Attachment Tech. Information

This document pretains to SAT-LOI-20190328-00020 for Letter of Intent on a Satellite Space Stations filing.

IBFS_SATLOI2019032800020_1640867

             MYRIOTA NON-GEOSTATIONARY SATELLITE SYSTEM

                                  ATTACHMENT A
                   TECHNICAL INFORMATION TO SUPPLEMENT SCHEDULE S

A.1       SCOPE AND PURPOSE

          This attachment contains the information required under Part 25 of the Commission’s

rules that cannot be fully captured by the associated Schedule S.


A.2       OVERALL DESCRIPTION

          Myriota seeks access to the U.S. market for a non-voice, non-geostationary (“NVNG”)

satellite system of small satellites that will communicate with low-power NVNG modules and

employ advanced signal processing to provide connectivity to a new generation of Internet of

Things (“IoT”) devices. Myriota will deliver global coverage by enabling transmissions directly

from IoT devices to satellites in low-Earth orbit (“LEO”), which removes the need for intervening

ground-based infrastructure. Myriota’s LEO constellation will provide secure, low-cost

communications for IoT devices anywhere on the planet for economical massive scale direct-to-

orbit applications. As described in greater detail below, Myriota’s NVNG system will provide this

capability using a flexible and spectrum-efficient operating approach that will facilitate spectrum

sharing with other authorized systems while still providing robust and innovative services for its

customers.

          Orbital Parameters

          The Myriota non-geostationary orbit (“NGSO”) satellite system consists of 26 satellites

operating in 18 planes at an initial altitude of approximately 600 km. 1 Table A.2-1 below



1
      Myriota also seeks authority to communicate with follow-on satellites launched to replenish its constellation as
      satellites reach end of life.


                                                           1


summarizes the orbital parameters of this constellation.

      Altitude (km)                 Inclination            Number of Planes            Satellites per Plane

            600                         54°                          10                          1

            600                         54°                          2                           2

            600                        97.7°                         6                           2
                            Table A.2—1. Summary of Orbital Parameters

Myriota‘s first three satellites, with a 3U cubesatform factor, will not have propulsive capability,

and thus will not be able to actively maintain orbital parameters. These satellites will be launched

via ride share into two of the 97.7 degree inclined orbital planes, and one near the 54 degree

inclined orbital planes. After the initial three satellites, Myriota will continue with satellite rollout

of a limited number of additional 3U satellites. Following this 3U phase, subsequent satellites

launched will have propulsion capability, and will be larger with a 6U form factor. They will

utilize dedicated launch precisely to the target inclination. As the constellation grows and is

replenished, the added propulsion capability will be used to conduct orbital station keeping, plane

phasing (utilizing the J2 perturbation), collision avoidance, and de—orbit maneuvers.

         Spectrum

         In the United States, Myriota will operateits NVNG system using the 399.9—400.05 MHz

(Earth—to—space) and 400.15—401 MHz (space—to—Earth) frequency band. Both bands have been

allocated to non—Federal MSS on a primary basis and have been specifically identified by the

Commission as being available for NVNG MSS operations." As illustrated in Figure A.2—1 below,

Myriota‘s satellites can vary channel bandwidth with on—board processing across the entire range

of both the uplink and downlink frequency bands authorized for its use. Accordingly, Myriota




2.   See 47 C.F.R. §§2.106, 25.202(@)(3). See also 47 C.F.R. § 2.106 n.US320 (the use ofthe 399.9—400.05 MHz and
     400.15—401 MHz bands by the MSS is limited to NVNG satellite systems).


proposes to operate multiple channels within the requested uplink and downlink frequencies.




                        Figure A.2-1. Illustration of Channel Variations

       Outside the U.S., Myriota will use additional spectrum to transmit both payload data and

payload command and control information between its spacecraft and gateway earth stations.

These transmissions will be performed in the 2025-2110 MHz band for uplinks, and in the 2200-

2290 MHz and 8025-8400 MHz bands for downlinks. Myriota will also perform telemetry,

tracking, and control (“TT&C”) operations from locations outside the U.S. Myriota does not

request market access with respect to these additional frequency bands at this time.

A.3    PREDICTED SPACE STATION ANTENNA GAIN CONTOURS

       All satellites in the Myriota NVNG constellation have been designed with the same

transmit and receive antenna beams. These beams are fixed with respect to the satellite body. The

spacecraft attitude is maneuverable, and the expected gain of the dipole antennas will be between

-1.9 dBi and 2.15 dBi at nadir. The antenna gain contours for the beams of a representative space

station, which are essentially the same for satellites operating in all planes within the constellation,

are shown in Figure A.3-1 below and embedded in the associated Schedule S.




                                                   3


                      Figure A.3-1. Representative Antenna Gain Contour Plot

A.4       TT&C CHARACTERISTICS

          The Myriota TT&C operations communicate with spacecraft during pre-launch, transfer

    orbit, and on-station operations, as well as during spacecraft emergencies. 3                     All TT&C

    communications will be conducted over authenticated and encrypted links for commanding,

    telemetry (mission related data), and customer data. During all phases of the mission, TT&C

    operations will use the following frequency bands:

       For space-to-Earth: 2200-2290 MHz.

       For Earth-to-space: 2025-2110 MHz.



3
      The information provided in this section complements that provided in the associated Schedule S and Technical
      Database.



                                                         4


As noted above, Myriota will conduct TT&C operations using ground station facilities located

outside the U.S., and therefore does not seek authority for market access with respect to TT&C

spectrum at this time.

    A.5    CESSATION OF EMISSIONS

          Each active satellite transmission chain (channel amplifiers and associated solid state

power amplifier) can be individually turned on and off by ground telecommand, thereby

causing cessation of emissions from the satellite, as required by Section 25.207 of the

Commission's rules.

A.6       SPECTRUM SHARING ANALYSES

          As discussed in Section A.2 above, the frequency ranges Myriota proposes to use in the

U.S. have been designated by the Commission for use by commercial NVNG MSS systems.

However, that spectrum is also shared with other services in the U.S. Table of Frequency

Allocations. As required in Section 25.142 of the Commission’s rules, Myriota below (1)

demonstrates, based on existing system information publicly available at the Commission, that it

will not cause unacceptable interference to any NVNG MSS system currently authorized to

construct or operate, (2) provides the power flux-density (“PFD”) produced by its system at the

Earth’s surface in the 400.15-401 MHz band to demonstrate that no further coordination with

terrestrial systems is necessary, (3) describes the measures it would employ to protect the radio

astronomy service in the 406.1-410 MHz band from harmful interference from unwanted

emissions, and (4) demonstrates compliance with applicable emission limitations. 4

          As discussed below, Myriota has designed its NVNG system to achieve a high degree of

flexibility and spectral efficiency in order to facilitate frequency sharing and to protect other


4
      See 47 C.F.R. § 25.142(a)(1)-(3).



                                                  5


authorized satellite and terrestrial systems in compliance with U.S. and international regulations

and under reasonable coordination arrangements. Applying these and other sharing mechanisms

as described throughout this section, Myriota is confident that it can successfully coordinate its

system with other authorized satellite and terrestrial networks.

A.6.1 Spectrum Sharing with Respect to Other NVNG Satellite Systems

          Myriota intends to operate its NVNG system in the U.S. using the 399.9-400.05 MHz uplink

and 400.15-401 MHz downlink bands, which have been allocated for use by commercial NVNG MSS

systems. 5 Section 25.142(a)(1) of the Commission’s rules requires all NVNG applicants to file

information demonstrating, on the basis of information publicly available at the Commission at the

time of filing, that they will not cause unacceptable interference to any NVNG MSS system authorized

to construct or operate. Below we provide a brief history of the Commission’s NVNG licensing

activity before addressing the situation in each band in which Myriota proposes to operate in the United

States.

          In the mid-1990’s, the Commission conducted two NVNG processing rounds. As a result

of a consensus spectrum use plan negotiated by the applicants in the second processing round, the

Commission issued a total of five licenses for NVNG MSS systems, sometimes referred to as

“Little LEO” systems. 6 The Commission did not authorize any NVNG system to operate in the

399.9-400.05 MHz band at that time (or in subsequent years). However, of these five NVNG

licenses, three included authorization to operate in the 400.15-401 MHz band.

          System 1 was originally licensed to Leo One and covered 400.15-400.505 MHz and
           400.645-401 MHz bands.

5
    See 47 C.F.R. §§ 2.106, 25.202(a)(3). See also 47 C.F.R. § 2.106 n.US320 (the use of the 399.9-400.05 MHz and
    400.15-401 MHz bands by the MSS is limited to NVNG satellite systems).
6
    See Amendment of Part 25 of the Commission’s Rules to Establish Rules and Policies Pertaining to the Second
    Processing Round of the Non-Voice, Non-Geostationary Mobile-Satellite Service, 13 FCC Rcd. 9111 (1997)
    (“Second NVNG Processing Round Order”).



                                                       6


          System 2 was originally licensed to Final Analysis and covered the entire 400.15-401
           MHz band.

          System 5 was originally licensed to VITA, covered the 400.505-400.5977 MHz and
           400.5983-400.645 MHz bands, and was required to timeshare with System 2.

By December 2005, all three of these licenses had been either surrendered by the licensee or

cancelled for failure to meet applicable deployment milestones. Each time, the Commission issued

a public notice stating that the licensee’s spectrum would be available for new applicants on a first-

come, first-served (“FCFS”) basis. 7

        The only NVNG licensee to launch and operate a system authorized to provide service in

the U.S. was Orbital Communications Corporation (“Orbcomm”), which originally was licensed

to use spectrum in the 137-138 MHz (uplink) and 148-150 MHz (downlink) bands. However, in

2007, Orbcomm applied for the spectrum formerly authorized to System 1, which includes

spectrum in the 400.15-401 MHz band. In support of its application, Orbcomm observed that

“sufficient Little LEO spectrum remains available to license three other Little LEO systems after

assigning System 1 frequencies to Orbcomm.” 8 In granting that application, the Commission also

authorized Orbcomm to operate temporarily in the remaining NVNG spectrum, on the condition

that “Orbcomm must operate jointly in the Little LEO spectrum with any other licensees operating

in the System 2, System 3, and VITA system segments under the plan adopted in the Second

Processing Round Report and Order if and when an applicant is authorized to operate in any of

those designated system segments.” 9




7
    See Public Notice, 19 FCC Rcd. 4804 (2004) (Final Analysis cancellation); Public Notice, 19 FCC Rcd. 5368
    (2004) (Leo One cancellation); Public Notice, 20 FCC Rcd. 20273 (2005) (VITA surrender).
8
    See Orbcomm License Corp., 23 FCC Rcd. 4804, ¶ 10 (2008).
9
    See id. ¶ 11.



                                                     7


       A.6.1.1        400.15—401 MHz

       As discussed above, the only operational NVNG system authorized by the Commission in

this downlink band is licensed to Orbcomm. It has been authorized to use the 400.15—400.505

MHz and 400.645—401 MHz bands on an ongoing basis but must share the remaining NVNG

spectrum in the band once another NVNG operator is authorized to use it. Ideally, Myriota would

Tike access to operate downlink communications using 140 kHz bandwidth. Table A.6.1.1—1 below

illustrates a channel plan arrangement for a contiguous 140 kHz spectrum assignment:


        Channel               Number of          Assigned             Required avg.
        bandwidth (kHz)       channels           bandwidth (kHz)      duty cycle (%)

                 10                    14                140                  10

                 20                    7                 140                  10

                 35                    4                 140                  10

                 70                    2                 140                  10
           Table A.6.1.1—1. IMlustration of Channel Plan for 140 kHz Assignment

Nonetheless, Myriota could operate its constellation in the spectrum assigned to either System 2

or System 5 from the second processing round, both ofwhich are currently available. Accordingly,

Myriota could operate without causing unacceptable interference to Orbcomm.

       Yet even in the absence of this legacy spectrum sharing plan, Myriota‘s system has the

flexibility and spectral efficiency to be able to operate harmoniously with Orbcomm in this band.

For example, Myriota‘s satellites can vary the bandwidth of their emissions through on—board

processing, and dynamically control their emissions to accommodate sharing arrangements with

other users ofthe band. Myriota downlink emissions can range in bandwidth between 10—140 kHz

and operate within the entire 850 kHz MSS allocation or any portion thereof designated for their

use. Myriota downlink emissions can employ frequency hopping to move throughout the assigned


band, or operate with a defined channel plan, using either multiple contiguous channels or a

fragmented channel arrangement. By combining the 10% duty cycle with the flexibility of the

software defined radio on board its satellites, Myriota will be able to share spectrum by

coordinating usage and/or time of operations. Myriota has contacted Orbcomm to organize a

coordination meeting to discuss sharing arrangements of this band.

         Myriota recognizes that Hiber Inc. has also filed an application seeking U.S. market access

using this same spectrum band. 10 According to its application, Hiber intends to operate using 100

kHz bandwidth with a low duty cycle. Hiber contends that its system would be able to share this

band and would not preclude entry by other NVNG systems in the future.11 Since both Myriota and

Hiber will only transmit for a small fraction of time, there is a very low probability of harmful

interference between the systems even while sharing the same spectrum. As described above, the

spectrally efficient and flexible software defined radio on board its satellites will enable Myriota

to share with Hiber under a variety of possible arrangements. Myriota has already contacted Hiber

to organize a coordination meeting.

         A.6.1.2       399.9-400.05 MHz

         The 399.9-400.05 MHz band has been allocated for use by NVNG systems for over a decade.

However, the Commission has never issued an authorization to construct or operate a satellite system

in this uplink band. Accordingly, there is no risk that granting Myriota’s application could result in

unacceptable interference to an authorized NVNG system, satisfying the requirement in Section

25.142(a)(1).

         Yet even if this were not the case, Myriota’s system would be able to share this band with



10
     See Petition for Declaratory Ruling, IBFS File No. SAT-PDR-20180910-00069 (Sep. 10, 2018) (“Hiber PDR”).
11
     See id. at 7-8.



                                                      9


other NVNG systems without causing harmful interference. Both IoT modules and micro-

gateways transmit only when a Myriota satellite is overhead, significantly reducing the times

during which interference is even theoretically possible. All of Myriota’s NVNG terrestrial

stations in this band operate with less than 5 dBW EIRP. This would be within the limit currently

proposed under Agenda Item 1.2 to be considered at the World Radio Conference later this year. 12

Myriota’s IoT modules will operate with typical transmit duty cycle less than 0.02%, and

occasionally with duty cycle of 0.5%. They employ frequency hopping across the intended band,

with a narrow emission bandwidth of just 2 kHz. Myriota’s micro-gateways will typically operate

with transmit duty cycle less than 0.5% and occasionally up to 5%, with emission bandwidth

ranging from 2-20 kHz. Since the micro-gateways are far less numerous than other devices

communicating with Myriota satellites in this band and they remain within the EIRP limit under

consideration internationally, their slightly higher duty cycle will have a negligible effect on the

spectrum environment. These operating characteristics give Myriota the ability to share the entire

150 kHz range with other NVNG systems also operating in the 399.9-400.05 MHz band, as well

as the ability to operate in any portion of the band designated for its use.

         Here again, Myriota is aware that the Commission has received two other applications for

authority to operate space stations in this band. One was the application by Hiber discussed above.

The other was filed by Spire Global, Inc. (“Spire”), which proposes to operate back-up TT&C uplinks

in this spectrum for its Earth Exploration Satellite Service (“EESS”) system. 13 In response to a request


12
     See FEDERAL COMMUNICATIONS COMMISSION, DOCUMENT WAC/086, DRAFT PROPOSALS PRESENTED AT MARCH
     11TH, 2019 MEETING OF THE WORLD RADIOCOMMUNICATION CONFERENCE ADVISORY COMMITTEE, AGENDA
     ITEM 1.2 (2019): to consider the in-band power limits for earth stations operating in the mobile-satellite service,
     meteorological-satellite-service, and Earth exploration-satellite service in the frequency bands 401-403 MHz and
     399.9-400.05 MHz, in accordance with Resolution 765 (WRC-15).
13
     The Commission deferred consideration of Spire’s application with respect to this band. See, e.g., Stamp Grant, IBFS
     File Nos. SAT-LOA-20151123-00078 and SAT-AMD-20180102-00001, at n.2 (Nov. 29, 2018).




                                                           10


for information from the Commission, Spire contends that because its use of this spectrum for back-

up TT&C operations will be very infrequent and it is willing to turn off its earth station transmitter

when the NVNG satellite of another operator is in view, its operations would not preclude use of this

spectrum by other NVNG systems. 14 Thus, both Spire and Hiber contend that their systems can

share the 399.9-400.05 MHz with other NVNG satellite systems, and Myriota shares the same

belief. Myriota has contacted both Hiber and Spire to initiate discussion of potential sharing

techniques.

A.6.2 Spectrum Sharing with Respect to Terrestrial Networks

         Section 25.142(a)(2) of the Commission’s rules requires applicants for NVNG MSS

authorizations to provide the PFD produced at the Earth’s surface by each space station in the

400.15-401 MHz band, to allow determination of whether coordination with terrestrial services is

required under any applicable footnote of the U.S. table of frequency allocations. In this case, the

relevant footnote is 5.264, which provides that the PFD limit indicated in Annex 1 of Appendix 5

of the ITU Radio Regulations shall apply in this band. 15 That PFD limit is -125 dBW/m2/4 kHz

at the Earth’s surface. 16

         In order to demonstrate compliance with this limit, Table A.6.2-1 below calculates the PFD

for a satellite in Myriota’s system, assuming operations at maximum power, at both its initial

altitude and at the lowest altitude at which it will perform commercial operations.




14
     See Letter from Letter from Jonathan Rosenblatt to Jose P. Albuquerque, IBFS File Nos. SAT-LOA-20151123-
     00078, SAT-AMD-20161114-00107, and SAT-AMD-20180102-00001, at 5-6 (May 16, 2018) (“Spire Letter”).
15
     See id. § 2.106 n.5.264.
16
     See ITU Radio Regulations, Coordination thresholds for sharing between MSS (space-to-Earth) and terrestrial
     services in the same frequency bands and between non-GSO MSS feeder links (space-to-Earth) and terrestrial
     services in the same frequency bands and between RDSS (space-to-Earth) and terrestrial services in the same
     frequency bands, Appendix 5, Annex 1, ¶ 1.1.1.


                                                      11


       Satellite altitude [km]                               600                   400

       Antenna Gain [dBi]                                    2.15                  2.15

       Maximum EIRP [dBW]                                    14.5                   11
       (for arbitrary bandwidth 80 kHz)

       Maximum EIRP density [dBW/4 kHz]                       1.5                   -2

       Spreading loss [dB]                                 -126.555             -123.033

       PFD [dB(W/m2/4 kHz)]                                -125.055             -125.033
                     Table A.6.2-1. Maximum PFD at the Surface of the Earth

Because operations at 400 km illustrate a worst-case PFD, yet the value at this altitude is still lower

than the limit incorporated into the Commission’s rules, no coordination with terrestrial systems

in the 400.15-401 MHz band is required. If multiple satellites are simultaneously active in a given

area, Myriota’s system is flexible enough to control emissions such that the aggregate PFD on the

Earth’s surface will comply for any given 4 kHz range. Myriota also has the ability to manage the

satellites’ PFD levels during all phases of the mission, because the satellite downlink transmit

power is adjustable on-orbit, providing yet more assurance that its NVNG system will not cause

harmful interference to terrestrial systems.

       In addition, Myriota’s satellites comply with the requirement set forth in Section

25.142(a)(3)(ii) of the Commission’s rules that no signal received by satellites from sources

outside of the system shall be retransmitted with a PFD level exceeding the limits discussed above.

Signals received from terrestrial sources are demodulated and processed onboard the satellite. An

appropriate response is then generated, modulated, and transmitted by the satellite. Unknown or

incompatible signals received by a satellite are rejected and do not result in a transmission

response, ensuring that signals originating from sources outside of the Myriota network will not

be re-transmitted.




                                                  12


A.6.3 Protection of Radio Astronomy in the 406.1-410 MHz Band

         Section 25.142(a)(2) of the Commission’s rules also directs applicants for NVNG

authorizations to discuss the measures they would employ to protect the Radio Astronomy Service

(“RAS”) in the 406.1-410 MHz band from harmful interference from unwanted emissions.17

Myriota appreciates the importance of protecting RAS sites worldwide against harmful

interference. Indeed, Myriota has already held discussions with personnel in charge of protecting

Australia’s most significant and sensitive radio astronomy site at the Square Kilometre Array,

operated by the Commonwealth Scientific and Industrial Research Organisation (“CSIRO”). From

this experience, Myriota understands various techniques that can be employed to help mitigate

interference threats concerning RAS operations, as discussed below. Myriota will continue its

discussions with Australia’s CSIRO, and will commence reaching out to the international RAS

community, including relevant RAS contacts in the United States.                             Below we discuss

considerations that would be applicable in the 406.1-410 MHz band.

         In the 400.15-401 MHz downlink band, the theoretical worst-case Doppler effects will be

±10.5 kHz (as discussed below). These effects are insignificant relative to the frequency separation

between the NVNG and RAS operations (i.e., 5100 kHz separation between boundaries at 401

MHz and 406.1 MHz). As a result, Doppler effects will have no material impact on attenuation of

the satellite signal in this band. RAS facilities are generally vulnerable to interference from

satellite transmissions due to the high gain antennas used on many spacecraft, which tend to

concentrate energy in a specific direction and can unintentionally target an RAS antenna. By

contrast, Myriota’s satellite emissions will be extremely low over the 406.1-410 MHz range. Over


17
     See 47 C.F.R. § 25.142(a)(2). But see id. § 2.106 n.US74 (“In the band 406.1-410 MHz, the radio astronomy
     service shall be protected from unwanted emissions only to the extent that such radiation exceeds the level which
     would be present if the offending station were operating in compliance with the technical standards or criteria
     applicable to the service in which it operates”).



                                                         13


any 4 kHz measured bandwidth in this range, the EIRP from a Myriota satellite emission will be

attenuated at least 55 dB through front-end filtering compared to the emission at frequency of

operation. This equates to a PFD value at the Earth’s surface of less than -180 dBW/m2/4kHz.

Moreover, Myriota’s downlink emissions will not be continuous over time, with duty cycle 10%

or less. This reduces the average power received at the RAS site, and further reduces the

probability of harmful interference.

       Uplink transmissions from Myriota’s NVNG terrestrial stations will occur over 399.9-

400.05 MHz. RAS facilities have considerably lower antenna gain in the direction of all terrestrial

transmitters (i.e., at very low elevation angles). However, they may be susceptible to interference

from terrestrial transmitters that are operating in close proximity. This is very unlikely to be the

case for Myriota’s NVNG terrestrial stations for several reasons. For example, Myriota NVNG

terrestrial stations operate with EIRP less than 5 dBW over intended range 399.9-400.05 MHz,

and emissions outside this range will be reduced by at least 40 dB over any 4 kHz measured

bandwidth through front-end filtering compared to the emission at frequency of operation.

Myriota will manage the deployment of its micro-gateways such that they avoid interference

potential to RAS. Myriota’s IoT modules will operate with a low duty cycle (typically less than

0.02%), which further reduces the average power received by a RAS facility. If a specific RAS

site nonetheless experiences interference, Myriota can utilize its geofencing technology to prevent

IoT modules from ever transmitting within certain distances of a given location. Myriota has

employed this strategy to protect the Square Kilometer Array in Australia, and could apply it to

other RAS sites as appropriate. Myriota can even send messages instructing specific NVNG

terrestrial stations to cease transmission should interference concerns arise.




                                                 14


       Accordingly, using such measures, Myriota will protect RAS facilities operating in the

406.1-410 MHz band from harmful interference from unwanted emissions.

A.6.4 Compliance with Emission Limits

       Section 25.142(a)(3) requires applicants for NVNG authorizations to show that their space

stations will not exceed the emission limitations specified in Sections 25.202(f)(1)-(3), as

calculated for a fixed point on the Earth’s surface in the plane of the space station’s orbit,

considering the worst-case frequency tolerance of all frequency determining components, and

maximum positive and negative Doppler shift of both the uplink and downlink signals, taking into

account system design.

       For a satellite launched to an altitude of 600 km, the worst-case Doppler shift is 10.067

kHz, occurring at the upper limit of the 400.05-401 MHz downlink band. As shown in Table

A.6.4-1 below, as these satellites gradually lose altitude over time, the Doppler shift increases

slightly. To be conservative, assuming worst case Doppler shift of 10.5 kHz would comfortably

accommodate any such difference in satellite altitude.


    Satellite altitude              Transmit frequency          Doppler shift

    600 km                          400.05 MHz                  ± 10.043 kHz

                                    401 MHz                     ± 10.067 kHz

    400 km                          400.05 MHz                  ± 10.285 kHz

                                    401 MHz                     ± 10.309 kHz
                         Table A.6.4-1. Doppler Shift at Various Altitudes

Myriota’s satellite hardware is being designed to conform with the emission limits of Section

25.202(f), for a range of possible emission bandwidths. Figure A.6.4-1 below shows the required

emission mask necessary to conform to these emission limits, assuming an example emission




                                                 15


bandwidth of 80 kHz, for both worst-case Doppler effects (shown in red) and without considering

Doppler effects (shown in blue). Myriota’s satellites will conform to these limits.




                                Figure 8.6.4-1. Spectral Emission Limits

A.6.5 Spectrum Sharing with Respect to GSO Satellite Systems

         Section 25.289 of the Commission’s rules provides that an NGSO system licensee must

not cause unacceptable interference to, or claim protection from, a GSO FSS or GSO BSS

network. 18 However, there are no GSO satellite systems currently licensed by the Commission or

granted U.S. market access in the bands at issue in this petition. Accordingly, there is no basis for

concern with respect to potential interference to GSO satellite systems.

A.6.6 Coordination with U.S. Government Networks

         There are a variety of Federal allocations in the spectrum Myriota proposes to use for its

NVNG operations in the U.S., including Space Research and Land Mobile Radio operations in



18
     See 47 C.F.R. § 25.289.




                                                 16


the 399.9-400.05 MHz band and a variety of meteorological radiosonde operations in the 400.15-

401 MHz band. 19 Section 25.142(b)(2) of the Commission’s rules notes these dual allocations,

and the Commission’s role as liaison with the National Telecommunications and Information

Administration (“NTIA”) to reach agreement with respect to achieving compatible operations

between federal government users and commercial NVNG systems.                     Myriota’s agile and

spectrally-efficient system will facilitate coordination with federal spectrum users, and Myriota

pledges to work with the Commission and NTIA to reach appropriate coordination agreements.

         Myriota is also prepared to operate consistent with the requirements of Section 25.260 to

protect Department of Defense (“DoD”) operations in the 400.15-401 MHz band. 20 Myriota is

capable of complying with the regulations regarding restriction of transmissions into the

“protection area” of DoD satellites described in Section 25.260(a). In addition, as required under

Section 25.260(b), Myriota will provide a point of contact that will be available twenty-four hours

per day, seven days per week so that reports of harmful interference into DoD earth stations and

other operational issues can be reported and resolved expeditiously.

         In addition, each satellite will automatically turn off and cease satellite transmissions if,

after 72 consecutive hours, no reset signal is received from a Myriota feeder link earth station

and verified by the satellite. All satellites in Myriota’s NVNG system will be capable of

instantaneous shutdown on any sub-band upon command. Myriota’s NVNG system will be able

to change the frequency on which its satellites are operating within 125 minutes of receiving

notification from a DoD required frequency change in the 400.15-401 MHz band, and Myriota



19
     See, e.g., NTIA OFFICE OF SPECTRUM MANAGEMENT, Federal Government Spectrum Use Reports, 225 MHz –
     7.125 GHz (2015), https://www.ntia.doc.gov/page/federal-government-spectrum-use-reports-225-mhz-7125-
     ghz.
20
     See 47 C.F.R. § 25.260.



                                                    17


will use best efforts to reduce this implementation time to 90 minutes as it builds out additional

feeder link earth stations.

A.7     ITU FILINGS FOR MYRIOTA

        The Myriota NVNG system will operate under network filings made on its behalf with the

ITU by the Australian administration under the satellite network name MNSAT. A request for

coordination of this filing was published in BR IFIC 2878 on September 4, 2018.

A.8     ORBITAL DEBRIS MITIGATION

        Myriota intends to incorporate the material objectives set forth in this PDR into the

technical specifications established for design and operation of its NVNG system. Myriota will

internally review orbit debris mitigation throughout design for the spacecraft, and incorporate these

objectives, as appropriate, into its operational plans.      Because this mitigation statement is

necessarily forward looking, the process of designing, building, and testing may result in minor

improvements to the parameters discussed herein. In addition, Myriota will continue to stay

current with the Space Situational Awareness community and technology and, if appropriate,

Myriota will modify this mitigation statement.

Spacecraft Hardware Design

        Myriota has assessed and limited the amount of debris released in a planned manner during

normal operations and does not intend to release debris during the planned course of operations of

its NVNG system. Myriota is also aware of the possibility that its system could become a source

of debris in the unlikely case of a collision with small debris or meteoroids that could either create

jetsam or cause loss of control of the spacecraft and prevent post-mission disposal. Myriota is

undertaking steps to address this possibility by incorporating redundancy, shielding, separation of

components, and other physical characteristics into the satellites’ design. Myriota will continue to




                                                 18


review these aspects of on-orbit operations throughout the spacecraft design and manufacturing

process and will make such adjustments and improvements as appropriate to assure that its

spacecraft will not become a source of debris during operations or become derelict in space due to

a collision.

Minimizing Accidental Explosions

        Myriota is working with Tyvak-nanosatellite systems with the design of its spacecraft in a

manner that limits the probability of accidental explosion. The Myriota satellite batteries will be

equipped with protection circuitry. In addition, the low charges and small battery cells on the

satellites’ power system prevent a catastrophic failure, so that passivation at end of mission is not

necessary to prevent an explosion large enough to release orbital debris. The propulsion system

will be made safe at the end of mission, though the precise procedure for doing so will depend on

the technology adopted.

Safe Flight Profiles

        Through detailed and conscientious mission planning, Myriota has carefully assessed and

limited the probability of its system becoming a source of debris by collisions with large debris or

other operational space stations. Myriota is willing to engage with any operators of nearby

constellations and other space stations to ensure safe and coordinated space operations. To this

end, Myriota will utilize GNSS receivers to determine accurate spacecraft location ephemeris data

to assist in assessing conjunction risks, and through cooperation with the Combined Space

Operations Center and other spacecraft operators will conduct differential drag maneuver when

required (using differential drag with its initial satellites or propulsion for those launched later).

        Attached hereto is a preliminary Orbital Debris Assessment Report (“ODAR”), prepared

with the use of NASA’s Debris Assessment Software (“DAS”). For purposes of this report,




                                                  19


Myriota considered its non-propulsive first-generation satellites, since the lack of propulsion

presents a worse case for potential collisions. 21 As shown in that ODAR, DAS indicates that the

probability of any Myriota satellite colliding with debris or meteoroids greater than 10 cm in

diameter is less than 0.00000, whether the satellite is in the stowed or deployed configuration,

assuming an initial altitude of 600 km. The ballistic coefficient of the 6U satellites will be similar,

resulting in a less than 25-year lifetime. The upgraded satellites will use a combination of altitude

increase maneuvers and the J2 perturbation to achieve the Right Ascension of the Ascending Node

plane phasing. This makes it favorable that the launch altitude be less than constellation operating

altitude. Accordingly, even assuming a worst-case of a satellite that is inoperable upon orbital

injection, de-orbit and atmospheric demise would occur in much less than 25 years.

Post-Mission Disposal

         Each satellite in Myriota’s NVNG system is designed for a full capacity useful lifetime of

at least three years under the most limited power generation conditions, and will be duty cycled

beyond that date until system failure or orbital decay leads to atmospheric demise. After its

mission is complete, each Myriota spacecraft will be reoriented to increase drag in order to hasten

the atmospheric demise process. The spacecraft will begin to passivate itself by de-spinning

reaction wheels and drawing batteries down to a safe level and powering down. Over the following

months, the denser atmosphere will gradually lower the satellite’s apogee until its eventual

atmospheric demise. As suggested by the Commission, 22 Myriota intends to comply with Section

4.6 and 4.7 of NASA Technical Standard 8719.14A with respect to this re-entry process.



21
     See, e.g., Mitigation of Orbital Debris in the New Space Age, FCC 18-159, ¶ 26 (rel. Nov. 19, 2018) (with
     respect to collision risk, describing the Commission’s “current licensing practice” as “consider[ing] this risk to
     be zero or near zero during the period of time in which the spacecraft is maneuverable”).
22
     Mitigation of Orbital Debris, 19 FCC Rcd. 11567, ¶ 88 (2004).



                                                           20


       Under nominal conditions, Myriota would deploy its satellites at an altitude of

approximately 600 km and continue to conduct commercial operations until they reach an altitude

of approximately 400 km. In these circumstances, DAS analysis indicates that Myriota satellites

will reenter the Earth’s atmosphere within approximately 5.4 years after deployment, as illustrated

in Figure A.8-1 below.




   Figure A.8-1. Projected Demise of Deployed Myriota Satellite from 600 km Altitude

However, even if a satellite were launched to 600 km and immediately failed such that it remained

in its stowed configuration, DAS indicates that it would have an expected orbital lifetime of 24.7




                                                21


years – still less than the international standard of twenty-five years – as shown in Figure A.8-2

below.




     Figure A.8-2. Projected Demise of Stowed Myriota Satellite from 600 km Altitude

         Myriota also conducted a preliminary re-entry risk analysis using DAS and the bill of

materials of components with high melting temperatures. As modeled, DAS indicates the entire

satellite will demise completely during uncontrolled re-entry with no material surviving to reach

the Earth’s surface. Accordingly, the risk of human casualty on the ground from Myriota satellites

re-entering the atmosphere is zero.




                                               22


       Each satellite can be expected to spend less than a few weeks at altitudes below 480 km

where there will be any risk of conjunction with ISS and other human spaceflight orbiting

laboratories. As discussed above, Myriota will work with NASA and CSpOC in order to eliminate

conjunction risks.




                                             23


                             ENGINEERING CERTIFICATION


       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/ Dr. David Haley
                                              Dr. David Haley
                                              Chief Technology Officer
                                              MYRIOTA PTY. LTD.


                                              March 27, 2019
                                              Date



Document Created: 2019-04-28 11:49:09
Document Modified: 2019-04-28 11:49:09

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