Wireless and satellite petitions ask the FCC to reconsider an ord...

applications could be submitted -- in a separate order Thurs. (CD July 8 p3). Inmarsat and Mobile Satellite Ventures (MSV) addressed interference protection limits adopted by the Commission to protect Inmarsat’s MSS system satellites and mobile terminals (MTs) from harmful interference in the L-band. MSV said the technical restrictions on co-channel ATC user terminals in the L-band were too restrictive, allowing Inmarsat’s next- generation satellites an interference protection level of 1.4%: “This level of protection afforded Inmarsat is arbitrary because there is no record evidence to support that Inmarsat needs this level of interference protection.” The accepted international protection level is 6%, MSV said, and the FCC should adopt that as well. Not only will that level protect Inmarsat satellites, but the L-band spectrum can be use more efficiently, MSV said. A more-lenient protection level combined with an interference reduction factor of 3.5 dB for a half-rate vocoder (a device that compresses the voice signal) will allow applicants to deploy a larger number of base station carriers, 14,785, instead of 3,450, in the L- band, the company said. The Commission also should allow L- band base stations to operate at higher signal, power flux density and gain levels, all of which are set at “unreasonably conservative parameters” to protect Inmarsat user terminals, MSV said. Inmarsat told the FCC it was pleased with the adopted protection levels, but said they would be effective only if based on accurate assumptions about ATC systems and if they could be modified to account for system proposals that differed from FCC assumption. Peak gain levels specified by MSV in previous letters to the FCC are 1.5 dBi lower than what the Commission proposed, Inmarsat said, and could cause more interference than expected without certain additional limitations: “If one took this 1.5 dB adjustment into consideration in the Commission’s calculation of the expected level of self-interference from L-band ATC systems, the number of permissible MSV ATC base stations per channel would decrease to 1,221 (from 1,725).” The FCC also should clarify that the limit on the number of simultaneous transmitting ATC mobile terminals should be 90,000 to protect Inmarsat spacecraft from adjacent channel interference, the company said. Meanwhile, Boeing asked the FCC to clarify its rules on the geographic and temporal coverage requirements for MSS ATC systems. Where 2 GHz MSS licensees must provide service to the entire U.S. all of the time, 2 GHz MSS geostationary orbit licensees must provide service to the entire U.S. only “if technically feasible,” Boeing said. It’s not technically possible to provide MSS to all of Alaska from a GSO satellite and “the Commission’s geographic gating requirement for 2 GHz MSS operators should use the identical language as its geographic coverage requirement for 2 GHz MSS networks,” Boeing said. Cingular Wireless and CTIA also petitioned for reconsideration, raising concerns that gating criteria designed to ensure substantial satellite service weren’t adequate. Cingular argued that nothing in the order would prevent an MSS licensee from using 99% of its spectrum for terrestrial operations and having only terrestrial customers. “Porous gating criteria which allow predominant, if not total, terrestrial operations expose the unlawfulness of the FCC’s decision to not utilize auctions and the inconsistency with its satellite-only decisions,” Cingular said. The gating criteria don’t ensure ancillary terrestrial service will remain “truly ancillary,” it said. “While the rules do require the launch and continued operation of a mobile satellite system that meets the coverage requirements for the various MSS bands,” Cingular said, “those coverage requirements are defined solely in terms of one or more satellites being ‘in view’ of potential subscribers anywhere in the United States.” Similarly, it contended that commercial availability as defined in the order was linked to meeting coverage requirements, not requiring that an MSS licensee have paying satellite service subscribers. It called for 2 gating criteria changes: (1) Limiting the ability of MSS licensees to reduce satellite system capacity. (2) Requiring that customer equipment look first to the satellite to complete a connection. “The Commission must also make clear that MSS licensees bear the burden of demonstrating by credible evidence -- not just mere certification -- that the ATC gating criteria have been satisfied,” Cingular said. It also urged the FCC to clarify that an MSS licensee must satisfy all of its implementation milestones as part of the gating criteria. The rules “do not explicitly require” the satisfaction of implementation milestones to obtain ATC authority, but stipulate that a licensee’s service “must be commercially available” under the coverage requirements of a particular band. Similarly, CTIA said the FCC didn’t go far enough to ensure “ATC service would remain ‘ancillary’ in practice.” It said the order directed MSS ATC applicants to demonstrate that the ancillary offering was integrated with the MSS offering, which they could meet by satisfying a “safe harbor” standard or an individualized FCC assessment. A footnote to the order says such requirement shouldn’t be imposed on PDAs, laptops or other computers. But CTIA said the exact application of the footnote wasn’t clear. “There is no reason to treat PDAs or other computing devices that contain an MSS offering with an ATC component differently than a handset with the same functionality,” CTIA said.