Attachment COMMENTS

COMMENTS

COMMENT submitted by Iridium Satellite LLC

comments filed informally after the conclusion of the comment period

2006-02-10

This document pretains to SES-LIC-20050825-01183 for License on a Satellite Earth Station filing.

IBFS_SESLIC2005082501183_482578

Wiley Rein & Fielding ur R. Michael Senkowski 1776 K STREET NW February 10, 2006 202.719.7249 WASHINGTON, DC 20006 msenkows@wrf.com PHONE 202.719.7000 FAX 202.719.7049 Virginia Office VIA HAND DELIVERY 7925 JONES BRANCH DRIVE SUITE 6200 Marlene H. Dortch McLEAN, VA 22102 Secretary PHONE 703.905.2800 Federal Communications Commission FAX 703.905.2820 445 12th Street, S.W. Washington, D.C. 20554 www.wrf.com Re: Globalstar USA, LLC Clifton Earth Station/IOT Antenna Application, File No. SES—LIC—20050825—01183 Dear Ms. Dortch: Iridium Satellite LLC ("Iridium"), by its attorneys and pursuant to Section 25.154(b) of the rules of the Federal Communications Commission ("FCC" or "Commission"), is writing to express its concerns regarding the above—referenced earth station application ("Application") of Globalstar USA, LLC ("Globalstar).‘ Although Iridium recognizes the need for Globalstar to test its spare satellites, Iridium is concerned that Globalstar‘s operations, as described in the Application and supplemental January 27, 2006 letter, could cause harmful interference to Iridium‘s operations. Globalstar proposes to conduct in—orbit testing and other "maintenance and stationkeeping" activities. In particular, Globalstar plans to transmit a signal with a maximum e.i.r.p. of 24 dBW/4 kHz in the 1610—1618.725 MHz band, of which 1618.25—1618.725 MHz is shared with Iridium. As Globalstar acknowledges, this signal is significantly greater than that typically transmitted from a Globalstar handset transceiver and would be 39 dB in excess of the —15 dB(W/4kHz) applied to mobile earth stations under the Commission‘s rules and ITU Radio Regulations.2 The test signal would result in an interference—to—noise ratio of over 34 dB to 1 Section 25.154(b) permits the Commission to classify as "informal objections" any pleadings that are not filed in accordance to the filing deadlines that govern Part 25 satellite applications. 47 C.F.R. §25.154(b) (classifying as informal objections "any pleading not filed in accordance with" the filing deadlines in Section 25.154(a)). Although Globalstar‘s initial application was filed in August 2005, Iridium became aware of the full scope of Globalstar‘s proposed operations only after Globalstar submitted additional information regarding the Application on January 27, 2006. See Letter from Josh L. Roland, Counsel to Globalstar, to Marlene H. Dortch, Secretary, FCC, Re: IB File No. SES—LIC—20050825—01183 — Globalstar USA, LLC Clifton Earth Station/ IOT Antenna Application (filed Jan. 27, 2006) ("January 27 Letter"). 2 Application, Exhibit B (Request for Waiver and Additional Technical Details) at 2. See 47 C.F.R. § 2.106 note 5.364; ITU Radio Regulations, Edition of 2004 at Article 5, No. 5.364.

Wiley Rein & Fielding ur Marlene H. Dortch February 10, 2006 Page 2 Iridium‘s operations, which would be sufficient to eliminate an Iridium call that was on the same frequency.3 Globalstar concedes that it must "operate the [proposed] earth station on a non— interference basis," and that it may not harm "operations in the 1610—1618.725 MHz band and adjacent bands."* However, the Application provides no detail on the timing and frequency of Globalstar‘s proposed transmissions. Furthermore, the Application fails to propose any mechanism by which Iridium could monitor and notify Globalstar of any interference. Globalstar has not sought to coordinate the proposed operations with Iridium, even though standard industry practice is to initiate coordination of IOT operations prior to requesting FCC authority. It also appears that Globalstar has not submitted the frequency coordination report required by the FCC‘s rules." In order to ensure that Globalstar‘s proposed operations do not cause harmful interference, Iridium respectfully requests that the Commission permit Globalstar to operate only on an as—needed, special temporary authority basis, consistent with recent grants of authority for IOT. ° Iridium further requests that the Commission condition any grant of authority to Globalstar upon completion of a coordination agreement with Iridium. In the alternative, Iridium requests that the Commission restrict Globalstar‘s operations to frequencies not shared with Iridium, and require Globalistar to provide prior notice (at least 48 hours) of operations adjacent to Iridium frequencies, with access to real—time contact with Globalstar personnel during the testing period. 3 In addition, the link budget provided to the Commission in the January 27 letter shows that the downlink is at 6.98 GHz, even though the Application clearly states that the downlink is to be at 24 GHz. * Application, Exhibit B at 3. Globalstar further concedes that it must "accept any interference that Iridium may cause with regard to the use of the 1618.25—1618.725 MHz band." Id. at 1. 5 Application, Form 312 Schedule B, Response to Q. E18. °6 Given the "occasional" nature of the service, it is not clear why Globalstar needs a permanent authorization rather than an STA. The Commission typically issues temporary authority for a limited number of days for such testing. See, e.g. Columbia Communications Corporation, 20 FCC Red 1863, 1869 (2005) (([ 17) (granting STA to conduct in—orbit testing for a 60—day period, subject to conditions that the licensee coordinate its test operations with all potentially affected operating satellite networks, cause no harmful interference to any lawfully operating radiocommunications systems, and cease operations immediately upon notification of such harmful interference).

Wiley Rein &Fielding ur Marlene H. Dortch February 10, 2006 Page 3 Please direct any questions regarding this matter to the undersigned. Sincerely, /s/ R. Michael Senkowski R. Michael Senkowski Counsel to Iridium Satellite LLC ce: Scott Kotler William Adler Josh L. Roland

CERTIFICATE OF SERVICE I, Chin Kyung Yoo, hereby certify that on the 10" day of February, 2006, the foregoing Informal Objection of Iridium Satellite LLC was served on all parties listed below. Is/ Chin Kyung Yoo Scott Kotler Chief, Systems Analysis Branch, Satellite Division International Bureau Federal Communications Commission 445 12"" Street, S.W. Washington, DC 20554 (via hand delivery and e—mail) William Adler Globalstar USA, LLC 461 S. Milpitas Blvd. Milpitas, CA 95035 (via e—mail and first class U.S. mail, postage prepaid) Josh L. Roland Wilmer Cutler Pickering Hale and Dorr LLP 2445 M Street, NW Washington, DC 20037 Counsel to Globalstar USA, LLC {via e—mail and first class U.S. mail, postage prepaid) Best Copy & Printing fee@bepiweb.com (via e—mail)


Document Created: 2006-02-13 10:54:30
Document Modified: 2006-02-13 10:54:30
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