Iridium ltr re STA.p

LETTER submitted by Iridium Constellation LLC

Iridium Letter

2017-08-14

This document pretains to SES-MOD-20170726-00811 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017072600811_1261647

LAW OFFICES GOLDBERG, GODLES, WIENER & WRIGHT LLP 1025 Connecticut Avenue, N.W. WASHINGTON, D.C. 20036 HENRY GOLDBERG (202) 429-4900 JOSEPH A. GODLES TELECOPIER: JONATHAN L. WIENER (202) 429-4912 DEVENDRA (“DAVE”) KUMAR e-mail: ________ general@g2w2.com HENRIETTA WRIGHT website: www.g2w2.com THOMAS G. GHERARDI, P.C. COUNSEL ________ THOMAS S. TYCZ* SENIOR POLICY ADVISOR *NOT AN ATTORNEY August 14, 2017 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, DC 20554 Re: HNS License Sub, LLC Request for Special Temporary Authority File No. SES-STA-20170721-00792 Application for Modification of Blanket License File No. SES-MOD-20170726-00811, Call Sign E060445 Dear Ms. Dortch: Iridium Constellation LLC (“Iridium”) is writing to address one aspect of the above-referenced filings. In the first of the above-referenced filings, submitted on July 21, 2017, HNS License Sub, LLC (“HNS”) requested Special Temporary Authority to operate up to 100,000 0.9m GSO FSS terminals to communicate with five specified space stations on various Ka-band frequencies. The STA request was granted 10 days later, on July 31, 2017, and the grant was announced in a public notice dated August 9, 2017.1 In the second of the above-referenced filings, submitted on July 26, 2017, HNS requested modification of its blanket license to add authority for the up to 100,000 0.9m terminals that were the subject of its STA request.2 1 See Public Notice, Report No. SES-01981, Satellite Communications Services Information (Actions Taken), p. 9. 2 See File No. SES-MOD-20170726-00811.

The frequencies covered by HNS’ STA request and its modification application include the 29.25-29.3 GHz band, which is shared on a co-primary basis between the geostationary orbit fixed-satellite service (“GSO FSS”) and the non-geostationary orbit fixed-satellite service (“NGSO FSS”). Iridium operates NGSO FSS feeder link earth stations in this band. HNS stated in both its STA request and its modification application that Iridium’s operations in the band would be protected because HNS would comply with a coordination agreement with Iridium.3 Please be advised that Iridium disagrees with HNS’ statements as to protection of Iridium’s feeder links. Iridium will provide a fuller explanation within the 30-day comment period for HNS’ modification application.4 In the interim, Iridium assumes that, consistent with the Commission’s policies, any HNS operations pursuant to its STA will be on a secondary, non-interference basis. And in light of the issues with protection of its feeder links, Iridium is opposed to any extension of HNS’ STA. Please direct any questions regarding this filing to the undersigned. Respectfully submitted, Joseph A. Godles Attorney for Iridium Constellation LLC cc: Jennifer A. Manner, HNS 3 See HNS’ STA request, Narrative at n. 6; HNS’ modification application, Narrative at n. 4. 4 See Public Notice, Report No. SES-01978, Satellite Communications Services (Satellite Radio Applications Accepted for Filing), p. 24. GOLDBERG, GODLES, WIENER & WRIGHT


Document Created: 2017-08-14 17:04:08
Document Modified: 2017-08-14 17:04:08
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC