Iridium 4.10.19 Gold

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Iridium Communications Inc.

Iridium Ex Parte Letter

2019-05-14

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

IBFS_SESAMD2018053100856_1682070

1 8 0 0 M S T R E E T, N W SUITE 800N WASHINGTON, DC 20036 TEL 202.783.4141 FA X 202.783.5851 W W W.W B K L AW. C O M May 14, 2019 Marlene H. Dortch, Secretary Federal Communications Commission 445 12th Street, SW, Room TW-A325 Washington, DC 20554 Re: Ligado Network Subsidiary LLC, Amendment to License Modification Applications, IBFS File Nos. SAT-AMD-20180531-00045, SAT-AMD- 20180531-00044, SES-AMD-20180531-00856; SES-MOD-20151231- 00981, SAT-MOD-20151231-00090, and SAT-MOD-20151231-00091 (“the Modification Applications”); IB Docket Nos. 12-340, 11-109 Dear Ms. Dortch: Pursuant to Section 1.1206 of the Commission’s rules, 1 this letter provides notice that on May 10, 2019, Iridium Communications Inc. (Iridium), represented by Maureen C. McLaughlin, Vice President, Public Policy, and the undersigned met with Aaron Goldberger, Acting Wireless & International Advisor to Chairman Ajit Pai. During this meeting, Iridium discussed its latest business development plans, including the completion of Iridium® NEXT and the launch of the Iridium CertusSM service; and reiterated the topics covered by Iridium’s past filings regarding Ligado’s proposed terrestrial operations in the above referenced proceedings. The slides presented at the meeting are attached to this filing. Please direct any questions concerning this submission to the undersigned. Respectfully Submitted, /s/ Bryan N. Tramont Bryan N. Tramont Counsel to Iridium Communications Inc. Attachment cc: Aaron Goldberger 1 47 C.F.R. § 1.1206.

INTRODUCTION TO IRIDIUM COMMUNICATIONS MAY 2019

A NEW ERA FOR GLOBAL CONNECTIVITY • On January 11, 2019, a flight-proven SpaceX Falcon 9 rocket launched Iridium constellation with from Vandenberg Air Force Base and 100% global service area delivered the final 10 Iridium® NEXT satellites to low earth orbit (LEO) • This was the largest satellite constellation replacement ever • 66 cross-linked, low earth orbit (LEO) satellites • Only fully global voice and data provider; approximately 1,121,000 subscribers • Efficient operations using only 8.725 MHz of spectrum worldwide for uplink and downlink Architecture of 6 orbital planes • Messages are routed from satellite to of 11 satellites each at 780 km altitude satellite and grounded at teleports around the world 2 IRIDIUM BUSINESS INFORMATION

Iridium’s L-Band Neighborhood • Iridium currently licensed to operate in 1617.775-1626.5 MHz • 8.725 MHz total spectrum to provide uplink and downlink service links 3 IRIDIUM BUSINESS INFORMATION

Harmful Interference to Iridium Services from Ligado’s Proposed Terrestrial Operations Must Be Resolved • Ligado Networks (formerly LightSquared) seeks to operate a modified terrestrial network operating in the L‐band, including the 10 MHz adjacent to Iridium at 1627.5‐1637.5 MHz • Iridium’s technical analysis (submitted to FCC on Sept. 1, 2016) and aviation-specific technical analysis (submitted to FCC on Dec. 14, 2016) indicates that this terrestrial operation on that 10 MHz of spectrum would result in significant harmful interference to Iridium’s mobile terminals, including those used for vital SATCOM aviation services • Ligado’s May 2018 amendment does not address Iridium • Section 25.255 of the FCC’s rules requires Ligado to resolve any harmful interference from their terrestrial operations; purpose of the rule is clear – maximize flexibility consistent with sound spectrum management while providing absolute interference protection for incumbent MSS providers • The burden is on Ligado to resolve Iridium’s concerns; absent resolution, the FCC must not grant Ligado’s application with respect to the spectrum at 1627.5-1637.5 4 IRIDIUM BUSINESS INFORMATION

BROAD OPPOSITION TO LIGADO PROPOSAL “The [coalition] continues to have serious unresolved concerns with Ligado’s proposed operations … The existing services provided by the GPS, SATCOM, aviation and real-time environmental satellite data communities, which depend upon interference-free operations in spectrum adjacent to or co-channel to spectrum central to Ligado’s plans, are too important to jeopardize, especially for the speculative benefits of Ligado’s constantly evolving proposals, details of which continue to be lacking.” July 18, 2018 ex parte letter of Coalition of Aviation, SATCOM, and Weather Information Users ● AccuWeather ● American Geophysical Union ● Satelles Inc. ● Aviation Spectrum Resources, Inc. ● International Air Transport ● National Air Transportation ● Aerospace Industries Association Association Association ● DTN (formerly Schneider Electric) ● American Weather and Climate ● National Hydrologic Warning Council ● Aircraft Owners and Pilots Association Industry Association ● National Weather Association ● General Aviation Manufacturers ● Iridium Communications, Inc. ● Resilient Navigation & Timing Association ● American Meteorological Society Foundation ● Airlines for America ● Lockheed Martin ● National Emergency Number ● Gogo Business Aviation ● Microcom Design, Inc. Association ● ALERT Users Group ● Rockwell Collins Inc. ● University of Wisconsin, Space ● Helicopter Association International ● Narayan Strategy Science and Engineering Center 5 IRIDIUM BUSINESS INFORMATION

MAUREEN C. MCLAUGHLIN VICE PRESIDENT, PUBLIC POLICY IRIDIUM COMMUNICATIONS, INC. MAUREEN.MCLAUGHLIN@IRIDIUM.COM


Document Created: 2019-05-14 11:44:12
Document Modified: 2019-05-14 11:44:12
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC