Thales reply to Irid

REPLY submitted by Thales Avionics, Inc.

Reply to Iridium Opposition

2017-06-02

This document pretains to SES-LIC-20170217-00183 for License on a Satellite Earth Station filing.

IBFS_SESLIC2017021700183_1233586

                                                   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 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

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

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-

earth stations in motion.3 Thales understands that the 29.25 - 29.3 GHz band is used by Iridium for

its feeder links. Accordingly, Thales has requested coordination with Iridium for this 50 MHz of

spectrum. Until Thales and Iridium are able to reach a coordination agreement, Thales requests that

the Commission defer action on this portion of its 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


IV. CONCLUSION

Based on the foregoing, Thales requests the Commission to grant immediately its application, 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 and defer action on the 29.25 - 29.3 GHz band until Thales and Iridium

finalize a coordination agreement. Grant of these applications will advance the Commission’s

3
    See Iridium opposition at ¶ 9
4
    See Federal Communications Commission, Connecting America: The National Broadband Plan (2010) at 16-18.


                                                 -3-

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 2, 2017

                                              Thales Avionics, Inc.
                                              700 S. Babcock Street
                                              Melbourne, FL 32901 USA



                                              By:    /s/
                                                      Pat Amodio
                                                      Senior Director - Regulatory Compliance




                                  CERTIFICATE OF SERVICE


        I, David Katko, do hereby certify that on this 2nd 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/
                                                       David Katko



Document Created: 2017-06-02 11:05:44
Document Modified: 2017-06-02 11:05:44

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