Attachment Comments

Comments

COMMENT submitted by Horizon

Comments of Horizon

2008-05-02

This document pretains to SES-PDR-20080303-00367 for Petition for Declaratory Ruling on a Satellite Earth Station filing.

IBFS_SESPDR2008030300367_639327

Before the FEDERAL COMMUNICATIONS COMMISSION F/,IJD/Ac~~~~~ Washington, D.C. 20554 In the Matter of Request to Streamline Licensing of SES-PDR-20080303-00367 L-band User Terminals Using lnmarsat ) Satellite as Points of Communication 1 COMMENTS OF MOBILECOMMUNICATIONS, HORIZON INC. Horizon Mobile Communications, Inc. (“Horizon”) submits these Comments in support of the Petition for Declaratory Ruling (“PDR’) filed by Inmarsat, Inc. (“Inmarsat”) proposing that the International Bureau (the “Bureau”) make a ministerial change in the way that it specifies authorized points of communication in lnmarsat L-band’ user terminal licenses. The Commission has granted Horizon Special Temporary Authority (“STA”) for user terminal licenses with authority to communicate with lnmarsat spacecraft. Currently, Horizon must apply for individual authority for each Inmarsat user terminal to communicate with multiple lnmarsat spacecraft. Inmarsat’s proposal would permit applicants and licensees to seek authority to communicate with all lnmarsat spacecraft that have been approved for U.S. service in the L-band, by designating “ISAT” as the desired point of communication. The term “ISAT” would refer to all Inmarsat spacecraft that are contained on a list to be maintained by the ’ The L-band, as described in these Comments, refers to Inmarsat’s coordinated spectrum in the United States. The L-band encompasses frequencies from 1525-154411545-1 559 MHz and 1626.5- 1645.U1646.5-1660 MHz. The frequencies 1525-1544 MHz and 1626.5-1645.5 MHz are referred to as the “lower L-band” and 1545-1559 MHz and 1646.5-1660.5MHz are referred to as the “upper L- band.”

Commission, and would automatically provide authority to communicate with future Inmarsat L- band spacecraft once those spacecraft have been approved for U.S. service. Because L-band user terminals are authorized to communicate with Inmarsat spacecraft today on a spacecraft-by-spacecraft and orbital-location-by-orbital-locationbasis, each time that Inmarsat launches or relocates a satellite to serve the United States, a licensee of earth terminals must seek authority for the new point of communication. The current procedural process results in numerous, repetitive applications and modifications. Inmarsat’s proposed streamlining approach would obviate the need for such additional, duplicative filings. Designating “ISAT” as a point of communication in L-band user terminal licenses that authorize service with Inmarsat satellites would provide significant public interest benefits and is consistent with Commission policy. Streamlining the licensing process would minimize regulatory delay, conserve Commission resources, and speed service to the public. The Inmarsat proposal is consistent with Commission policy because it would not adversely affect the interference environment, the obligation to make all required technical and regulatory showings would remain unchanged, and it is consistent with other procedural streamlining mechanisms the Commission has adopted for other satellite services.2 For the foregoing reasons, Horizon respectfully submits its support of Inmarsat’s proposal and requests that the Commission create a list of all Inmarsat spacecraft that are approved to provide L-band service to the United States. In addition, Horizon requests that the 2 Intelsat North America, LLC, Application for Authority to Mod& Earth Station Authorization to Provide Launch and Early Orbit Phase (“LEOP ‘7 operationsfor Newly Launched Satellites, File Nos.: SES-MOD-20050615-00751, SES-AMD-20051116-01587, Call Sign E040125, Order and Authorization, DA 06-2557 7 14 (rel. Dec. 21, 2006); Amendment of the Commission’s Regulatory Policies to Allow Non-U S. Licensed Space Stations to Provide Domestic and International Satellite Service, First Order on Reconsideration, 15 Rcd 7207 f 16 (1 999). 2

FROM :SQTCOM Distribution FRX ND. :215 541-1009 May. 02 2008 10:32RM PI Commissiou modify Hori )XI'S existing authority to communicate with lnnxirsat spacecraft to specify ' I s A ' r as h e der :naledpoint of L;ornmiinictltion,3and allow applicants for and licensecs of lirture user tt! iinnls to specify 441SAT'" as the d c s i p t c d point of corninmication, thereby providing authori to communicate with all lnmnrsut spacecraft that arc npprovcd from time lo time to serve thc 1 ii led States. Kespeclliilly submitted, Adam C. Tliompaun President Horizon Mobilc Comtniuications, Inc. 22SO Skyview Lane Harleysvjlle, PA 10438 May 2,2008 Horizon rcspct.fully that, i.l:the Commission acts favcirably on the Timarsat PDR, the Commission authority to opcrate mobile earth station terminals utidcr Call Sign as the designated point of' communication. See File Nos. 3


Document Created: 2008-05-07 14:41:37
Document Modified: 2008-05-07 14:41:37
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