Attachment response

response

REPLY submitted by Lockheed Martin

response

2005-02-10

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

IBFS_SATLOA1999042700045_417990

nnupl 16 ATE 0 UUT IGAIE LEVENTHAL SENTER & LERMAN ruLC 15 2005 February 10, 2005 smm D. mamen cum o sicon somoreacomcon RECEIVED — FoG mesrim aamas BY HAND DELIVERY: FEB 1 0 2005 Mr. Thomas S. Tyez FodelCommunicaton Comnissin Chiet, Satelite Division Bieau/ Ofi . International Bureau Federal Communications Commission 445 Twelfth Street, S.W. Washington, DC 20554 Re: Applications of Lockheed Martin Corporation for Authority to Launch and Operate Geostationary Orbit Satellites in the Radionavigation— Satellite Service (File Nos. SAT—LOA—19990427—00045, erseg., Call Sign $2370; SAT—LOA—19990427—00046, er seq., Call Sign S2371; SAT—LOA— 19990427—00047, e seq., Call Sign 2372; SAT—L.OA—19990427—00049, er seq., Call Sign $2374; and SAT—LOA—19990427—00050, r seq., Call Sign: sras Dear Mr. Tyer: By this letter, Lockheed Martin Corporation ("Lockheed Martin®), an applicant for authority to establish a global radionavigation—satellite service (‘RNSS®)system called the Regional Positioning System ("RPS®) from the 107.3° W.L., 133° W.L, 79° W.L.71° E.L. and 131.8° EL. orbital locations, responds the Satelite Division‘s January 26, 2005 letter to Lockheed Martin with regard to the above—referenced applications. In ts January 26 Letter,the Satellite Division instructed Lockheed Martin to amendits above—referenced applications to include two—degree interference analyses with respect to the fixed—satellite service ("FSS") frequency requeststhat are included for feeder uplinks (i the case of the RPS applications for 107.3° W.L. and 133° W.L..) or both feeder uplinks and TT&C uses (in tcase of the remaining three RPS applications). On this date, Lockheed Martin is amending each of the five RPS pending RPS applications, on FCC Form 312, to include the requested information. In the January 26 Leter, the Satelite Division also reminded Lockheed Martin that after ts applications and most recent substantive amendments were filed, the Commission reached a decision to amend Part 25 ofits Rules to include provisions concerning the mitigation of orbital debris. See January 26 Letr, at 2 (citing Mirigation ofOrbital Debris, Second Report and Order, IB Docket No. 02—54, 19 FCC Red 11567 (2004)). It indicated that in view of the fact that the rule changes are expected to become effective in the near future, Lockheed Martin may wish to consider providing this information in connection with its amendments. January 26 Letter, at2.

Letter to Thomas Tycz & February 10, 2005 Page —2— As a satellite manufacturer as well as a proposed satellite operator, Lockheed Martin has a keen interest in the status of the Commission‘s rules and policies on the mitigation of orbital debris, and is a strong supporter of measures that strike the appropriate balance between ensuring the economical use of space by commercial satelites and the likelihood that the spacecraft Lockheed Martin builds and/or uses will be able to operate safely for the duration of their useful lifetimes. The five RPS spacecraftfll ito two general categories, as the Commission is aware: (1) the RPS spacecraft at 133° W.L. and 107.3° W.L., which are hosted payloads on FSS satelites being Iaunched this year by PanAmSat Corp. and Telesat Canada Corporation; and (2) the RPS spacecraft at 79° W.L, 71° EL.and 131.8° EL that Lockheed Martin currently is proposing to build, launch, and operate on its own. Thtwo eategories have some very different considerations. Lockheed Martin appreciates the Satellte Division‘s bringing the impending effectiveness of the rules and policies on orbital debris mitigation to its attention. It has considered providing the information in comnection with ts FCC Form 312 amendments containing the two—degree interference analyses for the FSS frequencies on RPS. With respect to both categories of RPS space stations described above, however, Lockheed Martin has determined that it is not currently in a position to provide the information to be required, and will, if necessary, await the issuance of a public notice calling for such information to be provided. See January 26 Letter, at 2. With respect to the payloads that are being hosted by PanAmSat and Telesat, respectively, Lockheed Martin notes that the post—mission disposal obligations for the payloads to be licensed to Lockheed Martin fll o the hosts. The RPS satellte at 133° W.L.. is being hosted by PanAmSat on the Galaxy 15 satellte that will be launched in a matter of months. The Commission authorized the satellte by grant stamp (with conditions) on August 11, 2004, subject to a condition relating to one element of the new rules on orbital debris mitigation.. PanAmSat subsequently filed a letter with the Commission that satified the condition. See Letter dated October 1, 2004, from J. Godles, Counsel for PanAmSat,to Secretary, Federal Communications Commission, in File No. SAT—LOA— 19991207—00119, erseg, Call Sign $2387) (providing information on potential for in—orbit collisions). The RNSS payload that Lockheed Martin is adding to the Galaxy 15 satellte will have no impact whatsoever on the orbital debris potentials of the Galaxy 15 satellte —either pre—mission, during the mission, or post—mission. The design ofthe RPS payload is at the same level of engineering as the PanAmSat Galaxy 15 spacecraft, and thus poses no increased risk of debris, either through designed releases (of which there are none since the Lockheed Martin payload itself contains no deployable elements) or through random collision and inadvertent release, explosion of fuel or pressurized vessels (as the RPS payload contains no propulsion fuel, oxidizer, pressurant, tanks, piping or other pressurized vessels which are the basis for potential explosions). There also is no risk of orbital debris from the RPS payload ue to collisions in orbit rising, station keeping maneuvers, and end of ife disposal, all of which are the sole responsibility of the host spacecraft operator. In short,the Lockheed Martin RPS payload on Galaxy 15 is bounded by the existing Galaxy 15 debris mitigation plan that the Commission favorably considered when it lcensed PanAmSat to launch and operate Galaxy 15 last summer.

Letter t Thomas Tycz 4 February 10, 2005 Page—3 — "The situation with Telesat and the Anik FIR satellt is similar. Although Telesat has not applied tothe Commission for authority to operate Anik FIR in the United States as of yet, Telesat has told the Commission that its future generation of Telesatsatelites (which includes the Anik FIR. spaceeraft that will host Lockheed Martin‘s RPS payload at 107.3° W.Lwill be designed to produce no in—orbit debris, and that the company‘s operational planning includes provision for de— orbiting its satellites at the end oftheir useful lives by raising the satelite orbit perigee and turning off all RP radiation sources. See Comments of Telesat Canada in TB Docket No. 02—54, Mitigation ofOrbital Debris, at 2:3 (filed July 17, 2002). Telesat goes into further detail on the measures it uses to minimize debris generated by accidental explosions and its proactive stance on avoidance of in—orbit collisions. 14. 5—7. ‘To the extent that Telesat may seek to serve the U.S. market in the FSS via Anik FIR, it will have to comply with the requirements of the Commission‘s orbital debris mitigation rules — something it can do by showing that the satelite‘s debris mitigation plans are subject to direct and effective regulatory oversight by Industry Canada (the Anik FIR system‘s nationallcensing authority). Lockheed Martin will consult with Telesat on the orbital debris mitigation situation, but notes for now that as is the case with the RPS payload on Galaxy 15, the design of the RPS payload is at the same level of engincering as the Telesat Anik FIR spacecraft, and thus poses no increased risk of debris, either through designed releases (of which there are none since the Lockheed Martin payload itself contains no deployable elements) orthrough random collision and inadvertent release, explosion offue! or pressurized vessels (as the RPS payload contains no propulsion fuel, oxidizer, pressurant,tanks, piping or other pressurized vessels which are the basis for potential explosions). There also is no risk of orbital debris from the RPS payload due t collisions in orbit raising, station keeping mancuvers, and end of ife disposal, all of which are the sole responsibility of Telesat as the host spacecraft operator. As for the Lockheed Martin RPS spacecraft at 71° E.L., 131.8° E.L., and 79° W.L., Lockheed Martin is stllin the process of developing its orbital debris mitigation plans. It will provide the details of those plans to the Commission no laterthan the date on which the Commission directs applicants with applications that were pending at the time the Second Report and Order in IB Docket No. 02—54 was adopted to file plans compliant with the new rule provisions. Please direct any questions concerning the status of Lockheed Martin‘s orbital debris mitigation plans for the five space stations of the RPS system to the undersigned. . Barich ffor Lockheed Martin Corporation Ms. Jabin Vahora, FCC Ms. Jennifer Warren, Senior Director, Trade & Regulatory Affairs, Lockheed Martin


Document Created: 2005-02-16 13:46:11
Document Modified: 2005-02-16 13:46:11
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