Ex Parte Notice - 11

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Amtech Systems LLC

Notice of Ex Parte Presentation

2009-11-18

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

IBFS_SESMOD2009042900536_781761

Colleen King 1776 K STREET NW November 18, 2009 202.719.7307 WASHINGTON, DC 20006 cking@wileyrein.com PHONE 202.719.7000 FAX 202.719.7049 7925 JONES BRANCH DRIVE VIA IBFS McLEAN, VA 22102 PHONE 703.905.2800 Marlene H. Dortch FAX 703.905.2820 Secretary Federal Communications Commission www.wileyrein.com 445 12th Street, S.W. Washington, DC 20554 Re: Amtech Systems LLC, Notice of Ex Parte Presentation, File Nos. SAT-MOD-20090429-00047, SAT-MOD-20090429- 00046, SES-MOD-20090429-00536 Dear Ms. Dortch: In accordance with Section 1.1206 of the Commission’s rules, 47 C.F.R. § 1.1206, this letter notifies the Commission that on November 17, 2009, George McGraw, Executive Vice President of Operations for Transcore, and Tom Houtman, an engineering consultant to Amtech Systems LLC (“Amtech”), and David Hilliard and the undersigned of Wiley Rein LLP, counsel for Amtech, met with Stephen Duall, Kathyrn Medley, William Bell, and Sylvia Lam of the FCC’s International Bureau to discuss SkyTerra Subsidiary LLC’s pending ATC waiver applications. Amtech reiterated positions consistent with its filings in this proceeding and presented the attached handout. Sincerely, /s/ Colleen King Colleen King cc: Stephen Duall Kathyrn Medley William Bell Sylvia Lam

Amtech Systems LLC Presentation to Satellite Division International Bureau November 17, 2009

Introduction • Amtech holds the FCC licenses authorizing the operation of tens of thousands of mobile earth terminals (METs) that would receive harmful interference from SkyTerra’s proposed ATC operations, if certain requested waivers are granted. • Transcore currently provides 22,000 Amtech-licensed METs (with 7,000-10,000 added annually) to end-user customers. These terminals, used on trucks and trains, are the heartbeat of the transportation industry. – Customers include the Department of Defense (DOD), the Tennessee Valley Authority, the Washington State Department of Transportation, the American Red Cross, Southern California Edison, Union Pacific and over 500 private trucking firms. • Roper Industries is the parent company of both Amtech and Transcore. Roper is a diversified growth company, with a broad customer base in end-markets that include water, energy, transportation, education, and healthcare. 2

Procedural History of SkyTerra’s Pending ATC Application • On April 29, 2009, SkyTerra filed an application for waiver of certain technical rules in the deployment of its ATC operations. • On July 10, 2009, Amtech filed a Petition to Deny, explaining that SkyTerra’s proposed operations would harm Amtech’s customers. – SkyWave Mobile Communications, Corp. filed comments presenting similar concerns. – Inmarsat and Mississippi Department of Public Safety filed comments in support. • On July 23, 2009 SkyTerra filed a Consolidated Opposition. • On August 4, 2009, Amtech filed a Reply to SkyTerra’s Consolidated Opposition. 3

Overview of Amtech’s Concern • Principal Technical Concern: – SkyTerra's proposed waiver of Section 25.253(d) would allow ATC base stations to operate at higher power than the current rule requires. – This higher power level will expand dramatically the exclusion zones around ATC base stations in which Amtech’s METS will experience harmful interference. – Expanded area from 200 meter radius to greater than 3 kilometer radius. • Impact on Amtech Customers: – SkyTerra suggests Amtech has no customers and will be unharmed by its proposed higher power ATC base station operations. In fact, Amtech provides service to over 22,000 customers. – Grant of SkyTerra’s application will degrade service for these and future Amtech customers in large geographic areas. 4

Overview of Amtech’s Concern • SkyTerra’s Agreement with Inmarsat Does Not Support Waiver: – SkyTerra requests the FCC waive its technical rules in deference to the SkyTerra-Inmarsat inter-operator coordination agreement. – The agreement is not public and there is no reason to believe it benefits anyone other than the two parties. – Private agreements do not condone non-compliance with FCC rules. – The harm to Amtech customers undermines any good cause to support SkyTerra’s requested waiver. – This is particularly true given that the Commission decided to permit ATC networks to operate only if they caused no harmful interference to primary MSS operations. 5

Principal Technical Issues • Increased interference • Elimination of Out of Channel Emissions (OOCE) restrictions protecting land mobile terminals • Coordination of frequency allocation cannot prevent intermodulation interference. • Terminals are at risk in both urban and suburban environments. 6

Interference Mechanisms • LNA-Mixer Saturation – -52 dBm with > 2 MHz separation – -60 dBm with < 2MHz separation • Intermodulation – -70 dBm from FCC analysis • Out of Channel Emissions 7

Interference Ranges Interference Ranges -30 Signal Level - WI-LOS Propagation, 42 dBW ATC EIRP -40 Overload Limit - > 2MHz Separation Overload Limit - < 2MHz Separation -50 Signal Levels (dBm) -60 -70 IM Overload Limit -80 -90 Signal Level - WI-LOS Propagation, 31.8 dBW ATC EIRP -100 -1 0 1 10 10 10 Range (km) 8

Out of Channel Emissions • General requirement replaced with aeronautical and marine specific requirements • No protection for land mobile terminals • SkyTerra ex parte submission of Oct 27: “all base stations within the same OOCE limit” • Specious argument: impossible to predict OOCE interference generally without radiated PSD level or equivalent information • The Commission has already established power levels in Section 25.253 of the rules that permit operation of terminals without interference. SkyTerra has not shown good cause to waive these rules. 9

Terminal Locations – Los Angeles 10

Terminal Locations - Brooklyn 11

Terminal Locations – The Bronx 12

Financial Impact to Our Company and Customers • Our Customers – 550 customers with over 22,000 Mobile Satellite Terminals – Adding 7,000 to 10,000 new terminals a year – Specific impact to a customer • Purchase replacement terminal • Pull the asset to which the terminal is attached into repair depot – Remove old unit – Install new unit – Dispose of old unit properly [they have Lithium batteries] – These will not be happy customers as they all purchased expecting 5 to 10 years of use • The Company – We’ll have to engage every customer explaining why what they bought will no longer work • Recompete for their business starting from adverse position • We would expect significant lose of current customers • This effort will give competitors significant advantage • In summary our customers will wake up one day and the system they rely on to run their business will not work when in urban areas with ATC service. 13

Conclusion • Amtech respectfully requests that the FCC deny SkyTerra’s request for waiver of Section 25.253 of the rules. • If the waiver is granted, it should be conditioned on SkyTerra complying with its obligation to operate on a non-harmful interference basis including, if necessary, funding the replacement of Amtech’s METs. 14


Document Created: 2009-11-18 16:13:11
Document Modified: 2009-11-18 16:13:11
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