Attachment Public Notice

This document pretains to SES-T/C-20070404-00441 for Transfer of Control on a Satellite Earth Station filing.

IBFS_SESTC2007040400441_571002

      PUBLIC NOTICE
       Federal Communications Commission                                         News Media Information 202 / 418-0500
       445 12th St., S.W.                                                                 Internet: http://www.fcc.gov
       Washington, D.C. 20554                                                                     TTY: 1-888-835-5322




                                                                                              DA 07-2257
                                                                                   Released: May 30, 2007

Stratos Global Corp. and Robert M. Franklin, Trustee, Seek FCC Consent to the Indirect Transfer
  of Control of Stratos Global’s Wholly-Owned, FCC-Authorized Subsidiaries from Stratos to an
                                        Irrevocable Trust

                                          WC Docket No. 07-73

                                 PLEADING CYCLE ESTABLISHED

Petitions to Deny Due:           June 29, 2007
Oppositions Due:                 July 9, 2007
Replies Due:                     July 16, 2007

I.         INTRODUCTION

         Stratos Global Corp. (Stratos Global) and Robert M. Franklin, Trustee (Trustee), have filed
Applications pursuant to sections 214 and 310(d) of the Communications Act of 1934, as amended
(Communications Act),1 seeking approval of the transfer of control of Stratos Global and its wholly-
owned subsidiaries (the “Stratos Subsidiaries”) that hold authorizations from the Commission (Stratos
Licensees and, together with Stratos Global and the Stratos Global Subsidiaries, “Stratos”) from the
current shareholders of Stratos Global to an irrevocable trust (Trust) for which Mr. Franklin is the
Trustee.

      Stratos provides mobile satellite service (MSS), fixed satellite service (FSS) and terrestrial
communications using, among other things, capacity that it purchases from various satellite operators.

        The Trust, to which Stratos would be transferred, is established under the laws of Canada by CIP
Canada Investment Inc. (CIP Canada), a wholly-owned subsidiary of CIP UK Holdings Limited (CIP
UK), which, in turn, is a wholly-owned subsidiary of Communications Investment Partners Limited
(CIP). CIP, a professional investment company, is making the proposed investment in Stratos Global
through its subsidiaries and the Trust. The beneficiary of the Trust, and therefore the beneficial owner of
Stratos Global, will be CIP Canada.

        Upon completion of the proposed transaction, the Trustee will have full autonomy to vote the
Stratos Global shares, subject to his fiduciary obligations to the beneficiary. Current Stratos management
will continue to operate the Stratos business, subject to the Trustee’s control and oversight through
exercise of his voting rights in the Stratos Global shares.


1
    47 U.S.C. §§ 214, 310(d).


        The proposed transaction will be financed indirectly by Inmarsat Finance III Limited (Inmarsat
Finance), a wholly-owned subsidiary of Inmarsat plc (Inmarsat). Another Inmarsat subsidiary, Inmarsat
Global Ltd. (Inmarsat Global), has contractual restrictions that expire in April, 2009, that prevent
Inmarsat Global from owning or controlling Stratos or any other distributor of Inmarsat services. CIP has
granted Inmarsat Finance a call option to acquire the stock of CIP UK, which is exercisable over a 17-
month period beginning in April 2009 and ending on December 31, 2010; thus, Inmarsat has an
irrevocable right to acquire Stratos Global after the contractual restrictions on Stratos Global have
expired. Until April 2009, the shares of Stratos Global will be held by the Trust to give the Trustee both
de jure and de facto control of Stratos, so as to comply with Inmarsat Global’s contractual obligations.

II.     THE PARTIES

        A.       The Transferor - Stratos Global

         Applicants represent that Stratos Global is a public company, traded on the Toronto Stock
Exchange, and is widely held, primarily by Canadian and U.S. shareholders. Stratos Global’s corporate
headquarters and principal place of business is Bethesda, Maryland. The Stratos Licensees are wholly-
owned subsidiaries of Stratos Holdings, Inc., a Delaware corporation, which is a wholly-owned subsidiary
of Stratos Wireless, Inc., a Canadian corporation, which, in turn, is a wholly-owned subsidiary of Stratos
Global, also a Canadian corporation.

          Stratos provides MSS, FSS and terrestrial communications services. In the United States, Stratos
provides MSS, FSS and VSAT (very small aperture terminal) satellite services, using satellite capacity
that it acquires from other entities. With respect to MSS, Stratos resells satellite services for satellite
operators such as Globalstar, Inmarsat, Iridium and MSV. Stratos holds FCC licenses for Inmarsat
mobile earth terminals, but does not own or operate any MSS gateway earth stations in the United States.
Stratos provides VSAT services by reselling the services of several providers of FSS systems, such as
Intelsat and SES, and using a number of U.S. VSAT hubs that are licensed to Stratos. Further, Stratos
operates a terrestrial microwave network in the Gulf of Mexico, which it primarily uses to serve offshore
oil and gas drilling platforms. Finally, Stratos provides local exchange, competitive access, and
interexchange telecommunications services in Louisiana and Texas, also primarily to oil and gas industry
customers.

        B.       The Transferee - The Trustee

        Applicants state that the Trust is organized under the laws of Canada solely to hold the shares of
Stratos Global upon completion of this proposed transaction. The Trustee is Robert M. Franklin, a
Canadian citizen. Mr. Franklin has served on the board of several corporations.2

        C.       CIP

         CIP is a limited partnership organized under the laws of the British Virgin Islands to hold shares
of Stratos Global. CIP is a professional investment company that focuses on investments in satellite
service companies. The five Directors and sole equity holders of CIP are Hans Lipman (a Dutch citizen),
Eric de Jong (a Dutch citizen), Hans van Moorsel (a Dutch citizen), Eric Le Proux (a French citizen) and
Victor Horcacitas (a dual U.S. and Mexican citizen). Each holds a 20 percent equity and voting interest
in CIP.

2
  Mr. Franklin served as chairman of Glenayre Electronics Limited, a telecommunications hardware and software
company from 1990-93; as a director of Call-Net Enterprises, Inc., a Canadian competitive carrier from 2002-2005;
and as Chairman of Placer Dome, Inc., a Canadian mining company, from 1993-2006. Mr. Franklin currently serves
as a director of Barrick, an international gold mining company.

                                                       2


         CIP has established two holding companies to effectuate the proposed transaction: CIP UK (a
private limited company incorporated under the laws of England and Wales); and CIP Canada (a
Canadian company). CIP Canada is wholly owned by CIP UK, which, in turn, is wholly owned by CIP.

        D.      Inmarsat Entities

          Inmarsat Finance, a company incorporated under the laws of England and Wales, is a special-
purpose company that was established by its direct parent company, Inmarsat, to provide debt financing
to CIP to fund the acquisition of Stratos. Inmarsat Global, also incorporated under the laws of England
and Wales, operates a global MSS satellite system that, through its distributors, offers a variety of mobile
satellite services. Inmarsat was created by the INMARSAT Convention in 1979 as an inter-governmental
organization to develop a global maritime satellite system. Inmarsat privatized in 1999 by converting to a
private UK company headquartered in London. In 2005, Inmarsat became a public company, listed on
the London Stock Exchange. Inmarsat’s shares are widely held, and no shareholder owns 10 percent or
more of the company. Applicants state that, in aggregate, more than 85 percent of Inmarsat’s shares are
owned by citizens of or entities organized under the laws of countries that are members of the World
Trade Organization (WTO). Applicants state that, at present, Inmarsat Global is contractually restricted
from selling its services directly to end users, or from owning or controlling a company that distributes its
services. Applicants further state that Inmarsat Global’s current distribution agreements, which contain
this restriction, will expire in April, 2010.

III.    THE TRANSACTION

        The agreement entered into between CIP UK, CIP Canada and Stratos Global, provides that CIP
Canada will purchase all the shares of Stratos Global through a Plan of Arrangement under the Business
Corporations Act of Canada. The Plan of Arrangement requires approval both by an Ontario court and by
66 2/3 percent of votes cast at a special meeting of the shareholders.

        Upon completion of the transaction, the shares of Stratos Global will be held by the Trust. The
Trust, which is irrevocable, was formed to give the Trustee de jure and de facto control of Stratos. The
Trust will exercise all voting rights in the Stratos Global stock. The Trust Agreement expressly prohibits
any communication between the CIP entities or the Inmarsat entities and the Trustee regarding the
operation of Stratos. Applicants state that the Trustee has no familial ties or business relationships with
CIP, apart from the Trust, or with Inmarsat. The Trustee may be removed only upon a finding by an
independent party that the Trustee is in breach of his fiduciary obligations, or if the Trustee is adjudged to
be incompetent by a court.

         Applicants further state that Inmarsat Finance will finance the transaction, pursuant to a “loan
facility” under which CIP UK may draw up to $250 million to fund the cost of CIP Canada’s acquisition
of Stratos. Additional funds will be available for CIP Canada’s refinancing of Stratos’s existing senior
debt facility or its funding of the tender offer for Stratos’s outstanding bonds required to be made
following completion of the transaction. The Applicants represent that the loan facility has a ten-year
term with an interest rate of 5.75 percent through December 31, 2010, and 11.5 percent thereafter.
Applicants note that interest on the loan is to be on a “paid in kind” basis until April 14, 2009. Applicants
further note that the loan is unsecured until April 14, 2009 (when a security package subordinated to the
existing Stratos indebtedness will be put into place), except that, in the event of a default, Inmarsat
Finance can require CIP UK to divest its shares in CIP Canada and to pay the net proceeds to Inmarsat
Finance. Thus, Applicants assert that, even as a creditor of CIP UK, Inmarsat will not be able to take
control over the management and affairs of Stratos until April 2009 and that, even then, could do so only
with prior permission from the Commission.


                                                      3


        Applicants state that CIP has granted Inmarsat Finance an irrevocable call option to acquire CIP
UK for consideration of $750,000. Applicants further state that the call is exercisable over a 17-month
period beginning in April, 2009, and ending December 31, 2010. The exercise price for the call will be
between $750,000 and $1,000,000, depending upon when the option is exercised. Unless and until it
exercises the call (and obtains regulatory approval), Inmarsat may not acquire any equity interest in
Stratos or influence its management.

         Subject to regulatory approval, the Trust will automatically terminate on April 14, 2009, unless
Stratos shares have not been transferred out of the Trust by that date. Applicants state that there are three
routes by which this may occur. First, Inmarsat Finance could exercise the call option to acquire CIP UK,
at which time the Trustee will transfer the shares to CIP Canada. Second, if Inmarsat Finance does not
exercise the call option, CIP Canada may acquire the shares. Third, if neither of these events has
occurred because governmental approvals cannot be obtained, the Trustee will arrange for an investment
bank to sell the shares through an auction.

IV.       THE APPLICATION

The Application consists of eleven individual applications and documents as follows:

      ·   Four FCC 312 Forms seeking consent for the transfer of Stratos Global’s VSAT, FSS and MSS
          earth station Authorizations;

      ·   Three FCC 214 Forms seeking consent for transfer of Stratos Global’s various international
          section 214 Authorizations;

      ·   Two FCC Domestic 214 applications seeking consent to transfer Stratos Global’s domestic
          section 214 authority;

      ·   One FCC Form 603 seeking consent to transfer Stratos Global’s various terrestrial radio licenses;
          and

      ·   One FCC Form 44 seeking consent to transfer Stratos Global’s Authorization as an Accounting
          Authority.

V.        SECTION 214 AUTHORIZATIONS

          A.      International Authorizations

        The following applications for consent to the transfer of control of international section 214
authorizations to Robert Franklin (Trustee) have been assigned the file number listed below:

International Facilities–Based and Resale Services:

File No.                          Authorization Holder                     Authorization Number

International Facilities-Based and Resale Services:

ITC-T/C-20070405-00136            Stratos Communications, Inc.             ITC-214-19980828-00591
                                                                           ITC-214-19980326-00205
                                                                           ITC-214-19980121-00028
                                                                           ITC-214-20010220-00657
                                                                           ITC-MOD-20040624-00241

                                                      4


Mobile Networks:

ITC-T/C-20070405-00133           Stratos Mobile Networks, Inc.            ITC-214-19981214-00859
                                                                          ITC-214-19970924-00580
                                                                          ITC-214-19970804-00455
                                                                          ITC-214-19970627-00356
                                                                          ITC-214-19961003-00481
                                                                          ITC-214-19980130-00053
                                                                          ITC-214-19910301-00010*
                                                                             (Formerly ITC-90-088)
                                                                          ITC-214-19901030-00011*
                                                                             (Formerly ITC-91-012)
                                                                          ITC-214-19910615-00009*
                                                                             (Formerly ITC-91-157)
                                                                          ITC-214-19911206-00008*
                                                                             (Formerly ITC-92-058)
                                                                          ITC-214-19911206-00007*
                                                                             (Formerly ITC-92-059)
                                                                          ITC-214-19921026-00124*
                                                                              (Formerly ITC-93-013)
                                                                          ITC-214-19921026-00123*
                                                                             (Formerly ITC-93-014)
                                                                          ITC-214-19910201-00255*
                                                                             (Formerly ITC-93-141)
                                                                          ITC-214-19931001-00254*
                                                                             (Formerly ITC-93-142)
                                                                          ITC-214-19930511-00253*
                                                                             (Formerly ITC-93-188)
                                                                          ITC-214-19950526-00034*
                                                                             (Formerly ITC-95-359)
                                                                          ITC-214-19951001-00033*
                                                                             (Formerly ITC-95-565)
                                                                          ITC-214-19951001-00032*
                                                                             (Formerly ITC-95-569)
                                                                          ITC-214-19960101-00012*
                                                                             (Formerly ITC-96-041)

*       The above File Numbers for the section 214 authorizations marked with an * are new numbers
assigned under the IBFS system. The former number for each such authorization is shown below the new
number.

Offshore:

ITC-T/C-20070405-00135           Stratos Offshore Services Company        ITC-214-19991220-00815
                                                                          ITC-214-19980914-00636

         Applicants request streamlined processing for all three of the above Applications. Applicants
assert that the Applications qualify for streamlined processing because the licensee in each of the
Applications, i.e., Stratos Mobile (ITC-T/C-20070405-133), Stratos Offshore (ITC-T/C-20070405-
00135), and Stratos Communications (ITC-T/C-20070405-00136), qualifies for a presumption of non-
dominance under section 63.10(a)(3) of the Commission’s rules, because the foreign carrier that each is
affiliated with has less than a 50 percent share of the local access markets in the relevant geographical
                                                       5


markets.3 Alternatively, Applicants assert that the Applications qualify for streamlined processing
because none of the three licensees is affiliated with any dominant U.S. carrier whose international
switched or private-line services it seeks to resell, see 47 C.F.R. § 63.12(c)(2).4

         In light of the multiple applications before the Commission in this transaction and the public
interest review associated with them, however, we conclude, pursuant to sections 63.12 (c) and (d) of the
Commission’s rules, that all three of the above international section 214 Transfer of Control Applications
transfer of control Application are not subject to streamlined treatment.5

           B.       Domestic Authorization

         The following applications for consent to the transfer of control of domestic section 214 authority
of Stratos Global Corporation and Stratos Offshore Services Company have been assigned the following
docket number:

Docket Number:                                 Authorization Holder

WC Docket No. 07-73                            Stratos Communications, Inc.
                                               Stratos Offshore Services Company

         Applicants filed two Applications for consent to transfer control of the domestic section 214
authority of Stratos Global Corporation and Stratos Offshore Services Company from Stratos
Communications, Inc. to Robert Franklin, Trustee. Stratos Communications, Inc., an indirect subsidiary
of transferor, Stratos Global Corporation, provides nationwide mobile satellite services where the
originating and terminating points may both be in the United States; Stratos Offshore Services Company,
a Stratos Communications, Inc., affiliate, provides wireline services in the United States, primarily in the
Gulf of Mexico region.

         Applicants assert that these transactions are entitled to presumptive streamlined treatment under
section 63.02(b)(1)(ii) of the Commission's rules because the proposed transactions involve only the
transfer of assets to a trust and the Trustee, Robert Franklin, is not a telecommunications provider.6
Alternatively, Applicants assert that these transactions are entitled to presumptive streamlined treatment
under section 63.02(b)(2)(i) because the Applicants and their affiliates will have a market share in the
interstate, interexchange market of less than 10 percent, provide competitive telephone exchange service
in markets served by a dominant local exchange carrier not party to the transaction, and are not dominant
with respect to any service.7 In light of the multiple applications before the Commission in this
transaction and the public interest review associated with them, however, we conclude, pursuant to
section 63.03(c) of the Commission’s rules, that Applicants’ domestic section 214 transfer of control
Applications are not subject to streamlined treatment.8




3
    See 47 C.F.R. § 63.10(a)(3) (2006).
4
    See 47 C.F.R. § 63.12(c)(2) (2006).
5
    See 47 C.F.R. § 63.12(c) and (d) (2006).
6
    See 47 C.F.R. § 63.03(b)(1)(ii) (2006).
7
    See 47 C.F.R. § 63.03(b)(2)(i) (2006).
8
    See 47 C.F.R. § 63.03(c) (2006).

                                                         6


VI.        SECTION 310(d) APPLICATIONS

           A.     Part 25-Satellite Earth Station, VSAT, and Space Station Authorization
           Applications

         The following applications for consent to the assignment and transfer of control of satellite earth
station, VSAT, and space station authorizations to Robert Franklin (Trustee) have been assigned the file
numbers listed below:

File No.                                   Licensee                                   Call Sign(s)

SES-T/C-20070404-00440                     Stratos Offshore Services Company          E950151
                                                                                      E010263

SES-T/C-20070404-00441                     Stratos Communications, Inc.               E010050
                                                                                      E010049
                                                                                      E010048
                                                                                      E010047
                                                                                      E000180

SES-T/C-20070404-00442                     Stratos Offshore Services Company          E950150
                                                                                      E950149
                                                                                      E960147
                                                                                      E950136
                                                                                      E950135

SES-T/C-20070404-00443                     Stratos Offshore Services Company          E980235

           B.       Part 90-Wireless Licenses

        The following application for consent to the assignment and transfer of control of wireless service
licenses to Robert Franklin (Trustee) has been assigned the file number listed below:

File No.                          Licensee                                            Lead Call Sign

00029617379                       Stratos Offshore Services Company                   WPNA687


VII.       APPLICATION FOR ASSIGNMENT OF ACCOUNTING AUTHORITY STATUS

        Pursuant to section 3.20 of the Commission’s rules,10 Applicants filed an Application for
Certification as an Accounting Authority (FCC Form 44). Applicants note that one of the Stratos

9
  By amendment filed April 27, 2007, Applicants amended this application to add 31 additional call signs for
microwave licenses to be transferred to the Trust. These 31 licenses were included in an assignment of licenses
from Chevron USA Inc., Sola Communications, L.L.C., and Devon Energy Corporation (the Chevron Assignment)
to Stratos Offshore, to which the Commission consented on March 3, 2007. Applicants state that they filed the
pending Transfer of Control application on April 5, 2007, after the Commission’s consent to the assignment but
before the transaction could be consummated. As a result, Applicants note that they could not include the 31
licenses in the Application. Now that the Chevron Assignment transaction has been completed, the Applicants have
added the additional call signs.
10
     47 C.F.R. § 3.20 (2006).

                                                       7


Licensees, Stratos Mobile Networks, Inc., is currently certified by the Commission as an accounting
authority in the maritime mobile and maritime mobile-satellite radio services, holding Accounting
Authority Identification Code (AAIC) No. US09.11 Maritime Mobile and Maritime Mobile-Satellite
communications refer to communications exchanged between two vessels on the high seas or between a
vessel and a land radio station. An accounting authority is an entity, licensed by a government, that
settles accounts for mobile radio stations on vessels licensed by that government, that is, the entity to
which a foreign maritime mobile radio station operator may send the bill for the vessel’s mobile
communications. The accounting authority sends the bill to the vessel operator and remits such vessel’s
payment to the foreign station operator.

         Applicants note that they do not, by this application, seek to assign, or otherwise encumber,
Stratos Mobile’s accounting authority status, but seek only to update the ownership and control
information in the Commission’s files with respect to that accounting authority certification. Applicants
note that section 3.51 of the Commission’s rules requires accounting authorities to notify the Commission
“in advance of any proposed transfer of control of an accounting authority’s firm or organization by any
means, to another entity.”12 Applicants note that notification is required because, under the proposed
transaction, the ultimate parent corporation of Stratos Mobile, Stratos Global Corporation, is going from a
publicly traded corporation to one that is privately held.

        Applicants assert that Stratos Mobile does not currently expect to change the way it administers
its Accounting Authority function as a result of the proposed transaction. Applicants assert that Stratos
Mobile will continue to perform all settlement operations for U.S. licensed vessels through its office in
Bethesda, Maryland (USA).

VIII.      PETITION FOR DECLARATORY RULING UNDER SECTION 310(b)(4)

        The Applicants have filed, pursuant to section 310 (b)(4) of the Communications Act, a petition
for a declaratory ruling that it is in the public interest for the Stratos Licensees to be controlled by a
Canadian Trust with a Canadian Trustee, with up to 100 percent foreign ownership.13

         According to the Applicants, after consummation of the proposed transaction, the stock of Stratos
will be owned by a Canadian Trust (whose Trustee is a citizen and resident of Canada). Further, the
direct and indirect beneficiaries of the Trust will be CIP Canada (a Canadian corporation), which is
wholly owned by CIP UK (a private company incorporated under the laws of England and Wales), which
in turn is a wholly-owned subsidiary of CIP (a British Virgin Islands corporation). Applicants state that
CIP is a new investment company whose initial (and only proposed current) investment will be in Stratos.
CIP is owned by five principals, each of whom holds a 20 percent equity and voting interest. These are
Hans Lipman (a Dutch citizen and resident), Eric Johannes Werner de Jong (a Dutch citizen and resident),
J.J.M. (“Hans”) van Moorsel (a Dutch citizen and resident), Eric Marie Alain Le Proux de la Riviere (a
French citizen and resident), and Victor Horcasitas Rivas (a dual U.S. and Mexican citizen, whose
primary residence is Spain). Finally, Applicants note that financing for the proposed transaction will
come from Inmarsat Finance III Limited, a subsidiary of a widely-held, publicly traded company,
Inmarsat, that is incorporated under the laws of England and Wales.

        Applicants state that the Trustee, CIP and its subsidiaries, and the CIP principals are all either
organized under the laws of or are citizens of Canada, the Netherlands, the British Virgin Islands,

11
     See Notification of Approval as an Accounting Authority, DA 04-758 (rel. March 23, 2004).
12
     47 C.F.R. § 3.51 (2006).
13
     47 U.S.C. § 310(b)(4).

                                                          8


England and Wales, Mexico or France, all of which are Members of the WTO. As a result, Applicants
argue that the presumption in the Commission’s Foreign Participation Order14 that foreign ownership in
excess of the section 310(b)(4) benchmark will serve the public interest applies to this Application.
Further, Applicants assert that, because this is CIP’s first investment in the communications industry, and
because the Trustee has no other cognizable interests in the telecommunications industry, the transaction
raises no competitive concerns. The petition for declaratory ruling has been assigned the file number ISP-
PDR-20070405-00006.

IX.        EX PARTE STATUS OF THIS PROCEEDING

         Pursuant to section 1.1200(a) of the Commission’s rules,15 the Commission may adopt modified
or more stringent ex parte procedures in particular proceedings if it finds that the public interest so
requires. We announce that this proceeding will be governed by permit-but-disclose ex parte procedures
that are applicable to non-restricted proceedings under section 1.1206 of the Commission’s rules.16

        We direct parties making oral ex parte presentations to the Commission’s statement re-
emphasizing the public’s responsibility in permit-but-disclose proceedings and are reminded that
memoranda summarizing the presentation must contain the presentation’s substance and not merely list
the subjects discussed.17 More than a one- or two-sentence description of the views and arguments
presented is generally required.18 Other rules pertaining to oral and written presentations are set forth in
section 1.1206(b) as well.19 We urge parties to use the Electronic Comment Filing System (ECFS) to file
ex parte submissions.20

X.         GENERAL INFORMATION

         The applications referenced herein have been found, upon initial review, to be acceptable for
filing. The Commission reserves the right to return any application if, upon further examination, it is
determined to be defective and not in conformance with the Commission’s rules or policies. Final action
on these applications will not be taken earlier than thirty-one (31) days following the date of this Public
Notice.21

         Interested parties must file petitions to deny or comments no later than June 29, 2007. Responses
or oppositions to comments and petitions must be filed no later than July 9, 2007. Replies to such
pleadings must be filed no later than July 16, 2007. All filings concerning matters referenced in this
Public Notice should refer to DA 07-2257 and WC Docket No. 07-73, as well as the specific file numbers
of the individual applications or other matters to which the filings pertain.


14
     Rules and Policies on Foreign Participation in the U.S. Telecommunications Market, 12 FCC Rcd 23891,
15
     47 C.F.R. § 1.1200(a) (2006).
16
     Id. § 1.1206.
17
  See Commission Emphasizes the Public’s Responsibilities in Permit-But-Disclose Proceedings, Public Notice, 15
FCC Rcd 19945 (2000).
18
     See 47 C.F.R. § 1.1206(b)(2) (2006).
19
     Id. § 1.1206(b).
20
     See discussion infra Part VI.
21
     See 47 U.S.C. § 309(b).

                                                         9


       Under the Commission’s procedures for the submission of filings and other documents,22
submissions in this matter may be filed electronically (i.e., though ECFS) or by hand delivery to the
Commission’s Massachusetts Avenue location.

·       Electronic Filers:23 Comments may be filed electronically using the Internet by accessing the
        ECFS: http://www.fcc.gov/cgb/ecfs/. In completing the transmittal screen, filers should include
        their full name, U.S. Postal Service mailing address, and the applicable docket number. Parties
        also may submit an electronic comment by Internet e-mail. To get filing instructions, filers
        should send an e-mail to ecfs@fcc.gov, and include the following words in the body of the
        message, “get form.” A sample form and directions will be sent in response.

·       Paper Filers: Parties who choose to file by paper must file an original and four copies of each
        filing.

        Filings can be sent by hand or messenger delivery, by commercial overnight courier, or by first-
        class or overnight U.S. Postal Service mail (although we continue to experience delays in
        receiving U.S. Postal Service mail). All filings must be addressed to the Commission's Secretary,
        Office of the Secretary, Federal Communications Commission.

        The Commission's contractor will receive hand-delivered or messenger-delivered paper filings for
        the Commission's Secretary at 236 Massachusetts Avenue, N.E., Suite 110, Washington, D.C.
        20002. The filing hours at this location are 8:00 a.m. to 7:00 p.m. All hand deliveries must be
        held together with rubber bands or fasteners. Any envelopes must be disposed of before entering
        the building.

        Commercial overnight mail (other than U.S. Postal Service Express Mail and Priority Mail) must
        be sent to 9300 East Hampton Drive, Capitol Heights, MD 20743.

        U.S. Postal Service first-class, Express, and Priority mail should be addressed to 445 12th Street,
        S.W., Washington, D.C. 20554.

        One copy of each pleading must be delivered electronically, by e-mail or facsimile, or if delivered
as paper copy, by hand or messenger delivery, by commercial overnight courier, or by first-class or
overnight U.S. Postal Service mail (according to the procedures set forth above for paper filings), to the
Commission's duplicating contractor, Best Copy and Printing, Inc., at fcc@bcpiweb.com or (202) 488-
5563 (facsimile).


      Additionally, filers may deliver courtesy copies by email or facsimile to the following
Commission staff:

(1) David Strickland, Policy Division, International Bureau, at David.Strickland@fcc.gov or (202) 418-
2824 (facsimile);


22
  See Implementation of Interim Electronic Filing Procedures for Certain Commission Filings, Order, 16 FCC Rcd
21483 (2001); see also FCC Announces a New Filing Location for Paper Documents and a New Fax Number for
General Correspondence, Public Notice, 16 FCC Rcd 22165 (2001); Reminder: Filing Locations for Paper
Documents and Instructions for Mailing Electronic Media, Public Notice, 18 FCC Rcd 16705 (2003).
23
  See Electronic Filing of Documents in Rulemaking Proceedings, GC Docket No. 97-113, Report and Order, 13
FCC Rcd 11322 (1998).

                                                      10


(2) John F. Copes, Policy Division, International Bureau, at John.Copes@fcc.gov or (202) 418-2824
(facsimile);

(3) Karl Kensinger, Satellite Division, International Bureau, a Karl.Kensinger@fcc.gov or (202) 418-
0748 (facsimile);

(4) Erin McGrath, Wireless Telecommunications Bureau, at Erin.McGrath@fcc.gov or (202) 418-7224
(facsimile);

(5) Gail Cohen, Wireline Competition Bureau, at Gail.Cohen@fcc.gov or (202) 418-1413 (facsimile);

(6) Regina Dorsey, Office of Managing Director, at Regina.Dorsey@fcc.gov or (202) 418-2843
(facsimile);

(7) Neil Dellar, Office of General Counsel, at Neil.Dellar@fcc.gov or (202) 418-1234 (facsimile).

        Copies of the Applications and any subsequently-filed documents in this matter may be obtained
from Best Copy and Printing, Inc., in person at 445 12th Street, S.W., Room CY-B402, Washington, D.C.
20554, via telephone at (202) 488-5300, via facsimile at (202) 488-5563, or via e-mail at
fcc@bcpiweb.com. The Applications and any associated documents are also available for public
inspection and copying during normal reference room hours at the following Commission office: FCC
Reference Information Center, 445 12th Street, S.W., Room CY-A257, Washington, D.C. 20554. The
Applications also are available electronically through the Commission’s ECFS, which may be accessed
on the Commission’s Internet website at http://www.fcc.gov.

         People with Disabilities: To request this Public Notice in accessible formats (computer diskette,
large print, audio recording, and Braille) send an email to fcc504@fcc.gov or call the Consumer &
Governmental Affairs Bureau at 202-418-0530 (voice), 202-418-0432 (tty).

        For further information, contact John Copes, Policy Division, International Bureau, at 202-418-
1478.

                                                  -FCC-




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Document Created: 2019-05-30 17:24:09
Document Modified: 2019-05-30 17:24:09

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