Attachment STA request

This document pretains to SES-STA-20101112-01422 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2010111201422_852128

                           Description of STA Request for E990143

        Comtech Mobile Datacom Corporation (“CMDC”) requests special temporary authority
(“STA”), pursuant to Section 25.120(b)(2) of the Commission’s Rules, to operate the mobile
earth terminals (“METs”) presently authorized pursuant to this license in portions of the L-band
(1525-1544/1545-1559 MHz and 1626.5-1645.5/1646.5-1660.5 MHz) on MSAT-2 in orbital
locations other than those currently listed on the license. CMDC is currently authorized to
operate its METs on MSAT-2 at 101.3°W.L. CMDC has been advised by LightSquared
Subsidiary LLC (“LightSquared”) that it will launch the replacement satellite for MSAT-2,
SkyTerra 1, on or about November 14, 2010, and that SkyTerra 1 will be located at 101.3°W.L.
To make room for SkyTerra 1, MSAT-2 will be relocated to 103.3°W.L. CMDC’s METs will
continue to communicate with MSAT-2 throughout the drift of this satellite from 101.3°W.L. to
103.3°W.L. It is CMDC’s understanding that its METs will continue to operate with MSAT-2
for an estimated eight (8) months after MSAT-2 is repositioned, until SkyTerra 1 has been fully
tested, service is transitioned to the new satellite, and MSAT-2 is taken out of service. CMDC
asks that the Commission grant this authority beginning as soon as possible.

         Section 25.120(b)(1) of the Commission’s Rules provides that the Commission may grant
a temporary authorization only upon a finding that there are extraordinary circumstances
requiring temporary operations in the public interest and that delay in the institution of these
temporary operations would seriously prejudice the public interest. CMDC submits that such
extraordinary circumstances exist here. This request is necessitated by the launch of SkyTerra 1
and the repositioning of MSAT-2; these events are beyond the control of CMDC. Grant of this
request will serve the public interest as it will enable CMDC to continue to meet the needs of
CMDC’s existing customers, including the U.S. Army, for services provided on LightSquared’s
satellites.

       CMDC acknowledges that any grant of this STA request is without prejudice to, and may
be conditioned on, the Commission’s final action on any CMDC application.

       For the reasons set forth above, CMDC respectfully requests that this STA be granted as
soon as possible.



Document Created: 2019-04-28 02:55:10
Document Modified: 2019-04-28 02:55:10

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