Attachment Narrative letter

This document pretains to SES-STA-20110429-00525 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011042900525_886892

SQUIRE, SANDERS & DEMPSEY (US) LLP Suite 500 1201 Pennsylvania Avenue, N.W. Washington, DC 20004 Office: +1.202.626.6600 Fax: +1.202.626.6780 Direct Dial: +1.202.626.6659 carlos.nalda@ssd.com April 29, 2011 BY ELECTRONIC FILING Kathryn Medley Satellite Division, International Bureau Federal Communications Commission 445 12th Street, S.W. Washington, DC 20554 Re: KVH Industries, Inc. Application to Extend Special Temporary Authority; SES-STA- 20091019-01338 (Call Sign E030131) Dear Ms. Medley: KVH Industries, Inc. (“KVH”), pursuant to Section 25.120 of the Commission’s Rules, 47 C.F.R. § 25.120, hereby requests a brief extension of its Special Temporary Authority (“STA”) to operate up to 15 V7 Land Mobile-Satellite Service (“LMSS”) earth stations in the 14.0-14.5 GHz and 11.7-12.2 GHz frequency bands using a single remote control point (a network operations center located in Carlsbad, California) with the AMC-15 satellite at 105°W.1 STA is sought for a period of up to 30 days or until KVH’s vehicle-mounted earth station (“VMES”) application is granted. Section 25.120 of the Commission’s rules permits grant of STA if the STA request has not been placed on public notice and the applicant plans to file a request for regular authority for the service.2 Concurrently with the instant application, KVH has filed an application for a VMES network license to operate its V7 and V3 terminals in the 14.0-14.5 GHz (transmit) and 10.95–11.2 GHz, 11.45–11.7 GHz and 11.7-12.2 GHz (receive) frequency bands.3 Since KVH’s LMSS STA expires today, however, KVH requests a brief extension of its STA to operate the V7 LMSS terminals until the Bureau acts on KVH’s 1 See SES-STA-20091019-01338 (Call Sign E030131) granted on Nov. 8, 2010. 2 See 47 C.F.R. § 25.120. 3 See IBFS Submission ID IB2011001258 filed Apr. 29, 2011. 36 OFFICES IN 16 COUNTRIES SQUIRE, SANDERS & DEMPSEY (US) LLP IS PART OF THE INTERNATIONAL LEGAL PRACTICE SQUIRE, SANDERS & DEMPSEY, WHICH OPERATES WORLDWIDE THROUGH A NUMBER OF SEPARATE LEGAL ENTITIES. PLEASE VISIT WWW.SSD.COM FOR MORE INFORMATION.

Kathryn Medley SQUIRE, SANDERS & DEMPSEY (US) LLP April 29, 2011 Page 2 VMES application. KVH hereby incorporates by reference the application materials and technical demonstration included with its previous request for STA.4 During the pendency of KVH’s VMES application, it will operate pursuant to its STA in conformance with the Commission’s VMES rules, albeit on a secondary basis. KVH will also operate in conformance with the conditions imposed on its current LMSS STA. Grant of the instant STA extension will confer no competitive advantage. KVH expressly acknowledges that: (i) grant of such a temporary extension shall not be construed as a finding by the Commission that the operations will serve the public interest, convenience, or necessity beyond the express terms of such temporary extension of the license, and (ii) such temporary extension shall not in any way affect or limit the action of the Commission with respect to its VMES license application or proceeding. Such a grant will, however, allow KVH to continue to deliver limited two-way broadband connectivity to vehicles equipped with its earth station terminals and operated by users in the public and private sectors while its application for regular VMES authority is pending. Therefore, grant of this brief STA extension will serve the public interest by addressing existing public and private sector demand for broadband land-mobile services. For the reasons underlying grant of KVH’s original land mobile STA request, the Commission should similarly grant this request for limited extension of such temporary authority. Moreover, the request for limited extension does not implicate the reasons that the Commission sought to limit multiple renewals of the original temporary authority (i.e., ongoing commercial operations under rolling LMSS STAs rather than a long-term VMES license, for which KVH has filed an application). Please feel free to contact me with any questions you may have or if KVH can provide any additional information to facilitate expeditious action on its STA extension request. Respectfully submitted, Squire, Sanders & Dempsey (US) LLP /s/ Carlos M. Nalda Carlos M. Nalda Counsel to KVH Industries, Inc. 4 See SES-STA-20091019-01338 (Call Sign E030131).


Document Created: 2011-04-29 11:48:39
Document Modified: 2011-04-29 11:48:39
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC