Attachment request

request

REQUEST submitted by Iridium

request

2004-04-06

This document pretains to SAT-MOD-20030828-00286 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2003082800286_369270

                                      Federal Communications Commission                                      DA 01—1636

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


In the Matter of Application of

Iridium LLC                                                           es O
Concerning Use of the 1990—2025/2165—2200 MHz                         IBFS Nos. SAT—LOA—19970926—00147
and Associated Frequency Bands for a Mobile—                                    SAT—AMD—20001103—00156
Satellite System


                                        ORDER AND AUTHORIZATION


          Adopted: July 17, 2001                                            Released: July 17, 2001

By the Chief, International Bureau:

                                             I.        INTRODUCTION

1.       By this Order, we authorize Iridium LLC (Iridium) to use spectrum in the 2 GHz band to provide
Mobile—Satellite Service (MSS).‘ We also authorize Iridium to operate feeder uplinks in the 29.1—29.25
GHz band, feeder downlinks in the 19.3—19.7 GHz band, and inter—satellite links in the 23.18—23.38 GHz
and 24.45—24.75 GHz bands. This action is a significant step in assigning this spectrum for MSS use and
facilitates implementation of Iridium‘s proposed system‘s technology and service offerings in the
marketplace.

                                              .        BACKGROUND

2.       Iridium proposes to construct and launch a mobile—satellite system comprised of ninety—six non—
geostationary satellite orbit (NGSO) satellites in eight orbital planes with twelve satellites equally spaced‘ ©
in each orbital plane." Iridium proposes to use service links® in the 2 GHz MSS band, feeder links® in the

‘ The term "2 GHz MSS Band" is used in this Order to refer to the 1990—2025 MHz (uplink) and 2165—2200 MHz
(downlink) frequencies. These frequencies are allocated to the Mobile—Satellite Service (MSS) in the United States.
See Amendment ofSection 2.106 of the Commission‘s Rules to Allocate Spectrum at 2 GHz for Use by the Mobile—
Satellite Service, ET Docket No. 95—18, First Report and Order and Further Notice of Proposed Rule Making, 12
FCC Red 7388 (1997), affd on recon., Memorandum Opinion and Order and Third Notice of Proposed Rule
Making and Order, 13 FCC Red 23949 (1998), further proceedings, Second Report And Order and Second
Memorandum Opinion and Order, 15 FCC Red 12315 (2000) (2 GHz Allocation & Relocation Proceeding).
* Application of Iridium LLC, File No. 187—SAT—P/LA—97(96); IBFS File No. SAT—LOA—19970926—00147 at 1, A—7
(Iridium Application).
* "Service links" are the radio links that transmit a user‘s messages in both directions between a user‘s earth terminal
and the system‘s satellite(s).

* "Feeder links" are the radio links that transmit a user‘s rriessqges in both directions between the system‘s satellite(s)
and its gateway earth station(s), connecting the MSS network with the public switched telephone network.

                                                             1


                                      Federal Communications Commission                                   DA 01—1636


  Ka—band," and inter—satellite service (ISS) links in the 23.18—23.38 GHz and 24.45—24.75 GHz bands.°
  Iridium proposes to use the 1990—2025 MHz and 2165—2200 MHz bands to serve the United States and,
  where feasible, to use the 1980—2025—MFizand 2160—2200 MHz bands to serve areas outside the United
  States.‘ The proposed satellites would operate at an altitude of approximately 850 kilometers in circular
  orbits." Each orbital plane in Iridium‘s system is inclined at 98.8 degrees to the equatorial plane with an
  orbital period of 102 minutes."
  3.      Iridium submitted its 2 GHz MSS application on September 26, 1997."" On March 19, 1998, we
  sought comment on Iridium‘s application and other 2 GHz MSS applications that we accepted for
 filing." Several parties commented on Iridium‘s proposal and The Boeing Company petitioned to defer
 consideration of this proposal." Iridium responded. The Commission subsequently adopted service
  rules for 2 GHz MSS systems." Iridium amended its application to address the requirements adopted in
_ the 2 GHz MSS Order."

                                               IH.        DISCUSSION

 4.     Under rules adopted in the Commission‘s 2 GHz MSS Order, Iridium must demonstrate that its
 system meets certain technical requirements. We address these requirements first. We then turn to
 Iridium‘s request for service links in the 2 GHz MSS band, Iridium‘s request for feeder links and inter—
 satellite links, Iridium‘s orbital debris mltlgatlon strategy, implementation milestones, and other
 licensing issues.


 * The "Ka—band" refers to the Earth—to—space (uplink) frequencies at 27.5—30.0 GHz and the corresponding space—to—
 Earth (downlink) frequencies at 17.7—20.2 GHz. The sub—bands 29.1—29.5 GHz and 19.3—19.7 GHz are allocated on
 a primary basis to MSS feeder uplinks.
 © ISS links are communication links between in—orbit satellites.

 ‘ Iridium Application at A—4 & A—5. The Members of the International Telecommunication Union (ITU) have
 divided the world into three Regions. Generally, Region 1 includes Africa, Europe, Northern and Western portions
 of Asia; Region 2 includes the Americas and Greenland; and Region 3 includes Southern portions of Asia, Australia
 and the South Pacific. See ITU Radio Regulations Article $5, Section I. In accordance with ITU Regulations, the
 1980—2010 MHz and 2170—2200 MHz bands are allocated to MSS worldwide. Id. Article $5, Section IV. Region 2
 allocations, however, vary slightly from those of the other regions. In Region 2, the 1980—1990 MHz band does not
 become available for MSS until January 1, 2005. I¢d. $5.389A. In addition, the 2010—2025 MHz and the 2165—2170—
 MHz bands, which the ITU already has made available for MSS use in Canada and the United States, will become
 available for MSS in the rest of Region 2 on January 1, 2002. Id. $5.389C & $5.389D.
 ® Iridium Application at A—7.
 ° Id.

 "° In this document, the terms "applicant" and "application" refer to all parties and their respective submissions that
 seek to operate 2 GHz MSS systems, whether the party is an applicant for U.S.—licensed systems or a filer of a letter
 of intent from non—U.S. licensed systems seeking to serve the U.S. market using 2 GHz MSS spectrum.
 " See Public Notice, Report No. SPB—119 (rel., March 19, 1998).                                                  ~
  For a list of pleadings submitted in response to Iridium‘s application, see Appendix A.
 " The Establishment ofPolicies and Service Rules for the Mobile Satellite Service in the 2 GHz Band, IB Docket
 No. 99—81, Report and Order, 15 FCC Red 16127 (2000) (2 GHz MSS Order).

 " Amendment to Pending Application of Iridium LLC, SAT—AMD—20001103—00156 (November 3, 2000) (Iridium
 Amendment); see also Public Notice, Report No. SAT—00061 (rél. November 29, 2000) (2 GHz MSS Amendment PN).

                                                           2


                                  Federal Communications Commission                             DA 01—1636

A.        Threshold Technical Requirements

          1.       Frequency Agility    =—~=—><~

5.       Under the Commission‘s service rules and policies, 2 GHz MSS systems must be capable of
operating across at least seventy percent of the United States‘ 2 GHz MSS allocation in the 1990—2025
MHz and 2165—2200 MHz bands." The Commission also requires that 2 GHz MSS systems be capable
of operating without fixed frequency translations between the uplink and downlink frequencies.‘"
Iridium‘s proposed system meets these requirements."

         2.       NGSO Coverage Requirements

6.       Section 25.143(b)(2) of the Commission‘s rules requires NGSO 2 GHz MSS systems to provide
continuous coverage throughout all fifty states, Puerto Rico and the U.S. Virgin Islands, i.e., that at least
one satellite is visible at an elevation angle of at least five degrees at all times within this geographic
area." In addition, at locations as far north as 70 degrees North Latitude and as far south as 55 degrees
South Latitude, NGSO MSS systems must operate such that at least one satellite is visible at an elevation
angle of at least five degrees for eighteen hours of every day." Iridium‘s proposed system meets these
requirements."

B.       Service—Link Spectrum

7.       The 2 GHz MSS Order adopted a hybrid band arrangement that divided the 2 GHz MSS uplink
(1990—2025 MHz) and downlink (2165—2200 MHz) bands into segments of equal bandwidth based on the
number of systems seeking assignments."‘ The Commission determined that providing 3.5 megahertz in
each direction for the nine then—pending system proponents would be sufficient to commence
operations." The Commission provided that, in the event not all system proponents proceed toward
authorization, the remaining system proponents would receive more than 3.5 megahertz of spectrum in
each direction upon authorization."      In addition, the Commission reserved one additional spectrum
segment in each direction for expansion of system(s) by operator(s) meeting certain criteria for service to
unserved areas."" The following formula expresses the amount of spectrum available for each system in
each direction of transmission:
         35 megahertz + (Number of System Proponents + One) = Size of Each Spectrum Segment**

" 2 GHz MSS Order, 15 FCC Red at 16152 C 52.

 Id. at 16152 4| 53.

 Iridium Application at A—4.
447 CFR. §25.143(b)@Gi).
" 47 CFR§25.143(b)@)Gi).
* Iridium Application at 27.
*‘ 2 GHz MSS Order, 15 FCC Red at 16138 « 16.

* Id. at 16139 « 17.

* Id.
* Id. at 16146—47 J 35—39.
® Id. at 16138 16.                                        Ts
                                                     ho


                                    Federal Communications Commission                                 DA 01—1636

There are currently eight 2 GHz MSS system proponents participating in this processing round." We
will not at this time, however, implement that portion of the Commission‘s 2 GLZz MSS Order that would
give each system proponent access—to more than 3.5 megahertz of spectrum in each direction on a
primary basis. Subsequent to release of the 2 GHz MSS Order, the Commission has received new
proposals for use of the 2 GHz MSS bands."" Delaying the designation of additional spectrum will give
the Commission the opportunity to consider these proposals.             Therefore, in this Order, Iridium will
receive access to a spectrum segment of 3.5 megahertz, in each direction of transmission, on a primary
basis, i.e., a "Selected Assignment.""" Iridium will choose its Selected Assignment such that the band
edge of the assignment is an integer multiple of 3.88 megahertz from the band edge of the 2 GHz MSS
band, which will allow the Commission to address the proposals before it.
8.       Iridium must identify the specific frequencies of its Selected Assignment when the first satellite
in its system reaches its intended orbit and notify the Commission in writing of its selection." Consistent
with the 2 GHz MSS Order, Iridium also may elect to operate outside its Selected Assignment on a
secondary basis with respect to other 2 GHz MSS operators, subject to certain conditions.""

C.       Other Requests for Spectrum Assignments

         1.       Feeder Links

9.   Iridium proposes feeder link operations in portions of the Ka—band spectrum designated for
NGSO MSS feeder links. Specifically, Iridium proposes to use the 29.1—29.5 GHz (Earth—to—space) and
the 19.3—19.7 GHz (space—to—Earth) bands.          The Commission established a co—primary allocation for
NGSO MSS feeder uplinks in the 29.1—29.5 GHz band that is shared with the Local Multipoint
Distribution Service (LMDS) at 29.1—29.25 GHz, and geostationary satellite orbit (GSO) fixed—satellite
service (FSS) systems at 29.25—29.5 GHz,"‘ subject to the special sharing requirements set forth in



* See 2 GHz MSS Amendment PN, Report No. SAT—00061.
*" See Ex parte Letter of New ICO Global Communications (Holdings) Ltd., IB Docket No. 99—81 (dated March 8,
2001) (ICO Ex Parte Letter); Petition for Rulemaking of the Cellular Telecommunications & Internet Association
{filed May 18, 2001) (CTIA Petition).

* Systems must be implemented consistent with the plans for incumbent relocation adopted in the 2 GFHz A//ocation® —
& Relocation Proceeding, Second Report And Order and Second Memorandum Opinion and Order, 15 FCC Red
12315, including the phased plan for relocation in the 1990—2025 MHz band.

* 2 GHz MSS Order, 15 FCC Red at 16138 [ 16. A satellite‘s intended orbit is the final orbit it will occupy to
provide commercial service. d n.75.
* Id. at 16139—40 [ 19. The 1990—2025 MHz (Earth—to—space) and 2165—2200 MHz (space—to—Earth) bands are
immediately adjacent to the 2025—2110 MHz (Earth—to—space, space—to—space) and 2200—2290 MHz (space—to—Earth,
space—to—space) bands, respectively, where the Federal Government has extensive satellite network operations. To
avoid the possibility of adjacent band interference, this potential interference situation needs to be considered by
both non—Government and Government satellite operators when implementing their respective satellite systems near
the band edges.
* See Rulemaking to Amend Parts 1, 2, 21, and 25 of the Commission‘s Rules to Redesignate the 27.5—29.5 GHz
Frequency Band, to Reallocate the 29.5—30.0 GHz Frequency Band, to Establish Rules and Policies for Local
Multipoint Distribution Service and for Fixed Satellite Services, First Report and Order and Fourth Notice of
Proposed Rulemaking, 11 FCC Red 19005, 19023—38 q 41—81 (1996), modified on recon., Memorandum Opinion
and Order, CC Docket No. 92—297, FCC 01—164 (rel., May 25,2001) (Ka—band Reconsideration Order).

                                                        4


                                    Federal Communications Commission                             DA 01—1636


 Sections 25.257 and 25.258 of the Commission‘s rules."" In addition, the Commission designated the
 19.3—19.7 GHz band for NGSO MSS feeder downlinks on a co—primary basis with the terrestrial fixed
 service (FS), subject to site and frequency—coordination." We note that Iridium is authorized to use the
29.1—29.25 GHz (Earth—to—space) and the 19.4—19.6 GHz band (space—to—Earth) for its currently
operational system and we are unaware of any interference problems with the co—primary services."
 10.      In its application, Iridium asks us to waive Section 25.258(c) of the Commission‘s rules, which
at the time Iridium filed its application,"" required NGSO MSS feeder link operations in the 29.25—29.5
GHz band to provide repeating sub—satellite ground tracks on the surface of the Earth."" Iridium‘s waiver
request was placed on Public Notice on October 15, 1997, along with its request to operate feeder links
in the Ka—band."" In response to this Public Notice, Hughes Communications Galaxy, Inc. (Hughes) filed
a Petition to Deny Iridium‘s waiver request."" The Commission recently eliminated the repeating ground
tracks requirement."" Therefore, we dismiss Iridium‘s waiver request and Hughes‘ Petition to Deny as
moot. Other commenters on Iridium‘s feeder link request raised concerns regarding the Iridium system‘s
ability to share frequencies in the Ka—band with FS operators in the 19.3—19.7 GHz band," GSO FSS
systems in the 29.25—29.5 GHz band,"" and LMDS facilities in the 29.1—29.25 GHz band." According to
Iridium, it is "committed to complying with the Commission‘s rules and policies, [and] to coordinating
with all services and systems with which it is required to coordinate . . . ."*" Indeed, Iridium has shown
its ability to do so through its feeder link operations in the 19.4—19.6 GHz and 29.1—29.25 GHz bands.
We will grant Iridium‘s requests for feeder link spectrum, as circumscribed below.
11.      We grant Iridium authority to configure its space stations to receive feeder link transmissions
from earth stations in the 29.1—29.5 GHz band; however, this authorization should not be construed as a
license for Earth—to—space transmission. Instead, Iridium must request authority for Earth—to—space
transmissions in an earth—station application."      At that time, Iridium will need to demonstrate that its


2 47 C.F.R. § 25.257; id. § 25.258, as modified by Ka—band Reconsideration Order, FCC 01—164.
* See Redesignation of the 17.7—19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations in the
 17.7—20.2 GHz and 27.5—30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the
17.3—17.8 GHz and 24.75—25.25 GHz Frequency Bands for Broadcast Satellite—Service Use, IB Docket No. 98—172,
Report and Order, 15 FCC Red 13430, 13456 J 53—54 (2000) (18 GHz Report and Order), petition for review
pending, Teledesic LLC v. FCC, D.C. Cir. No. 00—1466 (filed November 6, 2000).
* See U.S. Leo Services, Inc., Order and Authorization, 11 FCC Red 13962 (Int‘l Bur. 1996).
# 47 C.F.R. § 25.258(c) (1997).
* Iridium Application, Exhibit D at 1—2.
*" See Publi¢ Notice, Report No. SPB—106, 13 FCC Red 8020, 8021—22 (1997).

3 See Petition to Deny of Hughes Communications Galaxy, Inc. (filed December 22, 1997) (Hughes Petition).
* Ka—band Reconsideration Order, FCC 01—164, at 7.
* See Comments of the Fixed Point—to—Point Communications Section, Wireless Communications Division of the
Telecommunications Industry Association (filed December 22, 1997)

* See Comments of KaStar Satellite Communications Corp. (filed December 22, 1997); Comments of Lockheed
Martin Corporation (filed December 22, 1997). See also Hughes Petition, Exhibit A.
* See Comments of CellularVision USA, Inc. (filed December 22, 1997).
* Consolidated Opposition and Response of Iridium LLC at 2 (filed February 2, 1998).
*4 See 47 C.F.R. § 25.130.                                 ">



Document Created: 2004-04-07 16:07:32
Document Modified: 2004-04-07 16:07:32

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