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REPLY submitted by Thrane & Thrane Airtime Ltd.

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2006-11-08

This document pretains to SES-STA-20061019-01868 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006101901868_538145

Before the Federal Communications Commission Washington, D.C. 20554 In the Mater of ) ) Thrane & Thrane Airtime Ltd. ) SES—STA—20061019—01868 (Call Sign EO6O179) —————— REpLy conMENTS By its attomey, and pursuant to Section 1.45 of the Commission‘srules, 47 C.F.R. §1.45, Thrane & Thrane Airtime Lid. (‘T&T Airtime") hereby submits its Reply to the Comments of Mobile Satellite Ventures Subsidiary LLC (‘MSV*) in the above—captioned. matter: (the "Comments). For the reasons set forth sbove, MSV‘s contentions have no merit and should be rejected. In its Comments MSV does not oppose rencwal of T&T Airtime‘s special temporary authority (‘STA®) to provide Broadband Global Area Network (‘BGAN®) service over the Inmarsat—4 spacecraft. Rather, MSV urges the International Bureau (the "Bureau") to modify the conditions applicable to T&T Airtime‘s STA, to establish a firm expiration date for the STA of November 30, 2006, and to provide that no further extensions will be granted.. In support of its pleading, MSV attaches its pending Petition for Clarification, which seeks modification of all current BGAN STAs, and its Reply to the Joint Opposition to that Petition. Other, similarly situated partics have already responded to the arguments which MSV eiterates in its instont Comments and, in the interest of conserving the Commission‘s scarce resources, Thrane & Thrane Airtime herebyincorporates those prior submissions by reference, Thrane & Thrane Airtime simply wishes to add that, since the grant of its iniial STA, it has complied with all the standard conditions attached thereto, and MSV has failed to demonstrate in 1 See Jont Opposition, File Nos. SES—STA—20060310—00419 eral, filed June 19, 2006, and Joint Reply, ile Nos. SES—STA—20060906.01674 etal, ied September 20, 2006.

any way that these conditions are inadequate to address the potential for harmful interference which MSV has described. T&T Airtime also urges the Bureau to summarily reject MSV‘s request that T&T Airtime‘s STA should not be extended beyond November 30, 2006, the date marking the official end of the hurricane season. Contrary to MSV‘s claim, T&T Airtime has never stated that the hurricane season was the sole extraordinary circumstance justifying continued special temporary authority. Rather, hurricanes were cited as an illustration of the types of natural and other disasters for which BGAN service is a powerful tool to support emergency preparedness and recovery. As T&T noted in its application, moreover, "BGAN is needed as soon as possible by the U.S. military and the public safety community, which is secking improved data speeds in the event of a large—scale natural disaster or terrorist attack." Grant of special temporary authority, T&T Airtime stated, would "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 preparation or recovery effort that becomes necessary." Application Exhibit A, pp. 3—4.

WHEREFORE, Thrane & Thrane Airtime respectfully urges the Commission to grant ts application for extension of special temporary authority without the conditions requested by MSV. Respectfully submitted, c h a Eric Rishman d c _ Holland & Knight LLP 2099 Pennsylvania Avenue, NW Washington, DC 20006 (202) s28—1840 Counsel to Thrane & Thrane Ltd. November 8, 2006

CERTIFICATE OF SERVICE 1, ErieFishman, an attomey with the law firm of Holland & Knight LLP, hereby certify that on this 8" day of November, 2006, a true copy ofthe foregoing Reply Comments of Thrane & Thrane Airtime Ltd. was served by first class mail, postage pre—paid (or as otherwise indicated) upon the following: James Ball* Andrea Kelly* Interational Burcau 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® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12® Street, SW 445 12"Street, SW Washington, DC 20554 Washington, DC 20554 Howard Griboti® Karl Kensinger® Interational Bureau Interational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, SW 445 12" Street,SW Washington, DC 20554 Washington, DC 20554 Fem Jamulnek® John Martin® International Bureau Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12® Street, SW 445 12® Street, SW Washington, DC 20554 Washington, DC 20554 Stephen Duall® Robert Nelson® Intemational Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Street, SW 445 12" Street, SW Washington, DC 20554 Washington, DC 20554 JoAnn Ekblad® Suzanne O‘Connell* Intemational Bureau Intemational Bureau Federal Communications Commission Federal Communications Commission 445 12" Street,SW 445 12" Street, SW Washington, DC 20554 Washington, DC 20554

Jennifer A. Manner Bruce D. Jacobs Vice President, Regulatory Affairs David S. Konczal Mobile Satellite Ventures Subsidiary LLC Pillsbary Winthrop Shaw Pittman LLP 1002 Park Ridge Boulevard 2300 N Street, NW Reston, Virginia 20191 Washington, DC 20037—1128 Keith H. Fagan John P. Janka Senior Counsel Jeffrey A. Marks Telenor Satellite, Inc. Latham & Watkins LLP 1101 Wootton Parkway 555 Eleventh Street, NW, Suite 1000 Rockville, MD 20852 Washington, DC 20004 Diane J. Comell Mare A. Paul Vice President, Goverment Affairs Steptoe & Johnson LLP Inmarsat, Ic. 1330 Connecticut Avenue, NW 1100 Wilson Boulevard, Suite 1425 Washington, DC 20036—1795 Arlington, VA 22200 * by Hand Delivery Enc Fishman noomew


Document Created: 2006-12-07 15:30:02
Document Modified: 2006-12-07 15:30:02
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