Attachment letter

letter

LETTER submitted by Lockheed Martin

letter

2004-10-29

This document pretains to SAT-LOA-19990427-00045 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA1999042700045_405626

@ LEVENTHAL SENTER & LERMAN PLC October 29, 2004 Co asons ; Fleceived cwe. sumorescomcon NOV 0 4 2004 omciny cto en BY HAND DELIVERY: Poley Branch InternationalBureay Mr. Thomas S. Tyez Chief, Satellte Division Interational Bureau Federal Communications Commission 445 12® Street, S.W. Washington, DC 20045 Re: Lockheed Martin Corporation, Application for Authority to Launch and Operate Geostationary Satellites in the Radionavigation—Satellte Service at the 79° W.L., 71° E.L.and 131.8° E.L. Orbital Locations (File Nos. SAT—LOA—19990427—00045, —00049, and 00050; SAT—AMD—20030730—00149, —00152, and ~00153; SAT« AMD—20040721—00144, 00145 —00146 Dear Mr. Tyer: This lete is submitted on behalf of Lockheed Martin Corporation ("Lockheed Martin®), the applicant in the above—reference proceedings for authority to establish satelltes that would operate in the Radionavigation—Satellite Service ("RNSS®) from the 79° W.L., 71°E.L. and 1318 EL orbital locations. In this leter, LockheedMartin, by itattomeys, responds to the Satelite Division‘s October 8, 2004 letter equesting additional information on Lockheed Martin‘s plans for tperformance oftracking,telemetry and command (‘TT&C") functions for the three spacecraft. See Letter dated October 8, 2004, from Thomas S. Tycz, Chief, Satelite Division, to Jennifer Warren, Senior Director, Trade and Regulatory Affairs, Lockheed Martin Corp., at 1—2 ("October 8 Letter®) The Satellite Division‘s October 8 Lerter asks Lockheed Martin to provide: 1. Information regarding faciliies by which Lockheed Martin will execute control operations for ts proposed Asia/Pacific region satellis (ie., the satelites at 71° EL. and 131.8° EL),including,for exampl, "information regarding the locations of the primary and back—up TT&C stations [at] which TT&C functions will be carried out for ts proposed satellites, including whether these TT&C stations will be located on United States tertory in the Asia@Pacific region." October 8 Letter at1.

Mr. Thomas S. Tyez October 29, 2004 Page—2— 2. A description ofthe procedure Lockheed Martin would execute at Asia/Pacific region TT&C stations located outside U.S. territory "in the event that Lockheed [Martin] was required to shut down its RNSS satelites at the 71° EL. and 131.8°.L. orbital locations(.)"including an explanation of whether "Lockheed Martin will rtain the abilty, through actions initated using its United States facilites, and without any third—party intervention, to cease operations ofits proposed satellites." 14. at 2. 3. Information regarding the locations of the primary and back—up TT&C stations located in the United States for its proposed satellite at 79" W.L."" 1d. In its above—referenced applications, Lockheed Martin proposes toestablish dedicated satelltes atthe three orbital locations that are the subject of the October 8 Letter. In the case of the U.S.—visible satelite at 79° W.L., the expectation stated in the original application — .e.,that there will be a primary and a back—up TT&C station located in the U.S. o control and monitor the satelite — is current. In other words, it is likely — but not assured — that Lockheed Martin would co—locate both the primary and backeup TT&C facilites for this satellte with the ground uplink stations through which it will communicate with the two RNSS satellites (at 107.3° W.L. and 133° W.Lthat are in the ltter stages of construction now and slated for launch in 2005. See Lockheed Martin Corporation Applications, File Nos. SAT—AMD—20040203—00011 and SAT—AMD— 20040205—00012, er seq. Forthe AsiafPacific region spacecraft, the expectation stated in the original application —«., that there will be a primary and a back—up TT&C station located in the AsiafPacific region to control and monitor the satelite — also remains current. Lockheed Martin urges the Commission to recognize that because the applications for the three subject spacecraft remain at the "pending" stage with implementation plans that have yet to be finalized, Lockheed Martin is not yet able to provide more specific information regarding the locations of the primary and back—up TT&C stations that will be used to ransmit and receive TT&C signals from the three satellites in question. In each case, the answer to this question will necessarily depend on such factors as the identty of the anchor tenant/customer for the respective satelltes and the service objectives and performance requirements those customers and other significant users of the future spacecraft convey to Lockheed Martin. Lockheed Martin does not presently have any authorizations, applications for authorizations, or agreements for ground station facilties —either in the U.3. (including U.S. Possessions) or elsewhere — in connection with the contemplated TT&C functions for the three subject spacecraft. Lockheed Martin also continues to explore, with respect to each ofthe three proposed satellite networks, the possibility that ts proposed RNSS payload could be hosted on a satellte that is being developed for operation in another satellite service by a putative U.S.—licensed or non—U..—licensed operator. _In short,the three pending applications for Lockheed Martin RNSS satellites at 71° EL., 131.8° EL., and 79° W.Lare thus ata very different stage of implementation than are the two "fast—tracked applications for RNSS satelltes at 107.3° WL. and 133° W.L. that are under construction with anticipated launch in 2005.

> Mr. Thomas S. Tyer October 29, 2004 Page—3— Through engagement with staff, Lockheed Martin fully understands that U.S—Llcensed operators of satelltes that either do not serve the United States (due to orbital location/coverage considerations) orthat are comprised of a service—specific payload thatis hosted on a spacecraft that is established and physically controlled by another administration must possess the ability, through actions initited using U.S. faciities and without any third—party intervention, to cease operation of the satellite or payload. To the extent that Lockheed Martin ultimately may sek to locate the respective primary and/or back—up TT&C stations for any of the three RNSS satellites that are the subject of the October 8 Letter outside of the United States or its Possessions, Lockheed Martin emphasizes thatit will always possess the direct and unilateral ability t tim off the satelltes‘ TT&C and RNSS payloads from a location in the United States, and that it will establish a mechanism by which it can exercise this irect and unilateral ability. Purthermore, if Lockheed Martin seeks in the future to pursue a hosted payload scenario similar to the approach it is pursuing for its RNSS network at the 107.3° W.L. orbital location for one or more of these RNSS networks,it will establish a mechanism substantially similar to the one it recently established for tat situation. Lockheed Martin will apprise the Commission ofrelevant developments in its plans for TT&C facilies for the RNSS satelites at 71° E.L. 131.8° EL., and 79° W.L. as they occur. Lockheed Martin truststhatits above—expressed intentions regarding the prospect of the use of extra—U.3. TT&C facilities for control of RNSS satellites in the AsiaPacific region are sufficient at this early stage of the satelite implementation process. Should the Satellite Division have any further questions or require any additional information on this matter, please do not hesitate to contact the undersigned. Artorneifor Lockheed Martin Corporation Ms. Jennifer Warren Senior Director Trade & Regulatory Affairs Lockheed Martin Corporation 1550 Crystal Drive, Suite 400 Artington, VA 22202 ces Ms. Andrea Kelly Ms. Jabin Vahora Mr. Karl Kensinger mus


Document Created: 2004-11-18 14:30:15
Document Modified: 2004-11-18 14:30:15
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC