Attachment Attach C-Tech. Annex

This document pretains to SAT-LOA-20190807-00072 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2019080700072_1833523

                 Attachment C – Technical Annex
    1. Scope
This Attachment contains additional information regarding the Yet Another Mission (YAM) non-
geostationary (NGSO) satellite constellation required by Section 25.114 and other sections of the Part 25
rules that cannot be entered into the Schedule S online submission system.

    2. General Description (Section 25.114(d)(1))
The YAM-2 NGSO satellite will be the first in a constellation comprised of 10 micro-satellites hosting
various payloads. The YAM satellites will be launched into various orbits based upon available ride-
share opportunities.
YAM-2 customer payloads are as follows.
       a cryocooled hyperspectral imager with a ground sampling distance of 35 km1
       a hyperspectral imager with a ground sampling distance of 90 km
       an Internet of Things (IoT) payload that transmits in the 400.15-401 MHz band and receives in
        the 864-925 MHz band2
            o TX – Beacon
                      400.15 – 401 MHz (programmable in this range)
                      20% TX Duty cycle within 5s frame
                      Turnstile antenna
                      -1.0 dBi antenna gain
                      5 dBW EIRP
            o RX – Data Collection
                      Channels
                             CH1: 865.7 MHz – 1.4 MHz bandwidth
                             CH2: 868.86 MHz – 1.7 MHz bandwidth
                             CH3: 904.0 MHz – 4.0 MHz bandwidth
                             CH4: 922.0 MHz – 4.0 MHz bandwidth
                      Patch RX Antenna (low gain)
                             80-degree half power beamwidth
                             7.1 dBi peak gain
                      Patch Array RX Antenna (high gain)
                             43-degree half power beamwidth
                             11.3 dBi peak gain




1
  Loft Orbital is aware of the requirement to obtain a commercial remote sensing license from the National Oceanic
and Atmospheric Administration (NOAA) for the operations of imaging sensors and intends to comply with all
NOAA regulatory requirements. See 15 C.F.R. Part 960.
2
  The International Telecommunication Union (ITU) filing name is F-SAT-NG-8. This payload will be licensed by
the French administration, and the customer of this payload may separately request U.S. market access. See
Narrative at 5-6 n.6.

                                                         1


All YAM satellites will contain the following payloads.
         a software defined radio that receives and processes L-band data signals in the 1535-1559 MHz
          band from authorized and coordinated Inmarsat plc (Inmarsat) Geostationary (GSO) satellites
         a Globalstar terminal to demonstrate space-to-space communications relayed via the Globalstar
          constellation in the Globalstar-authorized and assigned frequencies, i.e., 1615.65 MHz/1616.88
          MHz and 2489.31 MHz/2490.54 MHz

      3. Spacecraft Overview
The YAM satellites will be manufactured and supplied by Blue Canyon Technologies (BCT) and is based
on their FlexBus platform. The satellite is 3-axis stabilized, achieves beam steering via body steering of
the bus, and does not employ any form of propulsion.
The YAM satellites offer the following common characteristics:
         5-year operational life
         3-axis stabilized
         S-band uplink and downlink telemetry, tracking, and command (TT&C)
         X-band downlink mission data
         Software defined radios (SDR)
         Intersatellite communications with the Globalstar constellation
The spacecraft will operate in the frequencies listed below.
Table 1 Frequencies

                   Usage                             Link Direction                 Spectrum Range
    TT&C Uplink                                 Uplink (Earth-space)           2025-2110 MHz
    TT&C Downlink                               Downlink (space-Earth)         2200-2290 MHz
    Payload Downlink                            Downlink (space-Earth)         8025-8400 MHz

    IoT Beacon                                  Downlink (space-Earth)         400.15–401 MHz
    IoT Data Collection                         Uplink (Earth-space)           864-925 MHz

    L-band Data Signal                          Receive (space-space)          1535-1559 MHz

    Globalstar – Data                           Transmit (space-space)         1613.8-1626.5 MHz
                                                                               (1615.65 MHz/1616.88 MHz
                                                                               center frequencies)
    Globalstar – Data                           Receive (space-space)          2483.5-2495 MHz
                                                                               (2489.31 MHz/2490.54 MHz
                                                                               center frequencies)


      4. Constellation
The YAM constellation will consist of 10 microsatellites in Low Earth Orbit (LEO) deployed between the
425 km to 570 km orbital altitude. The target nominal orbit altitude is 550 km.3 The actual constellation

3
 The YAM-2 satellite will be deployed between 500 km and 550 km at the discretion of the launch service provider.
Loft Orbital has assumed a 550 km deployment orbital altitude for purposes of the orbital debris analysis.

                                                       2


orbital parameters will be defined by available ride-sharing launch opportunities. Most ride-share
opportunities to LEO are for sun-synchronous orbit (SSO), and Loft Orbital seeks authority for such
deployment opportunities. Other ride share opportunities might also be considered, and Loft Orbital will
request the necessary authority for any such deployments at the appropriate time.
Loft Orbital will not seek to launch any satellites to an orbit altitude above 570 km to ensure that each
satellite it launches will meet the FCC’s 6-year de-orbit requirement for satellites authorized under the
FCC’s new small satellite streamlined licensing rules.4 For planning purposes, the constellation data
entered into the Schedule S system includes the following orbital planes:
Table 2 Representative Orbital Parameters

    Orbit ID              Altitude          Inclination            # SV
       1                    550                97.7                  2
       2                    525                97.6                  2
       3                    500                97.4                  2
       4                    475                97.3                  2
       5                    450                97.2                  1
       6                    425                97.1                  1


      5. Telemetry, Tracking and Control (TT&C)
The YAM TT&C sub-system provides for communications during on-station operations, as well as
during spacecraft emergencies. S-band telecommand transmissions are received and S-band telemetry
communications are transmitted by the spacecraft through patch antennas with near-omni directional
patterns during on-station operations and during both transfer orbit and emergency operations.
The S-band telemetry channels have a bandwidth of 2 MHz during normal operations and 200 kHz or 20
kHz during contingency operations. The S-band commanding channels have a bandwidth of 200 kHz
during normal operations and 20 kHz or 2 kHz during contingency operations. TT&C operations will be
conducted from Kongsberg Satellite Services (KSAT) TT&C sites including: Svalbard, Troll, and others
depending upon orbit inclination. The specific S-band telemetry channels and S-band commanding
channel have not yet been selected. As those bands are coordinated, Loft Orbital will work with its
ground station service provider, KSAT, to minimize spectrum overlap with other customers being served
from common locations. Representative channel information is provided below in Table 3 and Table 4.
The TT&C beams have peak gains of 7.4 dBi, and the links are designed for operation down to the -10
dBi contour of the patch antenna. Therefore, pursuant to Section 25.114(c)(4)(vi)(A) of the Commission’s
rules, contours for these beams are provided in the associated GXT files included in Schedule S.
Each YAM satellite will provide a unique telemetry marker both by selecting unique telemetry channels,
in cases where multiple satellites are deployed by the same launch vehicle, and by using a unique satellite
identifier within the telemetry signal to assure that each satellite telemetry stream can be unambiguously
identified.

Contact details for the control center are provided below:

           Address:
           Alexander B. Greenberg
           Co-Founder and Chief Operating Officer

4
    See Attachment A, Narrative § II(A).

                                                     3


        715 Bryant Street, Suite 202
        San Francisco, CA 94118
        Telephone:
        410-382-5050

    6. Frequency Plan
    6.1 S-Band
The following tables list the uplink and downlink S-band channel planned for the YAM constellation.
These channels are not finalized and define representative uplink and downlink S-band channels. This
information is also provided in the accompanying Schedule S but is included here for completeness.
Table 3 S-Band Downlink Frequency Plan


                                          Center
                    Bandwidth            Frequency
 Channel ID           (MHz)                (MHz)     Polarization
   SD1H                 2                  2207.5         R
   SD2H                 2                  2212.5         R
   SD3H                 2                  2217.5         R
   SD4H                 2                  2232.5         R
   SD5H                 2                  2242.5         R
   SD6H                 2                  2252.5         R
   SD7H                 2                  2262.5         R
   SD8H                 2                  2272.5         R
   SD9H                 2                  2287.5         R
   SD1M                0.2                 2207.5         R
   SD2M                0.2                 2212.5         R
   SD3M                0.2                 2217.5         R
   SD4M                0.2                 2232.5         R
   SD5M                0.2                 2242.5         R
   SD6M                0.2                 2252.5         R
   SD7M                0.2                 2262.5         R
   SD8M                0.2                 2272.5         R
   SD9M                0.2                 2287.5         R
   SD1L                 0.02               2207.5         R
   SD2L                 0.02               2212.5         R
   SD3L                 0.02               2217.5         R
   SD4L                 0.02               2232.5         R
   SD5L                 0.02               2242.5         R
   SD6L                 0.02               2252.5         R
   SD7L                 0.02               2262.5         R
   SD8L                 0.02               2272.5         R
   SD9L                 0.02               2287.5         R



                                                     4


The YAM constellation requires approximately 4 unique downlink channels to support planned
operations. Pending coordination with both NTIA and other domestic and international commercial
operators, a subset of channels will be selected. Given guidance from the FCC and NTIA, these channels
will most likely be selected from the following subset:
       2207.5 MHz
       2212.5 MHz
       2217.5 MHz
       2272.5 MHz
       2287.5 MHz
Table 4 S-Band Uplink Frequency Plan


                                        Center
                  Bandwidth            Frequency
Channel ID          (MHz)                (MHz)     Polarization
  SU1H                0.2                 2030          R
  SU2H                0.2                 2040          R
  SU3H                0.2                 2050          R
  SU4H                0.2                 2060          R
  SU5H                0.2                 2070          R
  SU6H                0.2                 2080          R
  SU7H                0.2                 2090          R
  SU8H                0.2                 2100          R
  SU9H                0.2                 2105          R
  SU1M               0.02                 2030          R
  SU2M               0.02                 2040          R
  SU3M               0.02                 2050          R
  SU4M               0.02                 2060          R
  SU5M               0.02                 2070          R
  SU6M               0.02                 2080          R
  SU7M               0.02                 2090          R
  SU8M               0.02                 2100          R
  SU9M               0.02                 2105          R
  SU1L               0.002                2030          R
  SU2L               0.002                2040          R
  SU3L               0.002                2050          R
  SU4L               0.002                2060          R
  SU5L               0.002                2070          R
  SU6L               0.002                2080          R
  SU7L               0.002                2090          R
  SU8L               0.002                2100          R
  SU9L               0.002                2105          R




                                                      5


The fully-deployed YAM constellation will require approximately 4 unique S-band uplink channels to
support planned operations. Pending coordination with both NTIA and other domestic and international
commercial operators, a subset of channels will be selected.

    6.2 X-Band
The following table lists the downlink X-band channel planned for the YAM constellation. This
information is also provided in the accompanying Schedule S but is included here for completeness.
Table 5 X-Band Downlink Frequency Plan


                                          Center
                    Bandwidth            Frequency
 Channel ID           (MHz)                (MHz)     Polarization
   XD1L                 10                  8050          R
   XD2L                 10                  8100          R
   XD3L                 10                  8150          R
   XD4L                 10                  8200          R
   XD5L                 10                  8250          R
   XD6L                 10                  8300          R
   XD7L                 10                  8350          R
   XD8L                 10                  8375          R
   XD1M                  25                 8050          R
   XD2M                  25                 8100          R
   XD3M                  25                 8150          R
   XD4M                  25                 8200          R
   XD5M                  25                 8250          R
   XD6M                  25                 8300          R
   XD7M                  25                 8350          R
   XD8M                  25                 8375          R
   XD1H                  50                 8050          R
   XD2H                  50                 8100          R
   XD3H                  50                 8150          R
   XD4H                  50                 8200          R
   XD5H                  50                 8250          R
   XD6H                  50                 8300          R
   XD7H                  50                 8350          R
   XD8H                  50                 8375          R


    6.3 Globalstar Intersatellite Link
The following tables list the S-band space-space receive channels and the L-band space-space transmit
channels planned for the YAM constellation. The channels listed in the following two tables reflect the
channels used for communications to/from the Globalstar network. This information is also provided in
the accompanying Schedule S but is included here for completeness.



                                                     6


Table 6 Globalstar L-Band Space-Space Transmit Frequency Plan


                                         Center
                     Bandwidth          Frequency
    Channel ID         (MHz)              (MHz)            Polarization
      GT01              1.23             1615.65              LHCP
      GT02              1.23             1616.88              LHCP


Table 7 Globalstar S-Band Space-Space Receive Frequency Plan


                                      Center
                  Bandwidth          Frequency
Channel ID          (MHz)              (MHz)          Polarization
  GR01               1.23             2489.31            LHCP
  GR02               1.23             2490.54            LHCP



      6.4 L-band Data Signals
The following table lists the L-band space-to-space receive channels planned for the YAM constellation.
The receive-only payload concurrently receives GPS navigational signals and MSS L-band data signals in
the 1535-1559 MHz band from authorized and coordinated Inmarsat satellites. The L-band data signal
provides satellite navigation correction data, augmenting the accuracy of Loft Orbital’s location
assessment.5
Table 8 L-Band Data Signal Space-to-Space Receive Frequency Plan


                                          Center
                     Bandwidth          Frequency
    Channel ID         (MHz)              (MHz)            Polarization
      IR01              0.005           1539.9325             RHCP
      IR02              0.005            1545.895             RHCP
      IR03             0.0025           1539.9525             RHCP
      IR04             0.0025             1546.26             RHCP
      IR05              0.005           1539.9125             RHCP
      IR06              0.005           1545.9275             RHCP
      IR07              0.005           1545.9375             RHCP
      IR08             0.0025           1539.9625             RHCP
      IR09             0.0025            1545.835             RHCP
      IR10             0.0025             1545.52             RHCP

5
 See Attachment A, Narrative § I(A). The Commission has authorized earth stations licensed in the United States to
communicate with Inmarsat satellites in this band. See, e.g., Application of Deere & Company, IBFS File No. SES-
LIC-20130422-00340, Exhibit C (filed Mar. 14, 2013); see also Inmarsat, Inc. Request to Streamline Licensing of L-
band Mobile-Satellite Service Terminals Using Inmarsat Satellites as Points of Communication, Order, IBFS File
No. SES-PDR-20080303-00367 (rel. Oct. 21, 2008).

                                                          7


       IR11             0.005        1539.9625           RHCP
       IR12             0.005         1545.875           RHCP


       7. Frequency Tolerance
The frequency tolerance requirements of Section 25.202(e) that the carrier frequency of each space station
transmitter be maintained within 0.002% of the reference frequency will be met.

       8. Out of Band Emissions
The out-of-band emission limits of Section 25.202(f)(1), (2), and (3) will be met.

       9. Frequency Reuse
The YAM constellation does not operate in any frequency bands where Section 25.210(f) applies.

       10.          Cessation of Emissions
All downlink transmissions can be turned on and off by ground telecommand, thereby achieving cessation
of emissions from the satellite, as required by Section 25.207 of the FCC’s rules.

       11.          ITU Filings
The YAM satellite constellation is associated with the USASAT-30J ITU filing. This ITU filing is being
submitted concurrently with this Part 25 FCC filing. The IoT hosted RF payload (operating in the
400.15-401 MHz band and the 864-925 MHz band) is separately authorized by the French
Administration.6

       12.          PFD Analysis
       A. 2200-2290 MHz
The Commission’s rules do not specify a PFD limit in the 2200–2290 MHz band; however, there are PFD
limits specified in rule No. 21.16 of the International Telecommunication Union (ITU) Radio
Regulations. The maximum PFD levels for the YAM-2 transmissions were calculated for the 2200-2290
MHz band and the results are provided in Schedule S and demonstrate that the downlink power flux
density (PFD) levels of the YAM carriers do not exceed the limits specified in rule No. 21.16 of the ITU
Radio Regulations.
Figure 1 below illustrates the S-band downlink PFD values in comparison with the ITU PFD limits in No.
21.16. This figure represents the maximum transmitted EIRP when the satellite is at the orbital altitudes
of 425 km, 500 km, and 550 km. For satellites at lower orbit altitudes the transmitted RF power is
attenuated commensurate with the difference in PFD at Nadir.




6
    See supra note 2.

                                                     8


                       -140.00
                                 0.00   5.00   10.00   15.00   20.00   25.00     30.00       35.00        40.00        45.00       50.00         55.00      60.00    65.00   70.00   75.00   80.00   85.00   90.00


                       -142.00



                       -144.00



                       -146.00
 PFD (dBW/m^2/4 kHz)




                       -148.00



                       -150.00



                       -152.00



                       -154.00



                       -156.00



                       -158.00



                       -160.00
                                                                                                     Earth Station Elevation Angle (degrees)

                                                                           425 km (29 dBm)           500 km (30 dBm)           550 km (31 dBm)           PFD Limit




Figure 1 S-band Downlink PFD Analysis

                         B. 8025-8400 MHz
The Commission’s rules do not specify a PFD limit in the 8025–8400 MHz band; however, there are PFD
limits specified in rule No. 21.16 of the International Telecommunication Union (ITU) Radio
Regulations. The maximum PFD levels for the YAM transmissions were calculated for the 8025–8400
MHz band and the results are provided in Schedule S and demonstrate that the downlink power flux
density (PFD) levels of the YAM-2 carriers do not exceed the limits specified in rule No. 21.16 of the
ITU Radio Regulations.
Figure 2 below illustrates the X-band downlink PFD values in comparison with the ITU PFD limits in
No. 21.16. This figure represents the maximum transmitted EIRP when the satellite is at the orbital
altitudes of 425 km, 500 km, and 550 km.




                                                                                                                  9


                          -135.00
                                    0.00   5.00    10.00   15.00   20.00   25.00     30.00     35.00         40.00      45.00      50.00         55.00    60.00      65.00   70.00   75.00   80.00   85.00   90.00




                          -140.00
    PFD (dBW/m^2/4 kHz)




                          -145.00




                          -150.00




                          -155.00




                          -160.00
                                                                                                       Earth Station Elevation Angle (degrees)

                                                                             425 km (30 dBm)       500 km (30 dBm)              550 km (30 dBm)          PFD Limit



Figure 2 X-band Downlink PFD Analysis

                           C. 8400-8500 MHz

PFD at the surface of the Earth in the 8400-8450 MHz band ITU-R Recommendation SA-1157 specifies a
maximum allowable interference power spectral flux-density level at the earth’s surface of -221
dB(W/Hz) to protect ground receivers in the deep-space research band operating in the 8400-8450 MHz
frequencies.7 Loft Orbital uses a combination of baseband digital filtering and hardware radio frequency
filtering to achieve the ITU recommended protection for its out-of-band emissions in this frequency band.

                           13.                    L-band Interference Analysis

1613.8-1626.5 MHz Frequency Band

Loft Orbital will use a Globalstar terminal to demonstrate space-to-space communications relayed via the
Globalstar constellation in the Globalstar-authorized and assigned frequencies, i.e., 1615.65 MHz/1616.88
MHz. Given an emission bandwidth of 1.23 MHz, the top end of this emission is 1617.495 MHz, which
provides 280 kHz frequency separation between this emission and the bottom end of the shared
Iridium/Globalstar spectrum band: 1617.775-1618.725 MHz.
Loft Orbital’s use of the Globalstar modems on its YAM constellation will not cause harmful interference
into Iridium for the following reasons:
                                   Globalstar uses closed-loop power control to manage PFD at its satellite receiver.
                                   Loft Orbital will only operate in frequencies authorized to Globalstar.
                                   The Globalstar modem safely meets the international standards governing out-of-channel
                                    emissions.



7
    See Recommendation ITU-R SA.1157-1 (Protection criteria for deep-space research) (2006).

                                                                                                                 10


The FCC has previously approved similar usage of Globalstar modems on NGSO satellites.8

    14.          Link Budgets
Link analysis for YAM-2 was conducted for representative carriers in the S-band uplink, S-band
downlink, and X-band downlink bands communicating with a 3.7m KSAT earth station. The results of
the link analysis are shown in Exhibit 1.

    15.          Satellite Antennas
S-band uplink and downlink share a common patch antenna. Antenna pattern cuts for the antenna at the
middle of the S-band uplink spectrum, 2050 MHz, and at the middle of the downlink spectrum band,
2250 MHz, are shown in the following two figures. The peak uplink antenna gain is 6 dBi towards Nadir.
The peak downlink antenna gain is 7.4 dBi towards Nadir. The S-band uplink and downlink beams are
effectively steerable via body steering of the YAM satellites. These beams can be steered to a minimum
elevation angle of 5 degrees anywhere within the satellite footprint. The X-band downlink antenna is a
fixed-steering patch array with maximum gain of 23 dBi. The antenna pattern for the downlink X-band
antenna is illustrated in Figure 5 and a projection of the X-band downlink antenna pattern, pointed
towards Nadir, is illustrated in Figure 6. The X-band downlink beam is effectively steerable via body
steering of the YAM satellites. This beam can be steered to a minimum elevation angle of 5 degrees
anywhere within the satellite footprint. The antenna patterns for the Globalstar space-space link are
illustrated in Figure 7 and Figure 8. The Globalstar RX beam is Zenith pointing and has a maximum gain
of 5.0 dBi and a 3dB beamwidth of 80 degrees. The Globalstar TX beam is Zenith pointing and has a
maximum gain of 4.3 dBi and a 3dB beamwidth of 90 degrees.
The antenna pattern for the reception of the L-band data signals from Inmarsat satellites is illustrated in
Figure 9. The L-band data signal RX beam is Zenith pointing and has a maximum gain of 5.0 dBi and a
3dB beamwidth of 80 degrees.
The antenna projections provided in the accompanying Schedule S reflect the beam projection towards
Nadir from a NGSO satellite with an orbital altitude of 550 km. Due to limitations in the ITU GIMS
software, the beam projections provided are GSO footprints. This approach was taken in order to provide
actual GXT contours rather than just images of projected contours which is the only available option for
NGSO systems.




8
 See, e.g., Stamp Grant, Astro Digital U.S., Inc., IBFS File No. SAT-LOA-20170508-00071 at Frequencies and n.4
(granted in part Aug. 1, 2018).

                                                      11


Figure 3 S-band Uplink TT&C - Antenna Pattern




                                                12


Figure 4 S-band Downlink TT&C - Antenna Pattern




Figure 5 X-band Downlink Mission Data - Antenna Pattern




                                                          13


               -15.00


                        -2
                       -1 0.00
                     -105.00
                     -
   -15.0
        0           -68..00.000
                   -4 0
                  -2.0.00
                        0

                   0.00

                                              .00
                                           -15
                                  -15.00




Figure 6 Projection of Nadir X-band Downlink Beam over the West Coast of Africa




                                                           14


Figure 7 Globalstar Duplex Antenna – L-band Transmit Pattern




Figure 8 Globalstar Duplex Antenna – S-band Receive Pattern




                                                          15


Figure 9 Inmarsat Antenna – L-band Receive Pattern




    16.           Earth Stations
The Loft Orbital YAM constellation will rely upon the KSAT Lite network of 3.7m Earth Stations for S-
band uplink and downlink TT&C communications and X-band downlink payload communications
services. The Characteristics of the KSAT Lite network of 3.7m antennas is summarized in Table 9
below.
Table 9 KSAT Antenna Characteristics

                                                         S-band             X-band
                  Reflector Size                          3.7m                3.7m
                  Downlink Band                      2200-2290 MHz       8025-8400 MHz
                  G/T (20-deg elevation)               12.6 dB/K           26.5 dB/K
                  Polarization                        LHCP/RHCP           LHCP/RHCP
                  Uplink Band                        2025-2110 MHz             NA
                  EIRP                                  44.8 dBW               NA


Loft Orbital will be using two ground stations in the KSat Lite network, SvalSat and TrollSat.


                                                     16


Table 10 KSAT Earth Station Locations Supporting the YAM Constellation

       Name                         Type                            Country              Coordinates
       SvalSat            S band (uplink, downlink)             Norway (Svalbard)   78.2298° N, 15.3965° E
                             X band (downlink)
      TrollSat            S band (uplink, downlink)                  Antarctica      72.0167° S, 2.5333° E
                             X band (downlink)

     17.          Orbital Debris Risk Mitigation Plan
Loft Orbital confirms that the YAM satellites will not undergo any planned release of debris during
their normal operations.9 In addition, all separation and deployment mechanisms, and any other
potential source of debris, will be retained by the spacecraft. Loft Orbital has also assessed the
probability of the space stations becoming sources of debris by collision with small debris or
meteoroids of less than one centimeter in diameter that could cause loss of control and prevent post-
mission disposal. Loft Orbital has taken steps to limit the effects of such collisions through shielding,
the placement of components, and the use of redundant systems.
Loft Orbital has assessed and limited the probability of accidental explosions during and after
completion of mission operations through a failure-mode verification analysis.10 As part of the satellite
manufacturing process, Loft Orbital has taken steps to ensure that debris generation will not result from
the conversion of energy sources on board the satellites into energy that fragments the satellites. All
sources of stored energy onboard the spacecraft will have been depleted or safely contained when no
longer required for mission operations or post-mission disposal.
Loft Orbital has assessed and limited the probability of the space stations becoming a source of debris by
collisions with large debris or other operational spacecraft.11 Loft Orbital will work closely with its
launch providers to ensure that the satellites are deployed in such a way as to minimize the potential for
in-plane collision. This specifically includes minimizing the potential for collision with crewed
spacecraft.
Loft Orbital participates in a sharing agreement with the Combined Space Operations Center (“CSpOC”)
to better coordinate collision avoidance measures and receive conjunction threat reports. Loft Orbital
satellites carry onboard GPS receivers that provide for precise orbital position determination. Loft
Orbital also receives from CSpOC updated two-line element sets, or “TLEs,” which facilitate the
identification and tracking of Loft Orbital satellites. CSpOC will be able to reach Loft Orbital’s satellite
operations team that is accessible twenty-four hours per day/seven days per week to ensure that Loft
Orbital can take immediate action to coordinate collision avoidance measures.
The YAM-2 satellite will not maintain its inclination angle, apogee, perigee, and right ascension of the
ascending node to any specified degrees of accuracy.
Loft Orbital’s detailed Orbital Debris Assessment Report is attached as Attachment D.12 The disclosure
of the orbital deployment parameters, orbital plane inclination, and the orbital period to be used can
assist third parties in identifying potential problems. This information also lends itself to coordination
between Loft Orbital and other operators located in similar orbits.




9
  See 47 C.F.R. § 25.114(d)(14)(i).
10
   See 47 C.F.R. § 25.114(d)(14)(ii).
11
   See 47 C.F.R. § 25.114(d)(14)(iii).
12
   See 47 C.F.R. § 25.114(d)(14)(iv).

                                                          17


CERTIFICATION OF PERSON RESPONSIBLE FOR
PREPARING ENGINEERING INFORMATION
I hereby certify that I am the technically qualified person responsible for preparation of
the engineering information contained in this application, that I am familiar with Part 25 of the
Commission’s rules, that I have either prepared or reviewed the engineering information
submitted in this application and that it is complete and accurate to the best of my knowledge and
belief.


                                                                           /s/
                                                                           _____________________
                                                                           David C Morse, Ph.D.
                                                                           Avaliant, LLC
                                                                           Bellevue, WA USA
                                                                           (425) 246-3080




                                                     18


EXHIBIT 1: YAM LINK BUDGETS




Figure 10 S-Band Uplink - Link Budget - Normal Operations




Figure 11 S-Band Uplink - Link Budget - Contingency Operations




                                                            19


Figure 12 S-Band Downlink - Link Budget - Normal Operations




                                                         20


Figure 13 S-Band Downlink - Link Budget - Contingency Operations




                                                          21


Figure 14 X-Band Downlink - Link Budget




                                          22



Document Created: 2019-08-07 16:55:42
Document Modified: 2019-08-07 16:55:42

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