Attachment Orbcomm License - Co

Orbcomm License - Co

REQUEST submitted by IB,FCC

Additional Information Request

2012-05-03

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

IBFS_SATMOD2011102100207_950834

                                       Federal Communications Commission
                                              Washington, DC 20554


International Bureau




                                                    May 3, 2012


        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. (Orbcomm) filed the referenced
        application to modify the license for Orbcomm‘s non—voice, non—geostationary, low—Earth orbit
        satellites. On December 6, 2011, the Satellite Division requested that Orbcomm file a
        supplement by to address questions regarding orbital debris issues. On January 18, 2012, the
        Satellite Policy Branch granted Orbcomm an extension of time to respond, to March 5, 2012. On
        that date, Orbcomm requested a further extension of time, to June 5, 2012, to supplement and
        amend its modification application.

                 We deny the request for further extension. In its request, Orbcomm claims that its
        deployment plans have changed and it has not yet been able to finalize a revised deployment plan
        for its new satellites in sufficient detail to prepare an amendment to the pending modification
        application. We find this explanation irrelevant to the questions asked in the Division‘s letter.
        The three questions in that letter concern: (1) the quantity of fuel in the fuel tank on Orbcomm‘s
        proposed satellites at end of life; (2) the risk of a potential re—connection scenario following end
        of life; and (3) the risks attendant with Orbcomm‘s plan to operate its next generation satellites at
        an inclination of 51.6 degrees, the same inclination as the International Space Station. These
        questions can be answered for Orbcomm‘s next generation satellites regardless of the timing or
        means of their deployment.


        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," your request for further extension
of time is denied, and we require the supplementation of Orbcomm License Corp.‘s modification
application within 15 days of the date of this letter, with responses to the questions in the
Satellite Division‘s December 6, 2011 letter. Failure to respond in that time period may lead to
dismissal of the modification application."




                                           AZ/_—————
                                            Sincerely,


                                               bert G. Nelson
                                            Chief, Satellite Division
                                            International Bureau




147 CFR § 25.111(a).
247 CFR § 0.261.
‘47 CF.R. § 25.112(c).



Document Created: 2012-05-03 14:51:27
Document Modified: 2012-05-03 14:51:27

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