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If you need the complete document, download the WordPerfect version or Adobe Acrobat version, if available. ***************************************************************** Before the Federal Communications Commission Washington, D.C. 20554 In the Matter of Application of Iridium LLC Concerning Use of the 1990-2025/2165-2200 MHz and Associated Frequency Bands for a Mobile- Satellite System ) ) ) ) ) ) ) File No. 187-SAT-P/LA-97(96) IBFS Nos. SAT-LOA-19970926-00147 SAT-AMD-20001103-00156 ORDER AND AUTHORIZATION Adopted: July 17, 2001 Released: July 17, 2001 By the Chief, International Bureau: I.INTRODUCTION 1. By this Order, we authorize Iridium LLC (Iridium) to use spectrum in the 2 GHz band to provide Mobile-Satellite Service (MSS). We also authorize Iridium to operate feeder uplinks in the 29.1-29.25 GHz band, feeder downlinks in the 19.3-19.7 GHz band, and inter-satellite links in the 23.18-23.38 GHz and 24.45-24.75 GHz bands. This action is a significant step in assigning this spectrum for MSS use and facilitates implementation of Iridium's proposed system's technology and service offerings in the marketplace. II.BACKGROUND 2. Iridium proposes to construct and launch a mobile-satellite system comprised of ninety-six non-geostationary satellite orbit (NGSO) satellites in eight orbital planes with twelve satellites equally spaced in each orbital plane. Iridium proposes to use service links in the 2 GHz MSS band, feeder links in the Ka-band, and inter-satellite service (ISS) links in the 23.18-23.38 GHz and 24.45-24.75 GHz bands. Iridium proposes to use the 1990-2025 MHz and 2165-2200 MHz bands to serve the United States and, where feasible, to use the 1980-2025 MHz and 2160-2200 MHz bands to serve areas outside the United States. The proposed satellites would operate at an altitude of approximately 850 kilometers in circular orbits. Each orbital plane in Iridium's system is inclined at 98.8 degrees to the equatorial plane with an orbital period of 102 minutes. 3. Iridium submitted its 2 GHz MSS application on September 26, 1997. On March 19, 1998, we sought comment on Iridium's application and other 2 GHz MSS applications that we accepted for filing. Several parties commented on Iridium's proposal and The Boeing Company petitioned to defer consideration of this proposal. Iridium responded. The Commission subsequently adopted service rules for 2 GHz MSS systems. Iridium amended its application to address the requirements adopted in the 2 GHz MSS Order. III.DISCUSSION 4. Under rules adopted in the Commission's 2 GHz MSS Order, Iridium must demonstrate that its system meets certain technical requirements. We address these requirements first. We then turn to Iridium's request for service links in the 2 GHz MSS band, Iridium's request for feeder links and inter-satellite links, Iridium's orbital debris mitigation strategy, implementation milestones, and other licensing issues. A. Threshold Technical Requirements 1. Frequency Agility 5. Under the Commission's service rules and policies, 2 GHz MSS systems must be capable of operating across at least seventy percent of the United States' 2 GHz MSS allocation in the 1990-2025 MHz and 2165-2200 MHz bands. The Commission also requires that 2 GHz MSS systems be capable of operating without fixed frequency translations between the uplink and downlink frequencies. Iridium's proposed system meets these requirements. 2. NGSO Coverage Requirements 6. Section 25.143(b)(2) of the Commission's rules requires NGSO 2 GHz MSS systems to provide continuous coverage throughout all fifty states, Puerto Rico and the U.S. Virgin Islands, i.e., that at least one satellite is visible at an elevation angle of at least five degrees at all times within this geographic area. In addition, at locations as far north as 70 degrees North Latitude and as far south as 55 degrees South Latitude, NGSO MSS systems must operate such that at least one satellite is visible at an elevation angle of at least five degrees for eighteen hours of every day. Iridium's proposed system meets these requirements. B. Service-Link Spectrum 7. The 2 GHz MSS Order adopted a hybrid band arrangement that divided the 2 GHz MSS uplink (1990-2025 MHz) and downlink (2165-2200 MHz) bands into segments of equal bandwidth based on the number of systems seeking assignments. The Commission determined that providing 3.5 megahertz in each direction for the nine then-pending system proponents would be sufficient to commence operations. The Commission provided that, in the event not all system proponents proceed toward authorization, the remaining system proponents would receive more than 3.5 megahertz of spectrum in each direction upon authorization. In addition, the Commission reserved one additional spectrum segment in each direction for expansion of system(s) by operator(s) meeting certain criteria for service to unserved areas. The following formula expresses the amount of spectrum available for each system in each direction of transmission: 35 megahertz ¸ (Number of System Proponents + One) = Size of Each Spectrum Segment There are currently eight 2 GHz MSS system proponents participating in this processing round. We will not at this time, however, implement that portion of the Commission's 2 GHz MSS Order that would give each system proponent access to more than 3.5 megahertz of spectrum in each direction on a primary basis. Subsequent to release of the 2 GHz MSS Order, the Commission has received new proposals for use of the 2 GHz MSS bands. Delaying the designation of additional spectrum will give the Commission the opportunity to consider these proposals. Therefore, in this Order, Iridium will receive access to a spectrum segment of 3.5 megahertz, in each direction of transmission, on a primary basis, i.e., a "Selected Assignment." Iridium will choose its Selected Assignment such that the band edge of the assignment is an integer multiple of 3.88 megahertz from the band edge of the 2 GHz MSS band, which will allow the Commission to address the proposals before it. 8. Iridium must identify the specific frequencies of its Selected Assignment when the first satellite in its system reaches its intended orbit and notify the Commission in writing of its selection. Consistent with the 2 GHz MSS Order, Iridium also may elect to operate outside its Selected Assignment on a secondary basis with respect to other 2 GHz MSS operators, subject to certain conditions. C. Other Requests for Spectrum Assignments 1. Feeder Links 9. Iridium proposes feeder link operations in portions of the Ka-band spectrum designated for NGSO MSS feeder links. Specifically, Iridium proposes to use the 29.1-29.5 GHz (Earth- to-space) and the 19.3-19.7 GHz (space-to-Earth) bands. The Commission established a co-primary allocation for NGSO MSS feeder uplinks in the 29.1-29.5 GHz band that is shared with the Local Multipoint Distribution Service (LMDS) at 29.1-29.25 GHz, and geostationary satellite orbit (GSO) fixed-satellite service (FSS) systems at 29.25-29.5 GHz, subject to the special sharing requirements set forth in Sections 25.257 and 25.258 of the Commission's rules. In addition, the Commission designated the 19.3-19.7 GHz band for NGSO MSS feeder downlinks on a co-primary basis with the terrestrial fixed service (FS), subject to site and frequency coordination. We note that Iridium is authorized to use the 29.1-29.25 GHz (Earth-to-space) and the 19.4-19.6 GHz band (space- to-Earth) for its currently operational system and we are unaware of any interference problems with the co-primary services. 10. In its application, Iridium asks us to waive Section 25.258(c) of the Commission's rules, which at the time Iridium filed its application, required NGSO MSS feeder link operations in the 29.25-29.5 GHz band to provide repeating sub-satellite ground tracks on the surface of the Earth. Iridium's waiver request was placed on Public Notice on October 15, 1997, along with its request to operate feeder links in the Ka-band. In response to this Public Notice, Hughes Communications Galaxy, Inc. (Hughes) filed a Petition to Deny Iridium's waiver request. The Commission recently eliminated the repeating ground tracks requirement. Therefore, we dismiss Iridium's waiver request and Hughes' Petition to Deny as moot. Other commenters on Iridium's feeder link request raised concerns regarding the Iridium system's ability to share frequencies in the Ka-band with FS operators in the 19.3-19.7 GHz band, GSO FSS systems in the 29.25-29.5 GHz band, and LMDS facilities in the 29.1-29.25 GHz band. According to Iridium, it is "committed to complying with the Commission's rules and policies, [and] to coordinating with all services and systems with which it is required to coordinate . . . ." Indeed, Iridium has shown its ability to do so through its feeder link operations in the 19.4-19.6 GHz and 29.1- 29.25 GHz bands. We will grant Iridium's requests for feeder link spectrum, as circumscribed below. 11. We grant Iridium authority to configure its space stations to receive feeder link transmissions from earth stations in the 29.1-29.5 GHz band; however, this authorization should not be construed as a license for Earth-to-space transmission. Instead, Iridium must request authority for Earth-to-space transmissions in an earth-station application. At that time, Iridium will need to demonstrate that its system can share the spectrum with other authorized services in the band, and specifically demonstrating that coordination with authorized GSO FSS operations in the band is feasible. Iridium also must comply with the provisions pertaining to coordination in Subsections 25.203(h) and 25.203(k) of the Commission's rules. 12. In the 19.3-19.7 GHz band, Iridium has met the requirements set forth in Section 25.208(c) of our rules. Therefore, we grant Iridium's request to transmit from its authorized space stations to earth stations in the 19.3-19.7 GHz band. Prior to using this band, Iridium must coordinate with the U.S. Government systems operating in the 19.3-19.7 GHz frequency band, in accordance with footnote US334 to the Table of Frequency Allocations. This footnote requires coordination of commercial systems with U.S. Government systems in the 17.8-20.2 GHz frequency band. We note that Government GSO and NGSO FSS networks are presently operating in the frequency band 17.8-20.2 GHz, and plan to operate in accordance with the power flux-density (PFD) limits contained in the current International Telecommunication Union (ITU) Radio Regulations. 2. Inter-Satellite Links 13. Iridium proposes to operate inter-satellite links at 23.18-23.38 GHz and 24.45-24.75 GHz bands. Iridium states that emissions limits and other protections will permit inter-service sharing and coordination will permit co-frequency operation with inter-satellite links of other NGSO networks. Iridium plans to use the inter-satellite links to communicate between satellites in the constellation and to improve efficiency and transmission quality. We grant Iridium's request to operate inter-satellite links in the 23.18-23.38 GHz band on a secondary basis to geostationary inter-satellite operations. We also grant Iridium's request to operate inter-satellite links in the 24.45-24.75 GHz band, subject to coordination among the other authorized users in the band. Under Footnote S5.533 of Section 2.106 of our rules, however, Iridium cannot claim protection against harmful interference from airport surface-detection-equipment stations of the radionavigation service in the 24.45- 24.65 GHz band. 14. The National Telecommunication and Information Administration (NTIA) has informed the Commission of sharing issues in the 22.55-23.55 GHz and 24.45-24.75 GHz bands. These sharing issues include coordination that will be required with Government operations and the requirement to meet specified PFD limits. Therefore, Iridium's inter-satellite service operations must be coordinated through the NTIA's Frequency Assignment Subcommittee of the Interdepartment Radio Advisory Committee. D. Pre-operational Authority 15. Under Commission rules, the fifteen-year license term for a 2 GHz MSS system begins upon a certification by the system operator that the first satellite in its system has begun operations consistent with the terms and conditions specified in its authorization. The Commission indicated in the 2 GHz MSS Order that it would "authorize system operators to conduct pre-operational testing in the license grant, to the extent that applicants include such information in their applications." Iridium did not request such authority. Accordingly, this authorization does not include authority for operations except at the orbits and on the frequencies specified in the application. Authority for any other radio transmissions on any frequency or satellite orbit will need to be obtained by filing a request for a license modification or special temporary authorization, as appropriate. E. Regulatory Classification 16. Iridium requests that the satellite operations being authorized herein not be regulated as a common carrier. Under the Communications Act, Commission Rules, and consistent with our 2 GHz MSS Order, we grant Iridium's request and treat its space station operations as non-common carrier. We will address the regulatory classification of earth stations operating as part of Iridium's system in connection with earth-station licensing. F. Implementation Milestones 17. The 2 GHz MSS Order adopted milestones for implementation that apply to 2 GHz MSS systems. Consistent with the 2 GHz MSS Order, Iridium must observe the following milestone requirements: Milestone Deadline Enter Non-contingent Satellite Manufacturing Contract 12 months after authorization Complete Critical Design Review (CDR) 24 months after authorization Begin Physical Construction of All Satellites 30 months after authorization Complete Construction and Launch First Two Satellites in System 42 months after authorization Certify Entire System Operational 72 months after authorization 18. Iridium must describe the status of system construction and operation in its annual reports, and file a certification with the Commission within ten days following each of the milestones specified above. G. Orbital Debris Mitigation 19. Currently, the FCC addresses issues regarding orbital debris and satellite systems on a case- by-case basis, under the general "public interest, convenience and necessity" standard in the Communications Act. To facilitate our orbital debris analysis, under Section 25.143(b)(1) of our rules, 2 GHz MSS system proponents are required to "describe the design and operational strategies that they will use, if any, to mitigate orbital debris." This rule also requires 2 GHz MSS system proponents to "submit a casualty risk assessment if planned post-mission disposal involves atmospheric re-entry of the spacecraft." 20. In adopting this requirement, the Commission indicated that applicants may wish to consult the National Aeronautics & Space Administration (NASA)/Department of Defense (DoD) Guidelines on Debris Mitigation, as well as the ITU Recommendation on disposal of geostationary satellites. The NASA/DoD Guidelines identify four main objectives: 1) controlling debris released during normal operations; 2) minimizing debris generated by accidental explosions; 3) selecting safe flight profiles and operational configurations; and 4) providing for post-mission disposal of space structures. 21. Under the NASA/DoD Guidelines, these objectives are accomplished by a number of means. The first objective controlling debris released during normal operations is addressed by minimizing the amount of debris released in a planned manner during normal operations. The second objective minimizing debris generated by accidental explosions is addressed by limiting the risk to other space systems from accidental explosions both during mission operations and after completion of mission operations. For mission operations, this is accomplished through analysis of credible failure modes and development of methods to limit the probability they will occur. Post-mission, this is accomplished through depletion of all sources of stored energy on board the spacecraft when they are no longer required for mission operations or post-mission disposal. The third objective selecting a safe flight profile and operational configuration is addressed through estimating and limiting the probability of collision with large objects during orbital lifetime, and the probability of disabling collisions with small debris during mission operations. 22. The fourth objective in the NASA/DoD Guidelines providing for post-mission disposal of space structures is met by planning for disposal of a spacecraft at the end of mission life to minimize impact on future space operations. This is accomplished through one of two options relevant here. The first option is atmospheric reentry, i.e., leaving the structure in an orbit in which it will remain in orbit for no longer than 25 years after mission completion. Under this option, it is also necessary to address the casualty risk from any portions of the spacecraft that may survive atmospheric reentry. The second option is maneuvering to a storage orbit. There are three suggested storage orbits. The first is between low and middle Earth orbit, i.e., satellite perigee altitude above 2,000 kilometers and apogee altitude below 19,700 kilometers. The second is between middle and geosynchronous Earth orbit, i.e., perigee altitude above 20,700 kilometers and apogee altitude below 35,300 kilometers. The third is above geosynchronous Earth orbit, i.e., perigee altitude above 36,100 kilometers (or approximately 300 kilometers above geosynchronous altitude). In addition to the NASA/DoD guidelines, and as the Commission observed in the 2 GHz MSS Order, the ITU has developed a recommendation concerning operations in the GSO. 23. Each of the 2 GHz MSS systems submitted a narrative statement concerning orbital debris mitigation. We note that, to the extent that the statements address debris mitigation issues involving launch vehicle operations, we have neither reviewed nor concluded the plans disclosed are appropriate. We also note that, to the extent debris mitigation plans for MSS systems change, the system proponents should evaluate those changes to determine whether disclosure and/or prior approval is required. 24. In its application amendment, Iridium presented a detailed and comprehensive plan for mitigating orbital debris addressing all phases of system operation. Specifically, Iridium indicated that it will minimize the risk of accidental explosions during mission operations as follows: "Failure mode and effects or equivalent analyses will be used to assure either that there are no credible failure modes which can lead to an accidental explosion on orbit or that design or operational procedures will be in place to limit the probability of such an event." 25. Iridium adequately addressed minimizing the potential for collision with large, known objects by stating that "[i]f an appropriate information or service is available, consideration will be given to maintaining an ongoing situational awareness capability designed to provide a warning of the collision risk posed by tracked objects" and "[i]deally, satellite station keeping maneuvers will be used to minimize the possibility of collision . . . ." Iridium also indicated that it will maintain "close working relationships with NASA, US Space Command, and other US Government agencies to ensure the risk of collision with US Government manned and unmanned assets" is minimized during all phases of system deployment, operations, and decommissioning. At this time, Iridium's plans and procedures are an appropriate response to this issue. 26. Iridium also addressed end-of-mission orbital debris mitigation issues, including defining a system disposal strategy and depletion of stored energy sources. As part of this plan, each Iridium satellite will be lowered to a disposal orbit at the end of its operational life. In the disposal orbit, the satellite will experience drag from the upper reaches of the Earth's atmosphere, causing its orbit to decay, until it reenters the Earth's atmosphere. Iridium indicates that this should occur within twenty-five years. Iridium estimates the reentry casualty expectation for each spacecraft to be "on the order of 1 in 10,000 to 1 in 1,000 (a more accurate estimate will be computed once the satellite configuration is better defined)." Iridium indicates that satellites will be designed "[t]o the maximum extent possible" so that the casualty expectation is less than 1 in 10,000 per reentry. Iridium indicates that when its constellation is fully deployed and operational for several years, approximately twelve satellites per year will be decommissioned and deorbited. 27. Iridium's estimated casualty risk for each spacecraft reentry is unacceptably high. That risk is of particular concern given that Iridium intends to dispose of multiple spacecraft. Nevertheless, Iridium indicates that the design of its satellites has not been finalized and that a satellite design involving a lower casualty risk is readily achievable. Therefore, we condition grant of this Order on the filing of an application for modification of Iridium's license to address end-of-life disposal, not later than six months prior to the CDR milestone. That application should also address the justification for choosing uncontrolled atmospheric reentry as a disposal option. We also note that this Order does not authorize the relocation of operational satellites to storage orbits at end-of-life. H. Other Issues 1. Coding Techniques 28. Iridium indicates that it intends to use both code-division multiple access (CDMA) and time-division multiple access (TDMA) technologies. In its Petition, Boeing questions how Iridium will use these incompatible technologies and requests that we require Iridium to "disclose the amount or percentage of the proposed capacity" that it will use for each access technique. Constellation and ICO raise similar objections. 29. Iridium recognizes the technical incompatibility of CDMA and TDMA technologies and does not propose to use the two protocols simultaneously within the same frequency band. Iridium states that it will use each protocol "within discrete sub-bands to support specific types of services: TDMA to support Iridium's voice communications services and CDMA to support a variety of variable rate data transmissions." 30. In the 2 GHz MSS Order, the Commission adopted a hybrid band arrangement that balanced the needs of operators capable of using overlapping frequencies with those of systems that may not be designed to share co-frequency by providing incentives for shared- technology proponents to cooperate during system implementation. While the Commission allowed operators to choose their exclusive Selected Assignments, the Commission elected to permit operators to aggregate their respective spectrum assignments by reaching sharing agreements among themselves. The 2 GHz MSS Order not only provides sufficient incentives for the 2 GHz MSS licensees to develop a sharing arrangement among satellite operators using different access technologies, but also offers sufficient protection in the event complete sharing cannot be accomplished. 2. GMDSS and AMS(R)S 31. Iridium states that its proposed system will "include priority preemptive capabilities designed to be consistent with the requirements for the Global Maritime Distress and Safety System (GMDSS) and the Aeronautical Mobile Satellite (Route) Service (AMS(R)S)." GMDSS is primarily a ship-to-shore system that consists of several distinct communications systems to provide communications for domestic and international maritime traffic. AMS(R)S is a type of MSS that uses mobile earth stations aboard aircraft to provide communications for domestic and international air traffic and air traffic control. Constellation criticizes Iridium's proposal as inappropriate for the 2 GHz MSS band. ARINC asserts that we should require priority and real-time preemption for AMS(R)S in the 2 GHz MSS band. Iridium responds by stating that it does not seek to obtain rights superior to other 2 GHz MSS licensees and by recognizing "the present limitations on AMS(R)S in the 2 GHz band." 32. The 2 GHz MSS Order held that, to the extent 2 GHz MSS licensees wish to provide GMDSS, AMS(R)S or other, similar services in the 2 GHz MSS band, licensees must meet certain statutory obligations and coordinate with the appropriate safety and rescue organizations. Consistent with the 2 GHz MSS Order, therefore, Iridium may equip its space stations with GMDSS and AMS(R)S capabilities. Before offering these services, however, Iridium must comply with relevant Commission rules, meet its statutory obligations and fulfill its coordination responsibilities. 3. Timing of Licensing 33. AT&T Wireless Services, Inc., Cingular Wireless LLC, Sprint PCS, and Verizon Wireless (Wireless Carriers) in a recent joint letter requested the Commission to defer grant of the pending 2 GHz MSS applications until (1) public comment is sought and received on the implications of New ICO Global Communications (Holdings) Ltd.'s March 8, 2001 ex parte letter proposing amendment of the 2 GHz MSS service rules to permit licensees to incorporate an "ancillary terrestrial component" into their 2 GHz MSS networks; and (2) the Commission considers a petition for rule making submitted by the Cellular Telecommunications & Internet Association (CTIA) requesting that the 2 GHz MSS bands be reallocated for other uses, such as terrestrial wireless services. For the reasons set forth in the ICO Order issued contemporaneously with this Order and Authorization, we deny the Wireless Carriers' request to defer action on the 2 GHz MSS applications. IV.ORDERING CLAUSES 34. Accordingly, IT IS ORDERED that the Application File No. 187-SAT-P/LA-97(96); IBFS File Nos. SAT-LOA-19970926-00147 and SAT-AMD-20001103-00156 IS GRANTED and Iridium LLC IS AUTHORIZED to construct, launch and operate ninety-six satellites capable of operating in the 1990-2025/2165-2200 MHz frequency bands in the United States, in accordance with the technical specifications set forth in its application, as amended, and the conditions set forth in the preceding paragraphs and consistent with our rules, unless specifically waived herein, and subject to the following conditions: a. Iridium LLC must choose a Selected Assignment in the 1990-2025 MHz and 2165- 2200 MHz frequency bands upon launch of one satellite into its authorized satellite orbit and commencement of operations by that satellite; b. The Selected Assignment shall give Iridium LLC access to 3.5 megahertz in each direction of transmission on a primary basis; c. The Selected Assignment shall be chosen such that the band edge of the assignment is an integer multiple of 3.88 megahertz from the band edge of the 2 GHz MSS band; d. Operations in frequencies in these bands outside the Selected Assignment shall be on a secondary basis to operations of other 2 GHz MSS systems; and e. No later than six month prior to the Critical Design Review milestone, Iridium LLC must file an application to modify this license to address end-of-life disposal of its satellites, in accordance with the orbital debris discussion in this Order and Authorization. 35. IT IS FURTHER ORDERED that Iridium LLC IS AUTHORIZED to operate its proposed mobile-satellite system in the 1980-2025 MHz and 2160-2200 MHz frequency bands outside the United States subject to the following conditions: a. In International Telecommunication Union (ITU) Regions 1 and 3, operations shall be limited to the 1980-2010 MHz and 2170-2200 MHz bands and shall comply with footnote S5.389F of the ITU Radio Regulations; b. In ITU Region 2, operations shall comply with footnotes S5.389A, S5.389B, S5.389C, S5.389D, S5.389E, and S5.390 of the ITU Radio Regulations; and c. Iridium LLC is obligated to comply with the applicable laws, regulations, rules, and licensing procedures for those countries it proposes to serve. 4. IT IS FURTHER ORDERED that Iridium LLC IS ASSIGNED the 29.1-29.5 GHz band (Earth-to-space) and 19.3-19.7 GHz band (space-to-Earth) for feeder link operations in accordance with the technical specifications set forth in its application and consistent with our rules unless specifically waived herein. 5. IT IS FURTHER ORDERED that Iridium LLC must coordinate its Ka-band feeder downlink operations with the U.S. Government systems, in accordance with footnote US334 to the Table of Frequency Allocations, 47 C.F.R.  2.106. 6. IT IS FURTHER ORDERED that Iridium LLC IS ASSIGNED the 23.18-23.38 GHz and 24.45-24.75 GHz bands for inter-satellite link operations in accordance with the technical specifications set forth in its application and consistent with our rules unless specifically waived herein. 7. IT IS FURTHER ORDERED that Iridium LLC cannot claim protection against harmful interference from airport surface-protection-equipment stations of the radionavigation service in the 24.45-24.65 GHz band, 47 C.F.R.  2.106 n. S5.533. 8. IT IS FURTHER ORDERED that Iridium LLC shall coordinate its use of the 23.18-23.38 GHz and 24.45-24.75 GHz bands for inter-satellite link operations through the Frequency Assignment Subcommittee of the Interdepartment Radio Advisory Committee of the National Telecommunication and Information Administration. 9. IT IS FURTHER ORDERED that the Petition to Hold in Abeyance of the Boeing Company (filed May 4, 1998) IS DENIED. 10. IT IS FURTHER ORDERED that the Petition to Deny of Hughes Communications Galaxy, Inc. (filed December 22, 1997) IS DISMISSED as moot. 11. IT IS FURTHER ORDERED that this authorization shall be become NULL and VOID with no further action required on the Commission's part in the event the space station is not constructed, launched and placed into operation in accordance with the technical parameters and terms and conditions of the authorization by the following dates: Milestone Deadline Enter Non-contingent Satellite Manufacturing Contract July 17, 2002 Complete Critical Design Review July 17, 2003 Begin Physical Construction of All Satellites January 17, 2004 Complete Construction and Launch First Two Satellites in System January 17, 2005 Certify Entire System Operational July 17, 2007 12. IT IS FURTHER ORDERED that Iridium LLC shall prepare the necessary information, as may be required, for submission to the ITU to initiate and complete the advance publication, international coordination, and notification process of this space station in accordance with the ITU Radio Regulations. No protection from interference caused by radio stations authorized by other administrations is guaranteed unless coordination procedures are timely completed or, with respect to individual administrations, coordination agreements are negotiated. Any radio station authorization for which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments with other administrations. See 47 C.F.R.  25.111(b). 13. IT IS FURTHER ORDERED that this Order and Authorization is subject to change by summary order of the Commission on 30 days' notice and does not confer any permanent right to use the orbit and spectrum. 14. IT IS FURTHER ORDERED that Iridium LLC may decline this authorization as conditioned within 30 days of the date of the release of this Order and Authorization. Failure to respond within this period will constitute formal acceptance of the authorization as conditioned. 15. This Order and Authorization is issued pursuant to Section 0.261 of the Commission's rules on delegations of authority, 47 C.F.R.  0.261, and is effective upon release. FEDERAL COMMUNICATIONS COMMISSION Donald Abelson Chief, International Bureau Appendix A LIST OF PLEADINGS ADDRESSING IRIDIUM'S APPLICATION AND AMENDMENT Filed May 4, 1998 Petition to Hold in Abeyance of the Boeing Company (Boeing Petition) Comments of Constellation Communications, Inc. (Constellation Comments) Consolidated Comments of ICO Services Limited (ICO Comments) Comments of Bell Atlantic (BA Comments) Comments of Aeronautical Radio, Inc. (ARINC Comments) Comments of the Wireless Cable Association International, Inc. (WCA Comments) Filed June 3, 1998 Consolidated Response and Opposition to Petition to Hold in Abeyance (Iridium Reply) Filed June 18, 1998 Consolidated Reply of Iridium LLC (Iridium Response) Consolidated Reply of the Boeing Company (Boeing Response) Reply of Constellation Communications, Inc. (Constellation Response) ICO's Consolidated Response to Reply Comments (ICO Response) Response of the Wireless Communications Association International, Inc. (WCA Response)