Attachment Petition to Deny

Petition to Deny

PETITION TO DENY submitted by Globalstar LLC ("Globalstar")

Globalstar has filed a Petition to Deny on November 14, 2005

2005-11-14

This document pretains to SES-MOD-20050927-01330 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2005092701330_465771

RECEIVED NoV 1 7 2005 Before the Sateite Diision FEDERAL COMMUNICATIONS COMMISSION InternatonalBureau Washington, D.C. 20554 ) Iridium Satelite Earth Station Modification ) File Nos. SES—MOD—20050927— Applications ) 01329/01330; Call Signs E9601322960622 ) ) Special Temporary Authority ) File Nos. SES—STA—20050930— ) 01349/01350; Call Signs 601322060622 ) Review of the Spectrum Sharing Plan ) 1B Docket No.02—364 Among Non—Geostationary Satelite Orbit ) Mobile Satellite Service Systems in the ) 1.672.4 GHte Bands ) RECEIVED § NoV 1 4 2005 reduncommoneiateescomnision TO Globalstar LLC ("Globalstar®) hereby requests that the Commission deny the above—captioned applications filed by Iridium Satellite, LLC ("Iridium") secking to modify its mobile satellit earth station license to permit it to operate terrestrial antennas or repeaters designed to repeat and amplify the signals of Iridium‘s Mobile Satelite Service ("MSS") space stations and mobile earth stations/terminals (°METs")." As discussed below, the applications (1) appear to seek authority to operate on frequencies in which Iridium is not lcensed to provide service, and (2) fail to address the threat of interference that operation ofthe devices will cause to Globalstar‘s licensed MSS services in frequency Y tridium Applications for Satellite Earth Station Modification, File Nos. SES—MOD— 20050927—01329/01330; Call signs E960O132/E960622 (Filed Sep. 27, 2005).

bands exclusively assigned to Globalstar and in bands in which Iridium and Globalstar are required to coordinate their operations. In the applications, Iidium states that the devices will be capable of operating in the 1616—1626.5 MHz frequency band and that"the proposed equipment operates only on those frequencies within the 1.6 GHz band that are assigned to the Tridium MSS system.:""" However, he applications and accompanying technical disclosures suggest that Iridium may intend to operate throughout the 1616—1626.5 MHz band.2" Although Tridium is authorized to operate in the 1621.35—1626.5 MHz band on an exclusive basis pursuant t its MSS authorization® and in the 1618.25—1621.35 MHz band on a co—primary basis under the Commission‘s 2004 Order in TB Docket No. 02—364" Iridium‘s earth stations are not permitted to transmit below 1618.25 MHz. As a result, the applications appear to request authority to operate on frequencies for which Iridium is not licensed to provide service. In addition to secking authority to operate in the 1616—1618.25 Mz band in which Iridium is notlicensed, the applications also fail t demonstrate that Iridium‘s proposed operations will not cause harmful interference to Globalstar‘s licensed services. First, although the applications do include a technical showing that purports to demonstrate that F104 ¥2 i *2 Order and Authorization, Application of U.S. Leo Services, Inc. 11 FCC Red 20474 1171999 ® Report and Order, Fourth Report and Order and Further Notice of Proposed Rulemaking, Review ofthe Spectrum Sharing Plan Among Non—Geostationary Satellite Orbit Mobile Satellite Service Systems in the 1.6/2.4 GHz Bands, 19 FCC Red 13356, 133674 44 (2004).

Iridium will meet the out—of—band emissions limits necessary to protect the radionavigation satellte service in the 1559—1610 MHz band, they fail to provide any technical showing that the proposed operations will not cause harmful interference to Globalstar‘s licensed operations in the 1610—1621.35 MHz band Specifically, if Irdium‘s new repeaters operate outside Globalstar‘s allocated frequency bands of 1610—1621.35 MH, it is suficient to suppress each Iridium carer‘s out—of—band emissions by 22.36 dB as shown in Table 1 in the Appendix. However, as the sumetable shows, operation of Iridium repeaters co—frequency in Globalstar‘s frequeney channels,such as in the frequency range 1616—1621.35 MHz, will cause the harmful interference from Iridium into Globalstar to greatly exceed (by 22.36 dB) Globalstar‘s allowable 3% degradation of service quality. Table 2 in the appendix shows the level of interference from Iridium carriers with peak EIRP level for Iidium mobie users (not repeaters) ata traffic level slightly higher than the current Iidium traffic load. This shows that interference from Iridium users into Globalstar is below the 3% allowable degradation. However, Table 3 in the Appendix shows the effect ofthe same traffic level of Irdium repeaters (not mobile users) into Globalstar. The increased EIRP of Iridium repeaters causes Iridium‘s interference to exceed Globalstar‘s allowable 3% degradation in service quality by about 12 dB, a very significant increase. Second, the peak EIRP level requested by Iridium for ts repeater fails to meet the foomote 5.364 requirement®of ~15 dBW4 kHz where Acronautical Radio Navigation € Foomote 5.364 (formerly 731E), which is incorporated into the U.S. Table of Frequency Allocations (47 C.F.R. § 2.106), applies to "mobile earth stations" operating in the 1610—1626.5 MHz band. Itprovides that such earth stations shall not produce an EIRP 3

System systems are present or —3 dBW/4kHz where such systems are not present. This in itself is a disqualifying factor. Third, before it may grant Iridium‘s application, the Commission must require a demonstration by Iridium that the out—of—band RF emission from the amplifier equipment in any 1 Hz of the frequency band falling within the Globalstar requency allocation of 1610— 1621.35 Mz is suppressed by at least 22.36 dB relative toits peak value." The emission levels proposed in the application, unmitigated by frequency separation and filtering for out—of—band emissions, are far in excess of those approved by the Commission and present a strong likelihood of causing interference, not only to Globalstar, but also to other licensees operating in adjacent spectrum. Finally, although Iridium originally filits application for the repeater exchange system in June 2004 and has filed a new application and several requests for special temporary authority ("STA®) since then, Iridium hasnever approached Globalstar to coordinate its proposed use of the 1618.25—1621.35 MHz frequency band, Indium recently took Globalstar to task for a similar omission ® density in excess of ~15 dB (W/ kH2)in the part ofthe band used by systems operating in accordance with the provisions ofNo. 5.366 (to which No. 4.10 applies),unless otherwise agreed by the affected administrations. In the part of the band where such systems are not operating, the mean EIRP density of a mobile earth station shall not exceed —3 dB (W/4 ki 2 See Appendix, Table 1. 8 See Letter to Marlene . Dortch from R. Michael Senkowski, dated October 19, 2005, File Nos. SAT—STA—20050923—00180/00181. The Commission has specifically required coordination of use of the 1618.25—1621.35 MHz band segment. 19 FCC Red at 13380—81 99 53.57.

In addition to requesting that the above—referenced applications be denied, Globalstar also asks that the Commission deny any further extension of Iridium‘s STA to operate the proposed devices, which was first granted on July 8, 2004 and subsequently extended six times, most recently on September30, 2005."" The original STA was based upon prior applications for authority to operate the proposed devices that were ultimately dismissed because Iridium fuiled to provide required technical information and demonstrate compliance with Commission‘s rules for METs:"" It is impossible to glean from Iridium‘s application orthe Bureau‘s grant thereof any rationale for extending the STA repeatedly once the underlying application was dismissed. As discussed above, the current STA is based upon pending applications that seek authority to operate in frequencies for which Iridium is notlcensed and has failed to undertake any required coordination with Globalstar‘s operations. Since the underlying applications on their face are not grantable because they request authority to operate in spectrum for which Iridium is not authorized to operate,the Commission should refuse to grant any further requests for extension ofthe STA. At a minimum, any future grants of special temporary authority should expressly limit Iidium‘s operations to the 1621.35— 1626.5 MHz band. # Iridium Application for Special Temporary Authority, File No. SES—8TA— 20040524—00717, filed May 24, 2004 (granting the original request for STA from July 8, 2004 through September , 2004); Grant of Authority, fridiun Application for Extension of Special TemporaryAuthority, File No. SES—STA—20050930—01349/01350 (Sept.30, 2005). The latest extension appears to have been inadvertently granted for 90 days from October 1 to December 31, 2005, rather than 60 days from October 1 to November 30. 12— See Letter from Scott Kotler, Chief, System Analysis Branch, Satellte Division, International Bureau, to Jennifer D. Hindiin, Counsel toIndium (DA 05—1548) (May 27,

Forall of the foregoing reasons, Globalstar requeststhat the Commission (1) deny the above—referenced applications and (2) deny any further requests by Iridium to extend the special temporary authority to operate the proposed devices to the extentthat Iridium seeks to operate outside the 1621.35—1626.5 MHz band. Respectfully Submitted, %\g ( B0 Ar Richard S. Roberts William T. Lake William F. Adler Wilmer Cutler Pickering Hale Globalstar LLC and Dore LLP 461 Milpitas Blvd. 2445 M Street, N.W. Milpitas, Califonia 95035 Washington, D.C. 20037 (408) 933—4401 (202) 663—6000 Counselfor Globalstar LLC November 14, 2005 2005) (dismissing Iridium‘s repeater applications, File Nos. SES—MOD—20050408—00401, SES—MOD—2005040—00402).

APPENDIX "Table 1: Interference from Iridiuzm Repeaters at capacityInto Globalstar (hows effects o i—band interference, as wellas required OOB emissons suppressn f only OOB interference) mdio nterference into Globalstar tss oiy Number ofIidium beams per Globalstar beam 3 Number ofidiumc in123 lz at capacity . seses _ |Average Iidiumtransmtpower per caer ________________| _ 185 08W__| [Typica range at 40 deg. Elov____ | 1952 km Path loss _ 16243 00 10530 dBWhz BRevantennagein ® ~ fee _ [Typical slfintererence density 189 dowhe Typical selfinterfrence plusthermal noise density —_| gzesootdawhie [Allwable % degradation due to extemaintererence % |Allowable total ntertfor 3% degradation of seltintert plus n 9230 cowhz Allowable external inte 207.71 BWz (0OB emission suppression ofIdum cariers 2230 Table2; Interference calcul in from Iidiom users(when system is ighty oaded) withpeak ENRP into Globaistar idiummobile users: Interference into Globalstar I | k oon Frequency 1618 hiz Numberoidium beams per Globalstar beamn se |Nomber Indium camers in 1.23 iz | a [Average Iidum transmt power por carier | sleew _ Typical range at 40 deg. Elev 1952/km Pahioes_ P dne ccomaced 2 dez40ke_ Imtrt densitypor bearn fromhdiumusersrexd at Globalstarsat. nput |____208.0}dBWHz_ iRev antennagain Typical se ce a "iea aowhiz _ "Typical seltintererence plus thermal noise density 192.19 dowiz [Alowable % degradation due extemalintorerence mes __o3% lowable total intert (or [Alowable extemal inter o

"Table 3: Interference calculation from Iridium epeaters (when system is lightlloaded) wth peak EIRP into Globalstar Inidium repeater: nterference into Globalstar REEFEFr: 195 80 dewhie Rerantenna gain 7 Typical selfinterrence density erence plus thermal noise denaiy [Alowable degradation toextormal interlrence_ ts 6 [Alowable totalnter. for3% degradation oseltinter plus naise) |___ 19236 dBWRiz Alowableextemalnter & mss 00B emission suppression ofIridium camiers t19tike

CERTIFICATE OF SERVICE 1, Josh L. Roland, do hereby certfy that a copy ofthe foregoing Petition To Deny filed by Globalstar LLC was served by hand on November 14, 2005, on the following parties (marked with an asterisk (*)) orfrst class United States mail, postage prepaid; Marlene H. Dortch, Secretary* Federal Communications Commission 445 12" Street, SW Room CY—B402 Washington, DC 20554 Cassandra Thomas* Satellite Division Interational Bureau Federal Communications Commission 445 12" Street, SW Washington, DC 20554 Karl Kensinger® Satellite Division International Bureau Federal Communications Commission 445 12" Street, SW Washington, DC 20554 Andrea Kelly*® Satelite Division International Bureau Federal Communications Commission 445 12"Street, SW Washington, DC 20554 Scott Kotler® Satellte Division International Bureau Federal Communications Commission 445 12" Street, SW Washington, DC 20554 Jennifer D. Hindin Wiley Rein & Fielding LLP 1776 K Streeu, NW Washington, DC 20006

Olga Madruga—Forti Iridium Satellite LLC 6701 DemocracyBlvc. Suite 500 Bethesda, MD 20817 %; L. Roland November 14, 2005


Document Created: 2005-11-22 11:53:56
Document Modified: 2005-11-22 11:53:56
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