Attachment Opposition

Opposition

OPPOSITION submitted by Inmarsat Ventures Limited

Opposition

2006-04-06

This document pretains to SES-MFS-20060130-00172 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2006013000172_493549

Before the RECQ'B&G l N A L FEDERAL COMMUNICATIONs commISSION or — 6 2006 Washington, DC 20554 APR Fedea Conmunicatens Comniion In the matter of ) Offev t Sertay Telenor Satellie, Inc. ) File No. SES—MFS—20060130—00172 OPPOSITION OF INMARSAT VENTURES LIMITED Inmarsat Ventures Limited ("Inmarsat") opposes the Petition to Hold in Abeyance (‘Petition") of Mobile Satellite Ventures Subsidiary LLC (MSV"). This proceeding involves a request by Telenor Satellite, Ic. ("Telenor") for license modifications to permit the provision of already—authorized Inmarsat services using a new point of communication — the Inmarsat—3 satellte at 142° W.L. ("T—3"). 1—3 has replaced the Inmarsat—2 ("L—2") spacecraft previously operating at 142° W.L., which was running out of station—keeping fuel. No one opposes the grant of Telenor‘s application. However, as with every other earth station application filed since August 2005 that seeks authority to communicate with the Inmarsatsatellte network, MSV secks to delay Commission grant." Specifically, MSV asks that the Commission not grantthis appliation untilInmarsat coordinates the operation of 3 with MSV and with the Canadion satellte system licensed to MSV Canada. MSV specifically requests that Inmarsat coordinate use ofthe 1545.8—1548 MHz band segment, portions of which Inmarsatdisagrees with MSV‘s charaeterization (see Petitionat 2—3) regarding the ongoing L—Band spectrum dispute between Inmarsat and MSV. Inmarsat has fully briefed this issue in prior pleadings and incorporates by reference a recent pleading that summarizes Inmarsat‘s positions on these issues, See Opposition of Inmarsat, File No. SES—MFS—200601 18—00050, t al. (filed Mar. 16, 2006) (with Consolidated Opposition ofInmarsat, File No. File No: SES—MFS—20051207—01709, eral. (filed Feb. 2, 2006) attached thereto as Exhibit A}.

MSV assertsare not currently available for Inmarsat‘s use. There is no basis to delay grant of authority as MSV requests. As an initial matte, there is no dispute about the 1545.8—1548 MHz band. Different portions ofthis band segment are currently used today by Inmarsat and by MSV, without any known interference problems. Moreover, Telenor is today clarifying that it does not seek authority to use the portions of this band segment being used by MSV. With regard to the 142° W.L. location, MSV ignores the fact that Inmarsat successfully operated its12 spacecraft at that location for over four years. Moreaver,in the absence of a new spectrum sharing agreement under the Mexico City MoU, Inmarsat intends to employ on 13 the very same L—Band frequencies that Inmarsat has been using for years to serve the United States. Thus, Telenor‘s request for authority to communicate with 13 cannot be expected to have any adverse interfrence effect on MSV, and MSV presents no technical evidence to the contrary. Furthermore, grant ofthis application is fully consistent with the recent grant of MSVs application to operate a new and uncoordinated L—Band MSS spacecraft at 63.5° W.L * That application was granted justlast year without anyobligation being imposed on MSV to effectuate coordination with Inmatsat prior to launching or operating MSV‘s spacecraftHere (asthe Commission found in MSV‘s case)" no other L—Band system in the vicinity of the United States could use the L—Band spectrum currently used by Inmarsat to serve the United States. Thus, the replacement of 2 at 142° W.L. with 1:3 will have no adverse interference effect on mSv. * Mobile Satellite Ventures Subsidiary LLC, Applicationfor Authority to Launch and Operate an L—band Mobile Satellte Service Satellite at 63.5° WL., 20 FCC Red 479 (2005). s T4.

Moreover, contrary to what MSV implies, Inmarsat has repeatedly attempted to coordinate ts North American fleet operations with MSV, but MSV has rebuffed those efforts citing "other‘" business issues that MSV wishes to address prior to continuing such a dialogue.* Fortunately, ITU Radio Regulations do not provide MSV with the right to veto Inmarsat‘s need to replace a dying satellite with one that will operate in a technically consistent manner." «++ For the foregoing reasons, the Commission should deny MSV‘s Petition and grant Telenor‘s application without any conditions, other than requiring that,in the absence of a new spectrum sharing agreement, service be provided on a non—harmful interference basis. Respectfully submitted, Diane J. Comell Johnl P. Japka AL Vice President, Government Affairs Teffrey A. Marks Invarsat, Ivc. Laman & Waans LLP 1100 Wilson Blyd, Suite 1425 555 Eleventh Street, N.W. Arlington, VA 22209 Suite 1000 Telephone: (703) 647 4767 Washington, D.C. 20004 Telephone: (202) 637—2200 April 6, 2006 * See Inmarsat Consolidated Response, File No. SES—STA—20051216—01756 eral, at 9—11 (Jan. 6,2006). 5 TTU Radio Regulation, Appendix 5 (Rev. WRC—03), AP—5—2 at 1 6(b)(c) (no further coordination required (i) when the technical characteristis of a new or modified frequency assignment are within the limits of those of a frequency assignment which has previously been coordinated; or(i) when the characteristics of an existing assignment are changed in such a way as not t increase interference to or from, as appropriate, the assignments ofother administrations).

CERTIFICATE OF SERVICE 1, Jeffrey A. Marks, hereby certify that on this 6th day of Apri, 2006, I caused to be served a trie copy of the foregoing "Opposition of Inmarsat Ventures Limited," by first class mail, postage pre—paid (or as othervise indicated) upon the following: James Ball® Andrea Kelly* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street,SW. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® Interational Bureau Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street,SW. Washington, DC 20554 Washington, DC 20554 Howard Gribott® Karl Kensinger® Intemational Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street,SW. 445 12"Street, S.W. Washington, DC 20554 Washington, DC 20554 Roderick Porter® Gardner Foster® International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnek® John Martin® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12"Street, S.W. Washington, DC 20554 Washington, DC 20554 Robert Nelson® JoAnn Ekblad* International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20584

Stephen Duall® Richard Engelman* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12"Street, S.W. 445 12" Street,SW. Washington, DC 20554 Washington, DC 20584 Keith H. Fagan Jennifer A. Manner Telenor Satelite, Inc. Vice President, Regulatory Affairs 1001 Wootton Parkway Mobile Satellite Ventures Subsidiary LLC Rockville, MD 20852 10802 Park Ridge Boulevard Reston, Virginia 20191 Bruce D. Jacobs David S. Konezal Pillsbury Winthrop Shaw Pittman LLP 2300 N Street, N.W. Washington, DC 20037—1128 *Via Electronic Mail


Document Created: 2006-04-10 12:47:59
Document Modified: 2006-04-10 12:47:59
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