Attachment STA extension

This document pretains to SES-STA-20161013-00837 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016101300837_1155452

                              REQUEST FOR EXTENSION OF
                            SPECIAL TEMPORARY AUTHORITY

       Iridium Satellite LLC and Iridium Constellation LLC (collectively, “Iridium”),
pursuant to Section 25.120 of the Commission’s Rules, hereby request an extension of
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 an extension of 180 days commencing on October 16, 2016.

       Iridium’s request is supported by good cause. The Commission previously
granted STAs, for a period of 30 days, for Iridium to operate its gateway earth stations
in the manner proposed herein. 2 These STAs enable Iridium to satisfy system
requirements for TT&C during the launch and early operation phase (“LEOP”) of
Iridium NEXT. TT&C transmissions are essential to the implementation, health and
safety of Iridium’s constellation. By granting Iridium’s initial STA requests, the
Commission already has determined that the operations proposed in this extension
request are in the public interest. Grant of an extension will provide continuing
authority for these operations.

       Iridium is not able to provide a launch schedule for Iridium NEXT at this time.
The launches have been delayed pending completion of an investigation into the
explosion on the launch pad of a SpaceX Falcon 9 rocket on September 1, 2016. Iridium
will provide updates to the Commission concerning its launch schedule as additional
information becomes available to it.

       The following operating parameters and non-interference showing were
submitted with Iridium’s initial STA requests and are repeated here for the convenience
of the Commission:

       Iridium’s Tempe, Chandler, and Fairbanks 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 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 an STA extension authorizing it to transmit these

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 Call sign E960244, SES-STA-20160804-00716; call sign E060300, SES-STA-20160804-00717; call sign

E050282, SES-STA-20160804-00718; and call sign E960131, SES-STA-20160804-00719.


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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 an extension of 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 an extension of 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.

       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 were
attached to the initial STA requests.

       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 were attached to the initial STA requests. 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


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.


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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 STA extensions will be on a secondary, unprotected, non-
interference basis.
                                       Conclusion
      Accordingly, and for good cause shown, Iridium respectfully asks that its
requests for STA extension be granted.



Document Created: 2016-10-13 16:31:16
Document Modified: 2016-10-13 16:31:16

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