K Modulation & Carriers Value Modulation TDMA Hub Uplink (GHz) 14.3694 Polarization - Horizontal Hub Downlink (GHz) 12.0694 Polarization - N/ertical ESN/ Uplink (GHz) 14.3698 - Polarization Horizontal ESN/ Downlink (GHz) 12.0698 - Polarization N/ertical ESV Antenna Value Major Axis (in) 1.35 Minor Axis (in) 1.20 Offset Angle (degrees) 23 TX gain at 14.25 GHz (dBi) 42.55 RX gain at 11.85 GHz (dBi) 41.65 TX cross-polarization at 14.25 GHz (dB) -34 RX cross-polarization at 11.85 GHz (dB) 43 ESV Power Value Input Power (Watts) 8 Data Rate (Kbits/s) 128 Occupied Bandwidth (KHz) 87 Transmit power (dBW) 9.03 Feeder loss (dB) 1.50 ESV Power Spectral Density Value Transmit power/BW (dBW/4OKHz) 5.66 TX power at antenna input (dBW/4OKHz) 4.16 Antenna main beam gain (dBi) 42.55 Transmit e.i.r.p. density (dBW/4OKHz) 46.71

‘•1 4 .1 Dec 5 2001 ~i04 Aol 041 borne a .1 —- I . Minor Ash 44.5 V~7O14.23GHz Kb I.. . ;.. ~ I I U — I -I- ~ I - Dec 320011203 Aot64i tiome 03 MinorH.20: H.20 Ash •I- H 20 4.5H’70 Degrees 14.2SGH7

LEVENTHAL S ENTER & LERMAN PLLC January 16. 2004 VIA FEDERAL EXPRESS Mr. Alonso Arturo Picazo Diaz Director de Asuntos Regulatorios SATMEX Boulevard Manuel Avila Camacho No. 40 Piso 24 Col. Lomas de Chapultepec CP Il000,DF MEXICO Re: Application of Maritime Telecommunications Network, Inc. Call Sign E010332 FCC File Number SESLIC2001 113002259 Dear~ft~ ica.zo: I am writing to you on behalf ofMaritime Telecommunications Network. Inc.. (“MTN”) concerning its earth station application pending before the U.S. Federal Communications Commission (“FCC”). MTN plans to use this earth station to communicate with Satmex-5, which is located at 116.8 degrees W.L. Your company operates the Solidaridad F2 satellite, which is located at 113.0 degrees W.L. Because Solidaridad F2 is located within six degrees of Satmex-5, the FCC requires that we provide you with the enclosed technical assessment. You have the right to reply to the enclosed materials. If you do not reply within 30 calendar days from the date of notice, the FCC will construe your not replying as an assent to the grant of MTN’s earth station application. Sincerely, Rodriguez Counsel to Maritime Telecommunications Network, Inc. RRRIrjc Attachments cc: Mr. William Howden International Bureau Federal Communications Commission by e-mail: Ms. Caroline Bass S~u Th ~GC ~A’AS’-W’JCTON. DZ 20C%.

Maritime Telecommunications Network, Inc. Adjacent Satellite Operator Notification Earth Station Onboard Vessel Performance As part of a license application filed by Maritime Telecommunications Network. Inc. (‘~MTN”) to operate earth stations onboard vessels (“ESN/s”) in the band 14.0 -14.5 GHz. the Federal Communications Commission (“FCC”) is requiring that MTN notify all operators of satellites that are within 6~ of the orbital location of Satmex-5. the satellite through which MTN’s ESN/s communicate when operating. You are receiving this notification as the operator of Solidaridad F2. which is located at 1 l3.00~ W.L. approximately 3.80~ from Satmex-5 at 116.8 W.L. This document provides the technical basis for adjacent satellite operators to determine that MTN’s ESN/ systems are operating in compliance with the terms of the inter-system coordination agreement and, therefore. do not pose any more potential for interference than a land-based earth station with the same performance characteristics. MTN uses stabilized antenna systems for ESN/s that operate with + 0_‘~ pointing accuracy of the exact position of the satellite through which the ESN/ is communicating. Any loss of synch with the satellite downlink or any mispointing error greater than ±0.5w will cause the terminal to cease transmission and not resume until the pointing accuracy is within ±0.2g. Therefore. these ESN/ terminals have the same or greater pointing accuracy than land-based N/SATs operating on the same satellite. The attached table provides the transmission parameters and related data necessary to characterize the performance of the ESN/ systems operated by MTN. In addition, antenna radiation patterns have been attached that show the pole and cross-pole performance of the complete antenna system in the plane of the geo-stationary satellites. As can be seen from the data. these ESN/ terminals are operating within the performance requirements established by the FCC for all N/SAT earth stations and within the limitations established in the inter-system coordination agreement. If you have any questions on this notification, please contact: Robert Hanson N/ice President Regulatory Affairs — Maritime Telecommunications Network. Inc. 3044 N. Commerce Parkway Miramar. FL 33025 United States of America Telephone: 720-635-8162 Facsimile: 303449-1272 E-mail: robert_hanson@mtnsat.com Raul R. Rodriguez Leventhal Senter & Lerman PLLC 2000 K Street. NW. Suite 600 Washington. DC 20002 United States of America Telephone: 202-4W-8970 Facsimile: 202-293-7783 E-mail: rrodri guez @ lsl-law.com Failure on your part to reply within 30 calendar days from the date of this notice will be construed as assent to the grant of MTN’s ESN/ application. Replies should be filed directly with the Federal Communications Commission. with copies to the individuals above .

Satmex-5 Value Orbital location 116.82W Beam Ku-2 Transponder 18K Modulation & Carriers Value Modulation TDMA Hub Uplink (GHz) 14.3694 - Polarization Horizontal Hub Downlink (0Hz) 12.0694 Polarization - N/ertical ESN/ Uplink (GHz) 14.3698 - Polarization Horizontal ESN/ Downlink (0Hz) 12.0698 Polarization - N/ertical ESV Antenna Value Major Axis (in) 1.35 Minor Axis (in) 1.20 Offset Angle (degrees) 23 TX gain at 14.25 GHz (dBi) 42.55 RX gain at 11.85 0Hz (dBi) 41.65 TX cross-polarization at 14.25 GHz (dB) -34 RX cross-polarization at 11.85 GHz (dB) -43 ESV Power Value Input Power (Watts) 8 Data Rate (Kbits/s) 128 Occupied Bandwidth (KHz) 87 Transmit power (dBW) 9.03 Feeder loss (dB) 1.50 ES~7 Power Spectral Density Value Transmit power/BW (dBW/4OKHz) 5.66 TX power at antenna input (dBW/4OKHz) 4.16 Antenna main beam gain (dBi) 42.55 Transmit e.i.r.p. density (dBW/4OKHz) 46.71

.—~ —+—-. . I ,...I 71 Dec5200l ~204Ant 041 DomeR MInor Axis 01- 4.5 Degrees V-rZOV,20- V*20V-7O1425GHz .1 I, —I <:4.1.:.. Dcc S 20&l 1208 Ant 641 Do,ne !3 Minor Mix .1- 4.5 Degreex H 20 H-20; H 2011.70 14 25Ghz

I ~V~NT~-1AL SVNTVR & LERHAN Januar 16. 2004 VIA FEDERAL EXPRESS Mr. Ro2er Tinlev N/ice President. Space Systems TELESAT CANADA 1601 Telesat Court Gloucester. ON KIB 5P4 CANADA Re: Application of Maritime Telecommunications Network, Inc. Call Sign E010332 FCC File Number SESL1C2001113002259 Dear Mr. Tinley: I am writin2 to you on behalf of Maritime Telecommunications Network. Inc., (~MTN” concerning its earth station application pending before the U.S. Federal Communications Commission (“FCC”). MTN plans to use this earth station to communicate with Satmex-5. which is located at 116.8 degrees W.L. Your company operates the Anik E2 satellite, which is located at 118.70 degrees W.L. Because Anik E2 is located within six degrees of Satmex-5. the FCC requires that we provide you with the enclosed technical assessment. You have the right to reply to the enclosed materials. If you do not reply within 30 calendar days from the date of notice, the FCC will construe your not replying as an assent to the grant of MTN’s earth station application. Sincerely. ~ Counsel to Maritime Telecommunications Network, Inc. RRR/~c Attachments cc: Mr. William Howden International Bureau Federal Communications Commission

Maritime Telecommunications Network. Inc. Adjacent Satellite Operator Notification Earth Station Onboard Vessel Performance As part of a license application filed by Maritime Telecommunications Network. inc. Q’MTNTh to operate earth stations onboard vessels (“ESN/s”) in the band 14.0 -14.5 GHz. the Federal Communications Commission (“FCC”) is requiring that MTN notify all operators of satellites that are within 60 of the orbital location of Satmex-5. the satellite through which MTN’s ESN/s communicate when operating. You are receiving this notification as the operator of Anik E2. which is located at 118.700 W.L. approximately 1.90~ from Satmex-5 at 116.8 W.L. This document provides the technical basis for adjacent satellite operators to determine that MTN’s ESN/ systems are operating in compliance with the terms of the inter- system coordination agreement and, therefore, do not pose any more potential for interference than a land-based earth station with the same performance characteristics. MTN uses stabilized antenna systems for ESN/s that operate with ±0.2w pointing accuracy of the exact position of the satellite through which the ESN/ is communicating. Any loss of synch with the satellite downlink or any mispointing error greater than ±0.5~ will cause the terminal to cease transmission and not resume until the pointing accuracy is within ±0.2g. Therefore, these ESN/ terminals have the same or greater pointing accuracy than land-based N/SATs operating on the same satellite. The attached table provides the transmission parameters and related data necessary to characterize the performance of the ESN/ systems operated by MTN. In addition. antenna radiation patterns have been attached that show the pole and cross-pole performance of the complete antenna system in the plane of the geo-stationary satellites. As can be seen from the data. these ESN/ terminals are operating within the performance requirements established by the FCC for all N/SAT earth stations and within the limitations established in the inter-system coordination agreement. If you have any questions on this notification. please contact: Robert Hanson N/ice President Regulatory Affairs — Maritime Telecommunications Network. Inc. 3044 N. Commerce Parkway Miramar, FL 33025 United States of America Telephone: 720-635-8162 Facsimile: 303-449-1272 E-mail: robert_hanson@mtnsat.com Raul R. Rodriguez Leventhal Senter & Lerman PLLC 2000 K Street. NW. Suite 600 Washington. DC 20002 United States of America Telephone: 202-4’9-8970 Facsimile: 202-293-7783 E-mail: rrodriguez@lsl-law.com Failure on your part to reply within 30 calendar days from the date of this notice will be construed as assent to the grant of MTN’s ESN/ application. Replies should be filed directly with the Federal Communications Commission, with copies to the individuals above .

Satmex-5 Value Orbital location 116.80W Beam Ku-2 Transponder 18K Modulation & Carriers Value Modulation TDMA Hub Uplink (GHz) 14.3694 Polarization Horizontal - Hub Downlink (GHz) 12.0694 Polarization - N/ertical ESN/ Uplink (GHz) 14.3698 Polarization Horizontal - ESM Downlink (GHz) 12.0698 Polarization - N/ertical ESV Antenna Value Major Axis (in) 1.35 Minor Axis (in) 1.20 Offset Angle (degrees) 23 TX gain at 14.25 GHz (dBi) 42.55 RX gain at 11.85 GHz (dBi) 41.65 TX cross-polarization at 14.25 GHz (dB) -34 RX cross-polarization at 11.85 GHz (dB) -43 ESV Power Value Input Power (Watts) 8 Data Rate (Kbits/s) 128 Occupied Bandwidth (KHz) 87 Transmit power (dBW) 9.03 Feeder loss (dB) 1.50 ESV Power Spectral Density Value Transmit power/BW (dBW/4OKHz) 5.66 TX power at antenna input (dBW/4OKHz) 4.16 Antenna main beam gain (dBi) 42.55 Transmit e.i.r.p. density (dBW/4OKHz) 46.71

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