Attachment 2003Supplemental Orb

2003Supplemental Orb

SUBMISSION FOR THE RECORD submitted by ICO

Supplemental Orbital Debris

2003-01-29

This document pretains to SAT-LOI-19970926-00163 for Letter of Intent on a Satellite Space Stations filing.

IBFS_SATLOI1997092600163_1071891

MorRrIsoN & FOERSTER ut ORlGlNAL SAN FRANCISCO ATTORNEYS AT LAW NEW YORK LOS ANGELES WASHINGTON, D.C. DENVER 2000 PENNSYLVANIA AVENUE, NW NORTHERN VIRGINIA PALO ALTO WASHINGTON, D.C. 20006—1888 LONDON WALNUT CREEK TELEPHONE (202) 887—1500 BRUSSELS SACRAMENTO TELEFACSIMILE (202) 887—0763 BEIJING CENTURY CITY HONG KONG ORANGE COUNTY SINGAPORE SAN DIEGO TOKYO January 29, 2003 Writer‘s Direct Contact (202) 887—1510 R EC E !VE l}Tritt@mofo.com By Hand Delivery Ms. Marlene H. Dortch JAN 2 9 2003 Secretary FEDERAL COMMUNICATIONS cowmmn Federal Communications Commission OFFICE OF THE SECRETARY o The Porisis Oceived 445 12®" Street, S.W., Room TW—A325 Fikp &8 9y Washington, D.C. 20554 ‘003 Re: ICO Satellite Services G.P. lmenmrg,wa Supplemental Orbital Debris Mitigation Statement File No. 188—SAT—LOI—97; IBFS Nos. SAT—LOI—19970926—00163 et al. Dear Ms. Dortch: Pursuant to Paragraph 22 of the order reserving 2 GHz mobile satellite service spectrum for the predecessor—in—interest of ICO Satellite Services G.P. ("ICO®"),‘ ICO submits this supplemental information regarding mitigation of orbital debris. The ICO LOI Order required ICO to "provid[e] greater specificity regarding the range of storage orbit parameters selected for disposal ofits satellites.""" ICO believes that it provided sufficient information in its orbital debris mitigation statement, which specified that each satellite "will be maneuvered into a storage orbit above its operational orbit" and "[i]n this storage orbit, the satellite will not interfere with future space operations."" ICO nonetheless supplements its \See ICO Services Limited, 16 FCC Red 13762, 13770—71 « 22 (IB/OET 2001) ("ICO LOI Order"). , * Id. > See Second Amendment to ICO Services Limited Letter of Intent, App. G, at 10 (Nov. 3, 2000). Under Section 6—2(b) of the National Aeronautics & Space Administration/Department of Defense Guidelines regarding assessment procedures for limiting orbital debris, disposal for final mission orbits with perigee altitudes above low earth orbit ("LEO") at 2,000 kilometers may be accomplished by maneuvering to a storage orbit anywhere between LEO and geostationary earth orbit. See Guidelines and Assessment Procedures for Limiting Orbital Debris, NSS 1740.14, § 6—2(b) (Aug. 1995) ("NASA/DoD Guidelines"). Based on Figure 6—1 of the NASA/DoD Guidelines, ICO‘s six—hour MEO may be considered as a "Low— Altitude Storage Orbit" (i.e., an orbit at least 500 kilometers above LEO). Thus, ICO‘s plan to move each

MorrIsON & FOERSTER iur Ms. Marlene H. Dortch January 29, 2003 Page Two debris mitigation statement to specify that it will boost each satellite at the end of its operational life to a storage orbit of approximately 10,690 kilometers, or 300 kilometers above the nominal ICO MEO orbit. The ICO LOI Order also notes that ICO and other 2 GHz MSS operators should "develop appropriate operational plans and procedures to minimize the probability of collision with large, known objects during satellite orbital lifetime."* According to the NASA/DoD Guidelines, the probability of collision with large, known objects for spacecraft in medium earth orbit ("MEO"), such as ICO‘s six—hour orbit at 10,390 kilometers, is zero." Under Section 5—1 of the NASA/DoD Guidelines, when the probability of collision with large, known objects is less than 0.001, the intent of the guidelines has been met. It is unclear whether the ICO LOI Order requires ICO specifically to address plans to minimize the probability of collision with large, known objects, particularly where that probability is zero. Nonetheless, in an abundance of caution, ICO supplements its debris mitigation statement to specify that it will consider maintaining an on—going situational awareness capability, with a view to providing adequate and timely warning of the risk of collision posed by tracked objects in space intersecting ICO‘s orbit, to the extent that appropriate information (i.e., orbit ephemeris data) is available. If necessary, satellite station—keeping maneuvers will be used to minimize the possibility of collision by avoiding intersecting orbits with large, known objects during the lifetime of ICO satellites. Because the risk of collision between ICO spacecraft and large, known objects is virtually non—existent, ICO does not anticipate any need to conduct avoidance maneuvers. Very truly yours, % Z/% Cheryl A. Tritt Counsel to ICO Satellite Services G.P. satellite just above MEO at the end of its operational life is in full compliance with the NASA/DoD Guidelines. * See ICO LOI Order, 16 FCC Red at 13770 « 22 ° Specifically, Section 5—1 (Assessment of Debris Generated by On—Orbit Collisions) of the NASA/DoD Guidelines provides that the probability, P, of an MEO space system colliding with an intact structure or large debris object during its mission life is zero. The instructions for computing this probability specifies that the orbital debris flux, one of the multiplicative terms in the equation for P, is taken to be zero for altitudes above 2000 kilometers. de—342796


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