Attachment dismiss letter

This document pretains to SES-MOD-20050408-00401 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2005040800401_434227

Federal Communications Commission Washington, D.C. 20554 DA 05—1548 May 27,2008 Jennifer D. Hindin, Esq. Wiley Rein & Fielding LLP 1776 K—Street, N.W. Washington, DC 20006 Re:— Iridium Satellite LLC (‘Iridium") Call Sign: E960132 SEs—MOD—20050408—00401 Iridium Carrir Services LLC ("Idium") Call Sign: E960622 SES—MOD—20050408—00402 Dear Ms. Hindin: On April 8, 2005, Iidium filed modification applications SES—MOD—20050408—00401 and SES—MOD—20050408—00402 to add a repeater exchange system for ts icensed Mobile—Satellte Service (°MSS") earth stations E960132 and E960622 respectively. Pursuant to Section 25.112(a)(1) ofthe Commission‘s rules, 47 C.FR. §25.112(@)(1), we dismiss both applications as defective because of intemal inconsistencies provided. Specifically, there are inconsistencies for the Equivalent Isotropic Radiated Power (EIRP) provided in the applications when compared with that derived from other data in the applications. In Form 312 Schedule B of both spplications, you indicate that the Total EIRP for All Cariers is 11.77 dBW (ltem EA0), while the computed Total EIRP for All Carriers is 7 dBW derived from the "$ Watts Maximum Total Input Power at the Antenna Flange (ftem E38)" and 0 dBi Antenna Gain Transmit (liem E41). Moreover, the EIRP Density you provided in the applications do not agree with that derived from other information in the application. Specifically, in Ttem E49, you indicate that the Maximum EIRP Density per Carier is —3.36 dBW/4kHz. "This value is less than and therefore inconsistent with the average value of —3.11 dBW/4 kHz as derived from the Maximum EIRP per carier of 7.0 dBW (Item E48) and a 41 kHz bandwidth for the emission (liem E47). Given these inconsistencies, we cannot determine the actual emission power in use. Purthermore, the Maximum EIRP Density towards the Horizon (Item E60) of —2.0 dBW4 kHz is inconsistent with the Maximum EIRP Density per Carer (ltem E49) of—3.36 dBW4 kHz, considering the type of the antenna specified in the applications. While we dismiss the application on the above basis, we take the opportunity to apprise you of other concems we have should you choose to re—file the application.

EDERAL COMMUNICATIONS COMMISSION Da 051508 In Question E16 of Form 312 Schedule B, you indicate that the proposed antennas comply with the antenna gain patterns specified in Section 25.209(a)(2) and (b) as demonstrated by the manufacturer‘s qualification measurements. ‘This is not consistent with an omni—directional antenna. Iridium requests a 10.5 megaherts (1616.0—1626.5 MHz) band of operation. Within an operational band, the repeater gain is usuallyrelatively uniform. Iridium‘s Test Report, however, shows that the output of the in—band test—tone at 1616.0 MH is approximately 20 d lower than the output of the in—band test—tone at 1626.5 MHz." ‘This means that the repeater‘s actual band of operation may be less than 10.5 megaherte when compared with the band requested in the application (Rtem E43/44). Moreover, we question whether use of an output test—tone ofat least 20 dB below the test powerlevel demonstrates compliance with Section 25.216(c) and (f) of the Commission‘s Rules. Therefore, in any refiling, you should explain the reasons for this difference or, altematively, change the parameters in the application. To ensure that the demonstration for compliance with Section 25.216(c) and (D of the Commission‘s Rules is valid, the test parameters should be essentially identical to the operating conditions. The Intermodulation Test Setup diagram‘ in your application, does not indicate that you used the same repeater output level fortesting as is specified in Item E38 (Total Input Power atthe Anterna Flange). Please identify the test power repeater output you used. Further, please confirm that the labeling for "IM without filter® (dark trace) and "IM with filter" (light race) are correct in Figure 14 of the Test Report. In addition, we cannot determine, on the basis of the Test Report‘s Intermodulation Plot,® whether emissions from the repeater are consistent with the requirements specified in Section 25.216 of the Commission‘s Rules, 47 C.F.R. §25.216. Specifically, our studies show that, across the 10.5 megahertz of the pass band, there is a possibilty that emissions from the repeater as a resultof input signals from multiple handsets may cause third order intermodulation products in the 1605.5—1610 MHz band—segment, and fifth order intermodulation products in the 1595—1610 MKHz band.—segment. Also, Section 25.216(€) and (D of the Commission‘s Rules requires a fixed attenuation for the 1559—1605 MHz band and a progressive attenuation for the 1605—1610 MHz band, respectively. Iridium‘s Test Report, however, reveals only a single Intermodulation test, with test—tones set at 1616.0 and 1626.5 MH for a thid order intermodulation product (2A—B) at 1605.5 MHe, and a ffth order intermodulation product (3A—2B) at 1595.0 MHz.To facilitate our * Test Reporttiled "Eagle Broadband L—band rdium 3 User Sadax Syatem Test Results of Aeronautcal RadioNavigational Stelte Service and Test Power Oatput (Rev 1.1)%dated April 62005. See Exhibitin the Application * See Figue 14 of he TestRepor. ". See Figure 2 on page 5 of the Test Report * See Figue 14 on page 7 of he TestReport

FEDERAL COMMUNICATIONS COMMISSION Da 051548 review of any refiled application please provide a demonstration of intermodulation testing showing the botiom, middle, and top frequencies of the third and fifth order intermodulation products in their band—segments. Accordingly, pursuant to Section 25.112(a)(1) ofthe Commission‘s rules, 47 C.FR. §25.112(a)(1), and Section 0.261 of the Commission‘s rules on delegations of authority, 47 CFR. §0.261, Iridium‘s applications to modify E960132 (SES— MOD—20050408— 00401) and E960622 (SES—MOD—20050408—00402), are dismissed as defective without prejudice to refiling." Sincerely, Anall4 /fi'L _ / EJ M Scott A. Kotler Chief, Systems Analysis Branch Satellte Division Interational Bureau * IfIidium reflesanapplication ideticalt he one dismised, wth the exeeption of supplying the correaed informationit neednot pay an appliction fee. See 47 C.BR. Setion1.1109(0)


Document Created: 2005-05-27 16:05:30
Document Modified: 2005-05-27 16:05:30
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