Attachment FCC>MTN 4/30

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

IBFS_SESLIC2001113002259_371202

                              Federal Communications Commission
                                    Washington, D.C. 20554


                                                             April 30, 2004


Raul Rodriguez, Esq.
Leventhal, Senter & Lerman, PLLC
2000 K Street, N.W.
Suite 600
Washington, D.C. 20006
Telephone: 202-429-8970


        Re:      Maritime Telecommunications Network Application,
                 File No. SES-LIC-2001113-002259, Call Sign: E010332



Dear Mr. Rodriguez:
         The Satellite Division is currently reviewing Maritime Telecommunications Network’s (“MTN”)
application for authority to operate earth stations on vessels utilizing the Ku band. As part of the
application process and pursuant to a request by the Federal Communications Commission, MTN served
adjacent satellite operators with an interference analysis. As noted in our Clarification Request,1 we have
identified certain discrepancies between the information contained in MTN’s application and the
interference analysis served on adjacent operators. In response, MTN admits to the presence of such
discrepancies but requests a preliminary opinion from the Commission that any amendment to its
application to correct such discrepancies would be a minor amendment.2 At this time, we decline to
provide MTN with the preliminary opinion it requests. Instead, as explained below, MTN is directed to
amend, by May 17, 2004, its pending application SES-LIC-2001113-002259 so that it conforms to the
system described in material served on adjacent operators, or its application will be dismissed without
prejudice to refiling.
         MTN is advised that its amendment should include all the changes identified by the Commission
or MTN in the correspondence listed in this letter. MTN’s amendment should also include, but should
not be limited, the name of the manufacturer and the model of the proposed antenna with a statement as to
whether the antenna conforms to Section 25.209(a) of the Commission’s Rules; values for input power
and power density and for emission power and power density; and specific points of communication.
Finally, we also advise MTN to file as an attachment to their amendment a statement responding, for the
amended proposed operation, to the items listed in the Commission’s letter of December 2003.3
Specifically, MTN should include in its attachment responses to questions on: Points of Communication;
Pointing Accuracy within 0.2 degrees; Muting; 24 Hour Contact; Acknowledgement that any license will
1
 Letter from William Howden, Chief, Systems Analysis Branch, Satellite Division, International Bureau, to Mr.
Raul Rodriguez, Leventhal, Senter & Lerman, PLLC, March 31, 2004 (Clarification Request).
2
 Letter from Mr. Raul Rodriguez, Leventhal, Senter & Lerman, PLLC, to William Howden, Chief, Systems
Analysis Branch, Satellite Division, International Bureau, April 22, 2004.
3
 Letter from William Howden, Chief, Systems Analysis Branch, Satellite Division, International Bureau, to Mr.
Raul Rodriguez, Leventhal, Senter & Lerman, PLLC, December 12, 2003.


be subject to the outcome of any future Rule Making; and petition for appropriate waiver of Section 2.106
of the Commission’s rules, for non-conforming use of FSS frequency bands for an ESV application.
        MTN is also directed to serve a copy of its amendment and any attachments included on operators
of adjacent satellites, on the same date as its filing of the amendment with the Commission.4 If you have
any questions, you may contact me at 202 418 2343.

                                                              Sincerely,


                                                              William Howden
                                                              Chief, Systems Analysis Branch
                                                              Satellite Division



cc:     Robert Hanson, Vice President — Regulatory Affairs
        Maritime Telecommunications Network, Inc.
        3044 N. Commerce Parkway
        Miramar. FL 33025

        John Forsey
        Director
        New Satellite Ventures & International Coordination
        Telesat Canada
        1601 Telesat Court
        Gloucester, ON K1B 5P4




4
  If MTN should serve its amendment and any accompanying attachments upon operators of adjacent satellites, the
operators would have 30 days from the receipt of such revised interference analysis to file comments or objections
with the Commission. Any such revised interference analysis should specifically notify operators of adjacent
satellites of the period within which to file comments or objections.



Document Created: 2004-04-30 14:14:49
Document Modified: 2004-04-30 14:14:49

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