Attachment ERRATA

ERRATA

ERRATA, ERRATUM OR ADDENDUM submitted by Stratos Communications, Inc.

ERRATA

2006-01-05

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

IBFS_SESSTA2005121601760_483314

STEPTOE &JOHNSON“P arrormeys at taw MareA Paul 1110 Connectiat Avence. NW roramous« Washington. DC 20036795 moaulBseproccom Tel2024203000 rax2024203002 seproccom January 5, 2006 BY HAND DELIVERY Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street NW Washington, DC 20554 Re:=— Stratos Communications, Inc. ERRATA for File Nos, SES—STA—20051216—01760, SES—STA—20051216—01761, SES—STA— 20051216—01762, SES—STA—20051216—01763 and SES—STA—20051216—01764 Dear Ms. Dortch: Stratos Communications, Inc.("Stratos") herebyfilesthis "Erata‘"to correct certain typographical errors in the above—captioned requests for special temporary authorization. While each of the FCC 312 forms for the above—captioned requests contain the correct information regarding the relevant call—signs and services provided, there were severaltypographical errors in the narrative descriptions attached to these requests. The typographical errors which Stratos seeks to correct are as follows: SEs—sTA—20051216—01760 (£000180 * In the last paragraph of page 1 of Attachment A, the FCC should be deleted from the list of government customers forthe Inmarsat services distributed by Stratos. wasimnoron + wew york +. rotnix +/ tos anorits +. tonpon +. arbsstis

STEPTOE &JOHNSON= Marlene H. Dortch January 5, 2006 Page 2 Ss—sTA—20051216—01761 (£010047 * In the last paragraph of page 1 of Attachment A, the FCC should be deleted from the list of government customers for the Inmarsat services distributed by Stratos * In fist full paragraph ofpage 2 of Attachment A, the references in sentence 4 to "Inmarsat M4" should refer to "Inmarsat Mservice and the call—sign reference to "£000180" should read ©E010047." In addition the parenthetical listing the other Inmarsat services should read "including B, C, M4 and Mini—M." * In the last paragraph of page 2 of Attachment A, the last sentence should refer to "Inmarsat M customers" and not "Inmarsat M4 customers." * In the first paragraph of page 4 of Aftachment A, the referenced file number should read "SES— MFS—20051122—01618" and the call—sign should read ©E010047." Shs—STA—20051216—01762 (£010048 In first paragraph ofpage 1 of Attachment A, the referenced call—sign should be E010048." In third paragraph of page 1 of Attachment A, the first sentence should refer to "File No. SES— MFS—20051122—01616" and to "call—sign E010048." * Footnote 1 of Aftachment A should refer to "Inmarsat M4, M, B, and C services." In the last paragraph of page 1 ofAftachment A, the FCC should be deleted from the lstof government customers for the Inmarsat services distributed by Stratos. * —In first fll paragraph on page 2 of Attachment A, thfirst sentence should refer to "File No. sEs—MFS—20051122—01616." * In first fll paragraph on page 2 of Attachment A, the second sentence should refer to "File No. ses—vFs—20051122—01616." * In first full paragraph on page 2 of Attachment A, the references in sentence 4 to "Inmarsat M" should refer to "Inmarsat mini—M" service and the call—sign reference to "E010047" should read "EO10048®, In addition the parenthetical isting the other Inmarsat services should read "including B, C, M4 and M." * In the last paragraph of page 2 ofAttachment A, the last sentence should refer to "Inmarsat mini— M" and not "Inmarsat M." * In the first paragraph of page 4 of Attachment A, the referenced file number should read "SES— MFS—20051 122—01616" and the call—sign should read ©E010048." Sis—sTA—20051216—01763 (£O10049) * In first paragraph ofpage 1 of Attachment A, the referenced call—sign should be ©E010049." * In third paragraph of page 1 of Aftachment A,the first sentence should refer to "File No. SES— MFS—20051122—01617" and to "call—sign E010049." * Footote 1 of Attachment A should refer to "Inmarsat Md, M, Mini—M, and C services."

STEPTOE &JOHNSON« Marlene H. Dortch January 5, 2006 Page3 * In the last paragraph of page 1 ofAttachment A, the FCC should be deleted from the list of government customers for the Inmarsat services distributed by Stratos. * In first full paragraph on page 2 of Attachment A, the first sentence should refer to "File No. SES—MFS—20051 122—01617." * In firt full paragraph on page 2 of Attachment A, the second sentence should refer to "File No. SES—MFS—20051 122—01617." * In firsfull paragraph on page 2 of Attachment A, the references in sentence 4 to "Inmarsat mini— M" should refer to "Inmarsat B" service and the call—sign reference to "£O10048" should read ©£O10049". In addition the parenthetical listing the other Inmarsat services should read "including C, M4, M and mini—M." * In the last paragraph ofpage 2 of Attachment A, the last sentence should refer t "Inmarsat B" and not "Inmarsat mini—M." * In the first paragraph ofpage 4 of Aftachment A, the referenced file number should read "SES— MFS—20051122—01617" and the call—sign should read "£010049." SEs.sTA—20051216—01764 (E010050 * In the last paragraph of page 1 of Attachment A, the FCC should be deleted from the list of government customers for the Inmarsat services distributed by Stratos. For the convenience of the Bureau, we have attached corrected versions of Attachment A for each of the applications to replace the current version of Attachment A. The changes listed above are the only changes made to corrected versions ofAttachment A. Please feelfree to contact me, if you have any questions regarding these applications. Respectfully submitted, Mas d Rul/eok, Mare A. Paul Counselfor Stratos Communications, Inc. Attachments

Stratos Communications, Inc. STA Request Correeted — Attachment A SES—STA—20051216—01760 (E000180 — Inmarsat M4 Service) DESCRIPTION OF STA REQUEST By this application, Stratos Communications, Inc.("Stratos") requests grant by January 13, 2006 of special temporary authority ("STA") for sixty (60) days to allow Stratos to maintain existing services to itscurrently licensed Inmarsat M4 terminals (call—sign ©000180) with the recently launched fourth—generation Inmarsat satellite to be located at 52.75° W.L ("Inmarsat 4F2") No new service is implicated by this request. Stratos merely wants to continue to provide essential services, which have been licensed for more than four years, to the U.. armed forces, Federal Emergency Management Ageney (‘FEMA"), U.S. Coast Guard, U.S. law enforcement, First Responders from state and local govermment, and important private sector customers. Stratos recently fled a modification application (File No. SES—MFS—20051 122 01614) for call—sign E00180 in order to add the Inmarsat4F2 as a point of communication. Stratos hereby incorporates by reference that modification application and its technical details and material for purposes of this STA request. The Stratos modification application was placed on Public Notice on December 7, 2005, and the time to file any Petitions and/or Comments on this modification application expires on January 6, 2006. On November 30, 2005, Mobile Satellite Ventures Subsidiary LLC (‘MSV) filed a Notice of Intent to Participate, and in addition, it filed a Motion to designate the proceding as "permit—but—disclose." See MSV Notice of Intent to Participate (Nov. 30, 2005); Motion to Designate Proceedings As "Permit—But— Disclose" (Nov. 30, 2005). Since October 2001, Stratos has been licensed by the FCC to provide Inmarsat services domesticallyin the United States, including the operation of Inmarsat B, C, M, mini—M and M4 terminals.". As set forth in the attached Declaration of Robert J. Roe, Senior Vice President of Sales for Stratos, Stratos‘s customers for Inmarsat services encompass a wide range of U.S. customers, including the U.S. military, the Federal Government, state and local govemments and private sector end—users. See Declaration of Robert J. Roc at 9 5 (Attachment B). U.S. military users include: the U.S. Army, Navy and Air Force. See Declaration of Robert 1. Roe at 16. Federal Government users include: the State Department, FEMA, the U.S. Coost * Additional modification applications were filed to modify the call—signs associated with the Stratos licenses to provide the Inmarsat M, mini—M, B and C services. Similar STA requests are being filed for each ofthese services. * See, eg.In the Matter ofCOMSAT Corporation d/a COMSATMobile Communications et al., 16 FCC Red 21661 (rel. Oct. 9, 2001) ("Inmarsat Market Access Order‘).

Guard and the Federal Bureau of Investigation. See Declaration of RobertJ. Roc at 7. State and local government customers include: New York Fire Department, Los Angeles Fire Department and National Guard Unitsrestoring devastated areas impacted by the recent hurricanes in the Gulf. See Declaration of RobertJ. Roe at 48. U.S. private sector customers include: ChevronTexaco, Global Santa Fe and Edison International (parent company of Southem Califomia Edison). See Declaration of Robert J. Roe at 1 9 As setforth in File No. SES—MFS—20051 122—01614, the Inmarsat 4F2 is licensed by the United Kingdom and will be located at the 52.75° W.L. orbital lcation. It was launched on November 8, 2005. As seforth in File No. SES—MFS—20051122—01614, grant ofthe modification application is in the public interest, is consistent with the ORBIT Actand satisies the Commission‘s D/SCO Hf standard.". Absent authority to communicate with the Inmarsat 4F2, Stratos will not be able to continue to provide the Inmarsat M4 service, licensed under callsign ©000180, to its existing or future customers because the M4 service, along with other Inmarsat services (including B, C, M and mini—M),will be migrated from the third generation Inmarsat satellite currently at 54° W.L. to the Inmarsat 4F2 satellteat 52.75° W.L. Inmarsatis scheduled to migrate these services to the Inmarsat 4F2 on January 15, 2006. Stratos has been informed by Inmarsat that maintaining this schedule is necessary because the Inmarsat 3 satellite currently at 54° W.L. needs to be moved to 142° W.L. where it will replace a second generation Inmarsat satellite,which is running out of fuel and needs to be decommissioned shortly. This second generation satellte at 142° W.L. is currently providing essential Inmarsatlease services to the U.S. Navy and U.S. Coast Guard. See Declaration of RobertJ. Roc at 4. An untimely migration of the "existing and evlved services" from the third generation Inmarsatsatellteto the new Inmarsat 4F2 satellite would jeopardize the continuity of these essentialservices currently being provided by the second generation satellite at the 142° W.L. orbital location. Since the current Public Notice period for the Stratos modification application is scheduled to expire on January 6, 2006 and MSV has already indicated itsintent t participate in this application proceeding, Stratos believes that iis unlikely that te International Bureau will ‘be able to act on the modification application in advance of the scheduled January 15, 2006 migration of the Inmarsat M4 service to the new Inmarsat 4F2 satellteat 52.75° W.L 3 Accordingly, Stratos is requesting this STA to ensure that there is no disruption ofservice to Stratos‘s existing Inmarsat M4 customers when Inmarsat migrates the services to the new satellte. * See 47 U.S.C. § 761 et seq. * See Amendment of the Commission‘s Polices to Allow Non—U.S. Licensed Space Stations Providing Domestic and International Service in the United States, 12 FCC Red 24004 (1997) (‘isco Im). 5 In all likelihood, Stratos and MSV will be in the middle ofthe pleading eycle for the Stratos modification application.

Grant of this STA requestis in the public interest. As set forth above, the Inmarsat services provided by Stratos are used not only by private industry, but also by the U.S. military, Federal Government, and state and local government. The Inmarsat services are used by these entities to facilitate military communications, law enforcement and homeland security, emergency relief efforts, protect lives and safeguard property and to provide critical communications services to support business operations in remote areas. See Declaration of Robert J. Roe at 19 5—8. Grant of this STA request will ensure that these end—users do not experience any disruption to the Inmarsat services they currently use and rely on. As stated by Mr. Roc, "Inmarsat services are used and critically relied upon by government ‘First Responders‘ and private industry, as a fexible and mobile backup to terrestrial voice and data communications networks in the event that a natural disaster or terrorist attack takes place." See Declaration of RobertJ. Roe at 1 10. Any disruption to the Inmarsat services used by First Responders would seriously compromise their ability to accomplish their crtical missions. See Declaration ofRobert J. Roe at $ 10. "The necessity of Inmarsat services was clearly demonstrated in the aftermath of hurricanes Katrina, Rita and Wilma in the Gulf of Mexico. n response to these devastating natural disasters, Stratos saw a noticeable increase in the demand for the Inmarsat services it distributes. Several months later, Inmarsatservices continue to play a vital role in the Gulof Mexico region in connection with the recovery and restorationefforts being undertaken by FEMA, the National Guard, the U.. Army, state and local governments, law enforcement personnel and the petroleum industry." See Declaration of Robert J. Roe at 4 11. In the words of Chairman Martin: If we leamed anything from Hurricane Katrina, it is that we cannot rely solely on terrestrial communications.. When radio towers are knocked down, satelite communications are, in some instances, the most effective means of communicating. See Written Statement of Chairman Kevin J. Martin atthe Hearing on Communications in a Disaster before the U.S. Senate Committee on Commerce, Science and Transportation at 7 (Sept. 22, 2005). The grant of this STA would ensure that there is no disruption in service to these end— users currently using and relying upon Inmarsat services. The Inmarsat services which currently are being provided over the Inmarsat satellite at 54° W.L. can and will be provided over the Inmarsat 4F2 at 52.75° W.L.. without adversely affecting the interference environment that exists today with respect to other operating L—Band spacecraft. Specifically, () the EIRP spectral density ofthe proposed carriers on the Inmarsat 4F2 will be no greater than the EIRP spectral density ofthe same services provided today over the Inmarsat satellite at 54° W.L., (1) the out—of—band emissions from the Inmarsat 4F2 carriers will not exceed the limits of §25.202(f) (1), (2) and (3), and (ii) no greater protection from interference into the Inmarsat 4F2 spacecraft or the Inmarsat mobile earth terminals, beyond the level of protection that exists today, is sought.. In sum, during the term of this STA, these services can and will be provided on Inmarsat4F2 within the technical envelope pursuant to which these services are currently provided on the third generation Inmarsatsatelite currently located at 54° W.L.

Stratos understands that grant of this requested STA will be without prejudice to, and will be conditioned on, the Bureau‘s action on the underlying modification 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 set forth above, Stratos respectfully requests that this STA be granted no later than January 13, 2006° forsixty (60) days. * January 13, 2006 is the last business day before the planned January 15, 2006 cut—over to the Inmarsat 4F2 satellte of the "existing and evlved" services.

STEPTOE &JOHNSON« CERTIFICATE OF SERVICE 1, Brendan Kasper, an attomey with the law firm of Steptoc & Johnson LLP, hereby certify that on this 5th day ofJanuary, 2006, served a true copy of the foregoing letter by first class mail, postage pre—paid (or as othervise indicated) upon the following: Tames Ball® Andrea Kelly* International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, SW. 445 12" Street, SW. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, SW. Washington, DC 20554 Washington, DC 20554 Howard Gribott® Karl Kensinger® International Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, SW Washington, DC 20554 Washington, DC 20554 Fem Jarmulnek® John Martin® International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street,SW. Washington, DC 20554 Washington, DC 20554 Stephen Duall* Jennifer A. Manner International Bureau Vice President, Regulatory Affairs Federal Communications Commission Mobile Satellite Ventures Subsidiary LLC 445 12" Streat, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20101 Robert Nelson® Bruce D. Jacobs Interational Bureau David S. Konczal Federal Communications Commission Pillsbury Winthrop Shaw Pittman LLP 445 12" Street, S.W. 2300 N Street, NW. Washington, DC 20554 Washington, DC 20037—1128

STEPTOE &JOHNSON« Marlene H. Dortch January 5, 2006 Page S JoAnn Ekblad® Tohn P. Janka International Bureau Jeffiey A. Marks Federal Communications Commission Latham & Watkins LLP 445 12" Street, S.W. | 535 Eleventh Street, N.W., Suite 1000 Washington, DC 20554 Washington, D.C. 20004 * by Hand Delivery


Document Created: 2006-02-16 16:08:31
Document Modified: 2006-02-16 16:08:31
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