Attachment Opposition

Opposition

OPPOSITION TO PETITION TO DENY submitted by Iridium Satellite LLC and Iridium Carrier Services LLC

Opposition

2005-12-22

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

IBFS_SESMOD2005092701330_482230

RECEIVED ORIGINAL JAN 0 3 2006 Saunifie FEDERAL COMMUNICATIONS COMMISSION R EC Satalte Diision Washington, D.C. 20554 EIVED IntomationaiBcreau DEC 2 2 2005 In the Matter of ) Feies towe 3 f ) ons e mmaen Iridium Satellte LLC and ) File Nos. SES—MOD—20050927—013 Iridium Carrier Services LLC ) and SES—MOD—20050927—01330 Mobile Earth Station Modification Applications ) ) Special Temporary Authority ) File Nos. SES—8TA—20050930—01349 ) and SES—$TA—20050930—01350 OPPOSITION To PETITION To DENY Pursuant to Section 25.154(c)ofthe Commission‘s rules, 47 C.ER. § 25.154(), Iidium Satellite LLC and Iridium Carrier Services LLC (collectively, "Iridium") oppose the petition (‘Petition") of Globalstar LLC ("Globalstar") to deny the above—captioned modification applications ("Applications") secking authorization to add amplifier equipment to the mobile satellte service (‘MSS") handsets authorized under Irdium‘s existing blanket mobile earth terminal (‘MET") licenses. To address Globalstar‘s interference concems, Iidium will implement minor modifications to the proposed equipment to ensure that the operating power of the equipment will be no higher than that of an Tridium handset. These modifications will be reflected in an amendment submitted concurrently with this filing.. As a result of these minor modifications, the proposed equipment will not create any greater risk of harmful interference deasion

than an ordinary Iridium handset. Accordingly, the Commission should reject the Petiion and grant the Applications immediately." L TRIDIUM IS NOT SEEKING ANY CHANGES IN THE FREQUENCIES AUTHORIZED UNDER ITS EXISTING MSS AND MET LICENSES As an initil matter, Globalstar misconstrues the scope of Tridium‘s request for modification. Tridium is secking to operate amplifier equipment on frequencies already assigned to its MSS system, and not on additional or differentfrequencies. As stated in the Applications, "the proposed equipment operates only on those frequencies within the 1.6 GHz band that are assigned to the Iridium MSS system."". Although the FCC Forms 312 included in the Applications specify a frequency range from 1616 MHz to 1626.5 MHz, this specification was intended merely to conform to the terms of Iidium‘s existing blanket MET licenses, which authorize MSS handsets "capable of operating in the 1616—1626.5 MHz frequency band."" The frequencies that actually will be used by both the proposed equipment and the Iridium METs, will be limited to those assigned to the Tridium MSS system and, to the extent applicable, coordinated with Globalstar. The Applications do not seek any changes to the frequencies authorized under Irdium‘s existing MSS and MET licenses. Moreover, the Applications do not ‘ In its Petition, Globalstar also requests that the Commission deny any further extension of Iridium‘s special temporary authority (°STA") to operate the proposed equipment, but Iidium has no pending request t extend its STA. Iridium notes, however, that t has been operating the proposed equipment on a limited basis under the STA for more than a year without receiving any interference complaints from Globalstar or any other licensee. * Iridium Satellite LLC Application, File No. SES—MOD—20050927—01329,Exhibit 3 at 2—3 (Sept. 27,2005); Iridium Carrier Services LLC Application, File No. SES—MOD—20050927— 01330, Exhibit at 2 (Sept.27, 2005). * Application of U.S. Leo Services, Inc., 11 FCC Red 20474, { 17 (In‘l Bur, 1996) (emphasis added). deasaon

propose to operate the proposed equipment on frequencies in the 1618.25—1621.35 MHz band that have not been coordinated with Globalstar. TL THE PROPOSED EQUIPMENT WILL NOT CAUSE HARMEUL INTERFERENCE TO GLOBALSTAR Through a combination of power set—up procedures and modified antenna design, the peak effective isotropic radiated power ("EIRP") of the proposed equipment will be lower than that of an ordinary Iridium handset. The power and EIRP levels for the proposed equipment set forth in the Applications represent the maximum levels that the equipment was capable of transmitting, without accounting for cable losses and assuming the original antenna design. In practice, cable losses between the indoor repeater units and the outdoor antennas are taken into account, and adjustment ofthe transmit power of the proposed equipment prior to installation ensures that the maximum transmitted power will be appropriately reduced. Specifically, the maximum power delivered to the antenna input of the proposed equipment will be adjusted prior to installation so as to not exceed +7.8 dBW, regardless of the cable length between the indoor repeater units and the outdoor antennas. Additionally, the outdoor transmit antenna of the proposed equipment will be modified to be more omni—directional so thatits peak gain will be no greater than +2.5 dBi, a 3. dB reduction from that of the originally proposed antenna design. ‘The radiation pattem ofthe proposed antenna is almost identical to that of an Tridium handset and is shown in Figure 1 below. deasios

The combination ofthese factors will reduce the maximum EIRP from the proposed equipment (spread evenly over one, two or three Iidium carriers), t a level no greater than deasso0s

+10.3 dBW, an 8.2 dB reduction from the level assumed by Globalstar (e, 18.5 dBW). In comparison, the peak EIRP of an Iridium handsctis 11.95 dBW per carrier." Iridium concurrently is amending the Applications to reflectthe reduced power, antenna gain, and EIRP levels ofthe proposed equipment. Consequently, as a result of both the modified antenna design and the installation procedures for the proposed equipment, the proposed equipment will be even more benign, from an interference perspective, than an ordinary Iridium handset. T1 THE PROPOSED EQUIPMENT MEETS THE MEAN EIRP DENSITY LIMIT SPECIFIED IN FOOTNOTE 5.364 OF THE ALLOCATIONS TABLE Contrary to Globalstar‘s contention, the proposed equipment meets the mean power density limit specified in footnote 5.364 of the Table of Frequeney Allocations." Foonote 5.364 provides that a "mobile earth station operating ... in this [1610—1626.5 MHz] band shall not produce a peak c.i.p. density in excess of —15 dBW4 kHz in the part of the band used by {aeronautical radionavigation] systems."" For mobile earth stations operating in the part of the 1610—1626.5 MHz band not used by aeronsutical radionavigation system, Footote 5.364 specifies a "mean ei.p. density" limit of —3 dBWA4kHz." A search of the Universal Licensing System database does not disclose the assignment of any seronautical radionavigation licenses in the 1618.25—1626.5 MHz band where the Irdium MSS system is authorized to operate. Thus, the peak power density limit of —15 dBW/ kHz, * See FCC Radio Authorization issued to ridium Carrier Services LLC (File No. SES—LIC— 199601 16—00005; Call Sign E960622) (granted Oct. 30, 1996). * See 47 CFR. §2.106, International Foomote 5.364. o 14. (emphasis added). doamom

which applies only to the part of the 1610—1626.5 MHz band used by aeronautical radionavigation systems, does not appear to apply to any Iridium equipment operating in that band. Consequently, the only limit specified in footnote 5.364 that could apply here is the mean EIRP density limit of —3 dBW/4kHz." Table 1 of the attached Appendix demonstrates that the proposed equipment, with the modifications discussed in Section II above, meets this imit, even in the worst case when it is transmitting simultancously into all four TDMA time slots in the same Iridium channel. Iv. CoNCLUSION Tridium filed the Applications more than a year ago and has taken more than adequate measures to ensure that the proposed equipment will not cause harmful interference to other Hicensed services. Both the U.S. military and public sefety organizations have expressed an urgent need for new products, such as the proposed equipment, that would enhance MS$ communications. Any further delay in the grant of the Applications would deprive Irdium * In the unlikely event that the peak EIRP density limit of —15 dBW4 kHz applies, Idium requests a waiver of that limit. A waiver would be appropriate because the proposed equipment will be installed primarily, if not exclusively, in fixed locations and therefore would present a substantially lower,if any, risk of interference to aeronautical radionavigation operations than would mobile earth stations subject to footnote 5.364 requirements. deasions

customers of innovative equipment that would enhance their communications capabilites during critical military operations and public safety missions. Based upon the foregoing, Iridium urges the Commission immediately to reject the Petition and to grant the Applications. Respectfully submitted, IRIDIUM SATELLITE LLC and IRIDIUM CARRIER SERYICES LLC Wiley Rein & Ficl 1776 K St, NW Washington, D.C. 20006 December 22, 2005 Their Attomeys deasiou

APPENDIX Table 1 — Calculation of Mean Transmit EIRP per 4 kHz Famaz Yae une Tonnas m Te mpare To3 ~ RedPVemrmnant sattymax i ane porerat Inn Ts arioma does rot acont +7.8 0BArerea pok fain» «2s o0. 7 Nes ranierf inaitrenn To inssc msere rndamet en hm TOW Teme s Tearda ha mmee, 3 —|Rofina ha vawuntiiors ces h ba im TDuX fane «m Tema wl B28 me. a me n 3.1e me. Fane Exvatonis ome. 7 emmoontmanttreprone copar 5 MemTidin reren ERE se ace solmwans_ isssrmin somene deasio

CERTIFICATE OF SERVICE 1, Christopher E. Ryan, do hereby certify that on December 22, 2005, a copy of the foregoing OPPOSITION was served by electronic mail or, asindicated below, by U.. mail upon the following: William T. Lake® Scott Kotler Josh L. Roland Branch Chief, Systems Analysis Branch Wilmer Cutler Pickering Hale and Dore LLP Satellte Division, Intemational Bureau 2445 M Street, NW Federal Communications Commission Washington, D.C. 20037 445 12th Street, SW Email: williom lake@wilmerhale.com Washington, DC 20554 josh.roland@wilmerhale.com Email: scott kotler@fec.gov Counsel for Globalstar LLC Frank Peace John Martin Satelite Division, Intemational Bureau Senior Engineer, Satellite Division Federal Communications Commission International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Email: frankpeace@fee.gov Washington, DC 20554 Email: john.martin@fec.gov Hsing Lin Cassandra Thomas Stellte Division, Intemational Bureau Deputy Division Chief Federal Communications Commission Satellite Division, International Bureau 445 12th Street, SW Federal Communications Commission Washington, DC 20554 445 12th Street, SW Email: hsingliu@fee.gov Washington, DC 20554 Email: CassandraThomas@fee.go Fem Jarmulnck Karl Kensinger Deputy Division Chief Associate Division Chief Satellte Division, Intemational Bureau Satellite Division, International Bureau Federal Communications Commission Federal Communications Commission 445 12th Street, SW 445 12th Street,SW Washington, DC 20554 Washington, DC 20554 Email: Fem Jarmulnck@fee.gov Email: Karl.Kensin * By electronic mail and U.S. mail deasso0


Document Created: 2006-02-09 11:30:20
Document Modified: 2006-02-09 11:30:20
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