Thales reply to Irid

REPLY submitted by Thales Avionics, Inc.

Thales updated reply to Iridium

2017-06-05

This document pretains to SES-AMD-20170414-00381 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2017041400381_1234627

BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 ------------------------------------------------------ In the Matter of ) ) Thales Avionics, Inc. ) File Nos. SES-LIC-20170217-00183 700 S. Babcock Street ) SES-AMD-20170414-00381 Melbourne, FL 32901 USA ) ) Call Sign: E170068 Applications for Blanket License to ) Operate Earth Stations Aboard Aircraft ) ------------------------------------------------------ REPLY TO OPPOSITION OF IRIDIUM CONSTELLATION LLC I. INTRODUCTION AND SUMMARY Thales herby request the Commission considers this updated version “REPLY TO OPPOSITION OF IRIDIUM CONSTELLATION LLC”, dated June 5th, 2017. This “updated” reply supersedes the reply that was submitted June 2nd, 2017. Thales Avionics, Inc. (“Thales”), pursuant to Section 25.154(c) of the Commission’s rules,1 hereby replies to the petition to deny filed by Iridium Constellation LLC (“Iridium”)2, in response to Thales’s above-referenced applications. Thales’s applications request a blanket license to operate earth stations aboard aircraft (ESAA) that would communicate with certain geostationary satellite orbit (“GSO”) Fixed-Satellite Service (“FSS”) space stations. II. DISCUSSION 1 47 C.F.R. § 25.154. 2 Petition to Deny of Iridium, File Nos. SES-LIC-20170217-00183 and SES-AMD-20170414-00381, (filed 05/26/2017), “Petition to Deny”.

-2- Iridium’s petition to deny encompasses 50 MHz between the 29.25 - 29.3 GHz band, which is reserved for MSS feeder links and for communications between GSO FSS space stations and earth stations in fixed locations and the band plan makes no provision for GSO FSS communications with earth stations in motion.3 Thales appreciates Iridium’s comments and understands that the 29.25 - 29.3 GHz band is used by Iridium for its feeder links. Thales therefore, agrees with Iridium and the importance of the 29.25 - 29.3 GHz band, as it is part of Iridium’s feeder link services, and therefore agrees to removing the 50 MHz portion of Thales’ Application covering between 29.25 to 29.3 GHz. Thales requests that the Commission remove the 50 MHz between 29.25 – 29.3 GHz band in Thales applications and move forward with grant of the use of the 18.3 – 19.3, 18.638 – 18.763, 19.7 – 20.2, 28.438 – 28.563, 29.3 – 30.0 and 29.5 – 30.0 GHz bands for Thales high-speed in-flight connectivity (IFC) services. III. PUBLIC INTEREST BENEFITS Grant of this application will serve the public interest. Thales is a global leader in providing leading-edge in-flight entertainment (IFE) and high-speed IFC services to commercial Airlines, their passengers, and crews. Thales’s IFC services will provide Airlines with new opportunities to meet passengers’ increasing demands for reliable, robust, high-speed IFC while also providing Airlines with access to critical, real-time data streams from inflight aircraft to help improve operational efficiencies. Notably, grant of the requested applications will serve the public interest by allowing Thales to meet broadband needs of US Airline passengers and offer services such as IFE and In-flight wireless and internet connectivity for passengers’ Wi-Fi enabled personal electronic devices including laptop computers, tablets and smartphones, VPN client access and mobile applications.4 3 See Iridium opposition at ¶ 9 4 See Federal Communications Commission, Connecting America: The National Broadband Plan (2010) at 16-18.

-3- IV. CONCLUSION Based on the foregoing, Thales requests the Commission remove the 29.25 - 29.3 GHz band and grant immediately its applications, Call Sign E170068, for use of the bands 18.3 – 19.3, 18.638 – 18.763, 19.7 – 20.2, 28.438 – 28.563, 29.3 – 30.0 and 29.5 – 30.0 GHz. Grant of these applications will advance the Commission’s broadband goals, is in the public interest, by allowing users to benefit directly from the applications and content they access through high-speed in-flight networks. Respectfully submitted, June 5, 2017 Thales Avionics, Inc. 700 S. Babcock Street Melbourne, FL 32901 USA By: /s/ Pat Amodio Senior Director - Regulatory Compliance CERTIFICATE OF SERVICE I, Gergana Hardy, do hereby certify that on this 5th day of June, 2017, I served a true copy of the foregoing by first class mail upon the following: Maureen C. McLaughlin Vice President Public Policy Iridium Constellation LLC 1750 Tysons Boulevard Suite 1400 McLean, VA 22102 /s/ Gergana Hardy


Document Created: 2017-06-05 19:04:51
Document Modified: 2017-06-05 19:04:51
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