Letter re O3b earth

LETTER submitted by O3b Limited

Letter regarding earth station license conditions

2014-12-12

This document pretains to SES-MOD-20140814-00652 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2014081400652_1071004

O3b Limited 900 17th Street, NW Suite 300 Washington, DC 20006 www.o3bnetworks.com December 12, 2014 VIA ELECTRONIC FILING Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Room TW-A325 Washington, D.C. 20554 Attn: Satellite Division, International Bureau Re: Earth Station License Conditions SES-MOD-20140814-00652 (call sign E100088) SES-MOD-20140814-00654 (call sign E130021) SES-MOD-20140814-00655 (call sign E130098) Dear Ms. Dortch: The above-referenced earth station modification applications filed by O3b Limited (“O3b”) request modification to earth station licenses that authorize communication with O3b’s space stations. For the reasons stated below, O3b requests that the Commission consider modifying or removing certain license conditions when it acts upon these earth station modification applications. O3b has been granted access to the U.S. market via earth station licenses that specify O3b’s UK- licensed space stations as points of communication. Because the earth station licenses provide market access for O3b’s space stations, the earth station licenses include conditions relating to the space stations in addition to including conditions relating to the earth stations. O3b has filed a Petition for Declaratory Ruling in which it: (i) requests access to the U.S. market for four new satellites O3b will be launching; and (ii) for administrative convenience, requests consolidation of the U.S. market access authority for its already-operating satellites with the U.S. market access authority for its four new satellites. Once these requests are granted, O3b will have a single authorization, independent of any earth station licenses, that will provide access to the U.S. market for its space station constellation.

Upon action on the Petition for Declaratory Ruling, therefore, the conditions in the above- mentioned earth stations that relate to O3b’s space stations will become unnecessary. The space station matters addressed by the conditions will at that point be covered by the conditions associated with O3b’s space station market access authorization. Accordingly, O3b asks that the Commission review earth station license conditions listed in Attachment A, and modify or remove them as appropriate, when it acts on the above-referenced earth station modification applications. Please direct any questions to the undersigned. Sincerely, /s/ Suzanne Malloy Suzanne Malloy Vice-President, Regulatory Affairs O3b Limited +1 202 478 7183 suzanne.malloy@o3bnetworks.com

Attachment A E100088 E130021 E130098 (Hawaii) (Texas) (Maritime) Description Conditions # Conditions # Conditions # Transmissions are limited to TT&C/GW; prohibition 90033 90089 - against operation with any other earth station 90035 90035 90035 Ephemeris data Ka band plan waiver: limitations on downlink 90036 90083 6610 transmissions 90037 90084 - PFD limits for space stations Completion of coordination with Federal systems (space 90038 90085 6607 station obligation) 90041 90041 90041 Cross-pol waiver 90043 90043 90043 Processing rounds 90044 90044 6597 Service area coverage requirement 90045 90045 6598 Orbital debris 90047 90088 6608 Milestones 90048 90048 90075 30 days to decline the authorization


Document Created: 2014-12-12 16:13:42
Document Modified: 2014-12-12 16:13:42
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