Attachment Comments, Petition

Comments, Petition

COMMENT submitted by Globalstar LLC ("Globalstar"

Comments

2006-02-03

This document pretains to SES-STA-20051229-01812 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2005122901812_482107

Before the RECEIVED FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 FEB 0 8 2006 Sateite Diision In the Matter of ) InternatonalBureau ) Iridium Satelite LLC and Iridium Carier ) File Nos. SES—MOD—20050927— Services LLC Earth Station Modification ) or329/01330; SES—AMD—20081222— Applications as Amended ) 01791/01792; Call Signs E9601327E950622 ) ) Special Temporary Authority ) File Nos. SES—3TA—20051229—01812813; ) Call Signs Eoeo13zfE0s0622 ) Review of the Spectrum Sharing Plan Among f ) 1B DocketNo.02:364 .. RECEIVEp Non—Geostationary Satellte Orbit Mobile ) ® ~ 3 2006 Sutellte Service Systems in the 1.6/2.4 GHz ) FotenComuntateny Bands ) , Ofecatseniyt Comments and Petition to Deny In the applications captioned above, Iridium Satellite, LLC (" Tridium") has sought to modify its mobile satellte earthstation license to permit it to operate terrestrial antennas or repeaters designed to repeat and amplify the signals of Iidium‘s Mobile Satellite Service (MSS") space stations and mobile earth stations/terminals (°METs")."" Pursuant to Section 25.154(a)of the Commission‘s rules, 47 C.FR. § 25.154(a), Globalstar LLC ("Globalstar®) hereby requests that the Commission deny the above—captioned applications to the extent that they seek authority to operate terrestrial transmitting devices in the 1616—1618.725 MHz band and deny the applications in all other respects pending Iridium‘s supplying additional, clarifying technical and operational information. Y Iridium Applications for Satellite Earth Station Modification, File Nos. SES—MOD— 20050927—01320/01330; Call signs E60132E960622 (filed Sept.27, 2005)("Original Applications"); Iridium Amendment to Application for Satellite Earth Station Modification, File No. SES—AMD—20051222—01791/01792 (filed Dec. 22, 2005)(Public Notice Report No. SES— 00781, Jan. 4, 2006) ("‘Amended Applications").

On November 14, 2005, Globalstarfiled a petition to deny Iridium‘s original modification applications.?" On December 22, 2005, Irdium concurrently filed the Amended Applications, as well as an opposition to Globalstar‘s petition to deny.®" Although the Amended Applications, which were placed on Public Notice on January 4, 2006, provide reduced power, antenna gain, and effective isotropic power ("EIRP") levels for the proposed equipment,® as discussed below, the applications are deficient in that they fail entirely to address the egitimate threat ofinterference that operation of the devices will cause to Globalstar‘s licensed MSS services in frequency bands exclusively assigned to Globaltar and in bands in which Iridium and Globalstar are required to coordinate their operations. These applications should be held in abeyance pending a coordination agreement between Iridium and Globalstar, pursuant to the Commission‘s L—band sharing plan,®and clarification of certain technical aspects discussed below. |._ As an initial matter,the Amended Applications are an amendment to a MET authorization that proposes rerrestrial operation in the band 1616—1626.5 MHz.®" While it is the case that Iridium‘s satellites are capable of operating, but not currently authorized to operate, across the full 1616—1626.5 MHz band, Iidium‘s METs are limited to the 1618.25—1626.5 MHz band. ® Globalstar Petition to Deny, Iidium Satellite LLC and Iridium Carmier Services LLC Earth Station Modification Applications as Amended, eal,File Nos. SES—MOD—20050927— 01329/01330 and SES—STA—20050930—01349/01350 (filed Nov. 14, 2005). ® Iridium Opposition to Petition to Deny, Iridium Satellite LLC and Iridium Carrier Services LLC Earth Station Modification Applications as Amended, eral, File Nos. SES—MOD— 20050927—01329/01330 and SES—STA—20050950—01349/01350 (filed Dec. 22, 2005) ("Triddum Opposition"). € See Amended Applications. ® See Report and Order, Fourth Report and Order and Further Notice of Proposed Rulemaking, /n the Marter ofReview ofthe Spectrum Sharing Plan Among Non—Geostationary Sutellite Orbit Mobile Satellite Service Systems in the 1.62.4 GHz Bands; Amendment ofPart 2 ofthe Commission‘s Rules to Allocate Spectrum Below 3 GHzfor Mobile and Fixed Services to Support the Introduction ofNew Advanced Wireless Services, including Third Generation Wireless Systems, 19 FCC Red 13356, 13336—81 49 44—53 (2004) (*L—Band Sharing Order").

Furthermore, the 1618.25—1621.35 MHz portion of this band is subject t coordination with Globalstar and subject to a pending petition for reconsideration in another proceeding." Coordination has not occurred, and the Amended Applications establish no basis for expanding the frequency range of Iridium‘s METs. Therefore, the Commission should deny the applications to the extent that they seek more extensive use of spectrum than is currently authorized for Indium‘s METs. In its opposition to Globalstar‘s original petition to deny, Inidium states that the applications "do not propose to operate the equipment on frequencies in the 1618.25—1621.35 Mz band that have not been coordinated with Globalstar."®" As noted above, not only do the applications propose operation below 1618.25 MHz, but in fact Iridium has not to date coordinated any use of the 1618.25—1621.35 MHz band with Globalstar; specifically, Indium has not eepondad to Globietar‘s OShowiing hormfut Interforence that contioues in Chamnels 7 and 8 in the Clifton gateway from regular (non—repeater) Iidium users when both systems are heavily loaded."" Thus, as Indium is well aware, Inidium has provided Globalstar with no assurance that the fixed repeaters, which may cause even higher interference levels than its existing METs, will be coordinated with Globalstar in any of the shared frequencies between 1618.25—1621.35 MHz. £ See Amended Applications at Form 312, Nos, 24, EA3/44, ESO, ES2S3. 2 Globalstar has petitioned the Commission for reconsideration of the sharing requirement to the extent that the shared portion begins at 1618.25, ather than 1618.725. See Petition for Reconsideration of Globalstar LLC, IB Docket No. 02—364 and ET Docket No. 00—258 (filed September 8, 2004). In order not to prejudice the outcome of that proceeding, the Bureau should establish the lower limit of Iidium‘s operation in this application to 1618.725 MHz. See L—Band Sharing Order at 13336—81 9§ 44—53. ® See Iridium Opposition at 2—3. 9 See Letter to Marlene H. Dortch, Secretary, Federal Communications Commission, from William F, Ader, Globalstar Vice President — Legal and Regulatory Affairs (Jan. 9, 2006)filed in IBFS File Nos. SAT—STA—20050923—00180/181; Letter to Marlene H. Dortch, Secretary, Federal Communications Commission, from William T. Lake, Counsel for Globalstar (Oct. 17, 2005),filed in IBFS File Nos. SAT—STA—20050923—00180/181 3

In addition, even as amended, the applications stll fail to demonstrate how Iridium‘s proposed operations will not cause harmful interference to Globalstar‘s licensed services without the required coordination. Although the applications do include a technical showing that purports to demonstrate thatIridium will meet the out—of—band emissions limits necessary to protect the radionavigation satellite service in the 1559—1610 MH 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, to the extent that Iidium‘s new repeaters operate outside Globalstar‘s sigened frequency bands of 1610—1621.35 MHz, it is necessary to suppress each Iridium carrier‘s out—of—band emissions by 14.16 dB as shown in Table 1 in the Appendix. However, even with the now—proposed EIRP levels of 10.3 dBW (reduced from the 18.5 dBW previously requested by Iridium), as the same table shows, operation of Tridium repesters co—frequency in Globalstar‘s frequency channels, such as in the frequency range 1616—1621.35 MHz,.® sll will cause the harmful interference from Iridium into Globalstar to greatly exceed (by 14.16 dB) Globalstar‘s allowable 3% degradation of service quality. Table 2 in the Appendix shows the effect of a medium traffic level ofIrdium repeaters into Globalstar. Even with the new EIRP of Iridium repeaters (10.3 dBW),Idium‘s interference exceeds Globalstar‘s allowable 3% degradation in service quality by sbout 7 dB, a very significant increase. Furthermore, Iidium has failed to demonstrate that the out—of—band RF emission from the proposed amplifier equipment in any 1 MHz of the frequency band falling within the Globalstar frequency allocation of 1610—1621.35 MHz is suppressed by atleast 14.16 dB relative to ts peak value. 19— We notethat Iidium does not have authority to use the portion ofthe band between 1616 and 1618.25 MHz for METs or other terrestrial applications, and that Globalstar strongly opposes any such grant of authority. See, e.g., Comments of Globalstarfiled in TB Docket No. 02—364 (Filed Sept.8, 2004). © See Appendix, Table 1.

Globalstar also requeststhat the Commission require Iridium to clarify the EIRP of its proposed repeaters. Itis unclear from Iridium‘s applications whether or not the repeaters will repeat more than one carrier, and to the extent that the repeater does in fact repeat more than one carrier,it is not clear if the reported EIRP is per carrier oiit is the total EIRP for the device. Finally, Globalstar also asks that the Commission deny any further requests for extension of Iridium‘s special temporary authority ("STA"), or new STA requests to operate the proposed devices. The original STA, which was granted on July 8, 2004, and subsequently extended six times (most recently Iridium filed an extension on December 29, 2008 for its STA which expired December 30, 2005),!* was based on prior applications for auxr;nri«y to operate the proposed devices that were dismissed because Iridium had failed to provide required technical information and demonstrate compliance with Commission‘s rules for METs."®" Since the underlying application on their face are Aot gtontable absontthe necessary prioe coontinatton with Globalstar,the Commission should refuse to grant any further requests for extension of the STA. At a minimum, any future STA grants should expressly limit Indium‘s operations to the 1621.35—1626.5 MHz band and to devices that comply with the out—of—band emissions estrictions. Conclusion For all of these reasons, Globalstar requests that the Commission require that Iidium provide additional technical information regarding the proposed devices, and require that Iridium coordinate the use ofthe proposed devices with Globalstar. Untl such clarification and _ Inidium Application for Special Temporary Authority, File No. SES—STA—20040524— 00717 (filed May 24, 2004) (granting the original request for STA from July 8, 2004 through September 8, 2004). Iridium Application for Extension of Special Temporary Authority, File Nos. SES—STA—20051229—01812/1813 (filed Dec. 29, 2005). & See Letter from Scott Kotler, Chief, System Analysis Branch, Satellite Division, International Bureau, to Jennifer D. Hindin, Counsel to Iridium (DA 05—1548) (May 27, 2005) (dismissing Iridium‘s repeater applications, File Nos. SES—MOD—2005040—00401, SES—MOD— 20050408—00402). $

coordination takes place, Globalstar requests that the Commission (1) deny the Amended Applications, and (2) deny any further request by Iridium to extend the special temporary authority to operate the devices proposed in the applications, ata minimum to the extent that Iridium seeks to operate in the 1621.35—1626.5 MHz band without meeting the out—of— band emissions restrictions in the Globalstar operations band. Respectfully Submitted, \ LUZLIR— William F. Adler iam T. Lake Globalstar LLC Wilmer Cutler Pickering Hale 461 Milpitas Blvd. and Dorr LLP Milpitas, Califomia 95035 2445 M Street, NW. (408) 9334401 Washington, D.C. 20037 (202) 663—6000 Counsel for Globalstar LLC | | Febrary 3, 2006

APPENDIX Tabier Interference from Tridiom Repeatersatcapacity nto Globalstar shows effectsof in—band interference, as well as required OB emissions suppression if only OOB interference) (Iridium repeater nterference into Giobaisiar f—— ,*‘A——“ ~dorelmne Number of Icium cariers in 1.23Miiz _ sesse _ Average Iidium transmit power percarier toskew se ow_| 189cowhie ~e2.40cowie ‘Alo exiemal in sn El 1 Alowable total inter. (or 3% degradation seltintertplus noise) ~102.50 cowne Allowable extemal nter. (or 3% degradation of seitintertpius noise ___207.71 BWz _) 00B emission supprossion of idium camiers EXBC :

Table2 + Interference calculation from Tridium repeaters (whesystem is at mediumm load) wth peak EIRP into Globalstar —200.48 cBwiviz ~ iss cowhe 102.40dBWiiz $% 4192.%0 cowie 207.71 dowine 724108

CERTIFICATE OF SERVICE 1, Josh L. Roland, do hereby certify that a copy of the foregoing Petition To Deny filed by Globalstar LLC was served by hand on February 3, 2006, on the following parties (marked with an asterisk (*)) or first class United States mail, postage prepaid: Marlene H. Dortch, Secretary* Cassandra Thomas Federal Communications Commission Satellte Division 445 12" Street, SW International Bureau Room CY—B402 Federal Communications Commission Washington, DC 20554 445 12" Street, SW Washington, DC 20554 Karl Kensinger Andrea Kelly Satelite Division Satellite Division International Bureau International Bureau Federal Communications Commission Federal Communications Commission 445 12" Stree, SW 445 12" Street, SW | Washington, DC 20554 Washington, DC 20554 | Scott Kotler Jennifer D. Hindin Satellte Division Wiley Rein & Fielding LLP International Bureau 1776 K Street, NW Federal Communications Commission Washington, DC 20006 445 12" Street, SW Washington, DC 20554 Olga Madruga—Forti Iridium Satellite LLC 6701 Democracy Blvd. Suite 500 Bethesda, MD 20817 Loz 14| L. Roland February 3, 2005


Document Created: 2006-02-08 11:08:27
Document Modified: 2006-02-08 11:08:27
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