Attachment ERRATA

This document pretains to SES-STA-20051216-01762 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005121601762_475392

STEPTOE &JOHNSON« arrorneys at caw MareA Past 1310 Commecteut Aenve. NY rmanois Washingin.Dc 20036705 mpaul@steproccom Tel2024293000 rox2024203002 steproccom January 5, 2006 BY HAND DELIVERY JAN —5 2006 Marlene H. Dortch rede Sccretary 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") hercby files this "Errata" o 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 several typographical 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 for the Inmarsat services distributed by Stratos. washimotow +. New vork +/ rnotnix +. tos anoruts +. tonbon +. srusstus

STEPTOE &JOHNSON Mariene H. Dortch January 5, 2006 Page 2 sEs—STA—20051216—01761 (£010047) * In the last paragraph of page 1 ofAftachment A, the FCC should be deleted from the ist of government customers for the Inmarsat services distributed by Stratos. * In firsfull paragraph of page 2 of Attachment A, the references in sentence 4 to "Inmarsat MA" should refer to "Inmarsat M" service and the call—sign reference to "E00O180" should read "£010047.". In addition the parenthetical listing the other Inmarsat services should read "including B, C, Mand 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 Attachment A, the referenced file number should read "SES— MFS—20051 122—01618" and the call—sign should read ©£010047." SEs—5TA—20051216—01762 (£O10048) In first paragraph of page 1 of Attachment A, the referenced call—sign should be "EO10048." In third paragraph ofpage 1 of Attachment A, the frst sentence should refer to "File No. SES— MFS—20051 122—01616" and to "call—sign E010048." * Footnote 1 of Attachment A should refer to "Inmarsat M4, M, B, and C services." * In the last paragraph of page 1 ofAttachment A, the FCC should be deleted from the lst of government customers for the Inmarsat services distrbuted by Stratos. * In first full paragraph on page 2 of Atachment A, the first 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—MFS—20081122—01616." * In first full paragraph on page 2 of Attachment A, the references in sentence 4 to "Inmarsat MY" should refer to "Inmarsat mini—M" service and the call—sign reference to E010047should read ©BO10048®,_ In addition the parenthctical isting the other Inmarsat services should read "including B, C, M4 and M." * In the last paragraph ofpage 2 of Attachment 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—20051122—01616" and the call—sign should read "£O10048." Sis—sTA—20051216—01763 (€010049) in first paragraph of page 1 of Attachment A, the referenced call—sign should be "£010049." in third paragraph ofpage 1 of Attachment A, the first sentence should refer t "File No. SES— MFS—20051 122—01617" and to "call—sign E010049." * Footnote 1 of Attachment A should refer to "Inmarsat M4, M, Mini—M, and C services."

STEPTOE &JOHNSON« Marlene H. Dortch January 5, 2006 Page 3 * In the last paragraph ofpage 1 of Attachment A, the FCC should be deleted from the ist of government customers for the Inmarsat services distributed by Stratos. * In first fll paragraph on page 2 of Attachment A, the first sentence should refer o "File No. SES—MFS—20051122—01617." * In first fll paragraph on page 2 of Attachment A, the second sentence should refer to "File No. SES—MFS—20051 122—01617." + In firs full 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 "EO10049", In addition the parenthetical listing the other Inmarsat services should read "including C, M4, M and mini—M." * In the last paragraph of page 2 of Atachment A, the last sentence should refer to "Inmarsat B"" and not "Inmarsat mini—M." * In the first paragraph of page 4 of Attachment A, the referenced file number should read "SES— MFS—20051 122—01617" and the call—sign should read "E010049." Sis—sTA—20051216—01764 (EO10050) * In the last paragraph ofpage 1 of Attachment A, the FCC should be deleted from the lst of government customers for the Inmarsat services distrbuted by Stratos. For the convenience of the Bureau, we have attached corrected versions of Attachment A for each ofthe applications to replace the current version of Attachment A. The changes listed above are the only changes made to corrected versions of Attachment A.. Please feelfree to contact me, ifyou have any questions regarding these applications. Respectfully submitted, Mas d Rud/BDK Mare A. Paul Counselfor Stratos Communications, Inc Artachments

STEPTOE &JOHNSON CERTIFICATE OF SERVICE 1, Brendan Kasper, an attomey with the law firm of Steptoe & Johnson LLP, hereby certify that on this 5th day ofJanuary, 2006, served a true copy ofthe foregoing leter by first class mail, postage pre—paid (or as otherwise indicated) upon the following: Tames Bal® Andrea Kelly® Intemational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, SW. Washington, DC 20554 Washington, DC 20554 Cassandra Thomas® Scott Kotler® Interational 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® Interational Bureau Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Fom Jamulnek® John Martin® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Strect, S.W. Washington, DC 20554 Washington, DC 20554 Stephen Duall® Jennifer A. Manner Interational Bureau Vice President, Regulatory Affairs Federal Communications Commission Mobile Satellite Ventures Subsidiary LLC 445 12" Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 Robert Nelson® Bruce D. Jacobs International Bureau David S. Konezal Federal Communications Commission Pillsbury Winthrop Shaw Pittman LLP 445 12" Street, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1128

STEPTOE & JOHNSON= Marlene H. Dortch January 5, 2006 Page 5 ToAnn Elblad® Fohn P. Janka International Bureau Jeffrey A. Marks Federal Communications Commission Latham & Watkins LLP 445 12" Street, S.W. 555 Eleventh Street, N. , Suite 1000 Washington, DC 20554 Washington, D.C. 20004 * by Hand Delivery

Stratos Communications, Inc. STA Request Correeted — Attachment A SES—STA—20051216—01762 (E010048 — Inmarsat mini—M 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 toallow Stratos to maintain existing services to its currently liensed Inmarsat mini—M terminals (callsign £010048) with the recently launched fourth—generation Inmarsat satellite to be located at 52.75° W.L. (‘Inmarsat4E2"), Stratos is not asking tooffer any new service. Stratos merely wants to continue to provide essentil services, which have been licensed for more than four years, to the U.S. armed forces, Federal Emergency Management Ageney (‘FEMA®), U.S. Coast Guard, U.S. law enforcement, First Responders from state and local government, and important private sector customers. Stratos recently filed a modification application (File No. SES—MEFS—2005 1 122« 01616) for call—sign E010048 in order to add the Inmarsat 4F2 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 Satellte Ventures Subsidiary LLC (‘MSV) filed a Notice of Intent to Participate, and in addition,it filed a Motion to designate the proceeding as "permit—but—disclose." See MSV Notice of Intent o Participate (Nov. 30, 2005); Motion to Designate Proceedings As "Permit—But— Disclose" (Nov. 30, 2008). Since October 2001, Stratos has been licensed by the FCC to provide Inmarsat services domestically in the United States, including the operation of Inmarsat B, C, Mmini—M and M4 terminals" As set forth in the attached Declaration of Robert J. Roc, 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 governments and private sector end—users. See Declaration of Robert J. Roc at 1 5 (Attachment B). U.S. military users include: the U.S. Army, Navyand Air Force. See Declaration of Robert J. Roe at § 6. Federal Government users include:the State Department, FEMA, the U.S. Coast ‘ Additional modification applications were filed to modify the call—signs associated with the Stratos licenses to provide the Inmarsat M4, M, B and C services. Similar STA requests are being filed for each of these services. * See, eg.In the Matter ofCOMSAT Corporation d/b/a COMSATMobile Communications et al., 16 FCC Red 21661 (rel. Oct. 9, 2001) ("Imarsat Market Access Order®).

Guard and the Federal Bureau of Investigation. See Declaration of Robert J. Roe at 17. 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 Robert J. Roe at 4 8. U.S. private sector customers include: Chevron/Texaco, Global Santa Fe and Edison Intemational (parent company of Southem Califomia Edison). See Declaration of Robert J. Roe at49. As set forth in File No. SES—MFS—20051122—01616, the Inmarsat 4F2 is licensed by the United Kingdom and willbe located at the 52.75° W.L. orbitallocation.. It was launched on November 8, 205. As set forth in File No. SES—MFS—20051 122—01616, grant ofthe modification application is in the public interest,is consistent with the ORBIT Act" and satisfies the Commission‘s DISCO !I standard.* Absent authority to communicate with the Inmarsat 4F2, Stratos will not be able to continuto provide the Inmarsat mini—M service, licensed under call— sign E010048, to ts existing or future customers because the Inmarsat mini—M service, along with other Inmarsat services (including B, C, M4 and M), will be migrated from the third generation Inmarsat satellte currently at 54° W.L.. to the Inmarsat 4F2 satelliteat 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 Inmarsatsatellte, which is running out of fuel and needs to be decommissioned shortly. This second generation satellite at 142° W.L. is curently providing essential Inmarsat lease services to the U.. Navy and U.3. Coast Guard. See Declaration of Robert J. Roe at 4. An untimely migration of the "existing and evolved services" from the third generation Inmarsatsatellte to the new Inmarsat 4F2 satellte would jeopardize the continuity of these essential services currently being provided by the second generation satelitat 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 its intent to participate in this application proceeding, Stratos believes that it is unlikely that the International Bureau will be able to act on the modification application in advance of the scheduled January 15, 2006 migration ofthe Inmarsat mini—M service to the new Inmarsat 4F2 satellteat 52.75° W.L." Accordingly, Stratos is requesting this STA to ensure that there is no disruption of serviceto Stratos‘s existing Inmarsat min—M customers when Inmarsat migrates the services to the new satellte. * See 47 U.S.C. § 761 et seq. * See Amendment ofthe Commission‘s Polices to AllowNon—U.S. Licensed Space Stations Providing Domestic and International Service in the United States, 12 FCC Red 24094 (1997) ‘Disco im). * In alllikelihood, Stratos and MSV will be in the middle ofthe pleading eyele for the Stratos modification application.

Grant ofthis STA requestisin the public interest. As set forth above, the Inmarsatservices provided by Stratos are used not only by private industry, but also by the U.. military, Rederal Government, and state and local government. The Inmarsat services are used by these entitis to faciltate military communications, law enforcement and homeland security, emergency relief efforts, protectlives and safeguard property and to provide critical communications services to support business operations in remote areas. See Declaration of Robert J. Roc at 9 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. Roe, "Inmarsat services are used and critically relied upon by government ‘First Responders‘ and private industry, as a flexible and mobile backup to terrestrial vaice and data communications networks in the event that a natural disaster or terrorist attack takes place." See Declaration of Robert J. Roe at § 10. Any disruption to the Inmarsat services used by First Responders would seriously compromise their ability to accomplish their eitical missions. See Declaration of Robert J. Roc at 10. "The necessity of Inmarsatservices was clearly demonstrated in the aftermath of hurricanes Katrina, Rita and Wilma in the GulfofMexico. In response to these devastating natural disasters, Stratos saw a noticeable increase in the demand for the Inmarsat services it distributes. Several months late, Inmarsatservices continue to play a vital role in the Gulf of Mexico region in connection with the recovery and restoration efforts being undertaken by FEMA, the National Guard, the U.S. Army, state and local governments, law enforcement personnel and the petroleum industry." See Declaration of Robert J. Roe at 1 11. In the words of Chairman Martin: If we leamed anything from Hurricane Katrina, it is that we cannot ely solely on terrestrial communications. When radio towers are knocked down, satllite communications are, in some instances, the most effective means of communicating. See Writen Statement of Chairman Kevin J. Martin at the 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 satellte 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., (i) the out—of—band emissions from the Inmarsat 4F2 carriers will not exceed the limits of §25.202(1) (1), (2) and (3),and (i) no greater protection from interference into the Inmarsat 4F2 spacecraft orthe Inmarsat mobile carth 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 Inmarsat 4F2 within the technical envelope pursuant to which these services are currently provided on the third generation Inmarsat satellte 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‘saction on the underlying modification application (File No, SES—MEFS—20051122—01616) to modify call—sign E010048 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° for sixty (60) days. * Jantary 13, 2006 is the last business day before the planned January 15, 2006 cut—over to the Inmarsat 4F2 satellte of the "existing and evaived" services.


Document Created: 2006-01-11 15:26:11
Document Modified: 2006-01-11 15:26:11
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