Boeing Second Row 44

LETTER submitted by The Boeing Company

Boeing Second Letter

2008-10-20

This document pretains to SES-STA-20080811-01049 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2008081101049_671207

SqurrE, Sanpers & DempsEy L.L.P. Suite 500 g@ggIRE 7|| Counse Lecat 01 Pennsylvania 1201 F Avenue, NW. Washington, D.C. 20004—2401 S?iN @ERS wWORLDWIDE Office: +1.202.626.6600 Fax: +1.202.626.6780 Direct Dial: 202.626.6615 boleott@ssd.com October 20, 2008 Marlene H. Dortch Secretary Federal Communications Commission 445 12"" Street, S.W. Washington, DC 20554 Re: Application of Row 44, Inc. (Call Sign EO80100) IBFS File Numbers SES—LIC—20080508—00570, SES—AMD—20080619—00826, SES—STA—20080711—00928, SES—STA—2008081 1 —01049, SES—AMD—20080819—01074, SES—AMD—20080829—01 117 and SES—STA—20080903—01141 and IB Docket Nos. 07—101 and 05—20 Dear Ms. Dortch: On October 15, 2008, the Boeing Company ("Boeing"), by its attorneys, filed a letter with the Commission addressing the above—referenced dockets and file numbers. The primary intent of the letter was to raise awareness within the Commission regarding the critical need to adopt rules and policies for the licensing and operation of aeronautical mobile—satellite services ("AMSS") in the United States. Boeing‘s letter also addressed the pending applications of Row 44, Inc. for Commission authority to operate an AMSS network. Boeing‘s letter identified apparent technical concerns regarding Row44‘s proposed operations and requested that the Commission refrain from granting Row 44‘s applications until those concerns are addressed adequatelyin these proceedings. Boeing has since been told by Row 44 that the technical issues identified in Boeing‘s letter have already been addressed fully by Row44 in its various submissions to the Commission. In its capacity as a manufacturer of aircraft, Boeing has agreed to participate in an information exchange and discussion with Row44 to verifyits compliance with regulatory guidelines and requirements for AMSS. Boeing wishes to support Row 44 and potentially other suppliers of AMSS to provide to the public these communication services. Further delay in approval of AMSS rules and issuance of authorizations for AMSS providers is ultimately detrimental to the airlines, and the flying public. mra + Tysons CornER Br ISt a~ Brussris B i+ Moscow Pracu®k * WaR »Orsers: BucHarest + Burnos A HAGO

SquirE, SaAnpERs & DempsEYy LL.P. October 20, 2008 Page 2 Boeing believes that it is inappropriate for the technical objections that Boeing expressed in its October 15th letter to be considered by the Commission while Boeing‘s discussions with Row 44 are ongoing. Boeing therefore seeks to withdraw the concerns that it expressed regarding Row 44‘s applications. Boeing, however, remains convinced that the only way to prevent further confusion and disagreement regarding the appropriate rules and policies for AMSS networks is for the Commission to adopt expeditiously application processing and service rules that are applicable to this critically important and rapidly growing service. Thank you for your attention to this matter. Please contact the undersigned if you have any questions.


Document Created: 2008-10-20 15:42:38
Document Modified: 2008-10-20 15:42:38
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