RequestForExtensionO

REQUEST submitted by ORBCOMM License Corp.

Letter From Walter H. Sonnenfeldt

2012-01-04

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

IBFS_SATMOD2011102100207_932568

                                                     January 4, 2012




VIA IBFS

Robert Nelson, Chief
Satellite Division
International Bureau
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554


                              Re:        Application of ORBCOMM License Corp. For Authority to
                                         Modify its Non-Voice, Non-Geostationary Satellite Service
                                         Space Segment License (S2103) to Revise the Next-Generation
                                         Satellite Deployment Plan

                                         File No. SAT-MOD-20111021-00207

                                         REQUEST FOR EXTENSION OF TIME


Dear Mr. Nelson:

         On October 21, 2011, ORBCOMM License Corp. (“ORBCOMM”) filed the above-
referenced application (the “Modification Application”) to modify its Non-Voice, Non-
Geostationary Satellite Service FCC space segment license (FCC Call Sign S2103) to revise the
deployment plan for the eighteen currently authorized ORBCOMM Generation 2 (“OG2”)
satellites. The Modification Application was accepted for filing and placed on Public Notice on
December 2, 2011. 1 On December 6, 2011, the International Bureau requested that ORBCOMM
submit additional information to supplement the Modification Application on or before January
5, 2012 (the “Supplemental Information Request”). 2 For the reasons stated below, ORBCOMM
respectfully requests a sixty (60) day extension of time to respond to the Supplemental
Information Request.
1
         FCC Public Notice, Report No. SAT-00825, released December 2, 2011. As of the date of this submission,
no oppositions to the Modification Application have been entered in the IBFS record of the Modification
Application or served on ORBCOMM.
2
         December 6, 2011, Letter from Robert G. Nelson, Chief, Satellite Division, to Walter H. Sonnenfeldt and
Stephen L. Goodman, counsel for ORBCOMM License Corp.


2115 Linwood Avenue, Suite 100, Fort Lee, NJ 07024                      22265 Pacific Boulevard, Suite 200, Dulles, VA 20166
Telephone: 201-363-4900                                                                             Telephone: 703-433-6300
Facsimile: 703-433-6400                                                                             Facsimile: 703-433-6400

                                                      www.orbcomm.com


Robert Nelson, Chief
Satellite Division
International Bureau
Federal Communications Commission
January 4, 2012
Page 2 of 2



         Late last month, due in part to unforeseeable changed circumstances, ORBCOMM Inc.
and launch service provider Space Exploration Technologies (“SpaceX”) agreed to new revisions
of the planned deployment program for the eighteen currently authorized OG2 satellites. The
launch of the first OG2 spacecraft is now planned for mid-year 2012 as a secondary payload on
the first scheduled Falcon 9 Commercial Resupply Services (“CRS1”) NASA mission. Two
additional OG2 satellites are now planned for deployment later in 2012 in a high inclination orbit
as a secondary Falcon 9 payload. A dedicated Falcon 9 mission now planned for 2013 will
deploy at least eight additional OG2 satellites, with the remaining OG2 spacecraft to be deployed
by 2014. ORBCOMM and SpaceX are working to finalize the full details of the planned OG2
deployment plan revisions that are necessary to prepare a conforming amendment to the
Modification Application.

        Due to the above-described changed circumstances, and in the interest of administrative
efficiency, ORBCOMM is hereby requesting an extension of time to respond to the
Supplemental Information Request. Grant of this request will allow ORBCOMM to incorporate
the additional requested information as it relates to the revised OG2 deployment plan. This
should help to streamline the Commission’s review of the Modification Application, and thereby
serve the public interest, convenience, and necessity. Accordingly, there is good cause for grant
of the requested extension of time.

       Kindly direct any inquiries concerning this submission to the undersigned.

                                             Respectfully submitted,



                                             Walter H. Sonnenfeldt, Esq.
                                             Vice President, Regulatory Affairs
                                             ORBCOMM Inc.
                                             Direct Tel: (585) 461-3018
                                             E-Mail: sonnenfeldt.walter@orbcomm.com



Document Created: 2012-01-04 18:56:47
Document Modified: 2012-01-04 18:56:47

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