Attachment GRANT

GRANT

DECISION submitted by FCC,IB

GRANT

2004-12-10

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

IBFS_SATAMD2002091600173_412377

@ LEVENTHAL SENTER & LERMAN ruc sunend, mm cooasene via namp peurvery Mr. Thomas S. Tycr Chief,Sateite Division Interational Bureau Federal Communications Comm@s omid i 445 12" Stree, S.W., Room 6—A66 z z> Washington, D.C. 20554 esn o o4 To:(E Nmsslsues & Seoy Re: Application of irtual Geosatelite L.LC. for Authorityto Launeh / °C<> ) and Operate a Global Fixed—Satelite 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: Virtual Geosatelite,LLC. (*Virtual Geo),through its attomeys, hereby requestsa twelve—day extension of time in orderto respond to the two requests for additional information the Satelite Division made of Virual Geo in its November 10, 2004 lete in the above—referenced application procceding. 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 Satelte Division directed Virtual Geo to amend ts appliction on or before December 10, 2004 to include an updated and conforming orbitl debris mitigation plan and to provide, porsuant to Section 23.46(a) of the Commission‘s Rules, a computer program that demonstrites the proposed "Virgo" non—seostationary satllite orbit ("non—GSO") fied— satelite service (‘FSS®)system‘s compliance with the Ku—band equivalent power fux density (‘EPFD®)limits in Section 25.208 of he Commission‘s Rules.. For the reasons provided below, Virtal Geo requests an additiona twelve days — or until December 22, 2004 — within which to finalize and file the required amendment. With respectfrst t the orbital debris mitiation plan, Virtual Geo has used the eccasion ofthe November 10 Letter and the elaboration earlier this year othe Commission‘s policy on orbital debris mitigation to revisits 2002 plan for post—mission disposal of the spaceeraft in the proposed Virgo system. It has determined that under all relevant considerations, disposal of the sateltes via controlled atmospheri r.entry is the prefereed. method. As this marks a change from the prior proposal,and as a revised plan has had tobe developed in parallel with the EPFD showing also required of Virtual Geo, there has not been

4 Mr. Thomas S. Tyer December 8, 2004 Page 2— sufficient time for work to be fully completed on the revised submissionin advance of the original December 10 deadline. The bief extension Virtal Geo requests here would allow that work t be completed, and would lt Virtual Geo introduce the debris—reducing approach o having ts satelitesre—enter the atmosphere rather than lingerin orbit for conturies. In its November 10 Leter, the Satelite Division, noting a number of developments in the Commission‘s rulesand in Working Party 4of the Radiocommunication Sector ofthIntemmational Telecommunication Union ("TTU—R), also called upon Virtual Geo to provide a computer program (including source codes and an executable file) based on the software specification in related TTU—R Recommendation S.1503, to enable the Commission to determine the accurzcy of Virtual Geo‘s demonstrtion ofthe Virgo system‘s compliance with the EPFD limits. November 10 Lettr at 2.. Virtual Geo also reguires an extension of the complince deadline for this lement of he November 10 Lettr, In September 2002, Virusl Geo amended its applicationtoinclude a comprehensive showing of how ts propased non—GSO FSS system, using ellitical orbit satellites with active arcs thatare widely separated from the geostationary satelite orbit (°GSO®), willeasily meetthe applicable EPFD limits contained in Section 25.208 of the Commission‘s Rules, 47 CFR § 25.208. In he case ofthe Virgo system, tmaximum PFD produced at the surface ofthe Earth, taking into account various GSO earth station off—axis angles (from a minimum of 40° for one satelite t a maximum of 120") is used to generate the EPFD levels, ‘he relatively strailtforward analytical approach Virual Geo used n its September 2002 analysis of compliance with the Commission‘s EPFD limits— an appronch that showed that the maximum EPFDy..« and EPFD,, levels produced by the Virgo system are lower than the moststringent of the respective EPFD limits given in the FCC rules and Article 22 of the TTU 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 is found with non—GSO systems using cireular low—Earth orbits. See Vitual Geo Application, September 2002 Amendment, File No. SAT—AMD—2002—916—00173. In the low—Earth orbit case, the complex computer algorthms contemplated by the TTU studies and the Commission‘s rules are clearly necessary to ensurethat the EPFD levels established for the protection of GSO networks are met. In light ofthis background,severalfactors have combined to hinder Vitual Geo‘s effors at timely compliance with the EPFD element of the November 10 Letter, lading it to require a modest etension of he December 10 deadline. Firs, and notwithstanding the Satelte Division‘sleter, there is no completely stisfictory commercial computer program that is appropriate for assessing EPFD compliance by non—GSO FSS systems using highly—elliprical orbits (*HEO®). HEO systems such as Virgo are designed from the outset to minimize the production of nterference 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 Letteras being "readily available" are not identified in the TTBterature that discussesthem (see TTU—R Document 4A/78, Annex 13, May 2004), and thliterature itself

4 Mr. Thomas S. Tyez December 8, 2004 Page 3— suzgests that the tools under discussion are subjectto some materil shortcomings. With an extension to December 22, Virtual Geo is confident that it can build upon work done t date and ereate a program that accurately accomplishes the objectives setfort in Section 25.146(a)of the Commission‘s rules —i«., provide a vaid program thatallows the Commission todetermine Virgo‘s EPFD compliance. Second. and as the Division may be aware, TTU—R Working Party 4A just finalized a substantia revision of Recommendation S.1503 at its October 2008 meetine, and the iaftrevision to threcommendation was adopted for approval by correspondence by Study Group 4 on October 22 of this year. Virtial Geo and ts technical consultants ar assessing the revisions to Recommendation S.1503 (despite thefactthatthe revision t the recommendation is not yet formully spproved) in an effortto avoid having to re—amend it application again i ts «pplication remains pending when Recommendation S.1503—1 becomes effective. As the recommendation and ts revisions are lengthy and complex,the extension Virual Geo requests here is necessary o allow forthe completion of this effort Finally, Virtal Geo and ts technical consultantshave run into some procedural delays attibutable to questions over Virtual Geo‘s ability to submit proprictary software used for the assessment of EPFD compliance to the Commission. These dificulies, which remain unresolved, have led Virtual Geo t the conclusion that an altemative computer program has to be developed. Virtul Geo is developing the necessary program and is confident that work wl be finished in time for Virtual Geo to file the required materals withthe Commission on December 22 In sum, Virual Geo subrmits that good caus existsfor the grant by the Division of an extension untl December 22,2004 of the deadline for compliance with the November 10 Letter Please contact the undersigned ithere are any questions regarding this mattr. Respesifully submited, Stephen D. Baruch ces Ms. Fem Jarmulnck (by email Mr. Mark Young (by email Mr. Kal Krauktkramer (by email Mr. Sankar Persuud (by email)


Document Created: 2004-12-10 16:19:30
Document Modified: 2004-12-10 16:19:30
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