Attachment NTIA 8 4 04 OK

This document pretains to SES-LIC-20030311-00353 for License on a Satellite Earth Station filing.

IBFS_SESLIC2003031100353_395936

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08/05/04   THU 0 6 ~ 4 7FAX-202   501 8189            NTIA/OSM/SP&P                                          moo2
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                                                               UNITED STATES DEPARTMENT OF COMMERCE
                                                               N . t i d Talecommunkations and
                                                               Infomutkrr AdmirrhtrotiOrr
                                                               Washington. D.C. 20230


                                                    August 4,2004
                                              i ,
     Thomas Tycz
     Chief, Satellite Division
     International Bureau
     Federal Communications Commission
     Washgton, DC 20544

     RE:     NTLA Letter to FCC Dated March 19,2004
             SkyWave Mobile Communications, C o p .
             Radio Station Authorization
             File No. SES-LIC-20030311-00353
             Call Sign E030055

      Dear Mr. Tycz:                                       *


      This is a supplement to the letter I wrote io you concerning SkyWave on March 19,2004. After
      further consideration I would like to supplement our comments on one of the issues addressed,
      whether SkyWave should be authorized pursimnt to a waiver to the guidelines in the Lower Lband
      Report and Order (IBDocket No. 96-132). In my March 19, letter I suggested that in granting the
      authorization, a waiver of the footnotes US315 and S5.353A to Section 2.106 of the FCC's Rules
      should not be necessary given the modifications to the mobile earth terminals proposed by
      Skywave in its application and in discussions with NTIA. We continue to believe that these
      changes are an approach to operating METs in the shared band that would protect safety and
      distress communications in the GMDSS. On this basis, we continue to have no objections to a
      grant for a 15-year license term. However, after further consideration, we believe that granting the
      SkyWave application pursuant to a waiver would be the most appropriate way to proceed and
      would be consistent with the guidelines set forth in the lower L-band Report and Order. As
      technological advances are made in MET technology, the FCC and NTIA may wish to revaluate
      the priority and preemption requirernem in right of the technological evolution of these terminals.


                                                     Sincerely             ,    p;



                                                     Fhief, International ~pectrum~lans
                                                             and Policy Division

      CC      SylviaLam
              Cassandra Thomas



Document Created: 2004-09-13 13:28:25
Document Modified: 2004-09-13 13:28:25

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