Attachment ERRATA

This document pretains to SES-STA-20051216-01764 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005121601764_475401

STEPTOE &JOHNSON« artorners at taw Mare A ut 1330 Commeciewt Arenve. MW rmameim Washingn. DC 200361795 mpauiasteproccom Tel2024203000 tax2024003002 steproecom January 5, 2006 RECEIVED BY HAND DELIVERY Marlene H. Dortch nase 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" 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 several typographical errors in the narrative descriptions attached to these requests. ‘The typographical errors which Stratos secks 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 lst of government customers for the Inmarsat services distributed by Stratos. washmorow +. wewyork +/ rwotnix + tos anotits + towpon + sausstus

STEPTOE &JOHNSON Marlene H. Dortch January 5, 2006 Page 2 SEs—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 firt full paragraph of page 2 ofAttachment A, the references in sentence 4 to "Inmarsat M4"" should refer to "Inmarsat Mservice and the call—sign reference to "EOOO180" should read "EO10047." In addition the parentheticallsting the other Inmarsat services should read "including B, C, M4 and Mini—M." * In the last paragraph ofpage 2 of Attachment A, the last sentence should refer to "Inmarsat M customers" and not "Inmarsat M4 customers." * In the first paragraph ofpage 4 ofAttachment A, the referenced file number should read "SES— MFS—20051122—01618" and the call—sign should read ©£010047." Ss—sTA—20051216—01762 (£O10048 * In first paragraph ofpage 1 of Attachment A, the referenced call—sign should be ©E010048." * Inthird paragraph of page 1 of Attachment A, the frst sentence should refer to "File No. SES— MFS—20051122—01616" and to "call—sign EO10048." * Foomote 1 of Attachment A should refer to "Inmarsat M4, M, B, and C services." * In the last paragraph of page 1 of Attachment A, the FCC should be deleted from the istof government customers for the Inmarsatservices distrbuted by Stratos. * In first full paragraph on page 2 of Attachment A, the first sentence should refer o "File No. SEs—MES—20051122—01616." * —In first full paragraph on page 2 of Attachment A, the second sentence should refer to "File No. SES—MFS—20051122—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 ©E010047" should read "EO10048". In addition the parentheticallisting 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 ©E010048." Sis—sTA—20051216—01763 (EO10049) 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." * Footote 1 ofAttachment 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 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 first full paragraph on page 2 ofAttachment A, the second sentence should refer to "File No. SES—MES—20051122—01617." * In first full paragraph on page 2 ofAttachment 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—20051122—01617" and the call—sign should read ©E010040." Sis—sTA—20051216—01764 (£O10050 * 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. 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 of Attachment A.. Please feelfree to contact me, if you have any questions regarding these applications. Respectfully submitted, Mame 0 Rul/BDX Mare A. Poul 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 of January, 2006, served a true copy ofthe foregoing letter by first class mail, postage pre—paid (or as otherwise indicated) upon the following: Tames Ball® Andrea Kelly* International 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 Cassandra Thomas® Scot Kotler® 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 Howard Griboft® Karl Kensinger® Interational Burcau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, S.W. 445 12" Street, S.W. Washington, DC 20554 Washington, DC 20554 Fom Jamulnck® John Martin® Intemational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, SW 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" Street, S.W. 1002 Park Ridge Boulevard Washington, DC 20554 Reston, Virginia 20191 Robert Nelson® Bruce D. Jacobs International Bureau David S. Koncral 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 PageS ToAnn Elblad® Tohn P. Tanka International Bureau Jeffiey A. Marks Federal Communications Commission Latham & Watkins LLP 445 12Street, S.W. 555 Eleventh Street, N.W., Suite 1000 Washington, DC 20554 Washington, D.C. 20004 * by Hand Delivery

Stratos Communications, Inc. STA Request Correeted — Attachment A SBS—STA—20051216—01764 (B010050 — Inmarsat C 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 its currently licensed Inmarsat C terminals (callsign £010050) with the recently launched fourth—generation Inmarsat satellite to be located at 52.75° W.L.("Inmarsat 4p2 Stratos is not asking to offer any new service. Stratos merely wants to continue to provide essential services, which have been licensed for more than four years, to the U.S. armed forces, Federal Emergency Management Agency (‘FEMA"), U.S. Coast Guard, U.S. law enforcement, First Responders from state and local govemment, and important private sector customers. Stratos recently filed a modification application (File No. SES—MFS—20081 122« 01615) for call—sign E010050 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 to fle 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, 2008). Since October 2001, Stratos has been licensed by the PCto 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.3. military, the Federal Government, state and local governments and private sector end—users. See Declaration of Robert J. Roe at 9 5 (Attachment B). U.S. military users include: the U.S. Army, Navy and Air Force. See Declaration of Robert J. Roe at 16. Federal Government users include: the State Department, FEMA, the U.3. Coost ‘ Additional modification applications were filed to modify the call—signs associated with the Stratos licenses to provide the Inmarsat M, mini—M, M4, and B services. Similar STA requests are being filed for each of these services. * See, e.g, In the Matter ofCOMSAT Corporation d/b/a COMSAT Mobile 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 RobertJ. Roc at }7. 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 $ 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. Roc at 19. As set forth in File No. SES—MFS—20051 122—01615, 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—01615, 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 C service, lcensed under call—sign £010050, to its existing or future customers because the Inmarsat C service, along with other Inmarsat services (including B, M, mini—M and M4), will be migrated from the third generation Inmarsatsatelite currentlyat 54° W.L. to the Inmarsat 4F2 satellit at 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 satellte, 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.S. Navyand U.S. Coast Guard. See Declaration of Robert J. Roc at 1 4. An untimely migration of the "existing and evoived services" from the third generation Inmarsatsatellite t the new Inmarsat 4F2 satellite would jeopardizethe continuity of these essential services currently being provided by the second generation satelite atthe 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 is intent to participate in this application proceeding, Stratos believes thatit is unlikely thatthe International Bureau will ‘be able to act on the modification application in advance of the scheduled January 15, 2006 migration of the Inmarsat C service to the new Inmarsat 4F2 satellite at 52.75° w.L? Accordinly, Stratos is requesting this STA to ensure that there is no disruption of service to Stratos‘s existing Inmarsat C customers when Inmarsat migrates the services to the new satellie. * See 47 U.S.C. § 761 etseq * 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 24004 (1997) °DISCO It"). 5 In alllikelihood, Stratos and MSV will be in the middle othe pleading eycle for the Stratos modification application

Grant ofthis 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, Rederal Government, and state and local government. The Inmarsat services are used by these entities t facilitate military communications, law enforcement and homeland security, emergency reliefefforts, protectlives and safeguard property and to provide crtical communications services to support business operations in remote areas. See Declaration of RobertJ. Roe 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 ‘Fist 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 to the Inmarsat services used by First Responders would seriously compromise their ability to accomplish their critical 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 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, w 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, satellite communications are, in some instances, the most effective means of communicating. See Written 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 ofthis 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 satellteat 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 Inmarsatsatellte at 54° W.L., (i) the out—of—band emissions from the Inmarsat 4F2 cariers will not exceed the limits of §25.202(D (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 ofprotection 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‘s action on the underlying modification application (File No. SES—MFS—20051 122—01615) to modify callsign E010050 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 evalved" services.


Document Created: 2006-01-11 15:48:51
Document Modified: 2006-01-11 15:48:51
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