Motorola Satellite Communications, Inc
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BEFORE THE FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20564 In re Application of: MOTOROLA SATELLITE COMMUNICATIONS, INC. For Authority to Construct, Launch and Operate a Low Earth Orbit Satellite System in the 161 O-l 626.5 MHz Band. IRIDIUM SYSTEM APPUCATION Leonard S. Koisky Philip L. Malet Vice President and Alfred M. Mamlet Director of Regulatory Affairs Steptoe & Johnson Motorola, Inc. 1330 Connecticut Ave., N.W. 1350 I Street, N.W. Washington, D.C. 20036 Washington, D.C. 20005 (202) 429-6239 (202) 371.6932 Attorneys for Motorola Satellite Communications, inc. December 3, 1990 Motorola, Inc., through its wholly owned subsidiary Motorola Satellite Communications, Inc., is today filing an application with the Federal Communications Commission to construct, launch and operate a global digital mobile personal communications satellite system called IRIDIUM. Motorola is a world leader in the design and manufacturing of electronic equipment, systems, and components. Its products are distributed worldwide and include two-way mobile radios, pagers, cellular telephone systems, integrated circuits, and data and information processing and handling equipment. Motorola also is in the forefront of research and development of new and improved mobile communications equipment, cellular radio technologies and satellite communications subsystems. Motorola has combined its expertise in all of these areas to develop IRIDIUM. TRE IRIDIUM BYSTRM This past June, Motorola announced the development of its IRIDIUM mobile satellite system which envisions the use of many small low earth orbit satellites to provide worldwide cellular personal communications services. Subscribers to this system will use portable or mobile transceivers with low profile antennas to reach a constellation of 77 satellites. These satellites will be interconnected to one another by radio communications as they traverse the globe approximately 413 nautical miles above the.earth in seven polar orbits. Principles of cellular diversity are used to provide continuous line-of- sight coverage from and to virtually any point on the earth's surface, with spot beams providing substantial and unprecedented frequency reuse (more than 5 times in the U.S. alone). This application requests authority from the Commission to operate IRIDIUM for both domestic and international use. As a global communications satellite system with worldwide continuous coverage, IRIDIUM can offer the full range of mobile communi- cations services including radiodetermination, voice and data, on land, in the air, and on water. Any subscriber unit will be able to communicate with any other IRIDIUM subscriber unit anywhere in the world, or with any telephone connected to the public switched telephone network. Each satellite in the IRIDIUM system will be relatively small and have sophisticated electronics capable of communicating with mobile subscriber units and earth station gateways on the ground, and with other low earth orbit satellites in the constellation. IRIDIUM~s innovative digital cellular design and spot beam technology is somewhat analogous to present day cellular telephone systems, except in reverse. In the case of cellular telephones, a static set of cells serves a large number of mobile units, whereas IRIDIUM's cells will move at about 7,400 meters per second while mobile units remain relatively still. In this application, Motorola is requesting authority to use the RDSS uplink band (1610-1626.5 MRz) for the provision 5 of mobile satellite services. This 16.5 MRz of spectrum, however, will only meet expected demand for IRIDIUM services through the latter part of this decade. Ultimately, IRIDIUM will - need to access up to 100 MHz of L-band spectrum worldwide to meet projected demand into the next decade. In light of the current restrictions on the use of the RDSS band, Motorola has requested a waiver from the domestic frequency allocation table to provide both two-way voice and data services on a co-primary basis with radiodetermination services. Such generic mobile satellite ~- services in this band are fully consistent .with the Commission's proposed frequency allocation plans, and are fully compatible with the use of this spectrum by other compliant RDSS systems as well as by the radio astronomy and aeronautical radio navigation communities. In addition, IRIDIUM will need 200 l4l-I~ of spectrum in the Ka-band for its gateway feeder links and 200 MHz for the intersatellite links. Such use of the Ka-band spectrum is fully consistent with both the domestic and international table of allocations, and will be coordinated with others to avoid interference to any planned use of this band. Bulk transmission capacity on the IRIDIUM system will be provided to licensed and authorized carriers, who in turn will sell mobile communications services to the public in their authorized service areas. Due to its limited capacity and cost structure, IRIDIUM is not designed to compete with existing landline and terrestrial based cellular mobile systems. Instead, IRIDIUM will target markets not currently served by mobile communications services, such as (1) sparsely populated locations where there is insufficient demand to justify constructing terrestrial telephone systems; (2) areas in many developing countries with no existing telephone service: and (3) small urban areas that do not now have a terrestrial mobile communications structure. IRIDIUM will offer the full range of mobile services including RDSS, paging, messaging, voice, facsimile and data services. More than half of IRIDIUM's projected six million subscribers will use RDSS and ancillary paging and messaging services. IRIDIUM will provide mobile communications services to the entire United States, including all of its territories and possessions. In addition, IRIDIUM will extend the reach of modern, reliable telecommunications services to and from all worldwide locations. By supplying a full range of mobile - iv - services to many remote and underserved areas, IRIDIUM will provide critical life saving communications services to the public. IRIDIUM also achieves highly efficient use of the frequency spectrum by reusing the bandwidth by more than five times within the U.S. and more than 200 times worldwide. IRIDIUM~s innovative and flexible service will permit the constellation of satellites to shut off various frequencies and service offerings to accommodate regulatory requirements in any nation. In addition, IRIDIUM will be updated and expanded as satellites are replaced. Motorola's considerable experience in space communications, cellular technology and private mobile services provide the necessary qualifications for constructing this innovative system. IRIDIUM will promote U.S. leadership into the 21st century in mobile, personal and satellite communications. These innovative services will enhance U.S. global telecommunications competitiveness and positively affect U.S. trade. ~OTOROIA IS WY TO PROCEBD Motorola is firmly committed to the development of IRIDIUM. To date, it has devoted substantial resources to this project. Commission action on this application by early 1991 is imperative if Motorola is going to meet the demand for satellite mobile communications service by 1997. Certain elements of the satellite design must be fixed by the third quarter of 1991 in -v- order for IRIDIUW to become operational by 1997. In order to provide service as expeditiously as possible, Motorola concurrently requests a Section 319(d) waiver to begin construction on certain long-lead items in advance of a construction permit. mEION SROULD ACT RXPE~OUSL~ IRIDIUM is an excellent vehicle for furthering the U.S. goal of achieving a co-primary allocation in the 1610-1626.5 MHz band for RDSS and MSS, as proposed by the Commission in its recent Second Notice of Inouirv in GEN Docket No. 69-554, F.C.C. 90-316, released October, 1990. By approving this application promptly, the Commission will promote U.S. interests and provide an innovative worldwide offering for the upcoming WARCscheduled for February 1992. - vi - Paqe EXECUTIVESUMMARY .................... i . TABLE OF CONTENTS. ................... vii TABIEOFTABLES ..................... xv TABLE OF FIGURES .................... xvi CROSS-REFERENCETO APPENDIX B .............. xviii I. INTRODUCTION .................... 1 A. Overview of IRIDIUM System and Application . 1 B. Regulatory and Timing Issues ......... 4 C. Pioneers Preference Requested ......... ~7 D. Format and Content of Application ....... a II. PUBLIC INTEREST CONSIDERATIONS ........... 10 A. IRIDIUM Uniquely Meets the Mobile Service Needs of Users In the United States and Throughout the World . 10 B. No Other System Design Has Ever Been Proposed with the Orbit/Spectrum Efficiency of the IRIDIUM System . 12 C. The Unparalleled Flexibility and Innovations in the Technical Design of the IRIDIUM System Will Benefit the Public . 13 D. The IRIDIUM System Will Save Many Lives . 14 E. Motorola Is Uniquely Qualified to Operate the IRIDIUM Satellite System . 15 F. The IRIDIUM System Will Establish U.S. Leadership in Mobile, Personal and Satellite Communications for Many Years to Come . 16 G. The IRIDIUM System Will Make a Major Contribution to U.S. Global Competitiveness in Telecommunications . 16 - vii - H. IRIDIUM Promotes the Commission's Multiple Entry Policies for Satellite Delivered Mobile Services ................ 17 I. IRIDIUM Promotes the International Communications and Information Policy Goals of the United States ............. 18 III. MARKETS AND