Comments.Moxee.F.pdf

COMMENT submitted by Iridium Constellation LLC

Comments

2014-12-12

This document pretains to SES-MFS-20140924-00769 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2014092400769_1070923

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) DIRECTV ENTERPRISES, LLC ) File No. SES-MFS-20140924-00769 ) Request for Modification of Earth ) Station License ) COMMENTS OF IRIDIUM CONSTELLATION LLC Iridium Constellation LLC (“Iridium”) hereby comments on the above-captioned application filed by DIRECTV Enterprises, LLC (“DIRECTV”). Iridium has no objection to a grant of the application, but is filing these comments to clarify certain matters. In its application, DIRECTV seeks authority to add “ALSAT” as a point of communication for its earth station in Moxee, WA. The earth station operates 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 provides an exhibit in which it 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 antenna 1 See Section 25.203(k) of the Commission’s rules, 47 C.F.R. § 25.203(k).

-2- that is the subject of the above-referenced application 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 wish its lack of objection to DIRECTV’s latest application to be viewed as an endorsement of all elements of DIRECTV’s methodology. 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- 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 December 12, 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 12th day of December, 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: 2014-12-12 11:26:09
Document Modified: 2014-12-12 11:26:09
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