Attachment Cover Letter

This document pretains to SES-MOD-20120308-00251 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2012030800251_943293

LAWLER, METZGER, KEENEY & LOGAN, LLC 2001 K STREET, NW SUITE 802 WASHINGTON, D.C. 20006 STEPHEN J .BERMAN PHONE (202) 777-7700 FACSIMILE (202) 777-7763 March 8, 2012 Via Electronic Filing Mindel De La Torre Chief, International Bureau Federal Communications Commission 445 Twelfth Street, S.W. Washington, D.C. 20554 Re: Notification of Minor Modification of Fixed Earth Station Facility GUSA Licensee LLC SES-MFS-20091221-01601; Call Sign E030266 Dear Ms. De La Torre: Pursuant to Section 25.118 of the Federal Communications Commission’s (“FCC’s” or “Commission’s”) rules, 47 C.F.R. § 25.118, GUSA Licensee LLC (“Globalstar USA”) hereby notifies the Commission of a minor modification to its licensed fixed earth station facility in Clifton, Texas.1 This fixed earth station facility is used to conduct in-orbit testing (“IOT”) of Globalstar Inc.’s (“Globalstar’s”) Big LEO mobile satellite service (“MSS”) constellation. This testing includes initial in-orbit assessment of payload performance, as well as subsequent performance monitoring, maintenance, and station-keeping for Globalstar’s MSS satellites. On February 9, 2012, Globalstar USA modified the Clifton IOT facility by replacing the earth station antenna with an improved model. The new antenna has higher antenna gain, but will be operated at a considerably lower power level. The net effect of this modification is a reduction in maximum EIRP for these earth station operations (22.6 dBW for the new antenna versus 24.0 dBW for the prior antenna). Accordingly, deployment of the new IOT antenna constitutes a minor modification under Section 25.118(a) of the Commission’s rules. This minor modification is fully consistent with Globalstar USA’s existing earth station authorization, including the FCC’s waiver of Footnote 5.364 of the Table of Allocations.2 1 Globalstar was granted authority by the International Bureau to operate this earth station facility on October 14, 2010. GUSA Licensee, LLC; Application to Operate a Fixed Earth Station in the 1610-1618.725 MHz Band at Clifton, Texas for In-Orbit Testing, Order and Authorization, 25 FCC Rcd 14411 (IB 2010) (“Clifton Earth Station Order”). 2 Clifton Earth Station Order ¶¶ 5-10.

Ms. Mindel De La Torre March 8, 2012 Page 2 This upgrade to the Clifton IOT facility should enhance the performance of Globalstar’s MSS constellation, prolong the life of its satellites, and help ensure that Globalstar’s Big LEO operations remain compliant with Commission rules and the terms of its MSS license. Please do not hesitate to contact me with any questions. Respectfully submitted, /s/ Stephen J. Berman Stephen J. Berman


Document Created: 2019-05-07 15:24:37
Document Modified: 2019-05-07 15:24:37
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