Attachment Comments

Comments

COMMENT submitted by Amtech

Comments of Amtech

2008-04-30

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

IBFS_SESPDR2008030300367_639331

ORIGINAL Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 FILED/ACCEPTED APR 302008 Federal Communications Commlssron In the Matter of ) Office of the Secretary ) Request to Streamline Licensing of L-band 1 User Terminals Using Inmarsat Satellites as ) SES-PDR-20080303-00367 Points of Communication ) ) COMMENTS OF AMTECH SYSTEMS LLC Amtech Systems LLC (“Amtech”), by its counsel, hereby submits these Comments in support of the Petition for Declaratory Ruling 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 Inmarsat L-band’ user terminal licenses. Amtech holds two FCC blanket mobile earth station licenses with the Inmarsat 3F4 spacecraft at 142” W.L. as an authorized point of communication. Currently, Amtech must apply for modification of its earth station licenses each time it seeks to communicate with a new Inmarsat satellite or an existing Inmarsat satellite in a new orbital location. Inmarsat’s proposal would create an “ISAT” list of Inmarsat spacecraft that have been approved for U.S. service in the L-band and automatically add “ISAT” as a point of communication in existing earth station licenses that specify an Inmarsat satellite as a point of communication. Amtech supports this proposal as it would automatically expand Amtech’s authority to communicate 1 The L-band, as described in these Comments, refers to Inmarsat’s coordinated spectrum in the United States. The L-band encompasses frequencies from 1525-1544/1545- 1559 MHz and 1626.5-1645.5/1646.5-1660MHz. 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- 1660.5 MHz are referred to as the “upper L-band.” 1

with lnmarsat L-band spacecraft once those spacecraft have been approved for U.S. service. Designating “ISAT” as a point of communication in L-band earth station licenses would provide significant public interest benefits. Streamlining the earth station licensing process would minimize regulatory delay, conserve Commission resources, and speed service to the public, The lnmarsat proposal also shifts the obligation to provide the required technical and regulatory showings from the earth station licensee to the satellite operator in possession of such information, thus ensuring more accurate FCC filings. Moreover, it is consistent with other procedural streamlining mechanisms the Commission has adopted for other satellite services.’ For the foregoing reasons, Amtech supports Inmarsat’s proposal and requests that the Commission create a list of all lnmarsat spacecraft that are approved to provide L-band service to the United States. In addition, Amtech requests that the Commission modify Amtech’s existing two blanket earth station licenses (call signs E9903 16 and E0301 20) to specify “ISAT” as a designated point of communication,3 and allow Amtech and other prospective earth station licensees to specify “ISAT” as the designated point of 2 Iiztelsat North America, LLC, Applicatioiz.for Authority to Modib Earth Station Autlzorizarion to Provide Laurzclz aizd Early Orbit Phase ( “LEOP”) operatioris.for Newly Launched Satellites, File Nos.: SES-MOD-20050615-00751, SES-AMD-2005 1 1 16-01587, Call Sign E040125, Order and Authorization. DA 06-2557 ¶ 14 (Dec. 21,2006) (designating “LEOP” as a new point of communication); Public Notice, “International Bureau Satellite Engineering Branch Information: Revisions to Earth Station Licenses Authorized to Access INTELSAT,” Report No. SPB-172 (July 20,2001) (removing conditions on the use of Intelsat satellites for domestic service following Intelsat’s privatization).Ailze17drl~e1zrof the Coiizmissioiz ’s Regulatory Policies to Allow Non- U.S. Licensed Space Stations to Provide Donzestic aizd Interrzatioizal Satellite Service, First Order on Reconsideration, 15 FCC Rcd 7207 q( 16 (1999) (creating the “Permitted List” of non-US licensed satellites and granting authority for routine C- and Ku-band earth station licensees to communicate with Permitted List satellites ). 3 See File No. SES-MFS-20070511-00637 (Call Sign E990316) (granted Mar. 27, 2008); File No. SES-MFS-20070511-00638 (Call Sign E030120) (granted Mar. 27,2008). 2

communication in future applications, thereby providing authority to communicate with all Inmarsat spacecraft that are approved from time to time to serve the United States. Respectfully submitted, J"n= e: din Car Colleen King Wiley Rein LLP 1776 K Street NW Washington, DC 20006 TEL: 202.719.7000 FAX: 202.719.7049 Counsel for Amtech Systems LLC April 30,2008 3

CERTIFICATE OF SERVICE I, Pam Conley, do hereby certify that on April 30, 2008, I served a copy of Amtech Systems LLC's Comments upon the following parties by first-class U.S. mail: Diane J. Cornell John P. Janka Vice President, Government Affairs Jeffrey A. Marks Inmarsat, Inc. Latham & Watkins LLP 1101 Connecticut Avenue, N.W. 555 Eleventh Street, N.W. Suite 1200 Suite 1000 Washington, D.C. 20036 Washington, D.C. 20004 ,..--., ' i Pam Conley U 4


Document Created: 2008-05-07 14:33:40
Document Modified: 2008-05-07 14:33:40
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