Attachment Orbcomm - req for ad

Orbcomm - req for ad

REQUEST submitted by IB,FCC

Request

2011-12-06

This document pretains to SAT-MOD-20111021-00207 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2011102100207_929201

                            Federal Communications Commission
                                    Washington, D.C. 20554




                                         December 6, 2011



Walter H. Sonnenfeldt
Orbcomm, Inc.
2115 Linwood Avenue, Suite 100
Fort Lee, NJ 07024

Stephen L. Goodman, Esq.
Butzel Long Tighe Patton, PLLC
1747 Pennsylvania Ave., NW, Suite 300
Washington, DC 20006




        Re:    Modification Application of Orbcomm License Corp.
               IBFS File No. SAT—MOD—20111021—00207
               Call Sign: $2103

Dear Mr. Sonnenfeldt and Mr. Goodman:

        On October 21, 2011, Orbcomm License Corp. filed the referenced application to modify
the license for Orbcomm‘s non—voice, non—geostationary, low—Earth orbit (Little LEO) satellites.
In order to facilitate review of the application, we request that Orbcomm file a supplement to the
application to address the following:

         1)      Concerning fuel remaining in the fuel tanks at the end of the satellites‘ operational
life, the application notes that fuel is budgeted for maneuvering the space station to target
disposal at loweraltitudes. The application also states that after the satellite is so maneuvered,
"very small, residual amounts of fuel" will be left in the fuel tanks. Please quantify the amount
of residual hydrazine fuel that Orbcomm anticipates will remain at the conclusion of disposal
maneuvering. In addition, the application states that "very little pressure" will be left in the fuel
tanks. Please quantify the amount of pressure of the fuel tank at the conclusion of disposal
maneuvering, and indicate whether the fuel tank or other portions of the propulsion system will
be sealed in any manner, for example by a "normally closed" latch valve.

         2)     Concerning battery re—connection after end of operational life, the application
states that "a randomly tumbling satellite will keep the batteries at a low state of charge and will
reconnect the spacecraft bus and payload if the battery is sufficiently charged, avoiding an
overcharge condition." Please describe further the consequences of a potential battery
overcharge scenario. Would the re—connected spacecraft payload resume radiofrequency


transmission? Does Orbcomm have any means to permanently disable radiofrequency
transmission at end of life, regardless of battery re—connection? Can the batteries be completely
disconnected and left in a state of permanent discharge? If not, please explain why not.

        3)       Concerning safe flight profiles, we note that this application requests authority for
operation of the next generation Orbcomm satellites at an inclination of 51.6 degrees. This is the
same inclination as the International Space Station. We also note that the inclination of 51.6
degrees will be maintained even after the lowering of the perigee altitude at the end of mission.
Therefore, it is possible that the orbits of Orbcomm satellites could intersect the orbit of the
International Space Station. Please provide an analysis for the probability and frequency of
conjunctions between the each of the Orbcomm satellites and the ISS over the anticipated orbital
lifetime of the Orbcomm satellites.

        Accordingly, pursuant to Section 25.111(a) of the Commission‘s rules,‘ and Section
0.261 of the Commission‘s rules on delegations of authority," we require the supplementation of
the modification application of Orbcomm License Corp. within 30 days of the date of this letter,
with responses to the questions raised herein.


                                               Sincerely,
                                              off/—————
                                               Robert G. Nelson
                                               Chief, Satellite Division
                                               International Bureau




47 CF.R § 25.111(a).
°47 C.F.R § 0.261.



Document Created: 2011-12-06 14:21:29
Document Modified: 2011-12-06 14:21:29

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