Narrative

0399-EX-PL-2016 Text Documents

Tyvak Nano-Satellite Systems, Inc.

2016-06-03ELS_177586

                                 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 an   )   File No. ____-EX-PL-2016
Experimental Non-Geostationary         )
Low Earth Orbit Satellite              )




                          NARRATIVE EXHIBIT


                                              Table of Contents

I.     NARRATIVE INFORMATION REQUIRED BY FCC FORM 442.................. 1
                 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.............. 2
                 Question 6C. Showing that existing communications facilities are
                              inadequate ........................................................................ 3
                 Question 10. Transmitting equipment to be installed, including
                              manufacturer, model number and whether the
                              equipment is experimental in nature ................................ 3
                 Question 11A. Is the equipment listed in Item 10 capable of station
                               identification pursuant to Section 5.115 .......................... 5
                 Question 4.           Antenna Registration Form. Operation of
                                       Directional Antenna ......................................................... 6
II.    RELEVANT INFORMATION ADDRESSED IN SECTION 25.114 OF
       THE COMMISSION’S RULES .......................................................................... 7
                 A. Radio Frequency Plan ......................................................................... 7
                 B. Orbital Locations............................................................................... 11
                 C. Physical Characteristics of Satellite .................................................. 11
                 D. Schedule ............................................................................................ 13
                 E. General Description of Overall System Facilities, Operations
                    and Services ...................................................................................... 13
                 F. Predicted Spacecraft Antenna Gain Contours ................................... 14
                 G. Orbital Debris Mitigation.................................................................. 15
                            1. Limiting the amount of debris released and the
                               probability of the satellite becoming a source of debris
                               by collisions with small debris ............................................ 15
                            2. Limiting the probability of accidental explosions during
                               and after completion of the mission operations ................... 16
                            3. Limiting the probability of the satellite becoming a
                               source of debris by collisions with large debris or other
                               operational space stations .................................................... 16
                            4. Post-mission disposal plans for the space station at end
                               of life .................................................................................... 17
III.   CONCLUSION.................................................................................................. 17


                                  Before the
                    FEDERAL COMMUNICATIONS COMMISSION
                             Washington, DC 20554


In the Matter of                             )
                                             )
Tyvak Nano-Satellite Systems Inc.            )
                                             )   File No. ____-EX-PL-2016
Application for Authority for Ground         )
Testing, Launch, and Operation of an         )
Experimental Non-Geostationary               )
Low Earth Orbit Satellite                    )


                                  NARRATIVE EXHIBIT

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

vehicles to conduct tests of satellite components and for other scientific purposes. With this

Application, Tyvak requests two-year authority for ground testing, launch, and operation of a

single experimental non-geostationary (“NGSO”) low earth orbit (“LEO”) CubeSat satellite.

The RF communications links for the satellite will be two-way telemetry monitoring, tracking,

and command (“TT&C”) transmissions and payload data download in the 400 MHz UHF1 range.


I.     NARRATIVE INFORMATION REQUIRED BY FCC FORM 442

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

       Tyvak proposes to use a single CubeSat to validate the development of atmospheric

sensors and methods,    including taking periodic passive magnetometer readings, using the

Earth’s magnetic field for active vehicle torqueing, and demonstrating a passive Radio

Occultation (“RO”) GPS instrument to collect atmospheric data. The satellite will adhere to a


1
 Tyvak has previously received experimental authorization for similar CubeSats. ELS File No.
0194-EX-PL-2014, Call Sign WH2XDU (Granted Oct. 31, 2014).


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/.

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

Operations Center (“MOC”) in Irvine, California. TT&C for the satellite will be carried out by

Tyvak via a two-way link in the UHF band between 399.9-400.05 MHz.

       Prior to launch, Tyvak will conduct developmental testing of satellite components,

including its transmitters and receivers, at its Irvine, California facilities. Post launch, the

satellite on-orbit operations are expected to take 9 to 12 months, which will permit adequate time

to demonstrate the systems under investigation.

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

       The primary purpose of the program is to perform an in orbit test of a Radio Occultation

(“RO”) GPS instrument. 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.

       In addition, on-orbit data provides validation that future systems will operate successfully

on-orbit. The evaluation of hardware and software in an environment similar to that found in

space is not easily replicated on Earth. On-orbit component failures are often attributed to

unforeseen conditions or coupling of effects that cannot be tested adequately until on-orbit.

Consequently, the use of an on-orbit test bed provides significant risk reduction for future

satellite programs.


                                                  2


Question 6C. Showing that Existing Communications Facilities are Inadequate

       Currently, there are no comparable communications facilities to support the operation of

the CubeSat system for any of the required operations.

       For the TT&C communications link in the 399.9-400.05 MHz UHF band, as discussed in

a later section of this Application, Tyvak is unaware of any currently authorized use of the UHF

band between 399.9-400.05 MHz in the United States or other countries other than those

currently affiliated with Tyvak. Thus, there are no suitable existing facilities.

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

       The satellite has capabilities only for UHF TT&C and payload downlink. Both TT&C

and payload downlink are carried out in the UHF band between 399.9-400.05 MHz. 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


                                                  On‐board
                                                  Processor




                UHF
                Radio




                                                              CubeSat
        Type: UHF Radio
        Manufacturer: Tyvak
        Model: Endeavour UHF
        Custom



        Type: UHF Dipole antenna
        Manufacturer:
        Model:
        Custom / Experimental




        Type: Yagi antenna array (4)
        Manufacturer: M2 Systems
        Model: 400CP30
        Commercially Available

        Type: Power Amp
        Manufacturer: TE Systems
        Model: 4452RAS
        Commercially Available         Power Amp

                                          UHF
                                         Radio

                                   Type: UHF Radio
        Mission Operations
                                   Manufacturer: ICOM
              Center
                                   Model: IC‐9100
                                   Commercially Available

                                Mission Operations



Figure 1: CubeSat System Communications Components




                                   4


       The transmitting components aboard the satellite 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. The satellite possesses a UHF

system for vehicle command and telemetry retrieval and payload data download.

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

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

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

       The TT&C ground segment can address the satellite individually through the use of

spacecraft-specific message destination addresses, authentication counts, and/or encryption keys

using the same frequency allocation. The transmitting component located at the Irvine Earth

station is controlled by dedicated Microsoft Windows workstations. The workstations are used

for antenna pointing control, Doppler frequency shift corrections, and data processing for

transmission. The antenna (manufacturer/model: M2 Antenna Systems, Inc./400CP30) and radio

(manufacturer/model: ICOM/IC-9100) are commercially available, off-the-shelf units, which

will be modified with additional hardware to function at the requested frequencies.

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.




                                                5


Question 4:    Antenna Registration Form; Operation of Directional Antenna

       The satellite is a low earth orbit (“LEO”) spacecraft 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

seven minutes for each Earth station location. The UHF Earth station will use a computer-

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

satellite. The antenna has a maximum gain of +20.2dBi along the bore-sight of the antenna and a

half-power beam-width (i.e., -3dB) of approximately 30 degrees. The antenna array uses four

off-the-shelf, Yagi-type antennae developed by M2 Antenna Systems, Inc.

        Due to the satellite’s NGSO orbit, the range of antenna azimuth and elevation will vary

based on the relative motion of the satellite 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.

       In addition to on-orbit operations, the satellite components will undergo occasional

ground tests up until launch. Testing for the UHF TT&C link will be conducted in carrier

current (i.e., closed-loop) configuration and will not produce any measurable emissions.




                                                 6


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

      A. Radio Frequency Plan

UHF Communications System

         The CubeSat’s UHF communications system will operate using half-duplex

communications within the 399.9-400.05 MHz frequency band for telecommand (i.e., earth-to-

space) and telemetry (i.e., space-to-earth) communications. Although the CubeSat requires only

50 kHz of spectrum bandwidth, Tyvak requests herein authority to operate within the entire

399.9-400.05 MHz frequency band for the mission to facilitate design flexibility.

         The following diagram shows the proposed spectrum use of the CubeSat and ground

stations and also shows authorized spectrum uses in adjacent bands, such as the use by the

Orbcomm Little LEO MSS network of the 400.075-400.125 MHz band as a beacon frequency.

As explained below, the 399.9-400.05 MHz frequency band does not appear to be used by any

authorized government or non-government operator in the United States. Tyvak acknowledges

that the Commission has authorized operation of a federal Mobile Satellite System in the 399.99-

400.05 MHz portion of this fallow band, however, any Tyvak transmissions related to this

mission will be completed well before any Federal operations in the band commence.2 Therefore,

Tyvak’s proposed operation of its experimental satellite in 50 kHz of the 399.9-400.05 MHz

frequency band will not cause harmful interference to any authorized spectrum user.




2
 See Federal Space Station Use of the 399.0-400.05 MHz Band, ET Docket No. 13-115, Notice
of Proposed Rulemaking, FCC 13-65, ¶ 63 (2013).

                                                7


                      400.01                               400.05

                                                                          400.075                  400.125
             399.9
                               Tyvak Cubesats


                               PRIMARY                                              Orbcomm
                       RADIONAVIGATION SATELLITE

                                  PRIMARY                                      PRIMARY
                     Non-Voice, Non-Geostationary (NVNG)       STANDARD FREQUENCY AND TIME SIGNAL SATELLITE
                        Mobile Satellite Service (MSS)



        399.075       400            400.025          400.05         400.075         400.1     400.125        400.15

                                                                    MHz
                               Figure 2: CubeSat Spectrum Diagram (UHF)

         The 399.9-400.05 MHz frequency band is allocated internationally on a primary basis to

the Mobile Satellite Service (“MSS”) (earth-to-space). The 399.9-400.05 MHz frequency band

is also allocated internationally on a primary basis to the Radionavigation Satellite Service

(“RNSS”) until January 1, 2015.3 In the United States, the 399.9-400.05 MHz frequency band is

allocated to the MSS and RNSS services for both government and non-government use.

         During the 1995 World Radiocommunication Conference (“WRC-95”), the International

Telecommunication Union (“ITU”) allocated the 399.9-400.05 MHz band for the Little LEO

MSS service.         The Commission subsequently designated the 399.9-400.05 MHz band as

available for use by Little LEO MSS networks.4 None of the applicants for Little LEO MSS

licenses in the United States, however, requested authority to operate in the 399.9-400.05 MHz

3
    See 47 C.F.R. § 2.106 n.5.224B.
4
  See Amendment of Section 2.106 of the Commission’s Rules to Allocate Spectrum to the Fixed-
Satellite Service and the Mobile-Satellite Service for Low-Earth Orbit Satellites, Report and
Order, 8 FCC Rcd 1812 (1993); 47 C.F.R. §§ 2.106 n.US320 & 25.202(a)(3). Although the
Commission originally included the 399.9-400.05 MHz band in footnote US320, reference to the
399.9-400.05 MHz band was inadvertently deleted from US320 during a Commission effort to
consolidate footnotes. The Commission corrected the error, reincorporating the reference to the
399.9-400.05 MHz band in footnote US320. See Amendment of Parts 2, 25, and 73 of the
Commission’s Rules to Implement Decisions from the World Radiocommunication Conference
(Geneva, 2003) (WRC-03) Concerning Frequency Bands Between 5900 kHz and 27.5 GHz and
to Otherwise Update the Rules in this Frequency Range, Report and Order, 20 FCC Rcd 6570,
6625 (2005).

                                                               8


band.5 Therefore, the Commission refrained from adopting service rules for Little LEO MSS

networks operating in the 399.9-400.05 MHz band and did not issue any licenses to Little LEO

MSS networks authorizing them to operate in the band.6 Tyvak is unaware of any Little LEO

MSS network operating anywhere in the world (and particularly not in the United States) that

uses the 399.9-400.05 MHz band.

          The 399.9-400.05 MHz frequency band is also allocated internationally on a primary

basis to RNSS until January 1, 2015. The 399.9-400.05 MHz frequency band was previously

used by the U.S. Department of Defense for its TRANSIT-SAT RNSS system, which was a polar

orbiting satellite network that was primarily used for commercial and government maritime

navigation. The TRANSIT-SAT network, however, was decommissioned in December 1996.7

          It does not appear that the United States government or commercial operators are using

the 399.9-400.05 MHz frequency band for any other RNSS service. As a consequence, the

399.9-400.05 MHz frequency band appears to be fallow of any authorized use in the United

States. Therefore, the short term operation of Tyvak’s experimental CubeSats will not result in

harmful interference to any authorized spectrum user.

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

          Despite the absence of any authorized spectrum users in the 399.9-400.05 MHz band, the

satellite’s communications system has been designed to include several precautions to prevent

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

5
 See Amendment of Part 25 of the Commission’s Rules to Establish Rules and Policies
Pertaining to the Second Processing Round of the Non-Voice, Non-Geostationary Mobile
Satellite Service, Report and Order, 13 FCC Rcd 9111, 9120-21 (1997).
6
    See id. at 9121.
7
 See Federal Long-Range Spectrum Plan, Working Group 7 of the NTIA Spectrum Planning
Subcommittee (Sept. 2000), available at http://www.ntia.doc.gov/osmhome/LRSP/LRSP5a.htm.

                                                9


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.

       Second, the satellite uplink and downlink will use the same 50 kHz bandwidth in half-

duplex mode to send digital data using standard GMSK modulation with maximum data rates up

to 9,600 baud. 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 satellite transmitter can be adjusted to provide up to two watts of power output when

communicating with the Earth station. Transmission power on the Earth station transmitter can

be adjusted to provide up to 200 watts of power output. The communications parameters for the

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

following tables.

                    CubeSat Communications           Value
                    Parameters
                    Emission Designator              40K9G1D
                    Service                          Digital Data
                    Center Frequency                 400.03 MHz
                    Requested Bandwidth              50 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                             1.0 dBW
                        Table 1: Tyvak CubeSat UHF Space-to-Ground
                                 Communications Parameters

                                                10


                 Earth Station                      Value
                 Communications Parameters
                 Emission Designator                40K9G1D
                 Service                            Digital Data
                 Center Frequency                   400.03 MHz
                 Requested Bandwidth                50 kHz
                 (includes Doppler)
                 Modulation                         GMSK
                 Data Rate                          9,600 bps
                 Polarization                       Linear (H, V) or Circular
                 Antenna Type                       Yagi array
                 Antenna Gain                       +20.2 dBi (Max)
                 RF Power Output                    200 W
                 Line Losses                        -3dB
                 EIRP                               40.2 dBW
                     Table 2: Tyvak Earth Station UHF Ground-to-Space
                                Communications Parameters

   B. Orbital Locations

        The spacecraft will operate in LEO with the orbit parameters shown in Table 3, with an

orbit period of roughly 1.6 hours and typical ground access times of five to seven minutes per

pass.

                 Parameter                  Units        Value
                 Orbit Period               hrs          1.6 hrs
                 Orbit Altitude             km           610 km (circular)
                 Inclination                deg          97.8 degrees
                              Table 3: CubeSat Orbit Parameters

   C. Physical Characteristics of Satellite

        The satellite is a nano-class satellite (< 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. This satellite is 6U in size, meaning that it will have the

dimensions of approximately 30 x 20 x 10 centimeters. The CubeSat dispenser limits the total


                                               11


vehicle mass of a 6U CubeSat to less than 10kg respectively. The mass budget is identical for

each satellite and is provided in the following table:

                          Component / Subsystem              Mass [g] 6U
                          Payload                              5000
                          Spacecraft (Subtotal)                4700
                            Structure                          1100
                            Electrical Power System            2000
                            ADCS                                400
                            C&DH                                100
                            Communication                      1000
                            Thermal                             100
                          TOTAL                                7300
                            Table 4: CubeSat Mass Budget per Element

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

generate approximately 16 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 (6U)
                     Payload                             8500
                     Spacecraft (Subtotal)               11500
                       ADCS                              5000
                       C&DH                              600
                       Communication                     5500
                       Thermal                           400
                     TOTAL                               20000
                                 Table 5: CubeSat Power Budget



                                                 12


   D. Estimated Operational Lifetime

       The project timeline and major milestones for the launch and operation of the spacecraft

are provided in the following table. The dates are approximate and contingent upon the exact

launch date (“Time of Launch” or “ToL”), orbit parameters, and unforeseen events during on-

orbit operations.

          Milestone                            Date           Notes
          Delivery for Launch Integration      Jun 2016       ToL - 3 months
          Pre-launch testing of transmitting   July 2016      ToL - 2 months
          components
          Launch                               Sept 2016      ToL + 0
          Release from launch adapter          Sept 2016      ToL + 0hr 30min
          On-orbit check                       Sept 2016      ToL + 24 hours
          Start of experiments                 October 2016   ToL + 4 weeks
          Decommissioning                      Sept 2017      ToL + 12 months
          Re-entry                             June 2037      ToL + 20.8 year
                           Table 6: CubeSat System Major Milestones

   E. General Description of Overall System Facilities, Operations and Services

       The CubeSat provides a platform for on-orbit testing of advanced 3-axis control software

and hardware, sensor technologies, and RO GPS collection system. The systems onboard the

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

RO GPS payload. The satellite communicates with the Earth stations through a low-rate (9.6

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

       The CubeSat mission will be supported by a UHF Earth station at the Irvine MOC and an

additional Earth stations operated by Tyvak in Tromsø, Norway.          The Tromsø location is

identical to the Irvine MOC location in terms of hardware configuration and operation. The



                                                13


Tromsø location is operated by the Irvine MOC and will not store any TT&C or payload data

locally.

           The primary responsibilities of the Irvine MOC 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 archive

server.8 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.

    F. 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.




8
 TT&C data and payload data will be received directly from the spacecraft via UHF link and
securely transmitted to the MOC via a VPN over the Internet.

                                                 14


                         Figure 3: CubeSat L-Dipole UHF Antenna Gain Plot


   G. Orbital Debris Mitigation

       The CubeSat spacecraft will mitigate orbital debris by the following means. An Orbital

Debris Assessment Report (“ODAR”) / End of Mission Plan (“EOMP”) for the spacecraft is

provided as an attachment to this application.

           1. Limiting the amount of debris released and the probability of the satellite
              becoming a source of debris by collisions with small debris

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

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

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

(“P-POD”) system.

       The basic geometry of each satellite is a monolithic cubic structure (i.e., 30cm x 20cm x

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

                                                 15


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 ~ 0.07684 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 610 km, the space vehicle is anticipated to re-enter the

atmosphere within 20.75 year based on lifetime prediction simulations for the current mission

epoch (i.e., launch in Q32016).

           2. Limiting the probability of accidental explosions during and after completion of
              the mission operations

       The vehicle possesses energy storage devices (i.e., Li-ion batteries), which will be left in

a nearly discharged state as part of the decommissioning procedure.

           3. 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

CubeSat 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).

       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.




                                                  16


           4. Post-mission disposal plans for the space station at end of life

       The post-mission disposal plan for the CubeSat 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 vehicle. Anticipated atmospheric re-entry of the satellite is within 20.75 years of mission

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

Q32016). 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 proposed NGSO LEO satellite, which will

permit Tyvak to test and validate a Radio Occultation (“RO”) GPS instrument.               Tyvak’s

experiment will not cause harmful interference to any licensed service. Tyvak will conduct its

experiment using the vacant 399.9-400.05 MHz UHF band. Further, the Tyvak operation will

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

should be granted at the soonest practicable time.




                                                17



Document Created: 2016-06-03 09:00:57
Document Modified: 2016-06-03 09:00:57

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