Attachment letter

letter

LETTER submitted by Skybridge

letter

2004-07-19

This document pretains to SAT-LOA-19971222-00221 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1997122200221_384639

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                        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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