Attachment STA grant

This document pretains to SES-STA-20051216-01760 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005121601760_476600

esvome sessrnasiziearrse inssc States Communicatons,Inc Approved by OMB 300—0678 APPLICATION For EARETH STATION SPECIAL TEMPORARY AUTHORITY APPLICANT INFORMATIONEnter a descripion of this application to identify t on the main menu: 60 Day STA for E000180 to Allow Transiton of Inmarsat M4 Service to New Inmarsat 4F2 Satelite 1. Applicant Name: Stratos Communications,In. Phone Number: sot—214—s800 DBA Name: Fax Number: sot—214—s801 Streets 6901 Rockledge Drive Suite 900 E—Mail: Cig: Bethesda State: mp usa Zipeote: 20817 — Legal Department , SES—STh— 2005 121e— 0! TeQ on sin ELCOE omipus 0 18l0€ oratier dentiieg TermDates From ©Vi8/c0 ns 03718706 Approce CamankuCTthowes (sllb)ed To afeched Reling Division Chief cenditions) See. attached conditions.,

Stratos Communications, Inc. TBFS File Nos, SES—STA—20051216—01760, SES—STA—20051216—01761, SES—STA—20051216— 01762, SES—STA—20051216—01763, SES—STA—20051216—01764 The request of Stratos Communications, Inc.(Strtos) fo specialtemporary authority (8TA) 1 GRANTED. Accordingly, Ststos is authorized from January 18, 2006 to March 19, 2006 to continue operations on the Inmarsat 4F2 satellite using mobile earth terminals (METs) previously authorized under call signs E00O180, EO10047, EO10048, EO10049, and E010050 to communicate with the Inmarsat 34 satellite in accordance with the terms, conditions, and technical specifications se frthin the Commission‘s rulesand this document. 1. Neither the ageregate uplink EIRP densities in the diection ofany other L—band stellite serving the United States, nor the downlink EIRP densities at any geographical point within the United States, shallbe increased as a result of continuance on the Inmarsat 42 satellite of operations previously authorized on the Inmarsat 3B4 satllte. 2.. Operations on the Inmarsat 4F2 sateliteshall be on an unprotected basis. Stratos shall not claim protection from, and is required to acceptinterference from, other lwfully operating satelites or radiocommunication systems. 3.. No laterthan February 17, 2006 a report must be submitted addressing whether,given the increased capacity of the Inmarsat 4F2 satellit relative tothe Iamarsat 3F4 satelite, there would be any discontinuznce of,or degradation of the reliability of, existing operations should access to the "leaned"spectrum be terminated. In the event that the report asserts that such discontinuation or degradation may occur, the report must nclude a deiled, quantitative explanation of the basis ofthis assertion. Any such explanation must also incluea lst of the end—users, including any U.S. government end—users, using METs that may operate in the "loaned" spectrum unde this STA, a point of contact (name and telephone number) for each such end—user, and the number of METs associated with each such end—user, Any such explanation,to the extentthat it caims that termination ofoperations on the "loaned" spectrum would degrade service on other frequencies, must include a isof the potentilly affected end—users,including any U.S. govermment end—users, using METs operating under this STA, a point ofcontact(name and telephone number)for each such end— user, and the number of METs associated with each such end—user. Should the U.S. government users not authorizedisclosure offrequencies orservices used on the "loaned" spectrum, the report must include a point of contact (name and telephone number)for thassociated end—user who can verify the govermment‘suse. For purposes ofthis condition, "loaned" spectrum is defined as those bandwidth segments that were loaned to Inmarsat by MSV and MSV Canada, ither as part of the Revised 1999 Spectrum Sharing Arrangement (October 4, 1999),or lateras biliteral arangements between Inmarsatand MSV and Inmarsatand MSV Canada. 4.. Any action taken or expense incurred as a result ofoperations pursuant to this special temporary authority is solly at Sratos‘s own risk. 5.. The grant o this STA is not based on a finding that Inmarsat‘s L—band operations are consistent with operation on a none—interference basis. 6.. The grant ofthis STA is without prejudice to any future determination that the Commission may make as to whether Inmarsat‘s L—band operations are consistent with operation on a non—interference basis. 7.. This STA may be terminated or modified atthe Itermational Bureau‘s disretion, without a hearing,if conditions warrant

Stratos Communications, Inc. IBES File Nos. SES—STA—20051216—01760, SES—STA—20051216—01761, SES—STA—20051216— 01762, SES—STA—20051216—01763, SES—STA—20081216—01764 8.. Stratos must notify its customes in writing no later than February 17, 2006 that operations on the Inmarsat 4F2 satelte are pursuant to a 60—day grant of special temporary authority that may be terminated or modifiedatany time. 9. Authority granted in this STA is without prejudiceto the disposiion of he underlying modification applications in BFS File Nos, SES—MFS—20051202.0166, SES—MFS—20051 122—01614, SES—MES— 20081122.01615, SES—MEFS—20051 122.01616, SES—MFS—20081 122.01617, SES—MEPS—20081 122— o1618, SEs—MFS—20051 123.01626, SEs—MFS—20051 123—01627, Sis—MEFS—20051 123—01629, Sis— MFS—20081 123—01630, and SES—MFS—20051207—01700. 10. This grant is issued parsuant t Section 0.261 ofthe Commission‘s rules on delegated authority, 47 CR § 0.261, and is effective immediately. 11. Stratos is afforded thiry days from the date ofrelease ofthis action to decine this special temporary authorization as conditioned. Failure to respond within this period will constitute formal acceptance ofthespecial temporary authorization as conditioned.

esone sessraamenicance maotors States Communicatons,Inc Approved by OMB 3060—0078 ArPLICATION For EAKTH STATION SPECIAL TEVPORARY AUTHORITY APPLICANT INFORMATIONEnter a description ofthis application to identify t on the main menu: 60 Day STA for EOOOT0 to Allow Transition ofInmarsat M4 Serviceto New Inmarsat 4F2 Satelite 1— Applicant Name: Stratos Communications, Ic Phone Number: 30t—214—sa00 DBA Name: Fax Number: sot—214—si01 Streets 6901 Rockledge Drive Sute 900 E—Mail: City Bethesda State: mb Countrys USA Zipeote: 20817 — Attention: Leyal Department

2. Contact Name: Alfred Mamlet Phone Number: anz—a29—c204 Companys Steptoe & Johnson LLP Fax Number: anr—429—3002 Streets 1330 Comectiut Ave, NW R—Mai: amainlet@steptoc.com City: Washington State: pe County: USA Zipeode: zu03e ~1795 Attentions Relationship: Legal Counsel [youapplication is rlated tanapplcation fled withthe Commission,eateeithe e ie namberorth TB Submissin ID of therelated lpplication. Mease enteronly one) 3. Reference File Number SESMFS20051 12201614 or Submission ID ‘s. 1 a Te submited with this application? @ 1fYes,complete and atach FCC Form 159. IfNo,indicate reason forfee exemption(see 47 C.ER.Section 1.1114) & Govermmental Entity gy Noncommercial educationallcensce @ Other(please cxplain} (ib Fee Classification COB— Mobile Stelite Rarth Stitions 5. TypeRequest @ Uss Prior to Gram @5 ChangeSation Location g Oter 6. Requested Use Pror Date onsrzoos 7. Ciy 3 Latinde (G4mmsssty 0. 0. 00

o. Sure 10. Longitude (Gémmssst) 0 0. 00 11. Plcase supply any need atachments: Atachment1 STA Application Attachment 2: Roe Declaration Aftachment 3: Cent ofService 12. Description. (Ifthe compleie description docs no appear i hisbox, please go to the ond oT the form to view t in ienircly) stratos Comunications, Inc. (‘Stratos‘) requests special temporary authority to allow for the transition of the Innareat M4 service currently provided by the Innareat 3 satellite lat 54 W.1. to the new Innarsat 472 satellite at 52.75 W.L. Please see the attached Inarrative application for additional. detail. 13. By checking Ves, the undersined certfes that nither applicantnor any other partyto theappliation is Y g No subject ta denialofFederal benefitsthatincludes PCC benefis pursuant to Section $301 of the Anti~Drag Act of 1988, 21 U.S.C. Section 862, beeause ofa comvictionfor possession or distibution of a contrlledsubstance See 47 CFR 1.2002(b) forthe meaning of&quotsparty o the application&equot; forthese purposes 14 Nome of Person Signing 15. Tite of Peson Signing Paol Kugelman Assistant Secretary wicUrL FALSE STATEMENTS MAbE ON Ts FORMARE PUNISHABLE BV FINE AND / oR IMPRISONNENT (US. Code, Tite 18, Setion 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (US. Code, Til 47, Setion 312(a)(1)AND/OR FORFETTURE (U.S, Code, Tite 47, Section 503.

ree Novice requikep By TiE MPERWORK REDUCTION ACT "The public reporting forthis cllectiono information is estmatedt average 2 hours er respons,includingthe time foeviewing insructions, searching exising data sources, pathering and maintaining the required dato, and completing and reviewing th colletion of information. Ifyou have any comments on this burden estimate,orhow we can improve the colletion and reduce the brden ausesyou, please wite t the Foderal Communications Commission, AMD~PERM, Paperwork Reduction Project (3060—067%), Washington, DC20554. We will alsoaccept your comments regarding the Paperwork Reduction Act aspects of this colletion via the Itemct i you send them tofboley@feeo. PLEASE bo NorsExp comrLetep FORMS To THIs AppREss Remember — You are notrequied t respond toa cllectiono information sponsored by the Federal overnment, and th govermment may not conduct or sponsorthiscollecton,unless it displays currenty valOMB control number orifwe fil to provide you with this notie..This callection has been assigned an OMB contol numbeof 3060—0676 Tik ForEGoING Norck is REqutRED By THE rAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 10+—13, OctoneR 1, 1954 Us.C. SECrION 307.

Stratos Communications, nc. STA Request Atachment A pesciurrion or sra rEquest 1y this applieation, Sratos Communications,Inc.(‘Strats")requestsgrant by Junuary 13, 2006 of specialtemporary authority (‘STA®)for sixty(60) days tallow Stratos to maintain existing servicesto ts currenty censed Inmarsat M terminals (cal:sign €000180) with the recenty launched fourth—generation Inmarsat satelte to be ocated at 52.75° W.L. (Inmarsat 42") No new serviceisimpliated bythis request. Stratos merely wants to continue to provide essentil services, which have been leensed fr more than four years, to the U.S. armed forees, Federal Emergency Management Ageney(FEMA®), U.S.Const Guard, U.S. law enforeement, Fist Respondersfrom stat and local govermment, and important private sector customens. Strtos recently Ailed a modification applcation (Fie No. SES—MFS—20051 122« 01614) foreal—sign EOOOT8O in orderto add the Inmarsat 4F2 asa poin ofcommunication. Strtos hereby incorporates by reference that modifiction application and its technical details and materil for purposes ofthis STA request. The Stratos modification appliation was placed on Public Notice on December7, 2005, and the time o file any Petitions andor Comments on this modification application expies on January 6, 2006. On November 30, 2005, Mobile Satelite Ventures Subsidiry LLC CMSV®) fled a N o Intent to Partcipate, and in addition, it fleda Motionto designatethe proceeding as "permit—but—disclose.Sze MSV Notice of Intent to Paticipate (Nov. 30, 2005); Motion to Designate Procesdings As "PernitBut— Disclose" (Nov. 30, 2005) Since October 2001, Srtos has been censed by the FCC to provide Inmarsat services domesticall in the United Sttes, includingthe operation ofInmarsat B, C, M, min—M and M4 terminals." As set forth in the attached Declaration of Robert J Roe, Senior Vice President of Salesfor Strtos, Strtos‘s customers for Inmarst services encompassa wide range of U.S. cutomens,including the U.S, milta, the Federal Govemment, state and local governments and private sector end—wsers. SeeDeclarstion of Rober J.Roe at $ 5 (Atachment B). U.S. miltary usersinclude: the U.S. Army, Navy and Air Force. S Declaration of Robert 3. Roe at 6. Federal Govermment usersinclude:the State Department,the FCC, FEMA, the ‘ Additional modificationapplications were fled to modify the cal—signs associated with the Strtos Hcensesto provide th Inmarsat M., mini—M, B and C services. Similr STA requests are being filed foreach ofthese services. * Sbs «2. /ntheMaterofCOUSITCorporationds COMUSHTAobile Communicationsetat, 16 FCC Red 21661 (rl. Oct.9, 2001) (*/nmarsarMarketdecess one‘).

U.S. Const Guard and the Federal Bureau ofnvestigntion. Sbe Declaration ofRobert J. Roeat 1 7.e and local govemment customers include: New ork Fire Department, Los Angeles Fire Department and National Guard Units estoring devastated areasimpacted by the recent hurricanes in the Gulf. Sbe Declaration ofRobert J. Roeat 8. ULS. private sector customers include: Chevron/Texaco,Global Santa Fo and Edison International (parent company of Southem Califomia Edison). S Declaration oRobert J. Roe at 9. As setforh n File No. SES—MFS—20051122—01614, the Inmarsat 4F2 is licensed by the United Kingdom and willbelocatedat the 52.75° W.L. orbital location.. It was Iaunched on November 8, 2005, As sefoth in No. SES—MFS—20051 122—01614, grant ofthe modification application is in the public interest, is consistent with the ORBTT Act and satsies the Commission‘s A/5CO//standard.® Absent authorit to communicate withthe Inmarsat 4F2, Strats will not b ableto contiueto provide the Inmarsat M servie, censed undercalsign E000180, o ts existing orfture customers because the M4 service, along withother Inmarsat services (Including B, C, M and min—MD, willbe migrated from the third generation Inmarsat satelite currently at 54W.L.t the Inmarsat 4F2 sotelt at 52.75° W.L. Inmarsat is scheduled to migratethese services tothe Inmarsat 4F2 on January 15, 2006. Stratos hasbeen informed by Inmarsat that maintining this schedule is necessiry because the Inmarsat 3 satelite curentlyat $4° W.Lneedsto be moved to 142 W.L. where it wll replacea second generation Inmarst satelite, which is running outoffuel and needs to be decommissioned shortly. This second genertionstelite at 142° W.L. is currently providing essentialInmarsat leaseservicesto the U.S. Navy and U.S. Cost Guard. SeDeclration of Robert J Roe at 4. An untimely migntion ofthe "existing and evalved servics"from the hird genertion Inmarsatsotllite to the new Inmarsat 4F2 satllte would eopardizethe continuty of these essentil services currently being provided by the second generation satelt athe 142" W.Lorbital location. Sinceth current Public Notice period fotheStratos modifietion applicationis scheduled o expire on January 6, 2006 and MSV hasalready indicated ntentto artcipate in this aplication proceeding, Sratos believes tha it ulikely that thInterational Bureau will be ableto act on the modifiationapplication in advance of the scheduled January 15, 2006 migration of the Inmarsat M4 service t the new Inmarsat 4F2 satelte at 52.75° W.L." Accordingly, Strtos is requestingthis STA to ensure that there is no disruption ofsrviceto Strtos‘s existingInmarsat M# customers when Inmarsat migratesthe sevices o the new sutelite. * Sbed7 US.C. §761 ersey. * SteAmentnentofthe Commizsion‘sPolicestoAltowNon—US LiccnsedSpace Sutions ProvidingDomesticandInternationalServiein the UnitedStes, 12 ECC Red 24094 (1997@asco77) * n l lkelihood, Stratos and MSV will e n the middle ofthe pleading eyle for the Strtos modification application.

Grant ofthis STA request is in the publc nteest. As set frthabove,the Inmarsat services provided by Stratos are used not only by privatindustry, but also by the U.S. militay, Federal Govermment, and state and local government. The Inmarsat services are used bytheseenttes to faciltate militay communications,law enforcement and homeland securty, emergency relieeffots, protctlives and safeguard property and to provide critcal communications services to support business opertions in remoteareas. SeeDeclarat of Robert J. Roe at 9 5—8, Grant of his STA request will ensure thatthese end—users do not experience any disuptionto the Inmarsat servicesthey currently use and rely on. As stated by Mr. Roe,"Inmarsatservices are used and criallyreied upon by govemment ‘First Responders‘and private industry, as a flexible and mobile backupto terresral voice and data communications networks in the event tht t naturaldisaster otrroist atack takes place." SeeDeclaration of Robert J. Roe at9 10. Any disuption to the Inmarsat services used by First Responders would seiously compromisethir abilty o accomplish thei riial missions. Abe Declaration of Robert J.Roe at 3 10. "The necessity ofInmarsatservices was clearly demonstrted ithe aftermath of hurricanes Katrina, itand Wilma in the Gulf of Mexico. Inresponse to these devastating naturl disssters, Strtos saw a noticeableincrease in the demand for the Inmarsat srvices it distribates. Several monthslater, Inmarsat srvices continueto playa vital role in the Gulf o Mexico region in comnection with the recovery and restoration effors being undertaken by FEMA, the National Guard, the U.S. Army,state and local governments, law enforcement personnel and the peroleum industry.* See Declaration of Robert . Roe at 9 11. Inthe words of Chairman Martin: Ifwe learned anything from Hurricane Katrina, it is that we cannot rely solely on terestrl communications. When radio towers are knocked down, satelte communications are, in some instances, the most effetive means ofcommunicating, See Writen Statement ofChairman Kevin . Martn at the Hearing on Communications in a Disaster before the U.S. Senate Committec on Commerce, cience and Transportationat 7 (Sept. 22, 2008). The grant ofthis STA would ensure thatther is no disnuption in sevice to these end« users currenty using and relying upon Inmarsat services. "The Inmarsatservices which currenty are being provided over the Inmarsat satelteat54* W.L.can and will be provided over the Inmarst 4F2 at 2.75° WJL. without adversely affcting the interference environment that exists today with respectt other operating L—Band spacecraft. Specifially,() the EIRP spectrl density of the proposed carriers on the Inmarsat 4F2 willbeno greater than the EIRP spectral densty othesame services provided today over the Inmarst sateit at 5¢° W.L. (3)the out—oband emissions fom the Inmarsat 4F2 cariers willnot exceed th imis of §25.202(0 (1), 2) and (3),and (i no greater protection from interfrence into the Inmarsat 4F2 spacecrat ort Inmarsat mobile eath terminals, beyond thelevelofprotectionthat exiss today, is sought. In sum, duringthe erm of this STA, theseservices can and wll be provided on Inmarsat4F2 in the technical envelope pursantto which these services are curretly provided on thethrd generation Inmarsat stelite currenty located at 5# W.L.

Strtos understands that grant of this equested STA willbe without prejudiceto, and will be conditioned on,the Bureau‘s action on the underlying modifiction application (File No. SES—MFS—20051 122—01614)to modify call—sign E000180 to add the Inmarsat 4F2 as an authorized point of communication. For the reasons st forth above, Stratosrespectflly requests thatthis STA be uranted no atethan January 13, 2006for sinty (60) days. * January 13, 2006 is the las business day before the planned January 15, 2006 cut—over to the Inmarsat 4F2 satelteof the "existing and evalved" services.

DECLARATION OF ROBERT J. RoE 1, Robert J. Roe, hercby declareas fllows: T am Senior Vice President of Sales for Stzatos Communications,Inc. (*Stratos") 2 Stratos currently holds licenses from the FCC o operate Inmarsat B, C, M, mini—M and M4 terminals in the United States, As set forth in these censes, these Inmarsatterminals are permitted to communicate with a third generation Ininarsatsatelfte currently located ar se WiL. Stratos ecently submitted applieations t the FCC to modify these lcenses in order to add as a newpoint ofcommunication, a recently launched fourth generation Inmarsat satellite ("the Inmarsat 4F2")to be located at $2.75° W.L 1tis my understanding that the Inmarsat 4E2 sarelte willreplace the third generation Inmarsat satelite located at $4° W.L., and thi third generation satllte willbe moved by Inmarsatto 142° W.L., where it willreplace a second generation Inmarsatsatllte thatis being decommissioned. Stratos currently provides Inmarsat lease services over the second generation Inmarsat satelteat142° W.L.to the U.S. Navy and Coast Guard. Stratos provides Inmarsat services to a wide range of U.S. miltary, federal government, state and local government, and private sector end—users in the United States. "The U.S. militry uses Inmarsat services provided by Stratos t faciitate communications between the Navy‘s ships and militrycommand enters on land, special forces operating in remote areas, and for personal communications for miltary troops. Some of Stratos‘ U.S. military customers using the Inmarsatservices iclude: United States Army, Navy and Ar Foree.

"The Federal Govermment uses Inmarsat services provided by Stratos for emergency relief effort, law enforcement and homeland security. Some ofStratosfederal government customers ofthe Inmarsat services include: State Department, Federal Emergency Management Agency (*FEMA*), the U.S. Coast Guard and the Federal Burcau of Investigation. Like the Federal Government, state and local governments routinely use the Inmarsat services provided by Statos for lawenforcement and in order to protectlives and safeauard property. Some ofStratos state and local government customers of the Inmarsat services include: New York Fize Department, Los Angeles Fire Department and National Guard Units restoring devastated areas impacted by the recent storms. "The private sector, including numerous companiesin the oil and gas industy, use the Inmarsat services provided by Stzatos in order to provide citial communications services supporting their business operations in remote areas. Statou‘s U.S. private sector customers ofthe Inmarsat services include: Chevron/Texaco, Global Santa Fe and Hidison International(parent companyof Southem California Edison}. There is significant use ofInmarsat services being used by these frms today to restore operations devastated in the Gulfof Mexico 10. The Inmarsat services are used and crtically relied upon by government "First | Responders®and private industry, as a flexible and mobile backup to terrestrial voice and data communications networks in the event of a natural disastr,terorist attck, takes place. In particular, any disruption t the Inmarsat services used by First Responders would seriously compromise their abityto accomplish their criical missions.

11. The necessity of Inmarsa servies was clearly demonstated in the aflermath of hurricanes Katrina, Rtite and Wiliain the Gulf of Mexieo. In response tothese devastating natural disastes, Stratos saw a noticcale increase in the demand forthe Inmansat services it distbutes, Several monthslatr,Inmarsat services continue to play a vital role in the Gulf of Mexico region in connection with t recovery and restoration effors being undertaken by FEMA, the National Guard, the U.S. Army, state and local govermments,law enforcement persounel and the peroleum industy, 1, RobertJ.Roe,hersby declare under penalty ofperury underthe laws of the United States that the foregoing is tm and correctto the best of my knowledge,information and belie. ?&é?u Senior Vice President ofSales Strtos Communications,Inc. Executed on December {S, 2005.

CERTIFICATE OF SERVICE 1, Brendan Kasper, an attomey with th law firm of Steptoe & Johnson LLP, hereby cerify that on this 16th day of December,2005, served a true copy ofthe foregoing "STA Request," by fistclass mail, postage pre—paid (or as otherwise indicated) upon the following: James Ball* Andrea Kelly® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Stret,SW. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® International Bureau Intermational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S. W 445 12° Street,SW Washington, DC 20554 Washington, DC 20554 Howard Gribot® Karl Kensinger® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W 445 12"Street, S.W. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnck® Jennifer A. Manner International Bureau Vice President, Regulatory Affairs Federal Communications Commission Mobile Satelite Ventures Subsidiary LC 445 12° Street, S.W 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 Robert Nelson® Bruce D. Jacobst* International Bureau David S. Konezal Federal Communications Commission Pilsbury Winthrop Shaw Pittman LLP 445 12" Street, S.W. 2300 N Stree, NLW Washington, DC 20554 Washington, DC 20037—1128 bruceacobs@pillsburylaw.com JoAmn Ekblad* davidkoneral@pillsburylaw.com International Bureau Federal Communications Commission John P.Janka® 445 12" Stret,S.W Jeffiey A. Murks Washington, DC 20554 Latham & Watkins LLP 555 Eleventh Street, N.W., Suite 1000 Washington, D.C. 20004 * by electronic mail ** by Hand Delivery and electronic mail


Document Created: 2006-01-19 11:42:58
Document Modified: 2006-01-19 11:42:58
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