Attachment GRANT

This document pretains to SES-STA-20060315-00445 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006031500445_499882

                                                                                                            Approved by OMB
                                                                                                                   3060—0678

                                       APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INFORMATIONEnter a description of this application to identify it on the main menu:
Blanket MET STA Request 3/2006
 1. Applicant


           Name:               BT Americas Inc.                Phone Number:           703—755—6733
           DBA Name:                                           Fax Number:             703—755—6740
           Street:             11440 Commerce Park Drive       E—Mail:                 linda.cicco@bt.com


           City:               Reston                          State:                  VA
           Country:            USA                             Zipcode:                20191       —
           Attention:          Ms. Linda J. Cicco




                                        File #


                                        Call Sign E060076
                                        (or otheridentifier)




                International Bureau

                                                                                &   . 2 is MJ


                                          BT Americas, Inc.
                               IBFS File No. SES—STA—20060315—00445

The request of BT Americas, Inc. (BT Americas) for special temporary authority (STA) IS GRANTED.
Accordingly, BT Americas is authorized for a period of 60 days, ending July 11, 2006, to operate up to
5,000 Broadband Global Area Network (BGAN) mobile earth terminals (MET‘s) using the Inmarsat 4F2,
in accordance with the terms, conditions, and technical specifications set forth in the Commission‘s rules
and this document.

1.   Neither the aggregate uplink EIRP densities in the direction of any other L—band satellite serving the
     United States, nor the downlink EIRP densities at any geographical point within the United States,
     shall be increased, above the levels previously authorized in connection with operations using the
     Inmarsat 3F4 satellite, as a result of the operations authorized by this STA.

2.   Operations on the Inmarsat 4F2 satellite shall be on an unprotected basis. BT Americas shall not
     claim protection from, and is required to accept interference from, other lawfully operating satellites
     or radiocommunication systems.

3.   Operations are permitted on those frequencies previously used for authorized U.S. MET operations on
     the Inmarsat 3F4 satellite, except that operations are not permitted on certain frequencies, made
     available to Inmarsat by MSV USA and MSV Canada as part of the operator—to—operator coordination
     process, the use of which is currently an issue pending in connection with BT Americas‘ request for
     regular authority.

4.   Adequate guard bands shall be provided between the band edges of the carriers used by BT Americas
     and the band edges of MSV*‘s operations in order to preclude the possibility of unacceptable
     interference to MSV*‘s operations.

5.   Any action taken or expense incurred as a result of operations pursuant to this special temporary
     authority is solely at BT Americas‘ own risk.

6.   The grant of this STA is not based on a finding that Inmarsat‘s L—band operations are consistent with
     operation on a non—interference basis.

7.   The grant of this 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.

8.   This STA may be terminated or modified at the International Bureau‘s discretion, without a hearing, if
     conditions warrant.

9.   BT Americas must notify each customer, in writing and prior to initiation of service, that BGAN
     operations on the Inmarsat 4F2 satellite are pursuant to a grant of special temporary authority that
     may be terminated or modified at any time.                                               |

10. Authority granted in this STA is without prejudice to the disposition of any related applications for
    regular authority.

11. BT Americas shall not provide facilities—based or resale common carrier service that meets the
    definition, or is the functional equivalent, of a commercial mobile radio service, without receiving
    authorization under Section 214 of the Communications Act. For purposes of this condition, the
    definition of a commercial mobile radio service is set forth in Section 332(d) of the Communications
    Act and Section 20.3 of the Commission‘s rules.


                                        BT Americas, Inc.
                             IBFS File No. SES—STA—20060315—00445


12. This grant is issued pursuant to Section 0.261 of the Commussion‘s rules on delegated authority, 47
    C.F.R. § 0.261, and is effective immediately.

13. BT Americas is afforded thirty days from the date of release of this action to decline this special
    temporary authorization as conditioned. Failure to respond within this period will constitute formal
    acceptance of the special temporary authorization as conditioned.


2. Contact


             Name:        Linda J. Cicco                       Phone Number:                        703—755—6733
             Company:     BT Americas Inc.                     Fax Number:                          703—755—6740
             Street:      11440 Commerce Park Drive            E—Mail:                              linda.cicco@bt.com


             City:        Reston                               State:                                VA
             Country:     USA                                  Zipcode:                             20191       —
             Attention:                                        Relationship:                         Same


(If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related
application. Please enter only one.)
 3. Reference File Number or Submission ID

 4a. Is a fee submitted with this application"?
@ IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
g4 Governmental Entity        f3 Noncommercial educational licensee
g‘4 Other(please explain):

4b. Fee Classification    CGB — Mobile Satellite Earth Stations

5. Type Request


 g&y Use Prior to Grant                           y Change Station Location                         gy Other



6. Requested Use Prior Date
      04/17/2006
7. City                                                                   8. Latitude
                                                                          (dd mm ss.s h)    0   0   0.0


9. State                                                                   10. Longitude
                                                                           (dd mm ss.s h)    0    0   0.0
11. Please supply any need attachments.
Attachment 1: Attachment 1                        Attachment 2:                                       Attachment 3:



12. Description.   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     See Attachment        1.




13. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is               Yes        «y No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
of 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.


14. Name of Person Signing                                                 15. Title of Person Signing
   Linda J. Cicco                                                             Regulatory Compliance Manager

           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


                                                                    BT Americas Inc.
                                                                        STA Request
                                                                           Exhibit A
                                                                          Page 1 of 5
                                  STA REQUEST

             BT Americas, Inc. ((BT Americas") seeks special temporary authority

("STA") pursuant to Section 25.120 of the Commission‘s rules, 47 C.F.R. § 25.120,

for 60 days to allow BT Americas to provide Inmarsat‘s Broadband Global Area

Network @BGAN") service using up to 5,000 mobile earth terminals ("METs")

operating in the L—band in conjpunction with the Inmarsat 4F2 satellite located at

the 52.75° W.L. orbital location. Temporary authority to provide the BGAN service

using these MET‘s and this satellite will allow BT Americas to offer Inmarsat‘s

BGAN service in the United States while the International Bureau ("Bureau")

considers the underlying BGAN application previously filed by BT Americas.


1.     BACKGROUND

             On March 3, 2006, BT Americas filed an application ("BT Americas

BGAN Application") for a blanket license to operate 20,000 MET‘s with Inmarsat‘s

BGAN service (File Nos. SES-LFS-200603OS-OOS43, SES—AMD—20060315—____}).

BT Americas hereby incorporates by reference that application and its technical

details and material for purposes of this STA request.?



t    BT Americas attempted to file an amendment on March 15, 2006 to provide
additional technical information requested by the staff, but experienced technical
difficulties with IBFS. We will update the record with the appropriate amendment
file number once the technical difficulties are resolved and the amendment is
entered into the system.
2    BT Americas also incorporates by reference all ownership information and
certifications provided in the original BT Americas BGAN Application.


                                                                      BT Americas Inc.
                                                                            STA Request
                                                                              Exhibit A
                                                                             Page 2 of 5

              In the BT Americas BGAN Application, BT Americas proposes to offer

 Inmarsat BGAN services to U.S. consumers through four different BGAN MET‘s:

 NERA PUT manufactured by NERA, AddValue PUT manufactured by AddValue,

T&T Lite manufactured by Thrane and Thrane, and HNS Briefcase manufactured

by Hughes Network Systems. Each offers a different combination of size and data

transmission capability, and all comply with the Commussion‘s Rules for operation

in the L—band.} BT Americas plans to operate its MET‘s with Inmarsat‘s fourth

 generation satellite, the Inmarsat 4F2, which is located at 52.75° W .L.

              BT Americas expects to be able to provide the BGAN service over the

Inmarsat 4F2 by April 17, 2006, but understands the Bureau will not be able to

complete its review of the BT Americas application by thatl date. Accordingly, BT

Americas respectfully requests an STA to provide the BGAN service in the United

States as soon as it becomes available.

              For the same reasons set forth in the BT Americas BGAN Application,

grant of this STA is consistent with the ORBIT Act* and satisfies the Commussion‘s

DISCO II standard."



II.     PUBLIC INTEREST

              Grant of this STA request is in the public interest because it will


      File No. SES—LFS—20060303—00343, Exhibit B.
CAP




      47 U.S.C. § 761 et seq.
wew




      See Amendment of the Commission‘s Polictes to Allow Non—U.S. Licensed Space
t




Stations providing Domestic and International Service in the United State, 12 FCC
Red 24094 (1997) DISCO IT).


                                                                  BT Americas Inc.
                                                                      STA Request
                                                                          Exhibit A
                                                                         Page 3 of 5

allow U.S. consumers, including the U.S. military and public safety community

in particular, to access faster, more flexible, and more robust satellite broadband

services. These satellite broadband services will likely prove invaluable when

the next natural disaster or terrorist attack occurs.

             The BT Americas BGAN service will offer U.S. consumers Internet

Protocol packet—switched data and cirecuit—switched applications at speeds up to

492 Kbps. BGAN will provide U.S. customers broadband access to e—mail, local

area networks, the Internet, intranet/extranets, video conferencing services,

video—on—demand, and voice communications from almost anywhere in the

world.8 BGAN operates at eight times the speed of the fastest mobile services

available in the U.S. (Inmarsat GAN), and 100 times faster than MSV‘s services.

BGAN service is currently available in Europe, Africa, Asia and the Middle

East.‘ Prompt Commission grant of this request would allow U.S. subscribers to

enjoy the same advanced mobile satellite services as the rest of the world,

instead of operating at a fraction of the speed.

             BGAN is needed as soon as possible by the U.S. military and the

public safety community, which is seeking improved data speeds in the event of a

large—scale natural disaster or terrorist attack. The recent natural disasters

associated with hurricanes Katrina, Rita and Wilma in the Gulf of Mexico region



6   File No. SES LFS—20060303—00343, Exhibit B at 10.
_   Inmarsat Announces Launch of BGAN Service, Inmarsat website, available at
http://about.inmarsat.com/news/00018831.aspx"?language=EN&testonly=False.


                                                                   BT Americas Inc.
                                                                       STA Request
                                                                         Exhibit A
                                                                        Page 4 of 5

demonstrate an urgent need for the BGAN offering and approval of this STA

request. While the existing Inmarsat services played a vital role in the recovery

efforts, the data transmission speeds of these existing services relied on in the

Gulf, and throughout the United States, do not match the high speed terrestrial

networks people have come to expect. Prompt grant of this STA will ensure that

the higher data speeds offered by BGAN will be available when the next natural

disaster or terrorist attack takes place. Indeed, hurricane season begins this

year on June 18.8 Accordingly, grant of this STA by April 17¢" will allow

government "First Responders" and private industry users time to obtain and

deploy BGAN terminals and familiarize themselves with those terminals, as well

as the BGAN services and features, so that BGAN can have immediate impact on

any advance preparations or recovery effort that becomes necessary. Such

extraordinary circumstances justify grant of this requested STA.

            BGAN service is already available in Europe, Africa, Asia and the

Middle East. The benefit of equality of service is clear. U.S. customers will be

able to subscribe to BT Americas BGAN service in the United States and use it

around the world. Similarly, individuals that already use BGAN in other parts

of the world will be able to operate their equipment in the United States.

            The Inmarsat 4F2 satellite located at 52.75° W.L., which will be

used to provide the BGAN service, can be operated in a manner that will cause



$   See http:!/www.noaanews.noaa.gov/stories2005/s2540.htm.


                                                                  BT Americas Inc.
                                                                       STA Request
                                                                           Exhibit A
                                                                          Page 5 of 5

no greater potential for interference than Inmarsat‘s former satellite located at

54° W .L., Inmarsat 3. In many ways, Inmarsat 4F2 is more "interference

friendly" than Inmarsat 3 because Inmarsat 4F2 has narrower spot beams with

steeper antenna side lobes to reduce interference into adjacent areas, and it has

higher gain spot beams to allow the use of terminals that radiate less than one—

tenth the power of the Inmarsat data terminals currently used in the United

States. In sum, BGAN service will be provided on Inmarsat 4F2 in a manner

that will not adversely affect the current interference environment.

             BT Americas understands that grant of this requested STA will be

without prejudice to and will be conditioned on, the Bureau‘s action on the

underlying application (File Nos. SES—LFS—20060303—00343, SES—AMD—

20060315—_____®) for a blanket license to operate its 20,000 MET‘s with

Inmarsat‘s BGAN service.

             For the reasons set forth above, BT Americas respectfully requests

that this STA be granted no later than April 17, 2006 for 60 days.




9 See n.1l, supra.


                                CERTIFICATE OF SERVICE

            I, Cecelia Burnett, hereby certify that on this 15t" day of March, 2006, I
served a true copy of the foregoing Request for Special Temporary Authority by
electronic mail upon the following:


  Roderick Porter                              Gardner Foster
  International Bureau                         International Bureau
  Federal Communications Commission            Federal Communications Commission
  445 12t" Street, S.W.                        445 12¢" Street, S.W.
  Washington, D.C. 20554                       Washington, D.C. 20554

  Robert Nelson                                Andrea Kelly
  International Bureau                         International Bureau
  Federal Communications Commission            Federal Communications Commission
  445 12t" Street, S.W.                        445 12t° Street, S.W.
  Washington, D.C. 20554                       Washington, D.C. 20554

  Cassandra Thomas                             Scott Kotler
  International Bureau                         International Bureau
  Federal Communications Commission            Federal Communications Commission
  445 12t" Street, S.W.                        445 12t" Street, S.W.
  Washington, D.C. 20554                       Washington, D.C. 20554

  Howard Griboff                               Karl Kensinger
  International Bureau                         International Bureau
  Federal Communications Commission            Federal Communications Commission
  445 12t" Street, S.W.                        445 12t° Street, S.W.
  Washington, D.C. 20554                       Washington, D.C. 20554

 Fern Jarmulnek                                John Martin
 International Bureau                          International Bureau
 Federal Communications Commission             Federal Communications Commission
 445 12t" Street, S.W.                         445 12t" Street, S.W.
 Washington, D.C. 20554                        Washington, D.C. 20554

 Stephen Duall                                 Jennifer A. Manner
 International Bureau                          Vice President, Regulatory Affairs
 Federal Communications Commission             Mobile Satellite Ventures Subsidiary,
 445 12t" Street, S.W.                         L.L.C.
 Washington, D.C. 20554                        1002 Park Ridge Boulevard
                                               Reston, Virginia 20191


James Ball                             Bruce D. Jacobs
International Bureau                   David S. Konczal
Federal Communications Commission      Pillsbury Winthrop Shaw Pittman, L.L.P.
445 12t" Street, S.W.                  2300 N Street, N.W.
Washington, D.C. 20554                 Washington, D.C. 20037—1128

John P. Janka                          Diane J. Cornell
Jeffrey A. Marks                       Vice President, Government Affairs
Latham & Watkins, L LP.                Inmarsat, Inc.
555 Eleventh Street, NW., Suite 1000   1100 Wilson Blyd., Suite 1425
Washington, D.C. 20004                 Arlington, Virginia 22209




                                       /s/ Cecelia M. Burnett
                                       Cecelia M. Burnett



Document Created: 2019-04-28 18:49:45
Document Modified: 2019-04-28 18:49:45

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