Inmarsat Comments on

COMMENT submitted by Inmarsat Inc.

Comments of Inmarsat

2018-07-09

This document pretains to SES-AMD-20180531-00856 for Amended Filing on a Satellite Earth Station filing.

IBFS_SESAMD2018053100856_1452133

May 31, 2018 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554 Re: Amendment to License Modification Applications IBFS File Nos. SES-MOD-20151231-00981, SAT-MOD-20151231-00090, and SAT-MOD-20151231-00091 (the “Modification Applications”) IB Docket No. 11-109 Dear Ms. Dortch: Concurrently herewith, Ligado Networks LLC (“Ligado”) is filing an amendment to the above-captioned Modification Applications to fulfill the commitment Ligado made therein to protect certified aviation GPS receivers by limiting its power in the 1526-1536 MHz Band (the “Lower Downlink Band”) “as necessary to achieve compatibility with current and any future [Minimum Operational Performance Standards] insofar as they are incorporated into an active Technical Standard Order by the FAA.” 1 As amended, the Modification Applications would: (1) consistent with the Department of Transportation’s analysis in its recently released adjacent band compatibility study, require that Ligado’s ATC base stations operating in the Lower Downlink Band not exceed an EIRP of 9.8 dBW (10 W) with a +/- 45 degree cross-polarized base station antenna (an additional reduction of more than 99.3% from the nominal 32 dBW EIRP maximum set forth in the Modification Applications), 2 1 Modification Applications, Description of Proposed Modification at 7. 2 See U.S. Department of Transportation, “Global Positioning System (GPS) Adjacent Band Compatibility Assessment,” Final Report, at 118-19, 149, 152-53 (April 2018), available at https://www.transportation.gov/sites/dot.gov/files/docs/subdoc/186/dot-gps-adjacent-band-final- reportapril2018.pdf (“DOT Report”) (concluding EIRP limit of 9.8 dBW (10 W) at 1531 MHz

Ms. Marlene H. Dortch May 31, 2018 Page 2 (2) prohibit any Ligado ATC base station antenna in the Lower Downlink Band from operating at a location less than 250 feet laterally or less than 30 feet below an obstacle clearance surface established by the Federal Aviation Administration (under 14 C.F.R. Part 77 and its implementing orders and decisions), and (3) require Ligado to comply with the reporting, notification and monitoring obligations set forth in Exhibit 1 to the amendment. 3 This amendment thus ensures that Ligado’s proposed ATC operations will fully protect certified aviation GPS receivers, including the helicopter use case which the DOT found to be the most restrictive of the certified aviation device applications. The other evidence in the record, including the test results from the National Advanced Spectrum and Communications Test Network study and from the Roberson and Associates testing as well as the co-existence agreements with the GPS device manufacturers, establish that other GPS devices can co-exist with Ligado’s proposed operations. Ligado is also committed to providing specific mitigation measures (including but not limited to upgrading or replacing government devices) to address concerns about potential impact on U.S. Government devices and expects a requirement to this effect. Mid-band spectrum like the spectrum licensed to Ligado is vital to U.S. leadership in 5G because of its reliability and suitability for high-quality coverage and capacity deployment. If the Modification Applications are approved, Ligado will be uniquely positioned to leverage the potential of this mid-band spectrum by offering next-generation network capabilities. Ligado would concentrate on targeted deployments that deliver focused, highly secure and ultra-reliable communications over custom private networks to specific geographic locations that serve the industrial Internet of Things and the emerging 5G markets, particularly in critical infrastructure industry sectors such as rail, trucking, utilities, public safety, and oil and gas. This customized, ground-based network will include macro and micro sites and thus can effectively and efficiently serve the industrial Internet of Things with the power levels contained in this amendment and the Modification Applications. Ligado plans to invest up to $800 million in its satellite and terrestrial network capabilities, which could create at least 8,000 jobs. The amendment filed today assures protection for certified aviation receivers. Ligado’s co-existence agreements with major GPS will protect certified aviation receivers installed in helicopters operating in accordance with applicable existing MOPS). 3 Given that the sole effect of this amendment will be reducing potential interference to other parties, the amendment is deemed “minor” for procedural purposes. See 47 C.F.R. § 25.116.


Document Created: 2018-07-09 17:00:22
Document Modified: 2018-07-09 17:00:22
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