DGRB-001-98 — Globalstar Canada
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By Courier and e-mail to DGIR@ic.gc.ca
September 9, 1998
Space and International Regulatory Activities
Radiocommunication and Broadcasting Regulatory Branch
300 Slater Street
Ottawa, Ontario K1A OCA
Re: Notice No. DGRB-001-98 Canada Gazette, Part I, June 13, 1998
Consultation on Spectrum Licence Fees for Mobile Satellite Services in Canada Using MSS Spectrum Above 1 GHz
Globalstar Canada Co. ("Globalstar Canada") is pleased to comment on the above-referenced consultation paper.
Globalstar Canada has been authorized by Industry Canada to provide MSS services in Canada using the Globalstar LEO satellite network. We have participated in the discussions which led to the response of the Radio Advisory Board of Canada ("RABC"), and we endorse the suggestions and recommendations contained therein. We would add the following comments from the perspective of Globalstar Canada.
- With respect to the increment of spectrum to be used to calculate fees, we suggest an increment of 50 kHz would be appropriate to avoid unnecessary rounding-up and the payment of fees for unused and unassigned spectrum. 500 kHz is clearly too large an increment, and use of a smaller, more realistic one will not add any administrative complexity to the determination of fees.
- We support the Department's proposal to use a one-third multiplier with respect to spectrum that is shared, or is licensed on a non-exclusive basis, whether or not it may be shared at any point in time. Such spectrum is obviously of less value than dedicated spectrum, and the one-third multiplier recognizes that fact in a manner which deals equitably with different sharing scenarios, and which will be easy for the Department to administer.
- We also strongly endorse the suggestion of the RABC that for start-up operations, there should be a ramping-up mechanism, such as 25% in year one, 50% in year two, and full fee in the third and subsequent years. Start-up operations such as Globalstar Canada must invest considerable sums in building the necessary infrastructure, and will not be profitable for many years. Any new licence fee regime should recognize that fact, and should support the growth of new Canadian telecommunications companies through a phased approach to fees. Indeed, the current per-terminal approach to fees, while administratively cumbersome, does recognize the needs of start-up operations.
We would be pleased to answer any questions on the above, or to take part in any follow-up discussions that may be convened to further consider the Department's proposals.
Signed by Claude Lewis
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