Attachment ERRATA

This document pretains to SES-STA-20051216-01763 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005121601763_475396

STEPTOE &JOHNSON« arrorners at taw Mare A Paot 1110 Commecreut Avenve: NW rmamoume Washingion. DC 200361795 mpaultseproccom Tel 2024293000 ax200.0 8002 seproecom January 5, 2006 RECEIVED BY HAND DELIVERY JAN— 5 2006 Mariene H. Dortch retenic nc 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") hereby files this "Errata" 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 correctinformation 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 ofpage 1 of Attachment A, the FCC should be deleted from the istof government customers for the Inmarsat services distrbuted by Stratos. wasiiwcton + New vork + rwornix +. uos anoruts +. tonpon + srussrls

STEPTOE & JOHNSON= Mariene H. Dortch January 5, 2006 Page 2 Shs—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 frst full paragraph of page 2 of Attachment A, the references in sentence 4 to "Inmarsat M4" should refer to "Inmarsat M" service and the call—sign reference to "EOOO1 80" should read "E010047." In addition the parentheticallsting 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 frst paragraph ofpage 4 ofAttachment A, the referenced file number should read "SES— MFS—20051 122—01618" and the call—sign should read E010047." SEs—STA—20051216—01762 (E010048 In first paragraph of page 1 of Attachment A,the referenced call—sign should be "©O10048." In third paragraph of page 1 of Attachment A, the frst sentence should refer to "File No. SES— MFS—20051 122—01616" and to "callsign EO10048." Footote 1 of Attachment A should refer to "Inmarsat M4, MB, and C services." In the last paragraph ofpage 1 of Attachment 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 firt sentence should refer to "File No. SEs—MFS—20051122—01616." In firstfull paragraph on page 2 of Attachment A, the second sentence should refer to "File No. ses—vF3—20051122—01616." In firstfull paragraph on page 2 of Aftachment A, the references in sentence 4 to "Inmarsat M" should refer to "Inmarsat mini—M" service and the call—sign reference to E010047should read "EO10048", In addition the parenthetical listing 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 frst paragraph of page 4 of Attachment A, the referenced fle number should read "SES— MFS—20051122—01616" and the call—sign should read "E010048." SEs—sTA—200512 1763 (E0r0049 In first paragraph of page 1 of Attachment A, the referenced call—sign should be ©©010049." In third paragraph of page 1 of Attachment A, the first sentence should refer to "File No. SES— MFS—20051122—01617" and to "call—sign E010049." Foomote 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 of page 1 of Attachment A, the FCC should be deleted from the lst of government customers for the Inmarsatservices distributed by Stratos. * In first fll paragraph on page 2 of Attachment A, the first sentence should refer o "File No SES—MFS—20051 122—01617." * In first fll paragraph on page 2 of Attachment A, the second sentence should refer to "File No. SES—MFS—20051122—01617." * In first fll 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 "©010048"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 of page 2 of Attachment 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." SEs—sTA—20051216—01764 (£O10050 * Inthe last paragraph opage 1 of Attachment A, the FCC should be deleted from the lstof 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 Atachment 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 4 Rud/BDK Mare A. Paul Counselfor Stratos Communications, Inc. Attachments

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 letter by first class mail, postage pre—paid (or as othervise indicated) upon the following: Tames Ball® Andrea Kelly* Interational 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 Cassandra Thomas® Scot Kotler® Intemational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12° Street, S.W. Washington, DC 20554 Washington, DC 20554 Howard Griboft® Karl Kensinger® Interational Bureau Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, SW. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Fem Jarmulnck® Tohn Martin® 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 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" Strect, S.W. 2300 N Street, N.W. Washington, DC 20554 Washington, DC 20037—1 128

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

Stratos Communications, Inc. STA Request Corrected — Attachment A SES—STA—20051216—01763 (EO10049 — Inmarsat B 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 ts currently licensed Inmarsat B terminals (call—sign EO10049) with the recently launched fourth—generation Inmarsat satellite to be located at 52.75° W.L. ("Inmarsat ar29. Stratos is not asking to offer 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, Pederal Emergency Management Agency (‘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—MFS—20051 122— 01617) for call—sign E010049 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 ofthis STA request. The Stratos modification application was placed on Public Notice on December 7, 2005, and the time tofile any Petitions and/or Comments on this modification application expires on January 6, 2006. On November 30, 2005, Mobile Satelite 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 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 Stzatos, Stratos‘s customers for Inmarsat services encompass a wide range ofU.S. customers, including the U.S. militry, the Federal Government, state and local governments and private sector end—users. See Declaration of Robert J. Roc at 4 5 (Attachment B). U.S. military users include: the U.S. Army, Navy and Air Force. See Declaration of Robert J. Roe at 6. 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, M4, mini—M and C services. Similar STA requests are being filed for each ofthese services. * See, eg. In the Matter ofCOMSAT Corporation d/b/a COMSATMobile Communications et al., 16 FCC Red 21661 (rel. Oct. 9, 2001) ("Immarsat Market Access Order")

Guard and the Federal Bureau of Investigation. See Declaration of Robert J. Roat 17. State and local government customers include: New York Fire Department, Los Angeles Fire Department and National Guard Units restoring devastated areas impacted by the recent hurricanes in the Gulf. See Declaration of Robert J. Roe at 1 8. U.S. private sector customers include: Chevron/Texaco, Global Santa Fe and Edison International (parent company of Southem Califomia Edison), See Declaration of Robert J. Roc at 19. As set forth in File No. SES—MEFS—20051122—01617,the Inmarsat 4F2 is licensed by the United Kingdom and will be located at the 52.75° W.L. orbitallocation. It was launched on November 8, 205. As set forth in File No. SES—MFS—20051122—01617, grant of the modification application is in the public interest, is consistent with the ORBIT Act? and satisfies the Commission‘s DISCO II standard." Absent authority to communicate with the Inmarsat 4F2, Stratos will not be able to continue to provide the Inmarsat B service, lcensed under call—sign B010049, to its existing or future customers because the Inmarsat B service, along with other Inmarsat services (including C, M, M4 and mini—M, will be migrated from the third generation Inmarsatsatellite currently at 54° W.L. to the Inmarsat 4F2 satellite at 52.75° W.L. Inmarsatis scheduled to migrate these services to the Inmarsat 4F2 on January 15, 206. 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 satellit at 142° W.L. is currently providing essential Inmarsat lease services tothe U.3. Navyand U.3. Coast Guard. See Declaration of Robert J. Roc at 4. An untimely migration of the "existing and evoived services" from the third generation Inmarsat satellte to the new Inmarsat 4F2 satellte would jeopardizethe continuity of these essential services currently being provided by the second generation satelite atthe 142° W.L. orbitallocation. Since the current Public Notice period for the Stratos modification application is scheduled to expire on January 6, 2006 and MSV has already indicated is intent to participate in this application proceeding, Sizatos believes that t is unlikely thatthe International Bureau will be able to act on the modification application in advance of the scheduled January 15, 2006 migration ofthe Inmarsat B service tothe new Inmarsat 4F2 satelliteat 52.75° WL® Accordingly, Stratos is requesting this STA to ensure that there is no disruption of service to Stratos‘s existing Inmarsat B customers when Inmarsat migrates the services to the new satellite * See 47 U.S.C. § 761 et seq. * See Amendment ofthe Commission‘s Polices to Allow Non—U.S. Licensed Space Stations Providing Domestic and International Service in the United States, 12 FCC Red 24094 (1997) ‘pisco i) 5 In all likelihood, Stratos and MSV will be in the middle of the pleading eycle for the Stratos modification application.

Grant of this STA request is 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, Rederal Goverment, and state and local government. The Inmarsat services are used by these entites to faciltate military communications, law enforcement and homeland security, emergency reliefefforts, protectlives and safeguard property and to provide critical communications serviees to support business operations in remote areas. See Declaration of RobertJ. Roc at t¥ 5—8. Grant ofthis 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. Ro, "Inmarsat services are used and critically 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 that a natural disaster or terroristattack takes place." See Declaration of Robert J. Roe at § 10. Any disruption tothe Inmarsat services used by First Responders would seriously compromise their ability to accomplish their etical missions. See Declaration of Robert J. Roc at 1 10. "The necessity of Inmarsatservices was clearly demonstrated in the aftermath of hurricanes Katrina, Rita and Wilma in the Gulf of Mexico.. 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 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 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 of the 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 or the 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 Inmarsatsatellte currently located at 54° W.L.

Stratos understands that grant ofthis requested STA will be without prejudice to, and will be conditioned on, the Burau‘s action on the underlying modification application (File No. SES—MFS—20051122—01617) to modify call—sign £010049 to add the Inmarsat 4F2 as an authorized point of communication. Forthe reasons set forth above, Stratos respectfully requests that this STA be granted no later than January 13, 2006° for sixty (60) days. * January 13, 2006 is the last business day before the planned January 15, 2006 cut—over to the Inmarsat 4F2 satellteofthe "existing and evalved" services.


Document Created: 2006-01-11 15:40:24
Document Modified: 2006-01-11 15:40:24
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