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Petition for Rulemaking

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Petition for Rulemaking Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) FWCC Request for Declaratory Ruling on ) Partial-Band Licensing of Earth ) IB Docket No. 00-203 Stations in the Fixed-Satellite Service ) RM-9649 That Share Terrestrial Spectrum ) ) FWCC Petition for Rulemaking to Set ) Loading Standards for Earth Stations ) In the Fixed-Satellite Service that ) Share Terrestrial Spectrum ) ) Onsat Petition for Declaratory Order that Blanket ) Licensing Pursuant to Rule 25.115(c) Is Available for ) SAT-PDR-19990910-00091 Very Small Aperture Terminal Satellite Network ) Operations at C-Band ) ) Onsat Petition for Waiver of Rule 25.212(d) to the ) Extent Necessary to Permit Routine Licensing of 3.7 ) Meter Transmit and Receive Stations at C-Band ) ) Ex parte Letter Concerning Deployment of ) Geostationary Orbit FSS Earth Stations in the Shared ) Portion of the Ka-band ) ) REPLY COMMENTS OF THE GLOBAL VSAT FORUM The Global VSAT Forum hereby submits its reply comments in response to the Notice of Proposed Rulemaking in the above-captioned proceeding, FCC 00-369 (rel. Oct. 24, 2000) (the “Notice”). The Global VSAT Forum (GVF) is an association of organizations engaged in the delivery of advanced digital fixed satellite services via Very Small Aperture Terminals (VSATs) to consumers, and commercial and government enterprises worldwide.1 The term "VSAT" refers to fixed small-aperture terminals that provide interactive or receive-only telecommunications to an end-user premises via either geostationary or non-geostationary satellites, and operating across all FSS bands (C, Ku, and Ka-band). Headquartered in London, the GVF is an independent, non-partisan and non-profit organization with 112 members. The broad-based membership represents every major world region and every sector of the satellite industry, including satellite operators, VSAT network operators, VSAT manufacturers, system integrators, value added and enhanced service providers, telecom carriers, and users. The GVF fully supports the comments submitted by the Satellite Industry Association, the Satellite Broadcasting and Communications Association, The World Teleport Association and the Aerospace Industries Association of America (collectively, the “Satellite Industry Coalition” or the “Coalition”) to the FCC on January 8, 2001. We join the Satellite Industry Coalition in voicing our opinion that we believe the changes in satellite earth station licensing and coordination proposed by the Fixed Wireless Communications Coalition (“FWCC”) and reflected in the Notice could have devastating consequences for the satellite industry, for the following reasons: 1 The GVF’s corporate members include: AAE Systems, Anacom, Andrew, Asiasat, Belgacom, BT, Cable & Wireless/Vitacom, Channel Master, Codan, Communications Center, COMSAT, COMSYS, ESYS, EUTELSAT, Flash Networks, GE Americom, Gilat Satellite Networks, GS Telecom, Gulfsat, HOT Telecommunications, Hughes Network Systems Hutchison Corporate Access, IBM Global Network, INTELSAT, IWL Communications, Lockheed Martin-Intersputnik, Loral Cyberstar MCI-Worldcom, MTN, NASC (Russia), NEC, Netcom, New Skies Satellites, Norsat International, Nortel DASA, NSI Communications, PacAmTel, PanAmSat, Paradigm, PBI/Via Satellite magazine, Prodelin, Satworks, Scientific-Atlanta, SES-Astra, Signal Processors Ltd., Singapore Telecom, SNEF Groupe, Spaceline, Spacenet Inc., Stanford Telecom, Station 12, STM Wireless, TeleDanmark, Teledesic, Teleglobe, Telenor, Teleport Bulgaria, Telespazio, Telstra V Comm, Terrasat, Titan Wireless, Transcom, Transtel, UNISAT, United Telesys, Vertex, Viasat, VSPA (India), and York University. First, there is no evidence to support the licensing and coordination changes proposed by the FWCC. The existing Commission policies, which are being attacked by the FWCC, support satellite operations and enable both satellite services, as well as the fixed wireless community to grow and prosper side by side. The flexibility built into current regulations is essential to continued efficient provision of satellite services. The record contains no evidence that current policies unfairly disadvantage terrestrial operators, and therefore the Commission should not adopt rules that could substantially undermine the viability of next-generation broadband satellite systems. Second, the proposed use demonstration requirement is impractical and would unreasonably burden satellite services. The framework proposed by the Commission would be extremely cumbersome to apply, would require disclosure of competitively sensitive information, would involve frequency coordinators in making determinations for which they are ill prepared, and would severely impact the provision of VSAT services to the public. Accordingly, the Commission should reject the proposal. Thirdly, the Notice also proposes changes in the procedures for coordination of satellite and terrestrial facilities in shared spectrum. Specifically, the Notice suggests that in certain circumstances, the analysis and outcome of one coordination should affect future coordination involving the same or different parties. These new rules are unnecessary and would be impractical to implement. Therefore, the Commission should reject them. Fourth, the GVF supports the proposal made by Hughes that the Commission adopt a stream-lined licensing approach to facilitate the ubiquitous deployment of GSO FSS earth terminals in the Ka-band spectrum shared with FS systems. For the reasons set forth above, the FWCC proposals for changes in the licensing and coordination of earth stations, as modified and proposed in the Notice should be rejected. The GVF, however, urges the Commission to adopt the Hughes proposal for streamlined licensing of Ka-band terminals. Respectfully submitted, Global VSAT Forum By: __/s/ David Hartshorn_________ David Hartshorn Secretary General Global VSAT Forum 2 Victoria Square, Victoria Street St. Albans, Hertfordshire AL1 3TF UK February 9, 2001.
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