Attachment MTN>FCC 4/22

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

IBFS_SESLIC2001113002259_371201

LEVENTHAL S ENTER & LERMAN PLLC April 22, 2004 RAUL R. RODRIGUEZ E-MAIL (202) 416-6760 RRODRIGUEZ@LSLLAW.COM Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: Maritime Telecommunications Network Application File No. SES-LIC-20011130-02259; Call Si2n E010332 Dear Ms. Dortch: I am writing to you on behalf of Maritime Telecommunications Network, Inc. (“MTN”), in response to Mr. Howden’ s letter of March 31, 2004 concerning the referenced application, and consistent with our recent telephone conversations with Mr. Howden regarding this matter. The letter requested that MTN explain the “discrepancies” between the application as originally filed in November 200 land the interference analysis filed with adjacent satellite operators and copied to this application file on January 16, 2004 and on February 23, 2004. MTN agrees that certain earth station characteristics have changed since the filing ofthe application. Advances in technology now allow MTN to provide the same level of service using a smaller antenna. Accordingly, MTN has changed its system configuration with resulting efficiency gains in transmission bandwidth and power. The net result is that even though the antenna system has some notable differences (e.g., the reflector diameter has been reduced from 2.4 m to 1.2 in), the transmit spectral density is approximately 8 dbW/4KIHz less than the previous system and, therefore, the potential for interference is also considerably less. For these reasons, the change should be considered a minor modification and not require a major amendment. Please see the attachment to this letter that compares several technical characteristics between the 2001 application and more recent developments. MTN is prepared to amend its application, but respectfully requests that the modification be considered “minor,” and thus avoid the amended application’s being placed on public notice. Please consider that the original application was filed in 2001, and as recently as only two months ago, MTN served all possibly affected adjacent satellite operators with detailed interference analysis, and that no party has an objection pending with respect to the application’s “modified” technical charactenstics. In the interest of conserving Commission resources and the C rvS ~EiVNV<S — (<[ ) ~ kno) LEPc<)V< ~OI~<IC-~; ~-=< < S CO~i

Ms. Marlene H. Dortch April 22, 2004 Page -2- reasonably expeditious processing ofpending applications, we urge the Commission to permit MTN to file a ~~minor~~ modification to reflect changes in technology and its business plan since 2001, and not to require a major modification with the resulting further delay in the processing of this application. If the Commission does not concur in this request, MTN is prepared to file whatever amendment is deemed appropriate. In furtherance of this request, and to avoid any possible doubt, MTN reiterates the commitments it filed with the Commission in this proceeding with respect to points of communication, muting, notice to adjacent satellite operators, 24-hours point-of-contact and acknowledgment of subjectivity to the pending rule making on ESV operations. MTN hereby incorporates by reference its letter of January 16, 2004 filed in this proceeding concerning the commitments enumerated in this paragraph. Please contact MTN’s undersigned counsel with any questions or concerns with respect to this letter or the underlying earth station application. Respectfully submitted, Counsel to Maritime Telecommunications Network, Inc. RRRAj c Attachment cc: Mr. Bill Howden

Attachment The following table demonstrates the differences between the transmit characteristics of the original 2.4 m system and the new 1.2 m system. Comparison New Original Input Power (Watts) 7.06 14.1 Data Rate (Kbits/s) 384 384 Occupied Bandwidth (KHz) 349.19 349.19 Transmit power (dBW) 8.49 11.49 Reference BW Correction Factor (dBW/4KHz) 19.41 19.41 Transmit power/BW (dBW/4KHz) -10.92 -7.92 Feeder loss (dB) 6 6 TX Power at antenna input (dBW/4KHz) -16.92 -13.92 Antenna main beam gain (dBi) 42.55 47.50 Transmit e.i.r.p. density (dBW/4KHz) 25.63 33.58


Document Created: 2019-04-09 11:00:52
Document Modified: 2019-04-09 11:00:52
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