Attachment PanAmSat-DA 09-2363

PanAmSat-DA 09-2363

DECISION submitted by IB,FCC

DA 09-2363

2009-10-30

This document pretains to SAT-MOD-20090910-00097 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2009091000097_774765

                             Federal Communications Commission
                                     Washington, D.C. 20554


                                                                                      DA 09—2363

                                           October 30, 2009

Ms. Jennifer D. Hindin
Wiley Rein LLP
1776 K Street, NW
Washington, D.C. 20006—3006

                                                      Re:    PanAmSat Licensee Corp. Application to
                                                            Modify Authorization for Galaxy 11 to
                                                            Relocate to 76.85° W.L., IBFS File No.
                                                            SAT—MOD—20090910—00097 (Call Sign:
                                                            $2253)

Dear Ms. Hindin:

On September 10, 2009, PanAmSat Licensee Corp. (PanAmSat) filed the above—captioned
application to modify its authorization to permit relocation of Galaxy 11 from 32.8° E.L. to 76.85°
W.L., for the purpose of providing C— and Ku—band capacity in the Atlantic Ocean region. As
discussed below, we dismiss the application as defective, without prejudice to refiling.

Section 25.112 of the Commission‘s rules, 47 C.F.R. § 25.112, requires the Commussion to return,
as unacceptable for filing, any space station application that is not substantially complete, contains
internal inconsistencies, or does not substantially comply with the Commission‘s rules.

Section 25.114(d)(14)(iv) of the Commission‘s rules, 47 C.F.R. § 25.114(d)(14)(iv), requires
entities to include a statement detailing the post—mission disposal plans for the geostationary—Earth
orbit space stations, "including the quantity of fuel — if any — that will be reserved for post—mission
disposal maneuvers" as well as "the altitude selected for a post—mission disposal orbit and the
calculations that are used in deriving the disposal altitude."In its filing, PanAmSat stated that the
Galaxy 11 spacecraft would be disposed of at end of life by moving it to an "altitude above the
geostationary are and [would] reserve the necessary fuel to effectuate this end of life maneuver."
PanAmSat‘s application does not specify the information required by Section 25.114(d)(14)(iv) of
the Commission‘s rules because it does not provide the quantity of fuel reserved for post—mission
disposal maneuvers. PanAmSat did not seek a waiver of Section 25.114(d)(14)(iv), and its
application is accordingly subject to dismissal. We request that, when refiling, PanAmSat provide
both the amount of fuel reserved and the projected end—of—life spacecraft orbital parameters
(including orbital eccentricity, perigee, and apogee) used as a basis for deriving the fuel reserve. In
addition, please provide full information concerning the methods that will be used to assess and
provide adequate margins concerning fuel gauging uncertainty.


                                     Federal Communications Commission                              DA 09—2363




We note that the Commussion did not specify a minimum altitude for disposal of grandfathered
satellites in the Orbital Debris Order.‘ However, the Commission emphasized that "[t}he stated
current practice of several U.S. operators is, barring catastrophic hardware failures, to execute end—
of—life maneuvers that result in a disposal altitude of no less than 150 kilometers above" the
geostationary altitude." The Commission also noted variations in the stated practices at that time of
space station operators, with minimum perigee targets ranging from 100—192 kilometers above the
geostationary altitude. The Commission stated that "[allthough operators claim that such minimum
disposal altitudes are sufficient to protect the geostationary earth orbit, the target orbits, particularly
those in the lower end of this range, could, in fact, result in decommissioned spacecraft drifting
back into altitudes at which active ... spacecraft operate."" Accordingly, we request that PanAmSat,
to the extent it plans to dispose of the Galaxy 11 satellite at an orbit of less than 150 kilometers,
submit an analysis of the long—term evolution (100 years or more) of the orbit for the Galaxy 11
satellite, taking into account perturbing forces such as gravitational effects and solar radiation
pressure, and focusing in particular on perigee altitude. Please also provide an analysis of the
potential risks or constraints this satellite would present for operational geostationary spacecraft,
based upon the evolution of the orbit.

In addition, PanAmSat omitted information in Column (g) of FCC Form 312 — Schedule S, Table
S$7: Space Station Antenna Beam Characteristics. Specifically, PanAmSat did not provide the
Minimum Cross—Polar Isolation information required in Column (g). We request that, when
refiling, PanAmSat provide the information required in Table S7, Column (g).

Accordingly, pursuant to Section 25.112(a)(1) of the Commission‘s rules, 47 C.F.R. § 25.112(a)(1),
and Section 0.261 of the Commission‘s rules on delegations of authority, 47 C.F.R. § 0.261, we
dismiss the modification application of PanAmSat Licensee Corp. without prejudice to refiling.


                                                                    Sincerely,



                                                                    Robert G. Nelson
                                                                    Chief, Satellite Division
                                                                    International Bureau




‘ Mitigation of Orbital Debris, Second Report and Order, IB Docket No. 02—54, 19 FCC Red 11567 (2004) (Orbital
Debris Second Report and Order).
* Id.at 11600—01. See also Disclosure of Orbital Debris Mitigation Plans, Including Amendment of Pending
Applications, International Bureau Satellite Division Information, Public Notice, Report No. SPB—112, DA 05—2698,
October 13, 2005. The Commission also noted that a number of operators had exceeded that minimum. Orbital Debris
Second Report and Order, 19 FCC Red at 11600 n.208 (noting disposals in excess of 300 kilometers above GSO by
SES Americom and Intelsat).
* Id. at 11597 n.191.



Document Created: 2019-06-03 01:54:18
Document Modified: 2019-06-03 01:54:18

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