Iridium - Conditiona

WITHDRAWAL submitted by Iridium Constellation LLC

Iridium Withdrawal of Petition to Deny

2017-11-14

This document pretains to SAT-LOA-20161115-00117 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2016111500117_1303432

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


    In the Matter of
                                                                               File No.
    Audacy Corporation
                                                                               SAT-LOA-20161115-00117
    Application for Satellite Space Station Authorizations


                    CONDITIONAL WITHDRAWAL OF PETITION TO DENY

           On June 26, 2017, Iridium Constellation LLC (“Iridium”) petitioned to deny the

application of Audacy Corporation (“Audacy”) for authority to launch and operate a non-

geostationary satellite orbit (“NGSO”) system in the fixed satellite service (“FSS”) and inter-

satellite service (“ISS”). 1 In its petition, Iridium explained that Audacy would be unable to

coordinate its proposed operations in the 22.55-23.55 GHz band with Iridium’s inter-satellite

links, which operate in the 23.18 to 23.38 GHz band. 2 In response to Iridium’s petition, Audacy

committed to “fil[ing] a minor modification that removes the 23.18-23.38 GHz band currently

used by Iridium for inter-satellite links from Audacy’s pending NGSO application,” and

“concurrently amend[ing] its Schedule S to reflect this change.” 3

           Consistent with its commitment, Audacy has requested that its application be amended to

remove any request for authority to operate in the 23.18-23.38 GHz band. 4 Audacy also




1
      Petition to Deny of Iridium Constellation, LLC, IBFS File No. SAT-LOA-20161115-00117 (filed June 26,
      2017).
2
      Id. at 3-6.
3
      Opposition and Response of Audacy Corporation at 19-20, IBFS File No. SAT-LOA-20161115-00117 (filed
      July 7, 2017).
4
      Letter from James Spicer, Chief Engineer, Audacy, to Marlene H. Dortch, Secretary, FCC, at 1-2, IBFS File No.
      SAT-LOA-2016115-00117 (filed Aug. 11, 2017).

                                                         1


requested that its application be amended to delete all references to the 23.18-23.38 GHz band

from the legal narrative and Schedule S to reflect the change. 5

          The amendment sought by Audacy, if granted, would eliminate any frequency overlap

between its proposed system and Iridium’s inter-satellite links, and thereby moot the concerns

raised in Iridium’s petition. Accordingly, Iridium hereby withdraws its petition, conditioned on

the Bureau’s acceptance of Audacy’s request to amend its application.



                                                      Respectfully submitted,



Maureen C. McLaughlin                                 Scott Blake Harris
Vice President, Public Policy                         V. Shiva Goel
IRIDIUM CONSTELLATION LLC                             HARRIS, WILTSHIRE & GRANNIS LLP
1750 Tysons Boulevard, Suite 1400                     1919 M Street, NW, 8th Floor
McLean, VA 22102                                      Washington, DC 20036
(703) 287-7518                                        (202) 730-1313


November 14, 2017




5
    Id.

                                                 2


                               CERTIFICATE OF SERVICE
       I hereby certify that a true and correct copy of the foregoing Comments of Iridium
Constellation LLC was sent by mail on September 14, 2017, to the following:


       Ulises R. Pin
       Timothy Bransford
       Denise Wood
       Morgan, Lewis & Bockius LLP
       2020 K Street, N.W.
       Washington, D.C. 20006
       Counsel for Audacy Corporation




                                                    /s/
                                                           Elizabeth Marley



Document Created: 2019-04-11 16:54:23
Document Modified: 2019-04-11 16:54:23

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