Attachment Comments

Comments

COMMENT submitted by iPass

Ipass, Inc. comments in support of petition for declaratory ruling

2008-05-02

This document pretains to SES-LIC-20070712-00933 for License on a Satellite Earth Station filing.

IBFS_SESLIC2007071200933_639323

W I L K I N S O N ) BARKER) i K N A U E RL L P 2300 N SUITE STREET, 700 WASHINGTON, NW DC 20037 TEL 202.783.4141 FAX 202.703.5851 ORIGINAL www.wbklaw.com ROBERT G. M O R S E 202.383.3393 rmorse@wbklaw.com May 2,2008 Marlene H. Dortch Secretary Federal Communications Commission 445 Twelfth Street, SW Washington, DC 20554 Attn: Robert Nelson, Chief International Bureau, Satellite Division Re: iPass Inc. File No. SES-LIC-20070712-00933 Call Sign E070144 Dear Ms. Dortch: The attached letter was filed in support of Inmarsat, Inc.'s petition for declaratory ruling in File No. SES-PDR-20080303-00367. Please include the attached letter in the above- referenced file, as it relates to issues raised in that application. An original and two copies are submitted. WILKINSON BARKER KNAUER,LLP By:

In the Matter of 1 1 Request to Streamline Licensing of L-band ) File No. SES-PDR-20080303-00367 User Terminals Using Inmarsat Satellite as ) Points of Communication ) TPASS, INC. COMMENTS IN SUPPORT OF PETITION FOR DECLARATORY RULING iPass Inc. (“ipass”) hereby submits these Comments in support of the Petition for Declaratory Ruling filed by Inmarsat, Inc. (“Inmarsat”) proposing that the International Bureau (the “Bureau”) make a ministerial change in how it specifies authorized points of communication in Inmarsat L-band user terminal licenses.’ iPass is an applicant for a Commission user terminal license for authority to communicate with Inmarsat spacecraft.2 Currently, s a s s must apply for individual authority for each Inmarsat user terminal to communicate with multiple Inmarsat spacecraft. Inmarsat’s proposal would permit applicants and licensees to seek authority to communicate with all Inmarsat spacecraft that have been approved for U.S. service in the L-band, by designating “ISAT” as the desired point of communication. The term “ISAT” would refer to all Inmarsat spacecraft that are I The L-band, as described in these Comments, refers to Inmarsat’s coordinated spectrum in the United States. The L-band encompasses frequencies from 1525-1544/1545-1559M H z and 1626.5- 164531646.5-1660 MHz. The frequencies 1525-1544 MHz and 1626.5-1645.5 M H z are referred to as the “lower L-band’ and 1545-1559 MHz and 1646.5-1660.5 MHZ are referred to as the “upper L-band.” 2 See File No. SES-LIC-20070712-00933, Call Sign E070144. $ass has separately applied for and obtained Special Temporary Authority in connection with this pending application. See File Nos. SES- STA-209070716-00944, extended SES-STA-20080205-00 121, requestforhrther extensionpending SES-STA-20080407-00430.

contained on a list to be maintained by the Commission, and would automatically provide authority to communicate with fbture Inmarsat L-band spacecraft once those spacecraft have been approved for U.S. service. Because Lband user terminals are authorized to communicate with Inmarsat spacecraft today on a spacecraft-by-spacecraft and orbital-location-by-orbital-location basis, each time that Inmarsat launches or relocates a satellite to serve the United States, a licensee of earth terminals must seek authority for the new point of communication. The current process results in numerous, repetitive applications and modifications. Inmarsat’s proposed streamlining approach would obviate the need for such duplicative filings. Designating “ISAT” as a point of communication in L-band user terminal licenses that authorize service with Inmarsat satellites would provide significant public interest benefits and is consistent with Commission policy. Streamlining the licensing process would minimize regulatory delay, conserve Commission resources, and expedite service to the public. The Inmarsat proposal is consistent with Commission policy because it would not adversely affect the interference environment, applicants’ obligation to make all required technical and regulatory showings would remain unchanged, and it is consistent with other procedural streamlining mechanisms the Commission has adopted for other satellite service^.^ For the foregoing reasons, *ass strongly supports Inmarsat’s proposal and requests that the Commission create a list of all Inmarsat spacecraft that are approved to provide L-band 3 Intelsat North America, LLC, Application for Authority to Modi?j Earth Station Authorization to Provide Launch ana‘ Early Orbit Phase (“LEOP’Y operations for Newly Launched Satellites, File Nos. SES-MOD-20050615-00751, SES-AMD-2005II16-01587,CalI Sign E040125,Order and Authorization, DA 06-2557,v 14 (rel. Dec. 21, 2006); Amendment ofthe Commission s Regulatoly Policies to Allow Non-US. Licensed Space Stations to Provide Domestic and International Satellite Service, First Order on Reconsideration, 15 FCC Rcd 7207,T 16 (1999).

service to the United States. In addition, *ass requests that the Bureau’s grant of *ass’s pending application for a license to communicate with Inmarsat spacecrafi specify “ISAT” as the designated point of comm~nication,~ and allow applicants for and licensees of hture user terminals to specifL “ISAT” as the designated point of communication, thereby providing authority to communicate with all Inmarsat spacecraft that are approved from time to time to serve the United States. Respecthlly submitted, &,&? Bruce Posey fq3 Senior Vice President, General Counsel and Corporate Secretary 3800 Bridge Parkway Redwood Shores, CA 94065 (650) 232-4100 May 2,2008 4 This designation would be reflected in File No. SES-LIC-20070712-00933, and a copy of the instant filing is being submitted in that proceeding. See Public Notice, “International Bureau Satellite Engineering Branch Information: Revisions to Earth Station Licenses Authorized to Access INTELSAT,” Report No. SPB-172 (IB rel. July 20,200 1) (modifying specified earth station licenses to provide domestic service using INTELSAT satellites without requiring that the earth station licensees file license modification requests).


Document Created: 2008-05-07 14:39:54
Document Modified: 2008-05-07 14:39:54
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