Attachment Iridium Constellatio

Iridium Constellatio

DECISION submitted by IB, FCC

Grant with conditions

2019-09-04

This document pretains to SAT-STA-20190710-00058 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2019071000058_1888412

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                                                                             CallSigfi S2110 GrantDate_O9/¥t /19
                                                                             (orotheridentifier) TermDaics pericd of                            Approved by OMB
                                                                                                                                                           3060—0678
                                                                             From_O7/31719                                   To:   & da,
                                                        CRANTED®
Date & Time Filed: Jul 10 2019 3:15:27:416PM          International Bureau   Approved:
File Number: SAT—STA—20190710—00058
                                                     *twouth conclifions                                        3              J. Dual]
Callsign:                                                                                                        Chigt, Sarelliie Policy Bunch
                                           FEDERAL COMMUNICATIONS COMMISSION
                                APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                         FOR OFFICIAL USE ONLY


  APPLICANT INFORMATION
Enter a description of this application to identify it on the main menu:
 180—day STA for Block 1 extension
1. Applicant

           Name:         Iridium Constellation LLC            Phone Number:                                               703—287—7518
           DBA Name:                                          Fax Number:

           Street:       1750 Tysons Boulevard                E—Mail:                                                     maureen.mclaughlin@iridium.com


                         Suite 1400
           City:         McLean                               State:                                                      VA
           Country:       USA                                 Zipcode:                                                    22102      =
           Attention:    Ms Maureen C McLaughlin


                                               ATTACHMENT TO GRANT
                                                 Iridium Constellation LLC
                                       IBFS File No. SAT-STA-20190710-00058

  IBFS File No(s):         SAT-STA-20190710-00058                                                 GRANTED           —


  Licensee/Grantee:        Iridium Constellation LLC (Iridium)                                    With Conditions
  CaliSign:                S2110
  Satellite Name:          Iridium   1St   Generation Constellation
  Orbital Location:        763 km circular orbit, 86.4° inclination
  (required station-
  keeping tolerance)
  Administration:          United States of America
  Nature of Service:       Telemetry, tracking and command (TT&C)                           International Bureau
                                                                                              Satellite Division
  Scope of Grant:         Special temporary authorization for a period of 180 days to conduct TT&C operations with
                          the SV97 satellite, which is an in-orbit spare in Iridium’s Big LEO band non-geostationary
                          satellite orbit (NGSO) constellation’
  Service Area(s):        N/A
  Frequencies:             19.4-19.6 GHz (space-to-Earth)
                          29.1-29.3 GHz (Earth-to-space)

  Unless otherwise specified herein, operations under this grant must comport with the legal and technical
  specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules
  not waived herein. This grant is also subject to the following conditions:
      1.   Operations must comport with the conditions in IBFS No. SAT-MOD-20171030-00146.
  Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
  conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.

  This action is taken pursuant to Section 0.26 1 of the Commission’s rules on delegated authority, 47 C.F.R. §
  0.26 1, and is effective upon release.

 Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
 amended, 47 U.S.C. § 309(h).

 Action           September 4, 2019
 Date:
 Term Dates       From: July 31, 2019                     To: period of 180 days

 Approved:



                  Stephen J uall
                  Chief, Satellite Policy Branch




‘Iridium was previously granted a modification of its authorization under Call Sign S21 10 to extend the license term until
July 31, 2019. See IBFS File No. SAT-MOD-20171030-00l46, granted Jan. 18, 2018, as corrected on Mar. 22, 2018. Grant
of this special temporary authority request will permit ‘TT&C operations with SV97 for a period of 180 days after the
expiration of the current license term. Iridium expects that SV97 will be decommissioned in November 2019. IBFS File No.
SAT-STA-20l90710-00058, Narrative, at 1-2. Iridium concurrently filed a request for special temporary for a period of 30
days to conduct TT&C operations with SV97 pending grant of this 180-day STA request, IBFS File No. SAT-STA
20190710-00059, granted July 25, 2019.
                                                         Page 1 of 1


2. Contact

             Name:         Jennifer D. Hindin                   Phone Number:                        202—719—4975
             Company:      Wiley Rein LLP                       Fax Number:
             Street:       1776 K St NW                         E—Mail:                              jhindin@wileyrein.com


             City:         Washington                           State:                                DC
             Country:      USA                                  Zipcode:                             20006      —



             Attention:                                         Relationship:                        Legal Counsel


  (If your application is related to an application filed with the Commission, enter either the file number or the lB Submission ID of the related
application. Please enter only one.)
  3. Reference File Number or Submission ID
  4a. Is a fee submitted with this application?
• If Yes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
0   Governmental Entity     ~ Noncommercial educational licensee
o Other(please explain):
4b. Fee Classification    CXW   —   Space Station (Non—Geostationary)
5. Type Request


o Change Station Location                           • Extend Expiration Date                            Other


6. Temporary Orbit Location                                                7. Requested Extended Expiration Date
                                                                                2020—01—27 00:00:00.0


8. Description   (If the conplete description does not appear in this box, please go to the end of the form to view it in its entirety.)
     Iridium seeks STA for 180 days to extend the license term for its Block 1 satellites until
     Jan. 27, 2020.




9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject     • Yes           No
to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 1988,
21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See 47 CFR
 1.2002(b) for the meaning of "party to the application" for these purposes.


10. Name of Person Signing                                                  11. Title of Person Signing
Maureen C McLaughlin                                                        Vice President Public Policy
12. Please supply any need attachments.
 Attachment 1: Narrative                            Attachment 2:                                      Attachment 3:


          WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                 (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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                                                                     Before the

                                  FEDERAL COMMUNICATIONS COMMISSION

                                                         Washington, D.C. 20554



  Application of                                                          )
                                                                          )
  Iridium Constellation LLC                                               )   Call Sign: S2110
                                                                          )
  For Special Temporary Authority                                         )   File No. SAT-STA-2019____________
_______________________________________________________________________   )

                       APPLICATION FOR SPECIAL TEMPORARY AUTHORITY

            Iridium Constellation LLC (“Iridium”) hereby requests special temporary authority

(“STA”) for one hundred eighty (180) days) commencing July 31, 2019, to modify its

authorization for its “Big LEO” band non-geostationary satellite orbit (“NGSO”) constellation

(call sign S2 110) to extend the license term for its first-generation (“Block 1”) satellites until

January 27, 2020.2

            On January 18, 2018, the Commission granted Iridium’s license modification to extend

the license term for its Block I satellites until July 31, 2019 “so that it has sufficient time for its

new Iridium NEXT constellation to become fully operational, including having a full

complement of Iridium NEXT spare satellites in orbit.”3 Now almost eighteen months later,

Iridium nearly has completed the complex, real-time replacement of Block I with Iridium

NEXT, with just one Block I satellite, 5V97, remaining to be deorbited. Iridium expects the

final maneuver in this transition from Block Ito Iridium NEXT to occur in November 2019,




       See 47 C.F.R. § 25.120(b)(2). Concurrently with this application, Iridium is also filing a
request for STA for 30 days.
2      See Iridium Constellation LLC, SAT-MOD-20171030-00146, Stamp Grant (Jan. 18,
2018, corrective grant Mar. 22, 2018) (“Block I MOD Grant”).
       Id., Narrative, at 1.


when an Iridium NEXT vehicle will complete its drift to the Plane 4 spare satellite orbit.

Following its arrival and subsequent testing, Iridium expects to deorbit SV97.

       Accordingly, Iridium requests STA for 180 days to extend the license term for its Block 1

satellites until January 27, 2020, to allow sufficient time for Iridium to complete its transition to

its Iridium NEXT fleet. Extending the Block 1 license term will serve the public interest by

helping to ensure continuity of service for Iridium’s end users.

I.     BACKGROUND AND REQUEST FOR SPECIAL TEMPORARY AUTHORITY

       On January 1, 1995, the FCC authorized Iridium’s predecessor in interest to launch and

operate an NGSO mission constellation of 66 satellites in the Big LEO band along with 12 in-

orbit spares.4 On August 1, 2016, the Commission authorized Iridium to construct, deploy and

operate its second-generation satellite constellation, commonly known as Iridium NEXT, with 66

space stations and up to 1 5 “second-generation in-orbit satellites.”5 Specifically, the grant

“[was] based on a planned one-for-one substitution of first-generation satellites by second-

generation satellites, but [did] not preclude Iridium seeking authorization at a later date to retain

some first-generation satellites as spares.”6 In January 2018, the Commission extended the

Block 1 license term to July 31, 2019, and provided authority “to transit and maintain up to 18

first-generation satellites as in-orbit spares, and to maneuver and activate such spares as

necessary.”7




       See Application ofMotorola Satellite Communications, Inc., Order and Authorization, 10
FCC Rcd 2268, ¶ 25 (lB 1995).
       See generally Iridium Constellation LLC, Application for Modification of License to
Authorize a Second-Generation NGSO MSS Constellation, Order and Authorization, 31 FCC
Rcd. 8675, ¶~J 45-47 (Aug. 1, 2016) (“Iridium NEXT Order”).
6      Id.,~J5n.22.
        Block 1 MOD Grant, at 1.


                                                  -2-


        Iridium has completed nine successful Iridium NEXT launches. Following positioning

and completion of in-orbit testing, Iridium NEXT satellites have been brought into operation and

replaced first-generation satellites in specific orbital slots. Currently, just one Block 1 satellite

remains, SV97, which Iridium utilizes as a spare in Plane 4.

        Iridium has commenced drift of an Iridium NEXT satellite to Plane 4 to replace SV97,

and Iridium expects the Iridium NEXT satellite to arrive in November 2019. Once it arrives and

undergoes testing, Iridium will deorbit SV97. Accordingly, Iridium requests STA to extend the

Block I license term to January 27, 2020, which would provide Iridium with the time necessary

to complete the transition from Block I to the Iridium NEXT constellation.

II.     PUBLIC INTEREST STATEMENT

        Grant of this STA request will serve the public interest. Iridium NEXT “provide[s]

mobile voice and data services to end users on a network with improved voice quality and

enhanced data transmission speeds.”8 Iridium has nearly completed the unprecedented

engineering feat to replace its Block I constellation with Iridium NEXT in real-time. Just one

Block I satellite remains to be deorbited. Providing Iridium with the time necessary to replace

the remaining Block I satellite will allow Iridium to ensure the continuity of robust service for

Iridium’s customers.

        Additionally, the STA will have a negligible effect on orbital debris mitigation. As

Iridium has been launching second-generation satellites, it has been de-boosting and de-orbiting

its first generation satellites on a rolling basis. Having positioned its storage orbit just 15 km

below mission altitude, the remaining Block I satellite has been conserving fuel that may be

necessary for its de-orbiting once the Iridium NEXT spare satellite arrives.



8       Iridium NEXT Order,     ¶   1.


        Grant of this STA request also poses no interference risk. The location of the last Block

I spare satellite’s orbit has ensured safe station-keeping without any overlap in orbital position.

III.    CONCLUSION

        For the reasons herein, Iridium respectfully requests that the Commission grant STA to

extend the license teim for Iridium’s Block 1 satellite constellation for 180 days to January 27,

2020.


                                                   Respectfully submitted,



                                                   By: Maureen C. McLaughlin
 Jennifer D. Hindin                                Maureen C. McLaughlin
 Henry Gola                                        Vice President Public Policy
 Wiley Rein LLP                                    Iridium Satellite LLC
 1776 K Street NW                                  1750 Tysons Boulevard
 Washington, DC 20006                              Suite 1400
                                                   McLean, VA 22102

 July 10, 2019



Document Created: 2019-09-05 15:28:05
Document Modified: 2019-09-05 15:28:05

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