Comments COMMENT by Iridium Constellation LLC SES-MFS-20140924-00755 Comments.F.pdf

Comments.F.pdf

COMMENT submitted by Iridium Constellation LLC

Comments

2014-11-25

This document pretains to SES-MFS-20140924-00755 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2014092400755_1069945

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of )
)
DIRECTV ENTERPRISES, LLC ) File Nos. SES-MFS-20140924-00753
) SES-MFS-20140924-00754
Request for Modification of Earth ) SES-MFS-20140924-00755
Station Licenses ) SES-MFS-20140924-00756
) SES-MFS-20140924-00757
) SES-MFS-20140924-00758
) SES-MFS-20140924-00759
) SES-MFS-20140924-00760
) SES-MFS-20140924-00761
) SES-MFS-20140924-00762
) SES-MFS-20140924-00763
) SES-MFS-20140924-00764
) SES-MFS-20140924-00765
) SES-MFS-20140924-00766
) SES-MFS-20140924-00767
) SES-MFS-20140924-00768
) SES-MFS-20140924-00770
) SES-MFS-20140924-00771
) SES-MFS-20140924-00772
) SES-MFS-20140924-00773
) SES-MFS-20140924-00774
)

COMMENTS OF IRIDIUM CONSTELLATION LLC

Iridium Constellation LLC (“Iridium”) hereby comments on the above-captioned

applications filed by DIRECTV Enterprises, LLC (“DIRECTV”). Iridium has no

objection to a grant of the applications, but is filing these comments to clarify certain

matters.

-2-

In its applications, DIRECTV seeks authority to add “ALSAT” as a point of

communication for its above-referenced earth stations, which are at various locations.

The earth stations operate on Ka-band frequencies, including the 29.25-29.3 GHz sub-

band. DIRECTV operates Ka-band geostationary orbit satellites (“GSO”) with which its

earth stations communicate. Iridium operates a constellation of non-geostationary orbit

(“NGSO”) satellites that use Ka-band frequencies, including the 29.25-29.3 GHz sub-

band, for feeder links.

Pursuant to the Commission’s requirements for the shared 29.25-29.5 GHz band, 1

DIRECTV provided the same exhibit with each of its applications. In the exhibit,

DIRECTV concludes that its proposed earth station transmissions will not cause

unacceptable interference to Iridium’s feeder links. One of the bases for this conclusion

is the similarity between the Ka-band earth station antennas that are the subject of the

above-referenced applications and the Ka-band earth station antennas for which

DIRECTV was granted licenses in 2011.

Iridium previously filed comments concerning DIRECTV’s 2011 applications. In

its 2011 comments, Iridium stated that it had no objection to a grant of DIRECTV’s

applications but took issue with elements of the methodology DIRECTV used in

analyzing the potential for interference to Iridium’s feeder links. 2 Iridium continues to

have these methodological concerns, and is filing these comments because it does not

1See Section 25.203(k) of the Commission’s rules, 47 C.F.R. § 25.203(k).
2See Comments of Iridium Constellation LLC, FCC File Nos. SES-MFS-20111104-01314, SES-MFS-
20111104-01315, SES-MFS-20111104-01317, SES-MFS-20111104-01320, SES-MFS-20111104-01322, and SES-
MFS-20111104-01324 (Dec. 16, 2011).

-3-

wish its lack of objection to DIRECTV’s latest applications to be viewed as an

endorsement of all elements of DIRECTV’s methodology.

Iridium also notes that Section 25.258(a) of the Commission’s rules requires

coordination between operators of GSO FSS earth stations and NGSO MSS feeder links

using frequencies in the 29.25-29.5 GHz band. In light of the analysis provided by

DIRECTV, Iridium believes there should be no impediment to a successful coordination

in this matter. Iridium reserves the right, however, to seek relief should the outcome of

its coordination with DIRECTV, or the outcome of any future coordination, prove

unsatisfactory.

Respectfully submitted,

IRIDIUM CONSTELLATION LLC

By: /s/Donna Bethea Murphy
Donna Bethea Murphy
Vice President, Regulatory
Engineering
Iridium Constellation LLC
1750 Tysons Boulevard
Suite 1400
McLean, VA 22102
(703) 287-7400

November 25, 2014

CERTIFICATE OF SERVICE

I hereby certify that a true and correct copy of the foregoing Comments of
Iridium Constellation LLC was sent via first class mail, postage prepaid, this 25th day of
November, 2014, to the following:

William M. Wiltshire
Harris, Wiltshire & Grannis LLP
1919 M Street, NW
Suite 800
Washington, DC 20036

DIRECTV Enterprises, LLC
6050 Elmer Derr Rd.
Frederick, MD 21703
Attention: Jack Wengryniuk*

/s/ Joseph A. Godles
Joseph A. Godles

Document Created: 2014-11-25 16:14:14
Document Modified: 2014-11-25 16:14:14

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