Letter to FCC re Agr

AGREEMENT submitted by SkyTerra Subsidiary LLC and the U.S. GPS Industry Council

Ex Parte Letter

2009-08-13

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

IBFS_SESMOD2009042900536_731265

                                                  August 13, 2009

Via Electronic Filing (IBFS)

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

           Re:        Ex Parte Letter
                      SkyTerra Subsidiary LLC
                      File Nos. SAT-MOD-20090429-00046, SAT-MOD-20090429-00047, SES-
                      MOD-20090429-00536


Dear Ms. Dortch:

        We are pleased to inform you that, in connection with the above-referenced applications
of SkyTerra Subsidiary LLC (“SkyTerra”) to modify its Ancillary Terrestrial Component
authorization (the “ATC Modification Application”), the U.S. GPS Industry Council (“Council”)
and SkyTerra have agreed on out-of-band emissions (“OOBE”) limits for the operation of low-
power base stations with a maximum EIRP of -4 dBW/MHz that are intended to be deployed
indoors (“femtocells”) and personal computer (“PC”) data cards communicating with such base
stations.1 Specifically, SkyTerra will limit OOBE for femtocells and data cards communicating
with such femtocells to less than -114.7 dBW/MHz and -111.7 dBW/MHz in the 1559-1605
MHz band, respectively. These limits are intended to reduce the potential for harmful
interference to GPS receivers operating indoors, thereby addressing the concerns expressed by
the Council in its Comments regarding the ATC Modification Application.2

        SkyTerra and the Council therefore urge the Commission to adopt the OOBE limits set
forth in this letter as a license condition to the grant of the ATC Modification Application.




1
    The reference to “PC data cards” is intended to mean RF devices that work in conjunction with a PC or laptop
    computer, including external PC devices, such as USB modems, Type II PC cards, and ExpressCards, and
    internal PC devices that provide the same data communications functionality as such external devices. The
    reference is not intended to include handsets that are capable of voice and data transmissions independent of a
    PC, even if such device could function as an external PC modem.
2
    See Comments of the U.S. GPS Industry Council (July 10, 2009). The Council is separately filing a letter
    withdrawing its Comments, as a result of this agreement.


401365679v3


        Please direct any questions regarding this matter to the undersigned.

                                                       Respectfully submitted,



SkyTerra Subsidiary LLC                              The U.S. GPS Industry Council

By:            /s/                                   By:          /s/
        Bruce D. Jacobs                                    Raul R. Rodriguez

        Pillsbury Winthrop Shaw Pittman LLP                 Leventhal Senter PLLC
        2300 N Street, NW                                   2000 K Street, NW
        Washington, DC 20037                                Washington, DC 20006-1809
        Counsel for SkyTerra Subsidiary LLC                 Counsel for the U.S. GPS Industry
                                                            Council




cc (via email):

William Bell
Howard Griboff
Kathyrn Medley
Robert Nelson




                                                 2
401365679v3


                                CERTIFICATE OF SERVICE

       I, Renee Williams, a secretary with the law firm of Pillsbury Winthrop Shaw Pittman

LLP, hereby certify that on this 13th day of August 2009, I served a true copy of the foregoing

by first-class United States mail, postage prepaid, upon the following:


Tom Houtman                                       Jennifer D. Hindin
Director, Product Development                     Carl R. Frank
SkyWave Mobile Communications, Inc.               Colleen King
SkyWave Mobile Communications, Corp.              Wiley Rein LLP
1145 Innovation Drive, Suite 288                  1776 K Street NW
Ottawa, Ontario                                   Washington, DC 20006
Canada K2K 3G8                                    Counsel for Amtech Systems LLC

Diane J. Cornell                                  John P. Janka
Inmarsat, Inc.                                    Latham & Watkins LLP
1101 Connecticut Avenue, N.W.                     555 Eleventh Street, NW
Suite 1200                                        Suite 1000
Washington, DC 20036                              Washington, DC 20004-1304
                                                  Counsel for Inmarsat, Inc.


                                                            /s/
                                                            Renee Williams



Document Created: 2009-08-13 13:31:37
Document Modified: 2009-08-13 13:31:37

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