Attachment 1990Request for Waiv

1990Request for Waiv

WAIVER submitted by ORCOMM

Waiver Request

1990-03-02

This document pretains to SAT-A/O-19900228-00011 for Authority to Operate on a Satellite Space Stations filing.

IBFS_SATAO1990022800011_1058940

Before the FEDERAL COMMUNICATIONS COMMISSION WASHINGTON, D.C. 20554 ) In the Matter of the Application of ORBITAL COMMUNICATIONS CORPORATION ) ) F% e _No.._ ) f§§€§5;§§§j§§ For Authority to ) Cconstruct a Low—Orbit Mobile ) dA & aan Satellite System ) MAR 2 1990 ) Sufi?&um ©acitiyes fx,v);‘;s%g ":}f'} Satellite Radio Bran ch REQUEST FOR WAIVER UNDER SsECTION 319 (d) OF THE COMMUNICATIONS ACT Orbital Communications Corporation ("ORBCOMM"), by its attorneys, hereby requests a waiver pursuant to Section 319(d) of the Communications Act so that ORBCOMM can proceed immediately with the design and development phases of the construction of the satellites to be used in the low—earth orbit satellite systenm. As set forth in detail in the application for authority to construct being filed concurrently, the public interest would be well served by the prompt implementation of ORBCOMM‘s low—earth satellite system. ORBCOMM is prepared to accept the risk of undertaking preliminary construction work on the satellites pending final action by the Commission on its application. ORBCOMM is the separate subsidiary formed by Orkital Sciences Corporation ("OSC") to develop the ORBCOMM system. OSC, the parent corporation, was formed eight years ago to develop and operate space transportation systems and to engage in other space—related businesses in both the commercial and government sectors. In its brief history, OSC has developed

‘seVe£a1:major advaqced transportation products, including the Transfer Orbit Stage® orbit transfer vehicle and the Pegasus‘"" Air—Launched Space Booster now in production and preparing to launch payloads for customers including the National Aeronautics and Space Administration and the Department of Defense. ORBCOMM will use its demonstrated expertise to begin the construction of the satellites. PUBLIC_INTEREST CONSIDERATIONS The ORBCOMM satellite system will meet the unserved and underserved needs of U.S. consumers for low—cost, two—way data communications and position determination. One of the primary services that ORBCOMM will offer is safety and emergency communications to persons throughout the United States, including the ability to meet critical emergency communications needs in presently unserved areas such as those identified by the Commission in the PELTS proceeding."‘ In addition, ORBCOMM will provide low—cost data acquisition and tracking capabilities useful for environmental monitoring, tracking of stolen goods, and critical two—way data communications. The public interest would clearly be served by the availability of these services as quickly as possible. By its nature, a low—earth orbit satellite systenm provides world—wide coverage in addition to complete U.S. coverage, because the satellites overfly all of the globe as they 1/ Amendment of Parts 0, 1, 2, and 95 of the Commission‘s Rules Regarding the Establishment of a Personal Emergency Locator Transmitter Service, 4 FCC Red 8657 (1989) .

ciréie the earth. Since only a small incremental investment in earth stations is necessary to access the satellites, ORBCOMM can quickly and inexpensively bring these pioneering mobile communi— cations to other countries, including underdeveloped and less densely populated nations. ORBCOMM will be able to take advantage of the global coverage and export service to foreign countries, and thereby help offset the telecommunications trade deficit. ORBCOMM currently has a technological lead over other nations, but foreign countries are developing small satellite and low—earth launch capabilities, and they may catch up with ORBCOMM. Thus, delays threaten American preeminence in this new mobile satellite technology. In order to bring service to the public as~quickly as possible, and to maintain the U.S. technological lead, ORBCOMM requests a waiver under Section 319(d) of the Communications Act, so that it may begin work on the construction of the small satellites immediately. ORBCOMM recognizes that any work under— taken pursuant to this waiver will be at its own risk, and will not prejudice final Commission action on its low—earth orbit satellite system application. Respectfully submitted, MB//f— Albert Halprin~‘" Stephen L. Goodman Verner, Liipfert, Bernhard, McPherson and Hand 901 Fifteenth Street, N.W. Washington, D.C. 20005 Counsel for Orbital Communications Corporation Dated: February 28, 1990


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Document Modified: 2014-08-22 14:19:25
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