Inmarsat Comments on

COMMENT submitted by Inmarsat Global Ltd.

Inmarsat Comments on Syterra ATC Mod

2009-07-06

This document pretains to SES-MOD-20090429-00536 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2009042900536_720952

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 In the Matter of ) ) Mobile Satellite Ventures Subsidiary LLC ) ) Application for Minor Modification of Space ) File No. SAT-MOD-20090429-00047 Station License (AMSC-1) ) ) Application for Minor Modification of Space ) File No. SAT-MOD-20090429-00046 Station License (MSV-1) ) ) Application for Minor Modification of Blanket ) File No. SES-MOD-20090429-00536 License to Operate Mobile Earth Terminals ) (MSAT-1) ) COMMENTS OF INMARSAT GLOBAL LTD. Inmarsat Global Ltd. (“Inmarsat”) submits these comments in support of the above- referenced applications (collectively, the “Application”) of SkyTerra Subsidiary LLC (“SkyTerra”) to modify its Ancillary Terrestrial Component (“ATC”) authority by waiving the application of certain technical rules and thereby enabling the increased operating flexibility made possible by the December 20, 2007 international satellite coordination agreement among Inmarsat, SkyTerra and SkyTerra (Canada) Inc. (“SkyTerra Canada”) (the “Coordination Agreement”). As the Commission is well aware, Inmarsat was an active participant in the ATC rulemaking proceeding and urged the Commission to ensure that the deployment of ATC did not result in harmful levels of interference into Inmarsat’s L-Band Mobile Satellite Service (“MSS”) system. As Inmarsat indicated at the time, doing so was particularly important because of the

absence of a satellite coordination agreement between Inmarsat and SkyTerra or SkyTerra Canada at that time (a circumstance that has since changed). In the ATC rulemaking, the Commission adopted technical rules that are designed to minimize the risk of ATC interference into Inmarsat’s L-Band MSS system. Wisely, though, the Commission also recognized that satellite operators might enter into new satellite coordination arrangements that could enable ATC to be deployed in ways that vary from the technical limits of the ATC rules, while still providing suitable levels of interference protection to other MSS systems. 1 As SkyTerra correctly explains, 2 following years of spectrum-related disputes, and after years of international negotiations and technical collaboration, Inmarsat, SkyTerra, and SkyTerra Canada entered into the Coordination Agreement, which effectuated the coordination of their current and next-generation L-Band satellite fleets, and thereby allowed substantially increased and more efficient use of the scarce L-Band spectrum resource. The Coordination Agreement also provided a mechanism by which SkyTerra may proceed with ATC deployment as proposed in the Application, including a phased process for implementing ATC, and a mechanism for replacing or modifying Inmarsat terminals to increase their resiliency to ATC interference. SkyTerra has asked that grant of the Application be conditioned upon the continued existence of 1 See Flexibility for Delivery of Communications by Mobile Satellite Service Providers in the 2 GHz Band, the L-Band, and the 1.6/2.4 GHz Bands, 18 FCC Rcd 1962, at ¶ 143 (2003) (“ATC Order”) (“We support and encourage private negotiations among interested parties in the band and will consider waiver requests of these rules based on negotiated agreements.”); 47 C.F.R. § 25.253(a)(2) and (3) (“[a]ny future coordination agreement between the parties governing ATC operation[s] will supersede this paragraph”). 2 Application Narrative at 7. 2

the Coordination Agreement, and SkyTerra’s operation of its ATC network in accordance with that agreement. 3 For these reasons, Inmarsat believes that grant of the Application not only is in line with the provisions of the Coordination Agreement but also is consistent with Commission policy. 4 Inmarsat urges the Commission to grant SkyTerra’s Application, on the terms that SkyTerra proposes. INMARSAT GLOBAL LTD. By: /s/ Diane J. Cornell Diane J. Cornell Vice President, Government Affairs Inmarsat, Inc. 1101 Connecticut Avenue, N.W. Suite 1200 Washington, D.C. 20036 Telephone: (202) 248-5155 July 6, 2009 3 Application Narrative at 16. 4 ATC Order at ¶ 143 (“We believe we have accurately analyzed the potential for interference from SkyTerra ATC transmitters to Inmarsat; however, we recognize that both Inmarsat and SkyTerra reach somewhat different conclusions on the circumstances under which interference would occur. . . . While we adopt rules to prevent harmful interference, we do not intend to prohibit L-band MSS operators from agreeing to less restrictive limitations on MSS ATC.”). 3


Document Created: 2009-07-06 14:50:07
Document Modified: 2009-07-06 14:50:07
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