Attachment letter

letter

LETTER submitted by Skybridge

letter

2004-07-21

This document pretains to SAT-AMD-20031104-00323 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2003110400323_384643

I Pas AVENUE OF THE AMERICAS PAUL, WEISS. R I F K I N D . W H A R T O N 8 G A R R I S O N L L P NEW YORK. NY IO0 108’364 t e % 5 L S T R E E T . N W W A S H I N G T O N , DC Z.0038-5684 T w m w u\u 3 ~ ~ 3 0 0 0 FACSIMILE ( 2 I 2 1 757-3990 TELEPHONE (2021 223-7300 FACSIMILE (2021 2 2 3 - 7 4 2 0 6 2 . RUE DU FAUBOURG SAINT-HONORt 7 3 0 0 8 PARIS, FRANCE TELEPHONE 133 I 1 53 43 I 4 I 4 FACSIMILE (33I 1 53 43 M) 23 JEFFREY n. OLSON COMMUNICATIONS COUNSEL FUKOKU SElMEl BUILDING 2 - 2 UCHlSAlWAlCHO 2-CHOME T E L E P H O N E ( 2 0 2 ) 223-7326 CHIYODA-KU. TOKYO 100-001I , JAPAN E-rcAtL:]olsonOpaulwelss.com JUL 2 1 2004 JUL 1 9 2004 TELEPHONE I8 1-31 3 5 9 7 - 8 101 FACSIMILE ( 8 1-31 3 5 9 7 - 8 I20 2918 CHINA WORLD TOWER II Poky Branch NO. I JIANGUOMENWAI DAJIE Federal @rnrnunications Commission BEIJING. I 0 0 0 0 4 internationalBureau Office of Secretary PEOPLE’S REPUBLIC OF CHINA TELEPHONE 188-10)8505-6822 FACSIMILE tea- I 0)ee.os-ea30 July 19, 2004 IZTH FLOOR, HONG KONG c L u a BUILDING 3 A CHATER ROAD, CENTRAL HONG KONG TELEPHONE (8521 25360933 FACSIMILE 1852) 25360822 ALDER CASTLE I O NOBLE STRE- LONDON ECZV 7 J U . U.K. TELEPHONE (44 2 0 ) 7387 I 6 0 0 FACSIMILE (44 201 7367 I 6 5 0 Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, N.W. Washington, DC 20554 Re: Application of SkyBridge I1 L.L.C. for Authority to Launch and Operate the SkyBridge I1 System, December 22, 1997, SAT-LOA-19971222-00221 SAT-AMD-20031104-00323 Dear Ms. Dortch: This letter is submitted by SkyBridge I1 L.L.C. (“SkyBridge II”) in response to the PubIic Notice issued by the International Bureau on June 16,2004’ (the “PublicNotice”), requiring certain satellite applicants contemplating post-mission disposal by atmospheric re-entry to file a casualty risk assessment by July 19, 2004. In the above-referenced application, SkyBridge I1 indicated that the “method for disposal of the SkyBridge I1 satellites at the end of their operational lives has not been definitively determined,” and that atmospheric re-entry and/or storage orbit could be used.2 SkyBridge I1 hereby notifies the Commission that SkyBridge I1 intends 1 Public Notice, DA 04-1724, Report No. SPB-208, June 16,2004. 2 SAT-AMD-20031104-00323, Exhibit C to Form 3 12, at 2. As SkyBridge I1 also noted, the plans for post-mission disposal of spacecraft are developed in detail as part of the design process for the spacecraft, and SkyBridge LI would be able to provide greater specificity on its plans for spacecraft disposal as those plans are further developed in accordance with the standard design review process. Id. As indicated in NASA Safety Standard 1740.14 (at 2-3), orbital mitigation assessment reports should be completed in connection with the preliminary design review (“PDR”) and critical design review (“CDR’) of the spacecraft. More specifically, according to NASA, the PDR debris assessment should identify debris generation issues, and, where possible, assess those issues, and the CDR assessment should identify, assess, and resolve all debris issues in detail. Because the SkyBridge I1 system has not yet been licensed, the clock on the milestone requirements for the standard design review process, including CDR, where orbital debris mitigation plans are finalized, has not yet begun to run. Doc #:E€ 1:143378.1

P A U L , W E I S S . R I F K I N D ,W H A R T O N a G A R R I S O N LLP Ms. Marlene H. Dortch 2 to employ storage orbit for disposal of the SkyBridge I1 spacecraft. Therefore, a casualty risk assessment for atmospheric re-entry is not relevant or required. Updated information on the SkyBridge II orbital debris mitigation plan will be filed in accordance with the requirements of the Second Report and Order in the Commission’s proceeding on Mitigation of Orbital D e b r i ~ . ~ Respectf ub submittedA Diane C. Gaylor Attorneys for SkyBridge I1 L.L.C. cc: Tom Tycz Jennifer Gilsenan Sankar Persaud 3 Mitigation of Orbital Debris, Second Report and Order, IB Docket No. 02-54 (FCC 04-130, June 21, 2004). The deadline for filing updated orbital debris mitigation plans depends on the date of publication of the Second Report and Order in the Federal Register. Such publication has not yet occurred. Doc #:DC1:143378.1


Document Created: 2004-07-29 14:36:56
Document Modified: 2004-07-29 14:36:56
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