Orbital Debris Information

0108-EX-PL-2006 Text Documents

ORBCOMM License Corp.

2006-09-11ELS_77906

                                Stephen L. Goodman
                                532 North Pitt Street
                             Alexandria, Virginia 22314
                                   (202) 607-6756

                                 September 11, 2006

Mr. John Kennedy
Office of Engineering and Technology
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

       Re:    Experimental Application of ORBCOMM, File No. 0108-EX-PL-2006 –
              Orbital Debris Mitigation Report Responding to Request of August 10,
              2006; Reference Number 4484

              Submitted Electronically via the OET Filing System

Dear Mr. Kennedy:

         In response to your request of August 10, 2006, attached is the information on
orbital debris mitigation for ORBCOMM’s U.S. Coast Guard Demonstration Satellite as
specified in Section 5.63(e) of the Commission’s Rules, 47 C.F.R. § 5.63(e). By this
letter, ORBCOMM demonstrates that its experimental satellite complies with the
Commission’s orbital debris requirements and guidelines. Please contact the undersigned
if you have any additional questions.

                                    Sincerely,

                                    /s/
                                    Stephen L. Goodman
                                    Counsel for ORBCOMM


cc:    K. Kensinger


               ORBCOMM U.S. Coast Guard Demonstration Satellite
                Experimental Application File No. 0108-EX-PL-2006
                         Orbital Debris Mitigation Plan

        In accordance with Section 5.63(e) of the Commission’s Rules, following is the
orbital debris mitigation information in support of ORBCOMM’s pending experimental
application for the U.S. Coast Guard Demonstration Satellite (File No. 0108-EX-PL-
2006).


(1) ORBCOMM has assessed and limited the possibility of any debris released in a

planned manner during normal operations. There are no intentional releases of any

objects during any phase of the mission, including deployment, operations, nor disposal.

There are no shrouds or lens caps to be removed upon deployment, and no shrapnel is

generated during separation from the launch vehicle.

ORBCOMM understands and appreciates that small debris and meteoroids have the

potential of colliding with and doing damage to the spacecraft, and the satellite bus

structure was designed with this in mind. No components critical for bus functionality –

including maneuvering – are externally exposed. Internal components are provided with

physical protection either by the bus structure (approximately 3 mm thick aluminum

plating) or by thermal insulation that would serve to break up any small debris or

meteoroid upon impact. Any resulting debris or vapor continuing into the interior of the

spacecraft is unlikely to do damage to major components.

ORBCOMM believes that a conservative estimate of debris size that may threaten the

satellite’s ability to conduct a disposal maneuver is 2 cm. In order to assess the

likelihood of any such collisions, ORBCOMM utilized NASA’s Debris Assessment

Software (DAS v1.5.3) which is publicly-available. The target operational orbit of 920

km altitude (circular) and 83 deg inclination was inputted into the model, along with the


average cross-sectional area of 1.52 m2, and the resulting annual probability of collision

is 9x10-5. Based on this result, ORBCOMM believes the risk is negligible that impacts

with small debris will render the spacecraft unable to conduct its disposal maneuver.

(2) ORBCOMM believes there is virtually no possibility for its spacecraft to accidentally

explode on-orbit. All components involved in the retention and control of energy sources

have strong heritages, and energy sources will be minimized or depleted upon disposal of

the spacecraft. These sources include ammonia gas fuel for propulsion, NiMH batteries,

and momentum wheels. All remaining fuel will be consumed in conducting the disposal

maneuver, leaving the fuel tank with very little pressure and no potential for chemical

combustion. The battery pressure will be minimized, and momentum wheels will be de-

spun.

(3) ORBCOMM understands that other sizable objects exist in low Earth orbit, and that

there is some small possibility of physical collision with large objects, which would

generate additional orbital debris. In order to assess the likelihood of any such collisions,

ORBCOMM again used NASA’s Debris Assessment Software. The resulting annual

probability of collision for the operational orbit is 9.8x10-6.

ORBCOMM believes that this modeling demonstrates that the probability of catastrophic

collision over the life of the satellite mission is extremely small, and it therefore does not

constitute a significant risk of further contributing to the debris environment.

The ORBCOMM system is comprised of relatively small satellites in non-geostationary

orbit. Similar to ORBCOMM’s current spacecraft (some of which have been operating

for over a decade), there will be no active collision avoidance monitoring or

maneuvering, and no active coordination with other operators to avoid collision.


Further, because there are no mission requirements to do so (nor any Commission

requirements to do so, unlike requirements for geostationary satellites), orbital parameters

will not be maintained to any prescribed accuracy. During the operational life of the

satellite, the orbit altitude is expected to decay less than 10 km. The inclination shall

remain stable at approximately 83 deg, and the eccentricity will exhibit small oscillations

about its nominal value of zero. The ascending node and true anomaly will obviously

take on all possible values as they secularly and continuously precess.



(4) ORBCOMM recognizes that responsible disposal of post-mission hardware is the

most practical and effective means of preserving the orbital environment for future use.

This is, in fact, the principal reason driving the inclusion of a propulsion system on this

ORBCOMM spacecraft. Upon completion of its mission, the satellite will be shifted to a

different orbit, decreasing its perigee to facilitate a more rapid, uncontrolled reentry into

the atmosphere. Of its initial 2.8 kg of ammonia fuel, 97% is budgeted for disposal

maneuvering. The apogee and perigee altitudes following this maneuver are expected to

be approximately 920 km and 585 km, respectively.

ORBCOMM believes the orbital lifetime of the hardware, once the disposal maneuver is

completed, will be less than 25 years. In order to assess this expected orbital lifetime,

ORBCOMM again utilized NASA’s DAS software. Using an average cross sectional

area of 1.52 m2, mass of 80 kg, and initial altitude of 920/585 km, atmospheric reentry is

predicted to occur within 24.8 years of the disposal maneuver.

Upon reentry, ORBCOMM believes that the satellite will largely disintegrate and burn

up, although some of the more dense internal components may survive and strike the


Earth. ORBCOMM has performed a casualty analysis using the guidelines disclosed in

Public Notice DA 04-1724, Report No. SPB-208, “Clarification of 47 C.F.R. Sections

25.143(b), 25.145(c)(3), 25.146(i)(4) and 25.217(d) Regarding Casualty Risk Assessment

for Satellite Atmospheric Re-entry.” While the actual mass surviving reentry will be far

less, we have assumed for the sake of conservatism and simplicity that the entire

spacecraft will survive reentry. With this presumption, the equation this document

provides for casualty area reduces to the following:

     Ave Casualty Area = [(Cross-sectional area of person)1/2 + Cross-sectional area of debris)1/2]2,


where the cross-sectional area of a person was taken to be a circular footprint with a

radius of 1m, and the average cross-sectional area of the satellite is 1.52m2. The casualty

area then becomes 9.0m2. The clarification document then suggests that the casualty

probability can be computed from the following (presuming a single debris object):

             Probability of Casualty = [(Ave Casualty Area) x (Ave Population Density)].


The inclination of the orbit bounds the percentage of the Earth’s surface over which the

satellite may reenter. At 83 deg inclination, the possible landing area is 5.07x1014 m2, or

very nearly the entire globe. Coupling this with an estimate of the current global

population of roughly 6 billion yields a casualty probability of approximately 1x10-4.

ORBCOMM believes this presents a negligible casualty risk.



Document Created: 2006-09-11 16:00:56
Document Modified: 2006-09-11 16:00:56

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