Updated Narrative 09082016

0399-EX-PL-2016 Text Documents

Tyvak Nano-Satellite Systems, Inc.

2016-09-08ELS_181761

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-2016 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, referred to as CICERO from here on. CICERO will consist of a single technology demonstration satellite. The RF communications links for the satellite will be two-way telemetry monitoring, tracking, and command (“TT&C”) transmissions in the 400 MHz UHF1 range and space-to-Earth downlink and Earth-to-space uplink transmissions. 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 3-axis stabilization, servicing, formation flight, and the development of 1 Tyvak has previously received experimental authorization for similar CubeSats. ELS File No. 0194-EX-PL-2014, Call Sign WH2XDU (Granted Oct. 31, 2014).

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 CICERO program, Tyvak will develop a single satellite to perform a technology demonstration of a Radio Occultation (“RO”) GPS instrument. CICERO 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/. CICERO 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. TT&C for the satellites 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 CICERO 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. 2

With the proliferation of the CubeSat Standard and the availability of low-cost space access for those adhering to that standard, the cost to test miniature components on-orbit has become relatively inexpensive compared to equivalent ground testing and simulation. This is largely due to the availability of low-cost secondary payload launch options and cost sharing among multiple CubeSat developers. In addition, on-orbit data provides validation that future systems will operate successfully on-orbit through maneuvers. 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. 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 CICERO only has capabilities for UHF TT&C and payload downlink. Both TT&C and payload downlink on CICERO is 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 3

element. The specific model numbers are subject to change based on product availability and system upgrades. On-board Processor UHF CubeSat Radio Type: UHF Radio Manufacturer: Tyvak Model: Endeavour UHF Custom Type: UHF Dipole antenna Manufacturer: Model: Custom Custom / Experimental Type: Yagi antenna array (4) Manufacturer: M2 Systems Model: 400CP30 Commercially Available Type: Power Amp Manufacturer: TE Systems Model: 4452RAS Power Amp Commercially Available UHF Radio Mission Operations Type: UHF Radio Manufacturer: ICOM Center Model: IC-9100 Commercially Available Mission Operations Figure 1: CubeSat System Communications Components The transmitting components aboard CICERO 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. CICERO possesses a UHF system for vehicle command and telemetry retrieval and payload data download. 4

The TT&C communications system uses a Tyvak-developed UHF radio derived from commercially-available UHF communications systems. The radio operates at 19,200 baud using GMSK. The UHF system will use a custom designed half-wave dipole antenna. The TT&C ground segment can address CICERO 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 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. Question 4: Antenna Registration Form; Operation of Directional Antenna CIOCERO 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 seven minutes for each Earth station location. The UHF Earth station will use a computer-controlled tracking 5

antenna to point the Earth station’s antenna in the direction of the moving satellites. The antenna has a maximum gain of +16.2 dBi 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. CICERO 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. In addition to on-orbit operations, the satellite components will undergo developmental testing at Tyvak’s Irvine, CA facility beginning in October of 2015. Testing for the UHF TT&C link will be conducted in carrier current (i.e., closed-loop) configuration and will produce only unintentional emissions. Under the Commission’s rules, unintentional radiators operating in the frequency range between 9 kHz to 30 MHz must comply with the radiated emission limits for intentional radiators as provided in 47 C.F.R. § 15.209.2 As Tyvak’s test program may marginally exceed these limits, Tyvak seeks experimental authority for emissions in the appropriate ranges at the Tyvak facility. These developmental tests are expected to begin in November 2015. Commented [A1]: Bruce, should we keep or remove this statement II. RELEVANT INFORMATION ADDRESSED IN SECTION 25.114 OF THE Commented [A2]: Bruce, please update this argument if required for the application COMMISSION’S RULES 2 47 C.F.R. § 15.109(e). 6

Section 25.114(c)(4)(i) Radio Frequency Plan UHF Communications System The CubeSats’ 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 CubeSats require 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 CubeSats 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.3 Therefore, Tyvak’s proposed operation of its experimental satellites in 50 kHz of the 399.9-400.05 MHz frequency band will not cause harmful interference to any authorized spectrum user. 3 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: CubeSats 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, 2015.4 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.5 None of the applicants for Little LEO MSS licenses in the 4 See 47 C.F.R. § 2.106 n.5.224B. 5 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- 8

United States, however, requested authority to operate in the 399.9-400.05 MHz band.6 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.7 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 1996.8 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 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). 6 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). 7 See id. at 9121. 8 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

Despite the absence of any authorized spectrum users in the 399.9-400.05 MHz band, CICERO 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. 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 19,200 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 180 watts of power output. The communications parameters for the 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 16K5G1D Service Digital Data Center Frequency 399.92 MHz Requested Bandwidth 50 kHz (includes Doppler) Modulation GMSK Data Rate 19,200 bps Polarization Linear Antenna Type Dipole 10

CubeSat Communications Value Parameters Antenna Gain +2 dBi (Max) RF Power Output 2W Line/Misc Losses -2dB EIRP 1.0 dBW Table 1: Tyvak CubeSat UHF Communications Space-to-Ground Parameters Earth Station Value Communications Parameters Emission Designator 16K5G1D Service Digital Data Center Frequency 399.92 MHz Requested Bandwidth 50 kHz (includes Doppler) Modulation GMSK Data Rate 19,200 bps Polarization Linear (H, V) or Circular Antenna Type Yagi array Antenna Gain +16.2 dBi (Max) RF Power Output 180 W Line Losses -3dB ERP 4677.4 dBW Table 2: Tyvak Earth Station UHF Communications Parameters Section 25.114(c)(5)(i) Orbital Locations CICERO 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 610 km (circular) Inclination deg 97.8 degrees Table 7: CubeSat Orbit Parameters 11

Section 25.114(c)(10) Physical Characteristics of Satellites CICERO 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. CICERO is a 6U in size, which means each CubeSat will have the dimensions of approximately 30 x 20 x 10 centimeters. The CubeSat dispenser limits the total 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 9700 Table 8: CubeSat Mass Budget per Element For power generation, CICERO 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) 12

Payload 8500 Spacecraft (Subtotal) 11500 ADCS 5000 C&DH 600 Communication 5500 Thermal 400 TOTAL 20000 Table 9: Power Budget for CICERO Section 25.114(c)(12) Schedule The project timeline and major milestones for the launch and operation of the CICERO 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 Fabrication and RF closed loop Oct 2015- ToL - 13 months testing Feb 2016 Delivery for Launch Integration Jun 2016 ToL - 3 months Pre-launch testing of transmitting July ToL - 2 months components 2016 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 10: CubeSat System Major Milestones 13

Section 25.114(d)(1) General Description of Overall System Facilities, Operations and Services CICERO provides a platform for on-orbit testing of advanced 3-axis control software and hardware, sensor technologies, and RO GPS collection system. The onboard systems on CICERO provide nominal attitude, electrical power, data storage, and command function for the RO GPS payload. CICERO communicates with the Earth stations through a low-rate (19.2 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 several additional Earth stations operated by Tyvak affiliates at sites in North Pole, Alaska; Bozeman, Montana; Tromso Norway; and Columbia, Maryland. 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.9 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. 9 TT&C data will be received directly from the spacecraft via UHF link; payload data will be downlinked via X-band to third-party Earth stations and securely transmitted to the MOC via a VPN over the Internet. 14

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 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, CICERO 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 CICERO 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 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 CY2015). 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). 16

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 CICERO NGSO LEO satellite, which will permit Tyvak to demonstrate and validate advanced 3-axis stabilization hardware and software and RO GPS collection, 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 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


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Document Modified: 2016-09-08 14:45:04
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