Petition to Dismiss.

PETITION submitted by IRIDIUM CONSTELLATION LLC

Petition to Dismiss

2014-10-10

This document pretains to SES-AMD-20140617-00525 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2014061700525_1064622

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) Harris Corporation ) File Nos. SES-LIC-20140610-00469 and ) SES-AMD-20140617-00525 Application for Fixed ) Earth Station License ) PETITION TO DISMISS OF IRIDIUM SATELLITE LLC Iridium Constellation LLC (“Iridium”) hereby petitions to dismiss the above- captioned application filed by Harris Corporation (“Harris”). In its application, Harris seeks a license for a new fixed satellite earth station. The frequencies Harris proposes to use include the 29.25-29.3 GHz band. Iridium demonstrates below that Harris’ application is incomplete because it does not address the potential for Harris to cause unacceptable interference to Iridium’s non- geostationary satellite orbit (“NGSO”) feeder links and TT&C links in the 29.25-29.3 GHz band.

-2- DISCUSSION I. INTEREST OF IRIDIUM Iridium operates a constellation of 66 NGSO mobile satellite service (“MSS”) space stations in low earth orbit. Through its satellite constellation, the largest in the world, Iridium is able to deliver communication services to first responders, public safety personnel, the U.S. Department of Defense, border security officers, the aviation industry, and the energy sector in addition to providing essential backup communications across urban and rural areas alike. Every user communication on the Iridium satellite system is routed through a gateway earth station. Iridium’s gateways operate on feeder link frequencies that include the 29.25 -29.3 GHz band Harris proposes to use. Iridium also employs this band for the uplink portion of the TT&C links it uses to control and command its space stations. Iridium’s feeder links and TT&C links in the 29.25-29.3 GHz band are co- primary with Harris’s proposed operations in the band. II. HARRIS DOES NOT TAKE INTO ACCOUNT THE POTENTIAL FOR CAUSING UNACCEPTABLE INTERFERENCE TO IRIDIUM Section 25.203(k) of the Commission’s rules requires Ka-band earth station applicants such as Harris to show that: (1) they will not cause unacceptable interference to co-channel MSS feeder link earth stations; or (2) their operations will be consistent with the coordination agreements of the operators of the space stations at issue. Harris does not satisfy either element of this test.

-3- First, Harris did not, and could not, show compliance with a coordination agreement with Iridium. The parties have not entered into a coordination agreement, and Harris has not even attempted to coordinate its earth station. Second, Harris has not shown that it can avoid causing unacceptable interference to Iridium. In fact, Harris’s above-captioned application makes no mention of Section 25.203(k) and is silent as to whether unacceptable interference will occur. CONCLUSION Harris proposes to operate on frequencies that include the 29.25-29.3 GHz band. Iridium already employs this band on a primary basis for feeder links and for the uplink portion of the TT&C links it uses to control and command its space stations. The rules require Harris to show that it will not cause unacceptable interference to Iridium; Harris did not make this showing. Accordingly, Harris’ application is incomplete, and for the reasons stated herein the application should be dismissed. Respectfully submitted, IRIDIUM CONSTELLATION LLC By: /s/Donna Bethea Murphy Donna Bethea Murphy Vice President, Regulatory Engineering Iridium Constellation LLC 1750 Tysons Boulevard Suite 1400 McLean, VA 22102 (703) 287-7400 October 10, 2014

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing PETITION TO DISMISS OF IRIDIUM CONSTELLATION LLC was sent by first class mail, postage prepaid, this 10 day of October, 2014, to: Mr. Patrick T. Reilly Harris Corporation 1025 West NASA Blvd. Melbourne, Florida 32919 /s/ Deborah Wiggins Deborah Wiggins


Document Created: 2014-10-10 09:20:57
Document Modified: 2014-10-10 09:20:57
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