Attachment STA Request

This document pretains to SES-STA-20160804-00718 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016080400718_1145538

                  REQUEST FOR SPECIAL TEMPORARY AUTHORITY

       Iridium Satellite LLC and Iridium Constellation LLC (collectively, “Iridium”),
pursuant to Section 25.120 of the Commission’s Rules, hereby request special temporary
authority (“STA”) to operate their gateway earth stations located in Tempe, Arizona;
Chandler, Arizona; and Fairbanks, Alaska, in the manner identified below. 1 Iridium
seeks STAs for 30 days commencing on September 16, 2016. 2

       These gateway earth stations transmit and receive the feeder links and tracking,
telemetry, and command (“TT&C”) links for Iridium’s non-geostationary satellite orbit,
mobile satellite service constellation (call sign : S 2110). The STAs requested herein are
needed for Iridium to satisfy system requirements for TT&C during the launch and
early operation phase (“LEOP”) of Iridium’s next generation system, which is known as
Iridium NEXT.

      The Iridium NEXT telecommand signals are transmitted on two carriers, a 29.102
GHz carrier and a 29.298 GHz carrier, using a bandwidth of 1 MHz and a 1M00F9D
emission designator. Iridium seeks STAs authorizing it to transmit these carriers at 69.1
dBW EIRP and a 69.1 dBW/MHz EIRP density with a transmitter power of 11.7 dBW.

        Iridium also seeks authority to operate both Iridium NEXT uplink carriers from
its gateway earth station in Chandler, Arizona. Iridium’s license for Chandler includes
the 29.1-29.25 GHz portion of Iridium’s feeder link band that encompasses the 29.102
GHz Iridium NEXT TT&C frequency, but does not include the 29.25-29.3 GHz portion
of Iridium’s feeder link band that encompasses the 29.298 GHz Iridium NEXT TT&C
frequency.

       In addition, Iridium seeks authority to use its Tempe, Chandler, and Fairbanks
gateway earth stations to receive 13 Iridium NEXT telemetry carriers spaced at 400 kHz
with center frequencies from 19400.2 to 19405 MHz. The emission designator for these
telemetry carriers is 200KF9D.

       Iridium’s request for STAs is supported by good cause. TT&C transmissions are
essential to the implementation, health and safety of Iridium’s constellation, and the
authority requested in this filing is needed to implement its TT&C links and provide
coverage from all essential facilities. Ensuring the deployment, implementation, health
and safety of Iridium’s constellation is unquestionably in the public interest.

1 The call signs for these gateway earth stations are E050282, E060300, E960131, and E960244. The licensee
of the first three call signs is Iridium Satellite LLC. The licensee of the fourth call sign is Iridium
Constellation LLC. This exhibit accompanies separate STA requests that Iridium is filing for each call
sign.
2 The initial launch of Iridium NEXT space stations is scheduled for September 19, 2016, which is on a

Monday. Out of an abundance of caution, Iridium is requesting that the term of its STAs commence on
the preceding Friday.


                                                    2


       Operating in the manner requested in this filing, moreover, presents no concerns
of interference to the LMDS stations, Fixed Service stations, and Fixed-Satellite Service
stations that share Iridium’s TT&C/feeder link band.

       LMDS stations. Iridium shares the 29.1-29.25 GHz portion of its uplink
TT&C/feeder link band with LMDS. Iridium has coordinated its proposed uplink
operations with LMDS licensees; coordination reports prepared by Comsearch are
attached.

       Fixed Service stations. Iridium shares its 19.4-19.6 GHz downlink TT&C/feeder
link band with the Fixed Service. Iridium has coordinated its proposed downlink
operations with Fixed Service licensees. Coordination reports prepared by Comsearch
concerning those operations are attached.3

       Geostationary Satellite Orbit (“GSO”) Fixed-Satellite Service (“FSS”) stations.
The 29.25-29.3 GHz band Iridium uses to uplink its feeder link and TT&C transmissions
is shared on a co-primary basis with GSO FSS stations. Iridium’s Tempe and Fairbanks
gateway earth stations have been operating on these frequencies for years. 4

       In order to avoid interference to Iridium’s satellites, GSO FSS earth stations
operate in the 29.25-29.3 GHz band only in areas that are widely separated from
Iridium’s gateway earth stations. There are fixed separations in the case of
individually-licensed GSO FSS earth stations and exclusion zones around Iridium
gateway earth stations in the case of blanket-licensed GSO FSS earth stations.

        The separation distances required to avoid interference from GSO FSS earth
stations to Iridium’s satellites are far greater than the separation distances that are
required to avoid interference from Iridium gateway earth stations to GSO FSS
satellites. The locations at which GSO FSS stations transmit in the 29.25-29.3 GHz band,
therefore, of necessity are locations that protect GSO FSS satellites against interference
from Iridium gateway earth stations. In any event, the Iridium NEXT LEOP operations
pursuant to the requested STAs will be on a secondary, unprotected, non-interference
basis.
                                              Conclusion

      Accordingly, and for good cause shown, Iridium respectfully asks that its STA
requests be granted.

3 Please note that the coordinates shown for Iridium’s gateway earth stations in the Comsearch reports all
are based on NAD83. The coordinates shown in the FCC license for Iridium’s Chandler gateway earth
stations are based on NAD27, and Comsearch converted the coordinates to NAD83.
4 Although Iridium’s Chandler earth station has not been operating in the 29.25-29.3 GHz band, it is

located only 8.5 km (i.e., 5.3 miles) from Iridium’s Tempe earth station, which has been operating in the
29.25-29.3 GHz band.



Document Created: 2016-08-04 10:30:03
Document Modified: 2016-08-04 10:30:03

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