Orbital Debris Statement

0108-EX-PL-2006 Text Documents

ORBCOMM License Corp.

2006-05-31ELS_76288

         Experimental Application File No. 0108-EX-PL-2006
                     Supplementary Submission
       This supplementary submission addresses two issues that may arise with respect
to ORBCOMM’s application for experimental authority for placing an additional receiver
package on-board a planned replacement satellite for its non-voice, non-geostationary
(NVNG) mobile satellite system – coverage of the continental United States (CONUS)
and orbital debris mitigation plans.

                            Experimental Coverage Authority

         As ORBCOMM explained in its application, it will be adding a receiver to an
otherwise “technically identical” replacement satellite in order to validate the concept of
extending the coverage of the Coast Guard monitoring of the Automatic Identification
System (“AIS”) transmissions of ships at sea. Because of the ambiguity as to what
constitutes a “technically identical” satellite, out an abundance of caution ORBCOMM is
seeking experimental authority for this replacement and demonstration satellite. In order
to fulfill the Coast Guard program, ORBCOMM requires that its experimental authority
include CONUS. Such broad geographic coverage is necessary both (i) to provide
maximum experimental information on the efficacy and accuracy of satellite monitoring
of the AIS signals, and (ii) to enhance the reliability of the data downloads by providing
diversity and redundancy in the downlinks of the collected information to any of the
ORBCOMM earth station gateways located in the “four corners” of the United States
(Ocilla, Georgia; St. Johns, Arizona; Arcade, New York; and East Wenatchee,
Washington). Moreover, use of all of the ORBCOMM gateways will minimize the
latency of the AIS data downloads, thereby maximizing the timeliness of the information
delivered to the Coast Guard in fulfillment of the contract. For all of these reasons,
ORBCOMM requests that the experimental authority not be limited to a particular
geographic area within the United States.

                                Orbital Debris Mitigation

         Under Section 5.63(e) of the Commission’s Rules, applicants are required to
submit prescribed information on their orbital debris mitigation plans “except where the
satellite system has already been authorized by the FCC.” In this case, the ORBCOMM
satellite system has already been licensed by the Commission (Application of Orbital
Communications Corporation for Authority to Construct, Launch and Operate a Non-
Voice, Non-Geostationary Mobile-Satellite System, 9 FCC Rcd 6476 (1994)), and the
particular replacement satellite for which ORBCOMM is seeking experimental authority
is identical to the previous satellites (also manufactured by Orbital Sciences Corporation),
with the exception of an additional receiver package to evaluate the potential of low-
Earth orbit satellites to monitor AIS transmissions in support of the Coast Guard’s
monitoring mission. As such, the satellite incorporates the same features that minimize
the risk of accidental explosions or collisions so as not to become a source of orbital
debris.



Document Created: 2006-05-31 15:40:48
Document Modified: 2006-05-31 15:40:48

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