Federal Communications Commission DA 96-1789'
Before the
Federal Communications Commission 
Washington, D.C. 20554
In re Application of )
) 
Motorola Satellite Communications. Inc. ) File No. 85-SAT-ML-96
) 
For modification of license )
ORDER AND AUTHORIZATION
Adopted: October 30, 1996 Released: October 30 , 1996
By the Chief International Bureau:
1. Motorola Satellite Communications. Inc. ("MSC") has filed an application for 
modification of its authorization for the space segment of its proposed "IRIDIUM" low-earth- 
orbit satellite telecommunication system and an associated request for waiver of certain 
provisions of the FCC's rules. The application was placed on public notice on March 20. 
1996.' Hughes Communications Galaxy, Inc. and CellularVision USA, Inc. filed petitions to 
deny; MSC filed a consolidated response; and CellularVision filed a reply. We grant the 
application and the waiver requests.
2. MSC is one of three companies2 that have obtained permission from the FCC to 
construct, launch, and operate "Big LEO" Mobile Satellite Service (MSS) satellites -- low- 
Earth-orbit satellites that commercial licensees would use in conjunction with ground facilities 
to enable, subscribers equipped with mobile transceivers to conduct two-way voice and data 
communication with similarly-equipped subscribers or telephone users anywhere else in the 
world. The IRIDIUM System, like other Big LEO systems, would consist of four basic 
components: a constellation of non-geostationary LEO satellites; end-users' mobile 
transceivers; ground-based satellite-control facilities; and gateway earth stations. A message
Public Notice. Report No. SPB-40 (released March 20. 1996). 
The. other two are L'Q Licensee. Inc. and TRW Inc.
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transmitted from a subscriber's mobile transceiver would be received by a transiting 
IRIDIUM satellite and relayed, either directly or via links with other satellites in the 
IRIDIUM constellation, to a gateway earth station, where it would be analyzed for purposes 
of routing and billing and would then be relayed via satellite to another mobile terminal or 
would be directed to a destination on the public switched network. Return messages would 
follow the same path in reverse.
3. Spectrum in the 1610-1626.5 MHz and 2483.5-2500 MHz bands was 
internationally allocated for MSS at WRC-92, and the FCC accordingly effected a conforming 
adjustment of the domestic table of allocations. The Commission subsequently adopted a 
band-sharing plan for the Big LEO service: spectrum between 1610 and 1621.35 MHz would 
be assigned for shared use by as many as four Big LEO licensees using CDMA architecture 
for Earth-to-space service links; the 1621.35-1626.5 MHz band would be assigned to a single 
Big LEO licensee using TDMA/FDMA architecture, for service links in both directions 
(Earth-to-space and space-to-Earth); and the 2483.5-2500 MHz band would be reserved for 
service links in the space-to-Earth direction for CDMA systems.3 (The term "service links" 
refers to transmissions between satellites and end-users' mobile transceivers.) The 
Commission did not designate any spectrum for Big LEO feeder links, however, because it 
had not yet determined which frequencies should be allocated for that purpose. (The term 
"feeder links" refers to the transmission of users' messages in either direction between 
satellites and gateway earth stations. The Commission has regarded feeder-link transmission 
as a type of fixed-satellite service.4) The Commission noted in this regard that international 
allocation of spectrum for MSS feeder links was on the agenda for the World Radio 
Conference to be held in the fall of 1995 and said that it contemplated granting unconditional 
Big LEO feeder-link assignments once sufficient spectrum had been made available.5 The 
Commission also said that in the interim it would permit qualified applicants to construct 
satellites capable of operating with particular feeder-link frequencies at the applicants' own 
risk.
4. In a decision released on January 31, 1995, the FCC granted MSC authority to 
construct, launch, and operate sixty-six LEO satellites and twelve in-orbit spares capable of 
operating in the 1621.35-1626.5 MHz range for service links and the 23.18-23.38 GHz range 
for intersatellite transmissions. As there had not yet been any international or domestic 
allocation of spectrum for MSS feeder links, however, action was deferred with respect to 
MSC's request for authority to launch and operate the satellites with a capability of using 
19.4-19.6 GHz for satellite-to-gateway transmission and 29.1-29.3 GHz for gateway-to-
'' Amendment of the Commission's Rules to Establish Rules and Policies Pertaining to a Mobile Satellite 
Service in the 1610-1626.5/2483.5-2500 MHz Frequency Bands. 9 FCC Red 5936. ffi 43. 44. and 48 (1994) (Big 
LEO Report and Order).
4 Id atH163.
5 Id. at If 166 and 169.
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satellite transmission.6
5. In the current application. MSC requests'"removfal of] the condition placed on its 
license with respect to its feederlink spectrum and . . . launch and operational authority with 
respect to such spectrum." MSC maintains that the time is now ripe for such action because 
the ITU's recent allocation of spectrum for non-geostationary MSS feeder links at 5091-5250 
MHz, 6700-7075 MHz. 15.4-15.7 GHz. 19.3-19.6 GHz. and 29.1-29.4 GHz at the 1995 World 
Radiocomnuinications Conference7 has eliminated the uncertainty that previously militated 
against assigning spectrum for Big LEO feeder links.
6. Hughes and CellularVision object to MSC's request for additional operational 
authority. They contend that the FCC cannot properly grant MSC unconditional authority to 
use 19.4-19.6 GHz for feeder downlinks prior to resolution of issues under consideration in 
the Ka-Bands rulemaking in CC Docket No. 92-297. in which the Commission has undertaken 
to develop a plan for compatible use of spectrum in the 17.7-20.2 GHz and 27.5-30.0 GHz 
sub-bands by FSS. MSS. and LMDS systems.9 In response. MSC asserts that the Commission 
expressly decided in the Big LEO Report and Order that unconditional feeder-link licenses 
would be granted once either of two conditions was met, one of which was favorable action at 
WRC-95 on U.S. proposals for MSS feeder-link allocations, which has since occurred. MSC 
concedes, however, that it will have to comply with any band-sharing plan adopted in Docket 
92-297.
7. Discussion. The Commission adopted a band-sharing plan in the Ka-Band 
proceeding in a Report and Order released on July 22. lo As MSC's application comports with 
that plan, as well as with the corresponding WRC-95 allocation, the pre-conditions specified 
in the Big LEO Report and Order for granting feeder-link licenses have now been met, and
* Id. at
7 See Final Acts of the World Radiocommunications Conference. Pt. I, at 153, 158. 180. 185. and 190 (Nov. 
17, 1995).
3 Strictly speaking, it would be more apt to refer to the proceeding as "the K/Ka-Band rulemaking", since it 
pertains to use of the K Band (18-27 GHz) as well as to use of the Ka Band (27-40 GHz). Our use here of "Ka 
Band" as shorthand for the combined range of those two adjacent spectrum bands is consistent with prevalent 
usage in documents referring to that proceeding.
0 See Rulemaking to Amend Pans 1. 2. 21. and 25 of the Commission's Rules to Redesignate the 27.5-29.5 
GHz Frequency Band, to Reallocate the 29.5-30.0 GHz Frequency Band, to Establish Rules and Policies for 
Loca! Multipoint Distribution Service and for Fixed Satellite Services (Third NPRM), 11 FCC Red 53 (1995). 
See also CellularVision. Inc.. DA 95-2429 at <ffl 22 and 24 (released Dec. 7, 1995).
10 Rulemaking to Amend Pans 1. 2. 21. and 25 of the Commission's Rules to Redesignate the 27.5-29.5 
GHz Frequency Band, to Reallocate the 29.5-30.0 GHz Frequency Band, to Establish Rules and Policies for 
Local Multipoint Distribution Service and for Fixed Satellite Services. First Repon and Order and Fourth Notice 
of Proposed Rulemaking. FCC No. 96-3.11 (released July 22, 1996). 61 F.R. 39425 (July 29. 1996).
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the objections that the application is premature have become moot.
Additional and Enhanced Service Offerings
8. Enhanced ringing and paging services. MSC requests explicit authorization for the 
IRIDIUM System to provide enhanced ringing and paging services, in addition to the kinds of 
MSS service that it originally proposed to provide." The enhancement would enable users to 
receive ringing and paging messages during heavier atmospheric fading conditions and in 
buildings where attenuation is greater, according to MSC. One-way "ring alert" channels at 
1626.270833 MHz would be used to alert subscribers with special receive-only mobile earth 
terminals to the presence of incoming paging calls. Paging messages would be transmitted to 
the receive-only terminals at 1626.437500, 1626.395833, 1626.145833, or 1626.104167 MHz. 
Their duration would not exceed 20.32 milliseconds. The transmit power for the ring alert 
channel would be somewhat higher than the power used for a voice/data channel, so as to 
enable the mobile earth terminals to receive ring alerts even when their antennas are stowed, 
but spurious-emission performance would be better than that of the two-way channels on the 
system when fully loaded. MSC therefore contends that the addition of these services would 
not increase interference levels or complicate satellite-system coordination. No one else filed 
comments on this proposal.
9. As k appears that provision of these additional services would enhance the 
IRIDIUM System's usefulness without increasing interference, we conclude that it would 
serve the public interest to permit MSC to provide enhanced ringing and paging services as 
described above, using the specified frequencies, which it may do consistently with the 
existing terms of its satellite license.
10. Ancillary Fixed-Satellite Services. MSC requests permission to provide incidental 
and ancillary Fixed-Satellite Services in the 1.6 GHz MSS/RDSS bands. It says that one 
service of this type that it contemplates providing would involve deploying Mobile Exchange 
Units ("MXUs") that the proprietors of isolated telephone systems in remote areas could use 
to establish voice and data links with the IRIDIUM System. Although the units would be 
transportable, they might be installed as fixtures, in which event, MSC acknowledges, they 
could be regarded as components of Fixed-Satellite Service. While conceding that there are 
no international or domestic allocations in the pertinent frequency band for FSS, MSC 
maintains that Section 2.102 of the FCC's rules and No. 342 of the ITU's International Radio 
Regulations allow non-conforming use provided that no harmful interference is caused to 
existing services. It stresses, moreover, that the Commission has approved AMSC's 
analogous proposal to provide, on an "incidental or ancillary basis." two-way voice and data
1 MSC has previously reported that it intends to provide radiodetermination service, global paging, two-way 
messaging, data transmission, and two-way digital voice communications. Application of Motorola Satellite 
Communications. Inc. for IRIDIUM. a Low Earth Orbit Mobile Satellite Svstem. File No. CSS-91-I01 at 35-37 
( Dec. 1990).
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communications to people using portable terminals in fixed installations in remote areas, 
concluding that implementation, of the proposal would promote the public interest by affording 
service to segments of the population that currently have few alternative means of 
communication. i: MSC contends that its proposed deployment of MXUs in remote areas 
would similarly serve the public interest. It further contends that its proposal is consistent 
with the Commission's recent proposal to allow CMRS operators to provide fixed wireless 
local-loop services and other fixed services in spectrum primarily designated for mobile 
applications, citing Amendment of the Commission's Rules to Permit Flexible Service 
Offerings in the Commercial Mobile Radio Service. 13 No one has objected to this request.
11. We will grant the request for permission to provide fixed-satellite services on an 
ancillary basis, consistently with a general policy of flexibility reflected in precedent, 14 with 
the usual stipulation that the nonconforming service may only be provided on a no-harmful- 
interference basis vis-a-vis any licensed service provided in conformance with the Table of 
Allocations.
Emission Designators
12. The applicant proposes to modify the emission designators for the IRIDIUM 
System's service links, feeder links, intersatellite links, and control transmissions. It asserts 
that the change would reflect a design adjustment to take into account doppler shifts in 
frequency and would not affect compliance with FCC regulations or present any new 
interference issues.
13. CellularVision USA. Inc.. the only party to comment on this proposed change, 
contends (without explanation) that the proposed change of emission designators for the Ka 
Band could have a material bearing on co-frequency sharing between MSS and LMDS 
systems and objects that MSC has not provided a technical analysis to support its no-new- 
interference assertion. In response, MSC contends that the modification of the Ka Band 
designators would merely affect channel spacing for multiple carriers within the IRIDIUM 
System's assigned spectrum range and would have no effect on inter-system parameters.
14. It is true, as the applicant asserts, that the proposed modification would merely 
narrow the spacing between adjacent channels within its assigned spectrum without increasing 
interference to terrestrial fixed services. Operation pursuant to the space-to-Earth feeder-link
r- See AMSC Authorization Order, 4 FCC Red 6041, 6048 (1989).
13 11 FCC Red 2445 (1996).
14 See COMSAT and AMSC. 5 FCC RcJ4117. 4118 ^[8 (1990); AMSC Authorization. 4 FCC Red 6041, 
6048 1{51 (1989); Geostar Positioning Corp.. 4 FCC Red 4538, 4539 (1989); and Oualcomm, Inc.. 4 FCC Red 
1543. 1544 (1989).
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authorization that \ve are granting here could not cause interference to LMDS systems, 
because the band that \ve are assigning for MSC's space-to-Earth feeder links. 19.4-19.6 GHz. 
is far removed from the spectrum allocated for LMDS systems. Nor is there any reason for 
concern that MSC's space-to-Earth feeder-link transmissions will unduly interfere with 
terrestrial services operating in the same frequency range, as its power flux density ' 
specifications are within the limits prescribed in Section 25.208 of the rules.
15. Insofar as they pertain to the possibility of interference from Earth-to-space 
feeder-link transmission. CellularVision's comments are misdirected; the objection should 
have been filed in response to U.S. Leo's pending license application for a gateway Earth 
station for the IRIDIUM System (which we are concurrently granting in another order). We 
will overlook the procedural irregularity, though, and dispose of the objection here on the 
merits. We find that the proposed change of emission designators for the IRIDIUM System's 
feeder uplinks in the assigned band. 29.1-29.25 GHz, will not unduly affect co-frequency 
LMDS systems. The Commission's recently-adopted spectrum-sharing plan for the upper Ka 
Band establishes a geographic separation requirement to prevent harmful interference between 
MSS feeder uplinks and LMDS transmissions, 15 and the proposed change in emission 
designators is compatible with that provision, which should suffice for relevant purposes of 
protection. The proposal is also consistent with all other pertinent rule provisions.
16. We therefore grant the request for modification.
Technical Waivers
17. Emissions mask for intersatellite links. MSC has received authority to use 23.18- 
23.38 GHz for transmission between IRIDIUM satellites. It reports that, because of 
demanding technical and schedule requirements, the power amplifiers used in the satellites 
will have operating points set close to saturation and that as a result out-of-band emissions 
will occasionally exceed the emissions mask specified in Section 25.202(f) of the FCC's rules, 
to a slight extent. A waiver of 25.202(f) is therefore imperative if the IRIDIUM System is to 
operate on schedule and perform optimally, according to MSC, which proposes to adhere to a 
somewhat less restrictive emissions mask. 16 MSC asserts that because the planned inter- 
satellite transmitters would not point at the ground and would rarely be aligned with non- 
IRIDIUM satellites, any increased interference to other systems would be negligible even if no
15 See Rulemaking to Amend Pans 1. 2. 21. and 25. First Report and Order, supra, n.10.
'" MSC says in the application that for an emission bandwidth of 25 MHz the emissions in each inter- 
satellite channel "are expected to meet" the following limit: PSD(b) = -15 dB for 12.5 MHz < 
b < 37.5 MHz and -25 dB for 37.5 MHz < b.' where PSD(b) = power spectral density at offset 
frequency b. relative to the PSD measured at the carrier frequency, measured in a 4 kHz or 
larger bandwidth, and b = frequency of measurement relative to the carrier frequency.
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emissions mask were applied. It says that in order to further ensure against causing any put- 
of-band interference to other systems it would refrain from using the two outer channels in its 
authorized inter-satellite band on satellites that would exceed the 25.202(f) mask. 17 MSC 
asserts, moreover, that the proposed adjustment has no material bearing on the results of a 
recent study by NASA demonstrating that the IRIDIUM System would not interfere with 
NASA systems or foreign systems, which MSC has previously cited.
18. We grant the request for waiver of 25.202(f) for IRIDIUM's inter-satellite 
operation, with the following conditions. The waiver is granted only for the frequency sub- 
band 23.205-23.355 GHz within MSC's assigned bandwidth for intersatellite transmission and 
only to the levels indicated in its license modification application. 18 Since, as the applicant 
points out, the main lobes of the IRIDIUM cross-links would not point towards the .Earth, 
there would be substantial discrimination between the system's intersatellite transmissions and 
terrestrial services operating in bands adjacent to 23.18-23.38 GHz. We are therefore satisfied 
that emissions produced in adjacent bands from IRIDIUM cross-link transmissions on the six 
center channels will have negligible impact on those other services. We reserve discretion, 
however, to require greater attenuation to alleviate harmful interference pursuant to Paragraph 
(4) of Subsection 25.202(£).
19. Emissions mask for feeder downlinks. MSC also requests a waiver of Section 
25.202(f) with respect to feeder-link transmission. It plans to use adaptive power control for 
feeder-link transmissions from the IRIDIUM satellites, which would tend to suppress 
interference to other systems. MSC asserts that emissions will be within the limits set by the 
rule during normal operation but acknowledges that those limits would be exceeded on 
occasions when the satellites' amplifiers are driven close to saturation while boosting power to 
maintain adequate performance during periods of heavy rain. Such occasions would be 
infrequent and of short duration, according to MSC, which estimates that emissions would 
exceed the 25.202(f) mask only 0.1 percent of the time during transmission to IRIDIUM earth 
stations in arid locations and only 0.75 percent of the time during transmission to earth 
stations in "wet" locations, such as Atlanta. It asserts, moreover, that the possibility of 
increased interference during those infrequent occasions would arise only when an IRIDIUM 
satellite is close to the boresight of another system's receiving terrestrial antenna and that such 
intervals of alignment would be very brief; MSC calculates that an IRIDIUM satellite would 
pass through the 10 dB beamwidth of a typical ground station or terrestrial microwave 
antenna in about three seconds. Furthermore, MSC stresses that the increased atmospheric 
attenuation that would trigger a compensatory power-boost would tend to prevent any increase 
in interference from intermodulation products, in any event. In sum, MSC contends that 
operation in the power-boost mode as proposed would have negligible interference impact.
17 As designed, the IRIDIUM satellites would be capable of transmitting and receiving on 8 channels within 
the 200 MHz spectrum range assigned for inter-satellite links. Thus, limiting operation, as proposed, to the inner 
six channels would leave 25 MHz guardbands at either end of the assigned spectrum band.
l!s See footnote 16. above.
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No party filed comments in opposition to the waiver request.
20. In light of the considerations that the applicant stresses and also in light of the 
fact that the IRIDIUM satellites must, in any event, operate in compliance with the pertinent 
p.f.d. limits of Section 25.208(c) of the rules, which the applicant has not asked us to waive, 
we grant the request for waiver of 25.202(f) with respect to feeder link transmission from 
IRIDIUM satellites in the assigned 19.4-19.6 GHz sub-band, with the following provisos. 
Emissions during periods of power-boost must not exceed the predicted levels, 19 and MSC 
must take all practicable steps to limit spurious emissions outside of its authorized bandwidth 
to the levels that 25.202(f) permits. This waiver does not signify an intention to relinquish 
the discretion reserved in Paragraph 25.202(f)(4).20
Construction Milestones
21. The Commission stated in the Big LEO Report and Order that each Big LEO 
space-station licensee would be required to adhere to a timetable for implementation of its 
proposal. More specifically, it said that unless an applicant demonstrated a special need for 
additional time it would be required to begin construction of its first two satellites within one 
year after receiving an unconditional authorization, to begin construction of the remaining 
authorized satellites within three years of the same date, to complete construction of the first 
two within four years, and to put the entire system into operation within six years.21 The 
requirements are to be imposed by specifying the timetables as license conditions.22 To 
ensure compliance, the Commission adopted rule provisions requiring Big LEO licensees to 
file annual progress reports and to certify within ten days after each milestone date that the 
milestone requirement was met or else report that it was missed.23 We incorporate the 
milestone timetable detailed in the Big LEO Report and Order in the terms of MSCs license.
" MSC represents in the application that for an emission bandwidth of 6.25 MHz it expects emissions 
during periods of maximum power-boost to peak within this PSD mask: PSD(b) = -17 dB for 3.125 
MHz < b < 6.25 MHz, -27 dB for 6.25 MHz < b < 15.625 MHz, and -37 dB for 15.625 MHz < b, where 
PSD(b) = power spectral density at offset frequency b, relative to the PSD measured at the 
carrier frequency, both being measured in a 4 kHz or larger bandwidth, and b = frequency of 
measurement relative to the carrier frequency.
:o Paragraph 25.202(f)(4) provides that when emissions outside of the authorized bandwidth cause harmful 
interference, the Commission may require attenuation to levels below the limits specified in Subsection 25.202(f).
:i 9 FCC Red at 1189.
" id.
-' See47C.F.R. §25.143(e).
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22. Accordingly, pursuant to authority delegated by Section 0.261 of the FCC's rules. 
47 C.F.R. §0.261. IT IS ORDERED, that Application No. 85-SAT-ML-96 for modification of 
license IS GRANTED to the extent indicated herein, in accordance with the technical 
specifications set forth in the application and consistently with the FCC's rules except insofar 
as expressly waived herein.
23. IT IS FURTHER ORDERED that, unless extended by the Commission for good 
cause shown, this authorization will become null and void in the event that the licensee fails 
to meet the following progress schedule:
Construction Construction Fully 
Commenced Completed Operational
First two system satellites October 1997 October 2000
Remaining system satellites October 1999 October 2002
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24. IT IS FURTHER ORDERED that this license shall not vest in the licensee any 
right to operate space stations or use the assigned frequencies beyond the term thereof or in 
any manner other than authorized herein; that neither the license nor the rights granted 
thereunder shall be assigned or otherwise transferred in violation of the Communications Act; 
and that the rights granted herein are subject to the rights of use or control conferred by 47 
U.S.C. §706.
FEDERAL COMMUNICATIONS COMMISSION
Donald H. Gips
Chief, International Bureau
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