FAUNA Narrative

0281-EX-ST-2018 Pre Coordination Document

Tyvak Nano-Satellite Systems INC

2018-02-17ELS_205092

                                 Before the
                   FEDERAL COMMUNICATIONS COMMISSION
                            Washington, DC 20554



In the Matter of                       )
                                       )
Tyvak Nano-Satellite Systems Inc.      )
                                       )
Application for Authority for Ground   )
Testing, Launch, and Operation of      )   File No. ____-EX-PL-2018
Experimental Non-Geostationary         )
Low Earth Orbit Satellites             )




                          NARRATIVE EXHIBIT


                                         Table of Contents

I.    NARRATIVE INFORMATION REQUIRED BY FCC FORM 442 ................. 2
               Question 6A. Description of the nature of the research project
                            being conducted ............................................................... 1
               Question 6B. Showing that the communications facilities
                            requested are necessary for the research project .............. 3
               Question 6C. Showing that existing communications facilities are
                            inadequate ........................................................................ 4
               Question 8.         Justification of the need for a five-year
                                   experimental license term ................................................ 4
               Question 10. Transmitting equipment to be installed, including
                            manufacturer, model number and whether the
                            equipment is experimental in nature ................................ 5
               Question 11A. Is the equipment listed in Item 10 capable of station
                             identification pursuant to Section 5.115 .......................... 8
               Question 4.         Antenna Registration Form. Operation of
                                   Directional Antenna ......................................................... 8
II.   RELEVANT INFORMATION ADDRESSED IN SECTION 25.114 OF
      THE COMMISSION’S RULES .......................................................................... 9
               Section 25.114(c)(4)(1) Radio Frequency Plan ....................................... 9
               Section 25.114(c)(5)(1) Orbital Locations ............................................ 17
               Section 25.114(c)(10) Physical Characteristics of Satellites ................. 18
               Section 25.114(c)(12) Schedule............................................................. 20
               Section 25.114(d)(1) General Description of Overall System
                             Facilities, Operations and Services ................................ 20
               Section 25.114(d)(3) Predicted Spacecraft Antenna Gain Contours ..... 21
               Section 25.114(d)(14) Orbital Debris Mitigation .................................. 23
               Section 25.114(d)(14)(i) Limiting the amount of debris released
                             during normal operations and the probability of the
                             satellite becoming a source of debris by collisions
                             with small debris or meteoroids that could cause
                             loss of control and prevent post-mission disposal ......... 23
               Section 25.114(d)(14)(ii) Limiting the probability of accidental
                             explosions during and after completion of the
                             mission operations ......................................................... 24


                 Section 25.114(d)(14)(iii) Limiting the probability of the satellite
                               becoming a source of debris by collisions with large
                               debris or other operational space stations ...................... 25
                 Section 25.114(d)(14)(iv) Post-mission disposal plans for the space
                               station at end of life ....................................................... 25
III.   CONCLUSION.................................................................................................. 26




                                                         ii


                                     Before the
                       FEDERAL COMMUNICATIONS COMMISSION
                                Washington, DC 20554


    In the Matter of                             )
                                                 )
    Tyvak Nano-Satellite Systems Inc.            )
                                                 )    File No. ____-EX-PL-2015
    Application for Authority for Ground         )
    Testing, Launch, and Operation of            )
    Experimental Non-Geostationary               )
    Low Earth Orbit Satellites                   )


                                      NARRATIVE EXHIBIT

          Tyvak Nano-Satellite Systems Inc. (“Tyvak”) provides nano-satellite and CubeSat space

vehicle products and services that target advanced state-of-the-art capabilities to support

operationally and scientifically relevant missions. With this Application, Tyvak requests two-year

authority for ground testing, launch, and operation of an experimental non-geostationary (“NGSO”)

low earth orbit (“LEO”) CubeSat satellite, designated as PROPCUBE 2 – FAUNA, referred to as

FAUNA from here on. FAUNA will consist of a single technology demonstration satellite. The

FAUNA mission is owned by NRO Mission Integration Division (MID) and operated by the Naval

Post-Graduate School (NPS). The RF communications links for the satellite will be two-way

telemetry monitoring, and command (“T&C”) transmissions in the 915 MHz UHF and 450 MHz

UHF 1 for space-to-Earth downlink and Earth-to-space uplink transmissions respectively, and

payload data space-to-Earth downlink at a center frequency of 2340 MHz S-Band and 400 MHz.




1
  Authority for the UHF transmission has been granted from the NTIA per the colonyii-m450-
rfas. This application will transmit to stations listed in that NTIA authorization in addition to
stations listed in this application


UHF T&C spectrum allocation has been already been granted to this mission from the NTIA, this

application requests license for payload data for the S-Band and UHF transmission.


I.     NARRATIVE INFORMATION REQUIRED BY FCC FORM 442

Question 6A. Description of the Nature of the Research Project Being Conducted

       Through its technology demonstration satellites, Tyvak validates the technologies needed

to support spacecraft communication systems, position information and the development of

atmospheric sensors and methods for earth exploration satellite services (“EESS”). The program

leverages the inherent relative low costs of CubeSat vehicle manufacture and launch capabilities

to perform testing and demonstrations in real-world conditions, as well as flight training.

Throughout the course of the FAUNA program, Tyvak will develop a single satellite to perform a

technology demonstration of a beacon technology.

       FAUNA will adhere to a design specification co-developed by California State University,

San Luis Obispo (“Cal Poly”) and Stanford University (“Stanford”) referred to as the CubeSat

Standard. Additional information regarding the CubeSat Standard can be found at the CubeSat

Community website, http://www.CubeSat.org/.

       FAUNA will be fabricated, tested, launched, and operated by Tyvak using its Mission

Operations Center (“MOC”) in Irvine, California, and using affiliated Earth stations in other

locations. T&C for the satellites will be carried out by the Naval Post Graduate (NPS) school and

Tyvak via a two-way link in the UHF band with uplink on 440 MHz - 450 MHz.and downlink on

902 MHz – 928 MHz range.

Question 6B. Showing that the Communications Facilities Requested are Necessary for the
             Research Project



                                                2


       The primary purpose of the FAUNA program is to test and validate new satellite

capabilities or subsystems. On-orbit operation is the only effective way of collecting functional

and performance data in the relevant operational environment, and cannot be adequately

substituted by ground testing or computer simulation. Since this application is only requesting

approval for payload data downlink within the S-Band frequency range, no associated ground

station application is necessary due to no uplink via S-Band required.

Question 6C. Showing that Existing Communications Facilities are Inadequate

       Not applicable for this submission.

Question 10. Transmitting Equipment to be Installed, Including Manufacturer, Model
             Number and Whether the Equipment is Experimental in Nature

       FAUNA only has capabilities for UHF T&C and payload downlink data downlink via S-

Band and UHF. T&C on FAUNA is carried out in the UHF band with uplink on 440 MHz - 450

MHz and downlink on 902 MHz – 928 MHz range. Payload data downlink is carried out on S-

Band in the 2320 MHz – 2345 MHz range and 399.9 MHz – 400.05 MHz range. The following

graphic provides an overview of the transmitting and receiving components of each element. The

specific model numbers are subject to change based on product availability and system upgrades.




                                                3


                SPACE VEHICLE

                                         ON-BOARD
                                         Processor
                                                                                                          Type: S-Band Radio
                                                                                         S-BAND           Manufacturer: Quasonix
                                                                                          RADIO           Model: NanoTX
                                                                                                          Commercially Available
                                  Type: UHF Radio                                Type: UHF Radio
                       UHF        Manufacturer: Tyvak             UHF
                                                              Downconverter      Manufacturer: Tyvak
                      RADIO       Model: Intrepid UHF                            Model: Intrepid UHF
                                  Custom                                         Custom
                                                                              Type: 400 MHz UHF               Type: S-Band Patch
                   Type: 450 MHz UHF           Type: 915 MHz UHF              Dipole Antenna                  Antenna
                   Dipole Antenna              Dipole Antenna                 Manufacturer: Tyvak             Manufacturer: Haigh-Farr
                   Manufacturer: Tyvak         Manufacturer: Tyvak            Model: Intrepid                 Model: Custom
                   Model: Intrepid             Model: Intrepid                Custom                          Custom
                   Custom                      Custom




                                                        Type: S-Band Yagi                           Type: UHF/S-Band Dish
                Type: UHF Yagi Antenna
                                                        Antenna                                     Antenna
                Manufacturer: TRIVEC
                                                        Manufacturer: M2                            Manufacturer: Arecibo
                Model: AV 2040-1 Yagi
                                                        Model: 2.4-18R Yagi                         Model: 300 m Dish
                Commercially Available
                                                        Commercially Available                      Custom

                                     Type: Analog Digital                                                        Type: Analog Digital
                                     Converter                                                                   Converter
                      ADC            Manufacturer: RF-Space                                     ADC              Manufacturer: RF-Space
                                     Model: SDR-IP                                                               Model: SDR-IP
                                     Commercially Available                                                      Commercially Available

                                     Type: Receiver Radio                                                         Type: Receiver Radio
                    Receiver                                                                  Receiver
                                     Manufacturer: AOS                                                            Manufacturer: AOS
                     Radio           Model: AR5000A                                            Radio              Model: AR5000A
                                     Commercially Available                                                       Commercially Available


         NPS Ground Station & University of                                         Arecibo Ground Station
         Birmingham Ground Station*
         * University of Birmingham Ground Station only uses UHF
         not S-Band



                      Figure 1: CubeSat System Communications Components

       The transmitting components aboard FAUNA are controlled by a dedicated on-board

processor, which processes data for transmission, sends and receives data from the modem, and

activates the radio system depending on the state of operations. FAUNA possesses a UHF system

for vehicle command and telemetry retrieval and an S-Band TX for payload data download.

       The T&C communications system uses a Tyvak-developed UHF radio derived from

commercially-available UHF communications systems. The radio operates at 9,600 baud using


                                                                     4


GMSK. The UHF system will use a custom designed half-wave dipole antenna. The S-Band

transmitter is a commercially designed S-Band Transmitter (NanoTX) from Quasonix. The UHF

component of the payload transmitter is a Tyvak designed downconverter for the signal. The radio

operates at 1 Mbps baud using BPSK. The S-Band system will utilize a custom patch antenna from

Haigh-Farr.

       The T&C ground segment can address FAUNA individually through the use of different

message destination addresses, authentication counts and/or encryption keys using the same

frequency allocation.    The transmitting component located at the NPS & University of

Birmingham Earth stations are controlled by dedicated Microsoft Windows workstations. The

workstations are used for antenna pointing control, Doppler frequency shift corrections, and data

processing for transmission. The antennas used (UHF manufacturer/model: TRIVEC / AV 2040-

1 YAGI, S-Band manufacturer/model: M2 Antenna Systems, Inc. / 2.4-18R Yagi) and radio

(manufacturer/model: AOS/AR5000A) are commercially available, off-the-shelf units, which will

be modified with additional hardware to function at the requested frequencies. The University of

Birmingham does not utilize the S-Band antenna, only UHF. The Arecibo Earth Station utilizes

the same back end setup as the NPS, but has a custom 300 m dish for both UHF and S-Band.

Question 11A. Is the Equipment Listed in Item 10 Capable of Station Identification
              Pursuant to Section 5.115

       Each transmitting component of the system is capable of station identification at the end of

each complete transmission. The station identification process is incorporated into the mission

operations procedure. The space component will transmit the call sign in every packet transmitted

as part of its frame header. The frame header is not encoded or encrypted.


Question 4:   Antenna Registration Form; Operation of Directional Antenna

                                                5


       FAUNA is a low earth orbit (“LEO”) satellites in a sun-synchronous orbital with an orbit

period of approximately 1.6 hours. The satellite will pass over the Earth station roughly one to

twelve times per day depending on its location with an average access time of five to twelve

minutes for each Earth station location. The UHF / S-Band Earth stations will use a computer-

controlled tracking antenna to point the Earth station’s antenna in the direction of the moving

satellites. The UHF Trivec antenna has a maximum gain of 9 dBi along the bore-sight of the

antenna and a half-power beam-width (i.e., -3dB) of approximately 30 degrees. The S-Band M2

antenna has a maximum gain of 18 dBi along the bore-sight of the antenna and a half-power beam-

width (i.e., -3dB) of approximately 15 degrees. The Arecibo antenna is custom and has

approximately 72 dB of gain and a half-power beam-width of less than 1 degree.

        FAUNA is a NGSO satellite, thus the range of antenna azimuth and elevation will vary

based on the relative motion of the satellites with respect to the ground station. It will also differ

for each satellite pass. The Earth station will only transmit above a 10 degree elevation angle.

Consequently, the range of antenna elevation angles for all satellite passes will be between 10 and

170 degrees. The azimuth can vary between 0 degrees and 360 degrees. Earth station software

will be used to control the antenna azimuth and elevation rotors for antenna pointing and limit the

range of permissible elevation angles. In addition, the software will be used to predict satellite

contact times and antenna pointing angles to support Earth station planning and operations.

II.    RELEVANT INFORMATION ADDRESSED IN SECTION 25.114 OF THE
       COMMISSION’S RULES




                                                  6


Section 25.114(c)(4)(i) Radio Frequency Plan

UHF Communications System

       The FAUNA UHF communications system will operate using half-duplex communications

with uplink within 420 MHz - 450 MHz range designated for Amateur band and downlink within

the 902 MHz – 928 MHz range designated for ISM Equipment. FAUNA has already received

allocation for 12.5 kHz at 450 MHz center frequency and 115 kHz bandwidth at 915 MHz center

frequency through the NTIA (Reference: colonyii-m450-rfas). The payload UHF system down

converts the S-Band transmitter signal to 400 MHz for beacons.

Space-to-Earth and Earth-to-Space UHF Communications

       FAUNA has been designed to include several precautions to prevent harmful interference

to other services from space-to-Earth transmissions. First, as noted above, space-to-Earth satellite

transmissions will be controlled from the Earth station and the spacecraft will not transmit until it

receives a request from the Earth station or has on-board GPS confirmation that it is above the

designated ground station.

       The spacecraft transceiver uses a packet-based (non-continuous) communications, which

allows command reception between transmissions of packets to provide the ability to command

the satellite to cease space-to-Earth transmission operations in a timely manner, if required.

       The UHF satellite transmitter can be adjusted to provide up to two watts of power output

when communicating with the Earth station. UHF Transmission power on the Earth station

transmitter can be adjusted to provide up to 75 watts of power output. The UHF Payload

transmissions are down converted from the NanoTX transmitter and can provide up to two watts

of power output when beaconing to the Earth Station. The communications parameters for the



                                                 7


UHF communications system for the space-to-Earth and Earth-to-space links are show in the

following tables:

                    CubeSat Communications       Value
                    Parameters
                    Emission Designator          115KG1D
                    Service                      Digital Data
                    Center Frequency             915 MHz
                    Requested Bandwidth          115 kHz
                    (includes Doppler)
                    Modulation                   GMSK
                    Data Rate                    9,600 bps
                    Polarization                 Linear
                    Antenna Type                 Dipole
                    Antenna Gain                 +2 dBi (Max)
                    RF Power Output              2W
                    Line/Misc Losses             -2dB
                    EIRP                         3 dBW
 Table 1: FAUNA UHF Telemetry Communication Space-to-Ground (Downlink) Parameters


                    CubeSat Communications       Value
                    Parameters
                    Emission Designator          115KG1D
                    Service                      Digital Data
                    Center Frequency             400 MHz
                    Requested Bandwidth          1.7 MHz
                    (includes Doppler)
                    Modulation                   BPSK
                    Data Rate                    1 Mbps
                    Polarization                 Linear
                    Antenna Type                 Dipole
                    Antenna Gain                 +2 dBi (Max)
                    RF Power Output              2W
                    Line/Misc Losses             -2dB
                    EIRP                         3 dBW
     Table 2: FAUNA UHF Payload Data Communication Space-to-Ground (Downlink)
                                   Parameters




                                             8


                Earth Station                    Value
                Communications Parameters
                Emission Designator              12K5G1D
                Service                          Digital Data
                Center Frequency                 450 MHz
                Requested Bandwidth              12.5 kHz
                (includes Doppler)
                Modulation                       GMSK
                Data Rate                        9,600 bps
                Polarization                     Linear (H, V) or Circular
                Antenna Type                     Yagi array
                Antenna Gain                     +9 dBi (Max)
                RF Power Output                  75 W
                Line Losses                      -3dB
                EIRP                             24.75 dBW
  Table 3: NPS & University of Bermingham Station UHF Communications Earth-to-Space

                                    (Uplink) Parameters

                Earth Station                    Value
                Communications Parameters
                Emission Designator              12K5G1D
                Service                          Digital Data
                Center Frequency                 450 MHz
                Requested Bandwidth              12.5 kHz
                (includes Doppler)
                Modulation                       GMSK
                Data Rate                        9,600 bps
                Polarization                     Linear (H, V) or Circular
                Antenna Type                     Yagi array
                Antenna Gain                     +72 dBi (Max)
                RF Power Output                  75 W
                Line Losses                      -3dB
                EIRP                             87.75 dBW
        Table 3: Arecibo UHF Communications Earth-to-Space (Uplink) Parameters




S-Band Communications System

       The FAUNA S-Band communications system will operate only downlink operations

within the 2320 – 2345 MHz range designated for Satellite Communications. FAUNA will utilize

                                             9


Approximately 1.7 MHz of bandwidth with a 2340 MHz center frequency. The S-Band system is

capable of transmissions up to 1 Mbps digital but will not transmit the full data rate during

operations.

Space-to-Earth S-Band Communications

       FAUNA has been designed to include the same precautions used for UHF on S-Band as

well, in order to prevent harmful interference to other services from space-to-Earth transmissions.

First, as noted above, space-to-Earth satellite transmissions will be controlled from the Earth

station and the spacecraft will not transmit until it receives a request from the Earth station or has

on-board GPS confirmation that it is above the designated ground station.

       The spacecraft transceiver uses a packet-based (non-continuous) communications, which

allows command reception between transmissions of packets to provide the ability to command

via UHF the satellite to cease space-to-Earth transmission operations in a timely manner, if

required.

       The S-Band satellite transmitter can be adjusted to provide up to two watts of power output

when communicating with the Earth station. S-Band is only for downlink operations and thus

there are no transmissions from the Earth station. The communications parameters for the S-Band

downlink system for the space-to-Earth link are shown in the following tables:

                  CubeSat Communications              Value
                  Parameters
                  Emission Designator                 1M70G1D
                  Service                             Digital Data
                  Center Frequency                    2340 MHz
                  Requested Bandwidth                 1.7 MHz
                  (includes Doppler)
                  Modulation                          BPSK
                  Data Rate                           1 Mbps
                  Polarization                        RHCP
                  Antenna Type                        Patch

                                                 10


                  CubeSat Communications              Value
                  Parameters
                  Antenna Gain                        +5 dBi (Max)
                  RF Power Output                     2W
                  Line/Misc Losses                    -2dB
                  EIRP                                6.0 dBW
                           Table 4: FAUNA S-Band Communications
                                  Space-to-Ground Parameters


Section 25.114(c)(5)(i) Orbital Locations

       FAUNA is intended to operate in LEO with the orbit parameters shown in Table 6. Each

satellite will have an orbit period of roughly 1.6 hours with typical ground access times of five to

seven minutes per pass. The orbit parameters are presented in the following table:

                 Parameter                     Units          Value
                 Orbit Period                  hrs            1.6 hrs
                 Orbit Altitude                km             400 km (circular)
                 Inclination                   deg            51.6 degrees
                               Table 5: CubeSat Orbit Parameters

Section 25.114(c)(10) Physical Characteristics of Satellites

       FAUNA is a nano-class satellites (< 10 kg), in which each element conforms to the CubeSat

Standard. CubeSats can be designed in different sizes as long as they are multiples of the basic

CubeSat standard unit, which is 10×10×10 centimeters, generally referred to as a 1U CubeSat,

meaning one unit in size. FAUNA is a 1U in size, which means each CubeSat will have the

dimensions of approximately 10 x 10 x 10 centimeters. The CubeSat dispenser limits the total

vehicle mass of a 1U CubeSat to less than 1.17kg respectively. The mass budget is identical for

each satellite and is provided in the following table:

                         Component / Subsystem                 Mass [g] 6U
                         Payload                                  250

                                                 11


                         Component / Subsystem                Mass [g] 6U
                         Spacecraft (Subtotal)                   916
                           Structure                             200
                           Electrical Power System               200
                           ADCS                                  100
                           C&DH                                  100
                           Communication                         216
                         TOTAL                                  1166
                           Table 6: CubeSat Mass Budget per Element

       For power generation, FAUNA is equipped with body-mounted GaAs solar cells that

generate approximately 4 watts of power during a typical orbit. Because of the short operational

lifetime of the satellite (i.e., less than a year), the difference between the beginning-of-life (“BOL”)

and end-of-life (“EOL”) power generation is negligible. To permit operations during eclipse,

energy is stored on-board using Li-ion batteries, with power being distributed to subsystems and

components through the electrical power subsystem circuitry. For operations, the Payload is only

powered for a portion of the total orbit. The EOL power budget is provided in the following table:

                      Component / Subsystem              EOL Power [mW]
                                                         Orbit Averaged (1U)
                      Payload                            1000
                      Spacecraft (Subtotal)              3000
                        ADCS                             400
                        C&DH                             600
                        Communication                    2000
                      TOTAL                              4000
                                Table 7: Power Budget for FAUNA

Section 25.114(c)(12) Schedule

       The project timeline and major milestones for the launch and operation of the FAUNA are

provided in the following table. FAUNA has already been launched and is currently in operation

only for T&C, due to the NTIA authorization and lack of spectrum allocation for payload. The

dates are approximate and contingent upon unforeseen events during on-orbit operations.


                                                  12


         Milestone                             Date            Notes
         Launch                                January 12,     ToL + 0
                                               2018
         Release from launch adapter           January 12,     ToL + 0hr 30min
                                               2018
         On-orbit check                        January 19,     ToL + 7 days
                                               2018
         Decommissioning                       January 2019    ToL + 12 months
         Re-entry                              November        ToL + 2.8 year
                                               2020
                          Table 8: FAUNA System Major Milestones

Section 25.114(d)(1) General Description of Overall System Facilities, Operations and
                     Services

       FAUNA provides a platform for on-orbit testing of advanced 3-axis control software and

hardware, sensor technologies, and beacon communication system. The onboard systems on

FAUNA provide nominal attitude, electrical power, data storage, and command function for the

communication payload. FAUNA communicates with the Earth stations through a low-rate (9.6

kbps) half-duplex communications link operating in the UHF band.

       The FAUNA mission will be supported by a UHF Earth station at the at NPS Monterey,

CA facility, the University of Bermingham facility, and the Arecibo, PR facility.

       The primary responsibilities of the NPS Monterey, CA MOC facility will be to command

the space vehicle to initiate the experiments, recover spacecraft engineering telemetry, and manage

the function of the spacecraft. The Earth station equipment comprises a UHF yagi antenna array

and UHF transceiver. The MOC will also have vehicle control workstations and a mission data




                                                13


archive server.2 The workstations will serve as the primary interface with the ground controllers

and will be used for data processing, antenna/radio control, and engineering analysis. The mission

data archive server will archive command and telemetry data to support mission operations, status,

troubleshooting, and post-mission assessment.

Section 25.114(d)(3) Predicted Spacecraft Antenna Gain Contours

       The spacecraft UHF antenna is a half wavelength L-dipole antenna, which is essentially

omni-directional when mounted on the corner of a CubeSat structure. A simulation of the antenna

design is shown in Figure 3.




                         Figure 3: CubeSat L-Dipole UHF Antenna Gain Plot

      The S-Band patch antenna used for downlink has the following gain pattern provided by
Haigh-Farr:




2
 TT&C data will be received directly from the spacecraft via UHF link; payload data will be
downlinked via S-band

                                                14


Section 25.114(d)(14) Orbital Debris Mitigation

       The CubeSat spacecraft will mitigate orbital debris by the following means:

Section 25.114(d)(14)(i) Limiting the amount of debris released during normal operations
                         and the probability of the satellite becoming a source of debris by
                         collisions with small debris or meteoroids that could cause loss of
                         control and prevent post-mission disposal

       In order to limit the amount of debris generated during normal operations, FAUNA has

been designed so that all parts will remain attached to the satellite during launch, ejection, and

normal operations. This requirement is intrinsic to all satellites conforming to the CubeSat



                                               15


Standard and compliance is required for launch using the Poly-Picosatellite Orbital Deployer (“P-

POD”) system.

        The basic geometry of each FAUNA is a monolithic cubic structure (i.e., 10cm x 10cm x

10cm). Based on an orbital debris model (ref. NASA DAS v2.1), the probability of a single particle

impact with a size of 1 millimeter or larger over the mission lifetime is very low (i.e., roughly 1.3

x 10-3). This low probability of impact for the mission is a result of the small effective area of the

space vehicle (i.e., effective area ~ 0.001 m2) and the relatively short mission duration (i.e., mission

life less than one year).

        Catastrophic system failure due to orbital debris or micrometeoroid impact will not affect

the vehicle’s ability to de-orbit within the guidelines for vehicles operating in LEO (i.e., less than

25 years). Based on the mission orbit of 400 km, the space vehicle is anticipated to re-enter the

atmosphere within 2.75 year based on lifetime prediction simulations for the current mission epoch

(i.e., launch in Q12018).




                                                  16


Section 25.114(d)(14)(ii) Limiting the probability of accidental explosions during and after
                          completion of the mission operations

       The vehicles possess energy storage devices (i.e., Li-ion batteries), which will be left in a

nearly discharged state as part of the decommissioning procedure.

Section 25.114(d)(14)(iii) Limiting the probability of the satellite becoming a source of debris
                            by collisions with large debris or other operational space stations

       Based on a simple orbital debris model (ref. NASA DAS v2), the probability of the

CubeSats colliding with large debris or other space systems of sizes one centimeter or greater at

the mission orbit altitude and inclination is negligible (i.e., roughly 4x10-6).




                                                  17


       The launch provider has instituted deployment procedures in order to place the co-

manifested satellites in the launch vehicle into slightly different orbits in order to reduce the risk

of collision. One of these procedures is to stagger deployment times.

Section 25.114(d)(14)(iv) Post-mission disposal plans for the space station at end of life

       The post-mission disposal plan for the CubeSats includes the transition of all vehicle

systems to a dormant state, which includes the cessation of all radio operations (i.e., transmit and

receive). Energy storage devices will be held at a minimal charge state at the end of the life of the

vehicles. Anticipated atmospheric re-entry of the satellites is within 20.75 years of mission

completion based on its mission orbit, vehicle mass, geometry and mission epoch (i.e., launch in

CY2016). No active de-orbit maneuvers are required to meet the 25 year re-entry guidelines.

       Re-entry debris and probability of human casualty will be negligible. The materials used

on the vehicle include aluminum and PCB material, which have a relatively low melting

temperature as compared to other materials such as Ti or stainless steel, and are not expected to

survive reentry.

III.   CONCLUSION

       The Experimental Licensing Branch should grant Tyvak’s application for two-year

experimental authority to launch and operate the FAUNA NGSO LEO satellite, which will permit

Tyvak to demonstrate and validate advanced 3-axis stabilization hardware and software and

communication beacon technology, adding valuable on-orbit performance data for future CubeSat

Standard satellites. Tyvak’s experiment will not cause harmful interference to any licensed service.

Tyvak will conduct its experiment the 399.9-400.05 MHz UHF band and 2320 – 2345 MHz S-

Band band whose allocations include Satellite Communications (25). Further, the Tyvak operation



                                                 18


will meet the Commission’s orbital debris mitigation requirements.   Therefore, Tyvak’s

application should be granted at the soonest practicable time.




                                                19



Document Created: 2018-02-17 13:50:41
Document Modified: 2018-02-17 13:50:41

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