Federal Communications Commission DA 13-141 
Before the
Federal Communications Commission
Washington, D.C. 20554
In the Matter of
Iridium Constellation LLC
For Authority to Modify License For A Low Earth 
Orbit Mobile Satellite System
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File No.  SAT-MOD-19961204-00139
 SAT-AMD-20050816-00160
SAT-AMD-20051118-00236
Call Sign: S2110
MEMORANDUM OPINION AND ORDER
Adopted:  February 4, 2013  Released:  February 4, 2013 
By the Chief, International Bureau:
I. INTRODUCTION
1. With this Order, we grant the above-captioned application insofar as it requests 
modification of the space-station license held by Iridium Constellation LLC (“Iridium”)1 to add 
authority to provide Aeronautical Mobile-Satellite (Route) Service (“AMS(R)S”)2 in the 1618.725-
1626.5 MHz band.3 Consistent with Standards and Recommended Practices (“SARPs”) developed by 
the International Civil Aviation Organization (“ICAO”),4 the modified license includes conditions 
limiting Iridium’s AMS(R)S to geographic areas in which it is unlikely to receive interference from 
established primary services in adjacent frequency bands.  Grant of this application would serve the 
public interest by providing enhanced options for safety communications with aircraft in areas in which 
such communications are currently unavailable or limited.  
II. BACKGROUND
2. The Iridium system, which commenced commercial operation in 1998, provides voice and 
data Mobile-Satellite Service (“MSS”) via a constellation of non-geostationary-orbit satellites, using a 
time-division/frequency-division multiple-access protocol.  As originally granted in 1995, the Iridium 
  
1 Iridium is a successor-in-interest to Motorola Satellite Communications, Inc., the original licensee for the Iridium 
system satellites and the original applicant in the captioned modification application.  For ease of reference, we use 
the term “Iridium” in this Order to refer to both Iridium and its predecessors-in-interest.
2 Mobile-Satellite Service is satellite communication service for users equipped with earth stations that can be 
operated while in motion.  AMS(R)S is radio communication service linking aircraft earth stations via satellite to 
ground stations or other aircraft stations, reserved for communications concerning safety and regularity of aircraft 
flight along national or international civil air routes.  See 47 C.F.R. §2.1.
3 We dismiss, as duplicative, an amendment, IBFS File No. SAT-AMD-20051118-00236, proposing modification of 
the orbital debris mitigation plan for the Iridium system, as the licensee is requesting the same modification in 
another pending application.  See Application of Iridium Constellation LLC for Minor Modification of Mobile-
Satellite Service Authorization to Update Orbital Debris Mitigation Requirements, IBFS File No. SAT-MOD-
20080701-00140.  
4 ICAO, which operates under the auspices of the United Nations, issues SARPs for aviation communications 
systems that are binding upon ICAO contracting states, including the United States.
Federal Communications Commission DA 13-141
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space-station license authorized use of the 1621.35-1626.5 MHz frequency band for transmission in both 
directions between satellites and mobile earth stations.5 The International Bureau noted when granting 
the license that although the 1610-1626.5 MHz band is allocated for MSS uplink transmission on a 
primary basis, it is allocated for MSS downlink operation only on a secondary basis.  Hence, the Bureau
observed that the Iridium space-station licensee would be obliged to ensure that its MSS downlink 
operations would not harmfully interfere with primary services.6  
3. The 1610-1626.5 MHz band is also allocated for AMS(R)S on a primary basis regardless of 
the direction of transmission.7 Iridium requested authority for AMS(R)S in an application for license 
modification filed in 1996.  According to the application, Iridium aircraft earth stations would be used for 
air traffic control communications, communications pertaining to weather, flight planning, dispatch, 
maintenance, and cabin provisioning, and non-safety-related air-to-ground communications for crew or 
passengers.8 Iridium stressed that because its satellites can relay transmissions via inter-satellite 
crosslinks and are deployed in orbits that converge at the Earth’s poles, the Iridium system (unlike MSS 
systems with satellites deployed in geostationary equatorial orbits) could provide continuous coverage at 
high latitudes where many intercontinental flights are routed.9 Iridium asserted, moreover, that its aircraft 
earth stations, unlike aircraft earth stations linking with geostationary-orbit satellites, would not need 
large steered antennas and would therefore be suitable for installation in all classes of aircraft, from light 
single-engine to heavy commercial transport.10
4. Several parties filed petitions to deny Iridium’s application,11 including the licensed 
operator of the Globalstar MSS system,12 which was using the 1610-1621.35 MHz band for uplink 
transmissions from mobile earth stations to another constellation of non-geostationary-orbit satellites.13  
Another petitioner was AMSC, the operator of a U.S.-licensed MSS system that used portions of the 
1626.5-1660.5 MHz band for uplinks from mobile stations to a geostationary-orbit satellite.  Both the 
  
5 Motorola Satellite Communications, Inc., Order and Authorization, 10 FCC Rcd 2268 (Int’l Bur. 1995), corrected 
by Erratum, 10 FCC Rcd 3915 (1995), recon. denied 11 FCC Rcd 18502 (1996).
6 Id., ¶ 16.  A station lawfully using a frequency band for service of a type for which the band is allocated on a 
primary basis is entitled to protection against interference from stations that use the band for secondary-status 
services.  Stations operating in a secondary service cannot claim interference protection from stations lawfully 
operating in a primary service.  See 47 C.F.R. §§ 2.104(d) and 2.105(c).
7 See 47 C.F.R. § 2.106, Footnote 5.367.
8 Application of Motorola Satellite Communications, Inc. for Authority to Modify its License for a Low Earth Orbit 
Satellite System in the 1616-1626.5 MHz Band, filed Dec. 4, 1996, IBFS File No. SAT-MOD-19961204-00139 
(“Original Iridium AMS(R)S Application”), Appendix at 10.
9 Id. at 5 and Appendix at 3; Consolidated Opposition and Reply Comments of Motorola Satellite Communications, 
Inc. filed April 1, 1997, at 3.  The Commission commented on the coverage characteristics of non-geostationary 
satellite systems as compared with geostationary systems in Amendment of the Commission’s Rules to Establish 
Rules and Policies Pertaining to a Mobile Satellite Service in the 1610-1626.5/2483-2500 MHz Frequency Bands, 9 
FCC Rcd 5936 at ¶ 16 (1994).
10 Original Iridium AMS(R)S Application, Appendix at 3.
11 Petition to Deny filed by TRW Inc. on Feb. 18, 1997 (“TRW Petition”); Petition to Dismiss or Deny filed by 
Mobile Communications Holdings, Inc. on Feb. 18, 1997 (“MCHI Petition”); Petition to Deny or Grant with 
Conditions filed by L/Q Licensee, Inc. on Feb. 18, 1997 (“L/Q Petition”); Petition to Deny filed by AMSC 
Subsidiary Corp. on Feb. 18, 1997 (“AMSC Petition”).
12 The license for the Globalstar system was at that time held by L/Q Licensee, Inc.  For ease of reference, we refer 
in this Order to L/Q Licensee, Inc. and its successors in interest as “Globalstar.”
13 The Globalstar space-station license was granted simultaneously with the Iridium license.  See Loral/Qualcomm 
Partnership, L.P., Order and Authorization, 10 FCC Rcd 2333 (Int’l Bur. 1995).
Federal Communications Commission DA 13-141
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Globalstar system and the MSS system formerly licensed to AMSC are still in operation today in 
frequency bands immediately adjacent to the band that the Iridium system uses for uplinks and downlinks 
between satellites and mobile earth stations.14 The Globalstar system now uses the 1610-1618.725 MHz 
band for mobile uplinks, sharing the 1617.775-1618.725 MHz segment co-equally with the Iridium 
system, which is currently authorized to operate in the 1617.775-1626.5 MHz band.15
5. Globalstar and other petitioners expressed concern that Iridium’s request for AMS(R)S 
authority was a ploy to upgrade the status of Iridium’s downlink operations from secondary to super-
primary.16 These petitioners maintained that it would be unfair to force previously-licensed systems to 
limit their operations in order to protect Iridium’s AMS(R)S from interference, in view of the fact that 
Iridium had not applied for AMS(R)S authority until long after the cut-off date for mutually-exclusive 
applications for MSS operations in the 1610-1626.5 MHz band.17 In response, Iridium maintained that 
interference and protection issues could be resolved through coordination.18 Globalstar, AMSC, and other 
petitioners replied that Iridium had failed to show that it was technically feasible for AMS(R)S to be 
provided via the Iridium system without imposing additional restrictions on previously-licensed MSS 
systems.19 Further, Globalstar and another petitioner contended that imposition of such restrictions on 
previously-licensed systems to protect Iridium’s AMS(R)S was not contemplated by the Commission 
when it adopted service rules for MSS in the 1610-1626.5 MHz band.20
6. The Federal Aviation Administration (“FAA”) also filed comments.21 The FAA’s 1997 
comments stressed that ICAO had not established SARPs for aeronautical radio service via the Iridium 
system and maintained that any consideration of Iridium’s application before ICAO reached a decision on 
the acceptability of Iridium AMS(R)S would be premature.  In the ensuing years, ICAO and the FAA 
worked to revise SARPs for AMS(R)S, which had historically focused on provision of AMS(R)S by the 
Inmarsat system, to instead include a generic AMS(R)S SARP, supported by system-specific 
documentation.
  
14 The space-station license issued to AMSC, after passing through the hands of intermediate successors-in-interest, 
is now held by LightSquared Subsidiary LLC, which also has a license for operation of a second-generation space 
station in the 1.5/1.6 GHz MSS band.  SkyTerra Communications Inc., Transferor and Harbinger Capital Partners 
Funds, Transferee, Applications for Consent to Transfer Control of SkyTerra Subsidiary, LLC, Memorandum 
Opinion and Order and Declaratory Ruling, IB Docket No. 08-184, 24 FCC Rcd 3059 (2010).
15 See Globalstar Licensee LLC et al., Modification of Authority to Operate a Mobile Satellite System in the 1.6 GHz 
Frequency Band, Order of Modification, 23 FCC Rcd 15207 (2008).  
16 L/Q Petition at 2; TRW Petition at 7-8; MCHI Petition at 2.
17 L/Q Petition at 9; MCHI Petition at 2; TRW Petition at 6 and 8.  TRW and AMSC maintained that Iridium aircraft 
terminals would receive harmful interference unless onerous restrictions were imposed on mobile terminal operation 
in adjacent bands.  One petitioner estimated that a CDMA MSS terminal operating within limits previously agreed 
upon as suitable to protect ordinary Iridium operation could cause objectionable interference to reception of Iridium 
AMS(R)S downlinks in aircraft within a radius of up to 106 kilometers.  TRW Petition, Technical Appendix.  
AMSC submitted a similar showing.  AMSC Petition, Technical Appendix.
18 Consolidated Opposition and Reply Comments of Motorola Satellite Communications, Inc. filed Apr. 1, 1997, at 
9 and 21.
19 L/Q Reply to Consolidated Opposition filed Apr. 21, 1997 at 2, 6-7, and 9; Reply of TRW to Consolidated 
Opposition filed Apr. 21, 1997 at 4 and 6-7; AMSC Subsidiary Corp. Reply filed Apr. 21, 1997 at 1.
20 L/Q Reply at 2, 7, and n.6; TRW Reply at 12.
21 Letter with attachment from Gerald J. Markey to the FCC Secretary dated February 21, 1997.
Federal Communications Commission DA 13-141
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7. In August 2005, and in response to an inquiry from Commission staff,22 Iridium reported 
that it was helping ICAO develop technical standards for provision of AMS(R)S via the Iridium system.23  
In December 2011, Iridium informed the Commission of further developments.  First, it reported that 
ICAO had reviewed and approved a system-specific technical manual and validation report for Iridium 
AMS(R)S, as required by generic AMS(R)S SARPs.24 Iridium also pointed out that the FAA had issued a 
Technical Standard Order specifying performance requirements for approval of Iridium aircraft earth 
stations for air traffic control communications and other AMS(R)S operations.25 Finally, Iridium reported 
that in June 2011 the FAA announced that it approved use of Iridium equipment for AMS(R)S in oceanic 
and remote airspace.26 Iridium therefore requested prompt grant of its application for modification of its 
space-station license to include AMS(R)S authority.
8. We placed the filing of December 13, 2011 on public notice, inviting interested parties to 
file comments by January 11, 2012.27 We received comments from Globalstar, Inc.,28 Inmarsat, Inc.,29
and three air carriers30 and reply comments from Iridium.  Globalstar and Inmarsat request certain 
conditions on any grant, while the air carriers support a grant.  
III. DISCUSSION
9. We agree with Iridium that with advancement of the technical standardization process, 
grant of the application is now timely.  We discuss briefly below the conditions and scope of this action. 
10. Geographic Limitations on AMS(R)S authority. We will limit this grant to oceanic, polar 
and remote regions,31 consistent with Inmarsat’s request, the ICAO SARPs and the FAA’s Technical 
  
22 Letter to Michael R. Deutschman, Chief Counsel and Chief Administrative Officer, Iridium, from the Acting 
Chief, Satellite Division (July 25, 2005).  
23 Attachment 1 to Application Amendment SAT-AMD-20050816-00160.  
24 Letter to the FCC Secretary from Donna Bethea Murphy, Vice President for Regulatory Engineering, Iridium, 
filed Dec. 13, 2011 in IBFS SAT-MOD-19961204-00139 (“Iridium December 2011 Letter”).
25 Id., citing TSO-C159a, effective June 30, 2010.
26 Iridium December 2011 Letter at 3.  See also FAA presentation to the Cross Polar Working Group meeting of 7-
10 June 2011, “FANS-1A Over Iridium and Performance Based Communications Concept,” available at:
http://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/enroute/oceanic/documents/cross_polar/
CPWG11/FOI-CPWG_WP.ppt (last visited Jan. 24, 2013).
27 Policy Branch Information, Satellite Space Applications Accepted for Filing, Report No. SAT-00828 (Dec. 16, 
2011).
28 Comments of Globalstar, Inc. filed Jan. 11, 2012.  
29 Letter to the FCC Secretary dated Jan. 11, 2012 from Diane Cornell, Vice President, Government Affairs 
(“Inmarsat Comments”).  Inmarsat operates an MSS system in portions of the 1626.5-1660.5 MHz MSS uplink 
band.
30 Letter to the FCC Secretary dated Dec. 29, 2011 from Joe Burns, Managing Director Technology and Flight Test, 
United Airlines (“United Airlines Comments”); letter to the FCC Secretary dated Jan. 10, 2012 from Capt. Ken 
Rewick, Vice President for Flight Operations, Hawaiian Airlines (“Hawaiian Airlines Comments”); letter to the 
FCC Secretary dated Jan. 12, 2012 from Steve Dickson, Senior Vice President – Flight Operations, Delta Air Lines 
(“Delta Air Lines Comments”).
31 For purposes of this authorization, we consider oceanic regions to be those beyond 12 nautical miles from the 
baselines of the coastal states.  See Presidential Proclamation No. 5928, 54 Fed. Reg. 777 (1988); U.N. Convention 
on the Law of the Sea, 21 I.L.M. 1261, at Part II, Art. 2 (opened for signature 1982).  We consider “polar” regions to 
be those north of the Arctic Circle (66° 33? 44? N. Lat.), south of the Antarctic Circle (66° 33? 44? S. Lat.), and the 
Antarctic land masses and adjacent waters north of the Antarctic Circle. We do not define the term “remote areas” 
(continued....)
Federal Communications Commission DA 13-141
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Standard Orders.32 According to the applicant and the air carriers, it is in these regions that the need is 
greatest.33 In the event additional work by ICAO and airspace authorities results in revised SARPs and 
other standards that make possible additional expansion of the use of Iridium’s AMS(R)S, Iridium may 
seek a license modification.
11. Foreclosing Claims of “Super-primary” Status for Iridium AMS(R)S.  We will also 
condition this grant, as requested by Inmarsat,34 AMSC, and Globalstar, to make clear that grant of this 
application does not and should not be construed to require new restrictions on already licensed 
operations of earth stations in adjacent frequency bands.  These parties observe that hundreds of millions 
of dollars have been invested in installation of adjacent-band earth stations, some operating in recognized 
safety services, and others performing significant safety-related functions.35 These parties consequently 
urge that it would disserve the public interest to require expensive modification of such equipment to 
afford new protection for Iridium AMS(R)S.36 We agree.  We therefore condition the authority granted 
herein on a stipulation that any additional protection from interference from previously-authorized MSS 
operations in adjacent frequency bands, beyond that afforded by current arrangements, must be sought 
and obtained through inter-operator arrangements.  In the event Iridium seeks any such additional 
protection without having in place an inter-operator arrangement, its request will be considered premature 
and inconsistent with the requirements of this license.37
12. Status of ITU Coordination. Iridium’s use of the AMS(R)S allocation is subject to 
provisions in the International Telecommunication Union (ITU) Radio Regulations that specify an 
agreement seeking process, including coordination with any affected administrations, prior to bringing the 
assignment into use.38 The Commission has submitted on behalf of Iridium the appropriate filing to the 
ITU, but is in the early stages of the agreement seeking process.  This license, therefore, is conditioned to 
require that Iridium not provide AMS(R)S in territories for which it has not successfully completed the 
agreement seeking process. 
13. Priority and Preemptive Access. The FCC has consistently required that AMS(R)S 
providers give priority to safety messages, and design and operate their systems with the capability for 
real-time pre-emption of non-safety-related traffic in the event capacity is required for safety messages.  
We see no reason to take a different approach in this case, and therefore condition this license 
accordingly.  
  
(...continued from previous page)
as this is a term appropriate for individual countries and airspace authorities to define based on the particular 
circumstances, such as availability of traditional ground-based VHF infrastructure, within their territory or area of 
responsibility.  Iridium’s AMS(R)S will be subject to the specific constraints imposed by such countries and 
airspace authorities, and we condition this authorization accordingly.  See ¶ 16.d. infra. 
32 As Inmarsat correctly observes, the ICAO and FAA standards are premised on Iridium terminals operating in an 
interference environment suitable for their operations such as oceanic airspace, and neither ICAO nor the FAA has 
made a favorable finding concerning Iridium AMS(R)S operations in the more unfavorable interference 
environment of more intensively used airspace.  Inmarsat Comments at 2.  
33 Iridium December 2011 Letter at 2; United Airlines Comments at 2; Delta Air Lines Comments at 1; Hawaiian 
Airlines Comments at 2. 
34 Id. at 3.
35 These services include AMS(R)S, maritime safety applications, and 911 access.
36 Comments of Globalstar, Inc. filed Jan. 11, 2012, at 2-3.
37 See 47 C.F.R. § 1.401(e) (dismissal of petitions for rule making that are premature); 47 C.F.R. § 25.112(a)(2) 
(dismissal of defective applications).
38 ITU Radio Regulations, Articles 5.367 and 9.21, Edition 2012.
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14. Scope of the Grant.  Our action today does not grant a license for AMS(R)S earth stations.39  
Iridium will need to file an application to modify its earth station licenses, and that application must be 
granted before commencement of AMS(R)S operations in the United States and on U.S. commercial 
aircraft.  We anticipate that this request will be filed in the form of a blanket earth station authorization 
under Part 25 of the Commission’s rules.40
IV. CONCLUSION AND ORDERING CLAUSES
15. We conclude that a grant of this application would serve the public interest by providing 
enhanced options for safety communications with aircraft in areas in which such communications are 
currently unavailable or limited.   
16. Accordingly, IT IS ORDERED that the application of Iridium Constellation LLC for 
modification of the Iridium space-station license to include authority for AMS(R)S, IBFS File No. SAT-
MOD-19961204-00139, as amended by SAT-AMD-20050816-00160, IS GRANTED for operations in 
oceanic, polar, and remote regions, subject to the following conditions:
a. AMS(R)S operations shall be confined to the 1618.725-1626.5 MHz frequency band;
b. AMS(R)S operations shall comply with MSS coordination agreements with other MSS operators, 
the results of the agreement seeking process under ITU Radio Regulation 9.21, and coordination 
agreements with operators of radio astronomy observatories;
c. Any additional protection desired for AMS(R)S operations from interference from previously 
authorized MSS operations in adjacent frequency bands, beyond that afforded by existing 
arrangements, must be sought through new or modified inter-operator arrangements;
d. In connection with the provision of AMS(R)S to aircraft of any particular country of registry or in 
any particular airspace, Iridium is obliged to comply with the applicable laws, regulation, rules and 
licensing procedures of that country and/or the relevant airspace administrator.
e. Iridium must limit AMS(R)S operations outside the United States to the oceanic regions, the 
Antarctic land mass and adjacent waters, and the remote areas of those territories for which it has 
successfully completed the agreement seeking process pursuant to ITU Radio Regulation 5.367. 
f. Iridium shall give priority to AMS(R)S and 911 safety messages, by real-time pre-emption if 
necessary, over all Iridium message traffic that is not considered safety-related pursuant to a 
recognized safety service.. 
17. IT IS FURTHER ORDERED that the amendment proposing modification of the Iridium 
orbital debris mitigation plan, IBFS File No. SAT-AMD-20051118-00236, IS DISMISSED and that the 
  
39 Inmarsat’s request for a warning concerning installation of both Inmarsat and Iridium earth stations in the same 
aircraft can be addressed, to the extent necessary, in connection with earth station licensing.  See Inmarsat 
Comments at 4.
40 See In the Matter of Service Rules and Procedures to Govern the Use of Aeronautical Mobile Satellite Service 
Earth Stations in Frequency Bands Allocated to the Fixed Satellite Service, IB Docket No. 05-20, Report and Order, 
FCC 12-161 (released Dec. 28, 2012) (declining to include additional satellite frequency bands in Part 87 
aeronautical rules and indicating that AMS(R)S can be licensed under Part 25 on a case-by-case basis);  see also
Review of Part 87 of the Commission’s Rules Concerning the Aviation Radio Service, WT Docket No. 01-289, Third 
Report and Order, 25 FCC Rcd 7610 (2010) at n.4 (transferring the record concerning addition to Part 87 of satellite 
bands to IB Docket No. 05-20).  Given the limits on the scope of Iridium’s AMS(R)S operations, licensing under the 
Part 25 case-by-case approach appears appropriate.
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petitions to deny filed by L/Q Licensee, Inc., TRW Inc., Mobile Communications Holdings, Inc., and 
AMSC Subsidiary Corporation ARE GRANTED to the extent indicated herein and ARE OTHERWISE 
DENIED.
18. This Order is issued pursuant to Section 0.261 of the Commission’s rules on delegated 
authority, 47 C.F.R. §0.261, and is effective on release.
FEDERAL COMMUNICATIONS COMMISSION
Mindel De La Torre
Chief, International Bureau