Reply REPLY by The Boeing Company SAT-AMD-20180531-00044 Boeing Response on L

Boeing Response on L

REPLY submitted by The Boeing Company

Reply

2018-07-26

This document pretains to SAT-AMD-20180531-00044 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2018053100044_1474695

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of )
)
Amendment to License Modification ) SAT-AMD-20180531-00044
Applications of Ligado Networks Subsidiary ) SAT-AMD-20180531-00045
LLC )
) IB Docket No. 11-109
) IB Docket No. 12-340

To: Satellite Policy Branch

REPLY COMMENTS OF
THE BOEING COMPANY

The Boeing Company (“Boeing”) briefly responds to the reply comments of Ligado

Networks LLC (“Ligado”) regarding its proposed modifications to its pending application to

further modify the ancillary terrestrial component (“ATC”) of its L-band mobile satellite service

(“MSS”) network. 1 As Boeing observed previously, Boeing supports Ligado’s continuing

efforts to augment its satellite communications network with broadband terrestrial services.

The Commission, however, must ensure that Ligado’s proposed terrestrial use does not result in

harmful interference to important spectrum uses in adjacent frequency bands.

In its recent comments, Boeing addressed three issues: the need to ensure that GPS/GNSS

receivers used in small aircraft will not experience harmful interference; potential out-of-band

interference into Iridium transceivers, particularly those used in aviation; and the modifications

that will be needed to Inmarsat transceivers used aboard commercial and governmental aircraft

to enable the transceivers to withstand interference from Ligado’s broadband transmissions.

1
See Amendment to License Modification Applications of Ligado Networks Subsidiary LLC,
IBFS File Nos. SAT-AMD-20180531-00044 and SAT-AMD-20180531-00045.

Ligado provided a response on the first two of these issues in its July 19th reply

comments and Boeing anticipates that those parties that are the most directly affected by those

issues – i.e., small aircraft operators and Iridium – will address any following up concerns in

separate filings. 2 Ligado, however, did not address in its reply comments Boeing’s concern

about the significant cost and effort that will be necessary to modify Inmarsat transceivers that

are embedded in commercial and governmental aircraft.

Ligado’s failure to respond on this issue highlights Boeing’s apprehension that resolution

of the Inmarsat transceiver issue may continue to be delayed, potentially making it a sole

impediment to the operation of Ligado’s terrestrial system. In raising this point, Boeing

acknowledges that Ligado’s decision to reduce its base station power levels may address

interference into Inmarsat transceivers in certain operating conditions, such as on aircraft flying

at altitude, but an analysis of this issue has yet to be undertaken by the aviation industry through

RTCA committee SC-222 or by the FAA. Further, the interference issue with respect to

Inmarsat transceivers operating on aircraft at or near airports still needs to be addressed.

As Boeing noted in its previous comments, the required modifications to Inmarsat

transceivers on commercial and governmental aircraft will necessitate the FAA’s prior approval

and will have to be implemented on a rolling basis as aircraft become available for periodic

2
In addition, Boeing expects that RTCA committee SC-222 and the FAA will need to evaluate the impact on
Iridium transceivers.

2

Document Created: 2018-07-26 17:40:27
Document Modified: 2018-07-26 17:40:27

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