Attachment letter

letter

LETTER submitted by IB, FCC

letter

2007-04-27

This document pretains to SAT-LOA-20070314-00051 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2007031400051_563372

Federal Communications Commission Washington, DC 20554 International Bureau April 27, 2007 Elizabeth R. Park. Latham & Watkins LLP 555 Eleventh Street, NW, Suite 100 Washington, DC 20004—1304 Re: ViaSat, Inc. Applications for Launch and Operating Authority for Satellites Operating in the Ka—Band Fixed Satellite Service, File Nos. SAT—LOA—20070209—00028, Call Sign $2732, and SAT—LOA—20070314—00051, Call Sign $2737 Dear Ms. Park: This letter requests additional information regarding the above—captioned applications ("Applications") that ViaSat, Inc. ("ViaSat") filed on February 9 and March 14, 2007. The Applications are substantially similar and request that the Commussion grant launch and operation authority for two new Ka— band Fixed Satellite Service ("FSS") satellites to be located at the 115.2° W.L. (file no. SAT—LOA— 20070209—00028) and 77.3° W.L. (file no. SAT—LOA—20070314—00051) orbital locations. Prior to further processing of the Applications, we seek supplemental information regarding an aspect of the orbital debris mitigation/end—of—life operations statements that ViaSat has provided. In the Appendix A, Technical Annex, of each of the Applications, ViaSat says that "[alt end—of—life and once the satellite has been placed into its final disposal orbit, all on—board sources of stored energy will be depleted or secured, and the batteries will be discharged."‘ Section 25.114(d)(14)(ii) of the Commission‘s rules sets forth an applicant‘s reporting requirements regarding the assessment and probability of accidental explosions. Specifically, the rule requires: [a] statement that the space station operator has assessed and limited the probability of accidental explosions during and after completion of mission operations. This statement must include a demonstration that debris generation will not result from the conversion of energy sources on board the spacecraft into energy that fragments the spacecraft. Energy sources include chemical, pressure, and kinetic energy. This demonstration should address whether stored energy will be removed at the spacecraft‘s end oflife, by depleting residual fuel and leaving allfuel line valves open, venting any pressurized system, leaving all batteries in a permanent discharge state, and removing any remaining source ofstored energy, or through other equivalent procedures specifically disclosed in the application. . . ? Please confirm that ViaSat‘s statement that "all on—board sources of stored energy will be depleted or secured" is an indication that it will remove the spacecrafts‘ stored energy by depleting residual fuel and leaving all fuel line valves open, venting any pressurized system, leaving all batteries in a permanent ‘File No. SAT—LOA—20070209—00028, Appendix A, Technical Annex, Sec. 15.2, p. 19 and File No. SAT—LOA— 20070314—00051, Appendix A, Technical Annex, Sec. 15.2, p. 19. > 47 C.F.R. § 25.114(d)(14)(ii) (emphasis added).

discharge state, and removing any remaining source of stored energy. Alternatively, if Viasat is relying on what it believes to be "other equivalent procedures," please submit a detailed description of the procedures that will be relied on, as well as an analysis of the equivalency of these measures to those identified in the rule. We also note that Section 25.283(c) of the Commission‘s rules sets forth a requirement to vent fuel, relieve pressure vessels, and discharge batteries at the spacecraft‘s end oflife." Please provide the requested confirmation regarding ViaSat‘s orbital debris mitigation statements to the Secretary before May 15, 2007 with a courtesy copy to both Kal Krautkramer and Arthur Lechtman of my staff. Please contact either Mr. Krautkramer or Mr. Lechtman at (202) 418—0719 if you have any questions. Sincerely, Robert G. Nelson Chief, Satellite Division cc: Keven Lippert ViaSat, Inc. 6155 El Camino Real Carlsbad, CA 92009 * Specifically, this section provides that "[uJpon completion of any relocation authorized by paragraph (b) of this section, or any relocation at end—of—life specified in an authorization, or upon a spacecraft otherwise completing its authorized mission, a space station licensee shall ensure, unless prevented by technical failures beyond its control, that all stored energy sources on board the satellite are discharged, by venting excess propellant, discharging batteries, relieving pressure vessels, and other appropriate measures." 47 C.F.R. § 25.283(c). 2


Document Created: 2007-04-27 14:24:32
Document Modified: 2007-04-27 14:24:32
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