Attachment ESV letter

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

IBFS_SESLIC2001113002259_443907

                                  Federal Communications Commission
                                           Washington, DC 20554
International Bureau




                                                    July 26, 2005
       Raul R. Rodriguez
       Leventhal Senter & Lerman PLLC
       2000 K Street, NW., Suite 600
       Washington, DC 20006

                                                            Re: Call Sign: E010332
                                                                SES—LIC—20011130—02259
                                                                SES—AMD—20040518—00680
                                                                SES—AMD—20040812—01173
       Dear Mr. Rodriguez:

                 On November 30, 2001, Maritime Telecommunications Network Inc. (MTN)
       filed the above—captioned application, and amended it on May 18 and August 12, 2004.
       For the reasons stated below, we request MTN to amend the subject application.

               MTN seeks authority to operate a VSAT network on the Fixed—Satellite Service
       11.7—12.2 GHz and 14.0—14.5 GHz Ku—band spectrum. The VSAT network consists of up
       to ten earth stations on board U.S.—flagged ships at any location in U.S.— and adjacent
       waters, including when stationary at piers. We note that MTN‘s proposed use of the14.0—
        14.2 GHz band, which is shared with the Government space research service, has been
       successfully coordinated through NTIA. MTN also provided information in response to a
       Systems Analysis Branch inquiry.

               On December 15, 2004, the Commission adopted a number of new rules
       applicable to the type of operations contemplated under MTN‘s application, known as the
       operation of Earth Stations on Vessels (ESVs).‘ The substantive requirements of these
       rules took effect on March 2, 2005 and June 15, 2005." Specifically, we request that
       MTN demonstrate compliance, pursuant to Section 25.222 of the Commission‘s rules,
       with the following Ku—band ESV requirements:

       e    Ku—band ESV operators must meet an off—axis EIRP spectral density envelope as

       ‘   Procedures to Govern the Use of Satellite Earth Stations on Board Vessels in the 5925—6425
       MHz/3700—4200 MHz Bands and 14.0—14.5 GHz/11.7—12.2 GHz Bands, Report and Order, IB Docket No.
       02—10, FCC 04—286, 20 FCC Red 674 (2005).

       *‘   See 70 F.R. 4775 (Jan. 31, 2005) and 70 F.R. 34665 (June 15, 2005).


    described in 47 C.F.R. § 25.222(a)(1) through (5). Therefore, we request a
    demonstration as required by 47 C.F.R. § 25.222(b)(1), (2), or (3).

e   All emissions from the ESV shall automatically cease within 100 milliseconds if the
    angle between the orbital location of the target satellite and the axis of the main lobe
    of the ESV antenna exceeds 0.5 degrees, and transmission will not resume until such
    angle is less than 0.2 degrees (see 47 C.F.R. § 25.222(a)(7)). We request that MTN
    demonstrate how the proposed operation will comply with this requirement.

       Further action on the subject application will be withheld in order to provide
MTN an opportunity to respond to this letter. MTN is required to respond, by
amendment to the subject application, by August 10, 2005. Failure to do so will cause
the Commission to promptly dismiss the application without prejudice pursuant to
Section 25.112(c) of the rules. See 47 C.F.R. § 25.112(c).


                                              Sincerely,


                                               DuoDA Mokhrn
                                              Scott A. Kotler
                                              Chief, Systems Analysis Branch
                                              Satellite Division



Document Created: 2005-07-26 14:09:33
Document Modified: 2005-07-26 14:09:33

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