Attachment GRANT

This document pretains to SAT-AMD-20020916-00173 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2002091600173_409355

@ LEVENTHAL SENTER & LERMAN ruc December 8, 2004 Smnd, mamen cmatem mee 27 0mD— "ppditticessre Sav— ar viAl DELIVERY DELIVERY c.n...s Ca Gnithe iz ‘C‘Ck! Mr.Thomas S. Tyce Chict, Stellite Division P International Bureau C Federal Communications Cormsf@tometional 445 12" Strees, S.W., Room 6—A68 Aqpont Washington, D.C, 20554 rfeeicna No ANov Re: Application of Virtual Geosatellite LL.C. for Authority to Lawnch? CS 1.. and Operate a Global Fixed—Satellite Service System Employing Satelites in Sub—Geosynchronous Elliptical Orbits, File Nos. SAT— LOA—19980108—00007 and SAT—AMD—20020916—00173, Call Sign Sz36e Dear Mr. Tyer: Virtal Geositllte, LL C.(*Virtual Geo), through its ttomeys,hercby requestsa twelve—day extension of time in order to respond to the two requests for dditional information the Satelite Division made of Virtual Geo in its November 10, 2004 lete in the above—referenced application proceeding. See Letter dated November 10, 2004, from Thomas Tyez to David Castiel, President and Manager,Virtual Geo (‘November 10 Lettr®), In the November 10 Leter,the Satelite Division directed Virtual Geo to amend ts application on or before December 10, 2004 t include an updated and conforming orbital debris mitigation plan and to provide, pursuant to Section 25. 46(a) ofthe Commission‘s Rules, a computer program that demonstrtes the proposed "Virgo"non—peostationary satellte orbit(‘non—GSO®) fixed— satellite service (‘FSS") system‘s compliance with the Ku—band equivalent power ux density (‘EPFD®)limits in Section 25.208 of he Commission‘s Rules.. For the reasons provided below, Virual Geo requests an additionaltwelve days — or until December 22, 2004 within which to finalize and file the required amendment. With respectfirst t the orbital debris mitigation plan, Virtual Geo has used the cccasion of he November 10 Letr and the elsboration earlier this year of the Commission‘s policy on orbital debris mitigation to revistits 2002 plan for post—mission disposal o the spaceerafin the proposed Virgo system. Tt has determined that under all elovant considerations,disposal of he satelites via controlled atmospheric re—entry is the preferred method. As this marks a change from the pror proposal, nd as revised plan has had tobe developed in parllel with the EPFD showing also required of Virtual Geo, there has not been

4 Mr. Thomas S. Tyer December $, 2004 Page 2— sufficienttime for work to befullycompleted on the revised submission in advance ofthe original December 10 deadline. The brief extension Virual Geo requests here would allow that work to be completed, and would et Virtual Geo introduce the debris—reducing approach o havingits satelites re—enter th atmosphere rather thanlingerin orbit forconturies. In its November 10 Letter, the Satelite Division, noting a number of developments in the Commission‘s ules and in Working Party 4A ofh Radiocommunication Sector of the Itemational Telecommunication Uion ("TTU—R"), also called upon Virual Geo to provide a computer program (ncluding source codes and an executable fil)based on the software specification in related TTU—R Recommendation S.1503, to enable the Commission to determine the accurney of Virual Geo‘s demonstration of the Virgo system‘s compliance with the EPFD limits. November 10 Leter at 2.. Virtual Geo also reguires an extension of the compliance deadline for this lement of he November 10 Lettr, in September 2002, Virtual Geo amended is application to include a comprehensive showing of how its proposed non—GSO FSS system, using ellipical orbit satellites with active aresthatare widely separated from the geostationary satelite orbit (°GSO®), will easily meet the applicable EPFD limits contained Section 25.208 of the Commission‘s Rules, 47 C.FR, § 25.208. In the case ofthe Virgo system, the muximum PFD produced at the surface oftEarth,taking imto account various GSO earth station off—axis angles (from a minimum of 40° foone satelite t a maximum of 120") is used to generate the EPFD levels. ‘he relativel straightforward analytial approach Virtual Geo used i its September 2002 analysis of compliance with the Commission‘s EPFD limits — an approach that showed that the maximum EPFD.,., and EPFD,, levels produced by the Virgo system are lower than the moststringent ofthe respective EPFD limits given in the FCC rules and Article 22 of the ITU Radio Regulations — is much more approprite for use with the Virgo HEO architecture than it would be in the much closer case for EPFD compliance that found with non—GSO systems using circular low—Earth orbits. See Virtual Geo Application, September 2002 Amendment, File No. SAT—AMD—2002—916—00173. In the low—Earth orbit case, the complex computer algorithms contemplated by the TTU studies and the Commission‘s rules are clearly necessary to ensure that the EPFD levels established for t protection of GSO networks are met. In light ofthis background, several factors have combined to hinder Virtul Geo‘s efforsat timely compliance with the EPFD element of the November 10 Letter, leading it to require a modest extension of the December 10 deadlin. Firs, and notwithstanding the Sateite Division‘s leterthre is no completely satisfactory commercial computer program that is appropriate for assessing EPFD compliance by nor—GSO FSS systems using highly—eliprical orbits (*HEO®). HEO systems such as Virgo are designed from the outset to minimize the production ofiterference into GSO FSS networks through techniques such as wide separation of the non—GSO FSS system active ares from the GSO. The software tools referenced in the November 10 Letter asbeing "readily available" are not identifed in the TTU Hterature that discusses them (see ITU—R Document 4A/78, Annex 13, May 2004), and th literature itself


Document Created: 2004-12-10 15:35:18
Document Modified: 2004-12-10 15:35:18
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