WASHINGTON-#323810-v

OPPOSITION submitted by The Boeing Company

Opposition of Boeing

2012-06-28

This document pretains to SES-MOD-20120403-00326 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2012040300326_958031

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554 In the Matter of ) ) THE BOEING COMPANY ) File No. SES-MOD-20120403-00326 ) Application for Modification ) of Earth Station License ) ) OPPOSITION OF THE BOEING COMPANY The Boeing Company (“Boeing”), pursuant to Section 25.154 of the Commission’s rules, hereby submits its opposition to the petition filed by Iridium Satellite LLC (“Iridium”) to dismiss the above-captioned application (“Petition”). In its application, Boeing is seeking to modify the operations of an earth station that has operated successfully in the Ka-band for more than a year without any suggestion of harmful interference to other licensed operators in the band. The proposed modification adds additional points of communication for the earth station (adding ALSAT) without altering any other aspect of the earth station facility or its mode of operation. In its Petition, Iridium contends that the absence of a certification pursuant to Section 25.203(k) means that Boeing has not made the required showing that its operations will not cause unacceptable interference to Iridium. The absence of the certification was an inadvertent oversight that has been immediately corrected by Boeing when the omission was brought to its attention. Further, the correction did not change the operational parameters of the earth station. In its application for modification, Boeing specified the operational parameters for the continued

operation of its earth station and no indication was made (either in Boeing’s application or by Iridium in its Petition) that these specifications would derivate from the parameters specified in the coordination agreements between the operators of the space stations with which the Boeing earth station is to communicate and the operators of any other space station licensed to use the band. Thus, Boeing’s proposed continued operations as stated in the application are consistent with the coordination agreements, and no change to the proposed operations of the earth station is required to protect other space stations licensed to use the band. Because the omission was promptly corrected and did not change the operational parameters of the earth station, no need exists to dismiss the application or place it back on public notice for an additional 30 days. Respectfully submitted, THE BOEING COMPANY By: Bruce A. Olcott Squire Sanders LLP 1200 19th Street, N.W. Washington, D.C. 20036 (202) 626-6615 Its Attorneys June 28, 2012

CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing OPPOSITION OF THE BOEING COMPANY was sent by first class mail, postage prepaid, this 28th day of June, 2012, to each of the following: Donna Bethea Murphy Vice President, Regulatory Engineering Iridium Constellation LLC 1750 Tysons Boulevard Suite 1400 McLean, VA 22102 /s/ Claudia Darbie Claudia Darbie


Document Created: 2012-06-28 17:01:40
Document Modified: 2012-06-28 17:01:40
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