Attachment response

response

SUBMISSION FOR THE RECORD submitted by SkyBridge LLC

response

2004-11-10

This document pretains to SAT-LOA-19970228-00021 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1997022800021_407909

PAUL, WEISS, RIFKIND. whaRrTon 8 GARRISON LLP
                       wasumoron. be soose—seea


serrner 1. ouson
                                                             RECEIVED
tamceintonstenisn con                                           NoV 1 0 2004                 negediuent
                                                          Fadual WM
                                                                 pols.                       M   ore
                                                                                             Meeand
                                                                   nov 1 9 2004              Regite um
                                               November 10, 2004                             neomst arn masess

                                                                 ipntemamimet                io.
          By Hand
           Ms. Marlene H. Dortch
           Secretary                                                    font   0
           Federal Communications Commission
           445 12th St, S.W.
           Washington, DC 20554
                   Re:    Orbital Debris Mitigation; SkyBridge LL.C., Application
                          for Authority to Launch and Operate the SkyBridge
                          Satelite System — File Nos. SAT—LOA—19970228—00021;
                          SAT—AMD—19970703—00058; SAT—AMD—19980630—00056;
                          SAT—AMD—19990108—00004; SAT—AMD—20020917—00167;
                          SAT—AMD—20040719—00135; Call Sign $2241.
           Dear Ms. Dortch:

                            This leter is written on behalf of SkyBridge LL C. ("SkyBridge"),in
           response to a letter fom Thomas Tyez to the undersigned, dated October 1, 2004 (the
           "FCC Letter®)." The FCC Letter requested that SkyBridge provide certain additional
           details on its orbital debris mitigation plan for the SkyBridge satellite system.
           SkyBridge provides the requested information below.
                          The Commission requested a statement as to whether SkyBridge has
           assessed and limited the probability of ts satelltes becoming a source ofdebris by
           collision with large debris or other functioning satelites. As noted in its application,
           SkyBridge has every economic incentive to ensure the robustness of its spacecrat

               Leter from Thomas 5. Tyez, Chief, Satellte Diviion to Jefi Olson, File Nos.SAT—LOA«
               1997022s.00021; SAT—AMD—19970703—00058; SAT—AMD19980630—00086; SAT—AMD—
               19990108—00004; SAT—AMD—20020917.00167; SAT—AMD20040719.00138, dared October 1,
               204. Seealso Letter from Jefi H. Olson o Marlene K. Dorch,Secretuy,dated October 14,
               2004File Nos.SAT—LOA—19970228:—00021, t al; Lettr from Jetiey H. Olsn to Marlene H
               Dortch, Secretary,dated October 21, 2004, ile Nos. SAT—LOA—19970228—00021, eral.


           mersorsoss


rauL. weiss. RIFKIND. WHARTON 8 CARRISON LLP
     Ms. Marlene H. Dortch


    design to prevent loss of valuable assets." SkyBridge has assessed the risk of collision
    and the design of the satellitesto ensure that the risks of collision with debris or
    operating satellites do not pose an unreasonable risk t the physical integrity and
    operation of is satelltes. Purthermore, as discussed below, SkyBridge plans to
    implement an active monitoring regime that examines the trajectories ofother satelltes
    and objects on an ongoing basis,so that, in the event of a collision threat, emergency
    mancuvers can be employed to avoid that potential collsion. In addition to protecting
    the SkyBridge investment, such measures will also help limit the probability thatits
    satelltes will become a source of debris.
                    SkyBridge knows of no other NGSO system operating satellites
    sufficiently close (faking into account apogee, perigee, inclination, RAAN and
    stationkeeping tolerance) to the SkyBridge orbit (1469.3 km) to pose a systematic threat
    of collision due to overlapping orbital volumes. Noris SkyBridge aware of any such
    proposed NGSO system that is: (1) licensed by the Commission or any other
    administration; (2) the subject of a pending application before the Commission; or (3)
    the subject of an ITU filing and progressing toward implementation. Ifsuch a system
    were to be implemented, SkyBridge would, of course, coordinate its physical operations
    with the operator of such system to avoid any potential collision.
                    Further, in the event of a satellite or other object passing through or near
    the orbit of any SkyBridge satellite, the monitoring procedures noted above will enable
    SkyBridge to avoid a collision. This system works as follows: Two Line Element
    (TLE) data from the NORAD system is obtained twice per week, and propagated one
    week in advance to predict possible collsion scenarios. Whenever a satellteor other
    object is predicted to come closer than 1.5 km from a protected satellite,an alarm is
    generated, so that the potentially affected SkyBridge satellite can be maneuvered out of
    harm‘s way as necessary. Such small maneuvers will not adversely affect the
    operational mission of SkyBridge or other systems. It should be noted that this
    approach currently is employed by the French Centre National d‘Etudes Spatiales
    (CNES) with regard to the Spot satellites.
                   The Commission also requested clarification regarding the tolerance,
    during operational lif of the satellites, o which certain orbital parameters will be
    maintained. These tolerances are summarized in the following table:




    *   SeeSAT—AMD—20020917—00167, Extibt Car$


    perscrioms


rauL, weiss, rirKiND. whaRton 8 CarRISON LUP
     Ms. Marlene H. Dortch



     Orbital Parameter®               Tolerance
     Apogce                            e =20 m, where a is the semi—major x
                                       ae =2 x 10%, where e is eccentricity
     Perigee                           e =20 m, where a is the semi—major axis
                                       se =2 x 103 where e is eccentricity
     Inclination                       8 =15 x 10" deg., where i is inclination
     Right ascension of the            an =1.5 x 10" deg., where 2 is RAAN
     ascending node (RAAN)
     Satclite phasing                 Sa =0.1 deg., where a, the phasing, is ttmue
                                      anomaly difference between two adjacent satellites on
                                      two adjacent planes®

                       In practice, a is the parameter that experiences the greatest variation.
     When the stationkeeping constraintis nearing violation, « is corrected by a maneuver
     modifying the semi—major axis "a‘

        See SAT—AMD—19990108—00004, at A—15—17 fodetils on theSkyBridge constelationorbial
        parmetes
        "Theapogse and perigee aides (, and I respectively)canbe converted to semi—major axis and
        eccentvicity(@ and a respectively),and vice vess, viathe formulas:
               a     (R +R)2 (+ hJ2 +R
               e     (Re RJC +R  heb)Ourtary
        where:
               Ry=   cathradias   6278.14km
               m = apogee adius = R +h,
                   porigee mdios K. +1,
        In the casofhe SkyBridge constelation, hy = by 14893 k: a = 7847.49 kn; and c = 8 x 10(the
        eccentiity is never exactly ero in a realoritalsstem due to the carh‘selipict).
        ‘The toleranci thesame fr both phasing (irue anomalydiference betveen two steliteson the
        same plane (ame RAAN)) and relativephasing(rue anomalydiference between two adjacent
        sateliteson two adjacent planes(diferent RAAN)). The phasingand reativephasing fothe
        Skyridge constelltionare90and 67.5espectively


     mervcriouss


PAUL, weiss. AiFKIND, WHARTON 8 CARRISON LLP
     Ms. Marlene H. Dortch



                    As the Commission noted, SkyBridge has previously indicated that
     SkyBridge will maintain stationkeeping to within 0.1® This tolerance refers
     essentiallyto the tolerance fora, the source ofthe greatest variation, as noted in the
     table above. More precisely,it refers to the condition
       (sa+A0cosi)+A +(2Nsini}" <0.1deg, where Aa = Au, +2 Ae, and Au, is the mean
     and long term periodic evolution of the trie anomaly, and 2 Ae is the short maximal
     amplitude ofthe periodic term evolution of the trie anomaly coming from the
     eccentricity evolution. However, as noted above, in practice the term Aa dominates the
     equation, and leads to the need for orbital correction.

                     If there are any questions regarding this matter, please contact the
     undersigned.
                                                 Respectfully   submitted,




                                                 Diane C. Gaylor
                                                 Artorneysfor ShyBridge LLC.
     ces      Thomas Tycz
              Sankar Persaud
              Karl Kensinger




     *     SeeSAT—AMD—20020017—00167, ExtibitCar


     oerscrsass



Document Created: 2004-11-29 11:39:23
Document Modified: 2004-11-29 11:39:23

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC