Attachment Narrative

This document pretains to SES-STA-INTR2019-01025 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTAINTR201901025_1648361

                              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 is filing this STA extension request out of an abundance of caution; its
previously-filed extension request, which sought an extension through a date that is
approaching, remains pending.2

        Iridium’s request is supported by good cause. The Commission previously
granted STAs, initially for 30 and then for 180 days, so that Iridium could operate its
gateway earth stations in the manner proposed herein.3 These STAs enabled Iridium to
satisfy system requirements for TT&C during the launch and early operation phase
(“LEOP”) of Iridium’s second-generation Iridium NEXT satellites. TT&C transmissions
are essential to the implementation, health and safety of Iridium’s constellation.

        The Iridium NEXT satellites all have now been activated. Based on the
experience gained during LEOP, Iridium has determined that the revised parameters
authorized by its STAs will be required over the long term. Iridium, therefore, will
be filing modification applications seeking to continue these operations on a licensed
basis. Iridium hereby seeks an extension of its STAs in the interim, for an additional 180
days or, if sooner, until its modification applications are granted.

       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
pending action on Iridium’s modification applications.




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 SES-STA-20181010-03175 seeks extension of an STA request that expired Oct 20, 2018 and, if granted,

would expire Apr 18, 2019; SES-STA-20181010-03062, SES-STA-20181010-03160, and SES-STA-20181010-
03059 seek extensions of STA requests that expired Oct 28, 2018 and, if granted, would expire Apr 26,
2019.
3 See Call sign E050282, SES-STA-20160804-00718, SES-STA-20170523-00589, SES-STA-20180119-00047,

SES-STA-20181010-03062; call sign E060300, SES-STA-20160804-00717, SES-STA-20170523-00590, SES-
STA-20180119-00045, SES-STA-20181010-03175; call sign E960131, SES-STA-20160804-00719, SES-STA-
20170523-00591, SES-STA-20180119-00046, SES-STA-20181010-03160 ; and call sign E960244, SES-STA-
20160804-00716, SES-STA-20170523-00592, SES-STA-20180119-00048, SES-STA-20181010-03059


                                                    2


       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
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.4

4Please 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.


                                                     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.5

       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 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.




5 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: 2019-04-08 14:36:02
Document Modified: 2019-04-08 14:36:02

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