Attachment Dismissed Letter

This document pretains to SES-MFS-20070607-00768 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2007060700768_585272

                                 Federal Communications Commission
                                          Washington, D.C. 20554

                                                                                                          DA 07—3614

                                                   August 14, 2007


Keith H. Fagan
Telenor Satellite, Inc.
1101 Wootton Parkway
10Floor
Rockville, MD 20852

                                                       Re: Call Sign E000285
                                                           File No. SES—MFS—20070607—00768

Dear Mr. Fagan:

         On June 7, 2007, Telenor Satellite, Inc. (Telenor) filed the above—captioned application to modify
the existing blanket authority for 1000 Inmarsat B mobile earth terminals (MET‘s) to permit the MET‘s to
communicate with the Inmarsat—3F4 satellite at the 142° W.L. orbital location. For the reasons stated
below, we dismiss the application as defective without prejudice to refiling.‘

        Section 25.112 of the Commission‘s rules, 47 C.F.R. § 25.112, requires the Commission to return,
as unacceptable for filing, any earth station application that is not substantially complete, contains internal
inconsistencies, or does not substantially comply with the Commission‘s rules. Telenor‘s application
contains several omissions and discrepancies that renders it unacceptable and subject to dismissal. These
deficiencies are as follows:

       (1) Telenor did not submit Schedule B with its application. Section 25.117(c) of the
Commission‘s rules, 47 C.F.R. § 25.117(c) requires applications for modification of earth station
authorizations to be submitted on FCC Form 312, Main Form and include a Schedule B.

          (2) Telenor submitted information required in Schedule S but did not provide other information
required by Section 25.114(d) of the Commission‘s rules, 47 C.F.R. § 25.114(d), for the Inmarsat—3F4
satellite. Section 25.137 of the Commission‘s rules, 47 C.F.R. § 25.137, requires applicants seeking to
operate with a non—U.S. licensed satellite to provide the same technical information regarding the satellite
as applicants seeking to operate U.S. licensed satellites. U.S. space station applicants must file FCC Form
312, together with Schedule S and other information required by Section 25.114(d) of the Commission‘s
rules.

         Without this information, we have insufficient technical information to make a finding that
authorizing a non—U.S. licensed satellite to provide service to the United States will not cause interference
to other authorized U.S. operations. Inmarsat—3F4 previously served the United States from the 54° W.L.
orbital location without interference. This does not ensure that it will operate without interference at the
142° W.L. orbital location. The interference potential of a particular satellite depends upon its orbital
spacing from adjacent satellites, the types of services the adjacent satellite is providing, and which

‘ If Telenor refiles an application, it should file it as an amendment to its remaining pending modification
application for this earth station, File No. SES—MFS—20060118—00053.


                                      Federal Communications Commission                            DA 07—3614


transponders it uses to provide those services. Thus, the interference potential of a satellite varies with its
orbit location. Without additional technical information, we cannot determine whether allowing
Inmarsat—3F4 to provide service to the United States will interfere with satellites operating in the same
portion of the orbital arc.

         Although not grounds for dismissal, we ask Telenor to address the following items in any refiling:

         (1) Please provide the location and telephone number of the TT&C control point in item S14 of
Schedule S;

         (2) Telenor lists the 1.5 GHz band as a downlink band and the 1.6 GHz band as an uplink band in
the link budget analysis. In response to item S2e of Schedule S, however, there appears to be a
transcription error in that the "T (for "transmit") and "R" (for "receive") are reversed for the two
frequency bands. A similar transcription error occurs in response to item S9d of the attached Schedule S.
We ask Telenor to correct these errors in any future filings.

        Accordingly, pursuant to Section 25.112(a)(1) of the Commission‘s rules, 47 C.F.R.
§25.112(a)(1), and Section 0.261 of the Commission‘s rules on delegations of authority, 47 C.F.R.
§0.261, we dismiss above—captioned application without prejudice to refiling."


                                                       Sincerely,                —
                                                                                     1



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                                                       Scott A. Kotler
                                                       Chief, Systems Analysis Branch
                                                       Satellite Division
                                                       International Bureau




* If Telenor refiles an application identical to the one dismissed, with the exception of supplying the corrected
information, it need not pay an application fee. See 47 C.F.R. Section 1.1109(d).



Document Created: 2007-08-14 16:10:52
Document Modified: 2007-08-14 16:10:52

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