Attachment collision

collision

SUBMISSION FOR THE RECORD submitted by Rainbow

collision

2004-04-13

This document pretains to SAT-LOA-20030827-00173 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2003082700173_368842

                                                                          Received
                                 Rainbow DBS Company LLC
                               Statement Regarding Condition 8            APR 1 3 2004
                                   For its Ka-band Licenses
                                                                          PdloYBranctr
                                                                       l n t e m t l o e-treau
                                                                                       ~
Re:     SAT-LOA-2 0030827-00172
        SAT-LOA-20030827-00248
        SAT-LOA-20030827-00175
        SAT-LOA-20030827-00249
        SAT-LOA-20030827-00173

k       Introduction
        On November 21,2003, Rainbow DBS Company LLC (Rainbow) was granted
authorizationsby the FCC to launch and operate four satellites in systems that would use
Ka-band frequencies. These satellites would be at 62"WL, 129"WL, 71"WL and 119"WL
in the GSO. On January 5, 2004, Rainbow was granted authorization for a fifth satellite
(at 77"WL) to employ Ka-band frequencies. Condition 8 of each of those authorizations
requires Rainbow to submit a statement regarding measures that would be taken to
prevent in-orbit collisions with other satellites in the GSO. Specifically, the Condition
requires Rainbow to consider methods for the avoidance of collisions with satellites:
                Located at, or planned to be located at the Rainbow
                assigned orbit locations, or assigned in the vicinity of the
                Rainbow locations such that the stationkeeping volume of
                the respective satellites might overlap.

B.      The In-Orbit Situation
        In order to determine the satellites that need to be considered, Rainbow examined
the lists' of FCC licensed satellite systems as well as those under consideration by the
FCC. In addition, Rainbow examined the online database of the ITU-R2 and reviewed
the expected launch manifest of the 2003 Commercial Space Transportation Forecast of
the Federal Aviation Administration (May 2003).




' See IBFS Reports at www.fcc.gov.
 See "SNS on-line" at www.itu.int.


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         Based on these sources, the table below was prepared.
Rainbow Location           In-Orbit Satellites           Possible Future InOrbit Satellites

62"WL                     None                           62"WL           TDRS- 62W

129"WL                     128.98"WL Telesat 7            129"WL         LM-RPS-129W3
                                                          129"WL         CAN-BSS- 129

71"WL                     None                           7 1OWL          F-SAT-12 KA4

119"WL                     118.71"WL ANIK El             118.7"WL        CANSATKA-5X5
                           118.92"WL Echostar 7          1 18.8"WL       CANSAT- 14
                           119.07"WL Echostar 5          119"WL          USABSN- 1I
                           I I9.18"WL DirecTV 5          119"WL          Echostar EX- 1
                                                         119"WL          DirecTV 7.S
                                                         119"WL          PAS-ENDEAVOR- 119W6

77"WL                     None                           77"WL          Spectrum ~ s t 1 - 0 ~
                                                         77"WL          Telestar 4 (applied for on
                                                                         11/1/99)
                                                         77"WL          GIFTS-IOMI-1

         In addition to the satellites identified above, there are several nonU.S., in-orbit
satellites that are outside the "trigger" of the license condition, but are sufficiently close
to the Rainbow orbit locations to pose an in-orbit collision threat if they do not adhere to
the ITU stationkeeping limit of *O. 1". Rainbow will monitor the stationkeeping
performance of these satellites during the construction program of its satellites. If it
appears that problems might occur, the coordination program (outlined below) will be
extended to these satellites.
C.      Avoidance Methods
        Based upon its experience with Echostar regarding 6 1.5"WL, Rainbow expects to
be able to achieve station keeping, coordination agreements with the identified in-orbit
satellites. This activity will start approximately two years prior to the expected launch of
each Rainbow satellite. In the interim time period, Rainbow will periodically monitor the

 The ITU-R database lists this satellite at 129"WL but the FCC Pending Application List includes both the
applications for launch authority (4127199) and its amendment (7/30/03) as requesting 125"WL.
 And other filings by France in the ITU-R database at the same location.
 And several additional ITU-R filings at this location by Canada for differing frequencies.
 And one additional filing by Australia in the ITU-R database.
'FCC Application of 9/26/97 for V-band satellite.


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FCC and ITU-R databases and the FAA launch forecast to determine if additional
satellites will be launched that will create a potential in-orbit collision threat and
therefore require additional coordinations. To the extent any coordination arrangements
would require any changes (offsets) to Rainbow’s assigned orbital locations, Rainbow
will seek any necessary modifications to its authorizations from the Commission.
       In addition, Rainbow is concerned about the potential collision threat posed by
uncontrolled, inert objects that are in, or move through the equatorial GSO. Thus,
Rainbow intends to conduct discussions with entities that offer a “warning” service for
such threats. It is also suggested that the Commission establish a liaison link with NTIA
regarding U.S. Government satellites that appear to pose an in-orbit collision threat to
FCC-licensed satellites.




                                                                               Melvin Barmat
                                                                              January 7,2004
                                                                                2024676400




R-LCBSTATEMENT




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Document Created: 2004-04-13 15:24:03
Document Modified: 2004-04-13 15:24:03

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