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                                Before the
                      Federal Communications Commission
                          Washington, D.C. 20554

In the Matter of                     )
                                     )
Stratos Mobile Networks (USA), LLC           )
and                                 )
Marine Satellite Services, Inc.         )
                                     )
Petition for Waiver of               )
Section 20.15(d) of the              )
Commission's Rules                   )
                                     


                             ORDER


   Adopted:  December 28, 1999          Released: December  29, 1999


By the Deputy Chief, Commercial Wireless Division, Wireless Telecommunications Bureau:

     1.  On July 2, 1998, the Commission released its Memorandum Opinion and Order and Notice
of Proposed Rulemaking in WT Docket No. 98-100, in which it determined, among other things, to
forbear from enforcing the requirement that Commercial Mobil Radio Service (CMRS) providers file
tariffs except in those situations in which a United States CMRS provider has a foreign affiliate.  See
Section 20.15(d) of the Commission's rules, 47 C.F.R.  20.15(d).  In the CMRS Forbearance Order,
the Commission stated that the purpose of this rule is to enable it to determine the presence of any anti-
competitive price squeeze behavior by a CMRS provider.

     2.  On July 13, 1999, Stratos Mobile Networks (USA), LLC and Marine Satellite Services, Inc.
(collectively "Stratos"), filed a petition for waiver of section 20.15(d) of the Commission's rules to
permit Stratos to cancel its tariff in its entirety. Stratos stated that the Commission had recently granted
a request for a waiver of section 20.15(d) filed by GTE Airfone, Inc. and that similar circumstances
existed in Stratos's case.  Stratos also stated that it is required under Section 20.15(d) to file tariffs for
service to only one country, Canada, where it is affiliated with a number of carriers who accept
settlement payments from U.S. carriers.  Stratos asserted that the rates for calls to Canada in its tariffs
are the lowest rates charged for international calls.  Specifically, Stratos stated that it uses a zone
system to determine international rates and that Canada is in "zone 1" (that with the lowest rates) along
with the United States, and will remain so.  Stratos further argued that the volume of such calls is too
small to allow it to use the affiliations in an anti-competitive manner, and that there is no reasonable
alternative to a waiver.  

     3.  We find that Stratos has met the standard for grant of its petition for waiver of section
20.15(d) of the Commission's rules.  Absent a waiver, Stratos is required to file tariffs for international
calls to Canada.  A request for a waiver of Commission rules must "set forth the reasons in support
thereof including a showing that unique circumstances are involved and that there is no reasonable
alternative within existing rules."  We find that unique circumstances exist here because Stratos's rates
for all international calls are determined by use of a zone system. In addition, we find that because the
routes in question comprise only a very small portion of Stratos's service, there is no opportunity for
anti-competitive pricing behavior by Stratos on those routes. Moreover, we note that in its waiver
request Stratos affirmed its commitment to maintain its zone system and keep Canada in zone 1. 
Finally, there is no reasonable alternative to the filing of tariffs available to Stratos.  Accordingly, we
will grant its petition for waiver.

     
     4.  Accordingly, IT IS ORDERED that, pursuant to section 4(i) of the Communications Act of
1934, as amended, 47 U.S.C.  154(i), and section 0.331 of the Communication's rules, 47 C.F.R.
0.331, the petition filed by Stratos for waiver of the provisions of section 20.15(d) of the Commission
rules, 47 C.F.R.  20.15(d), IS GRANTED.
     
     5.  IT IS FURTHER ORDERED that this Order SHALL BE EFFECTIVE upon release, in
accordance with section 1.103 of the Commission's rules, 47 C.F.R.  1.103.


                                        Federal Communications Commission



                                   William W. Kunze
                                   Deputy Chief
                                   Commercial Wireless Division
                                   Wireless Telecommunications Bureau