Attachment Exhibit D

This document pretains to SAT-MOD-20181214-00090 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2018121400090_1590717

                                            Exhibit D

                                   Description of Application

         Ligado hereby requests an extension of the license term of MSAT-2 for two years,
through December 31, 2020. Since Ligado has launched and commenced operations of SkyTerra
1, the replacement satellite for MSAT-2,1 MSAT-2 has served as a backup for SkyTerra 1. All
customers have been transitioned to SkyTerra 1, and MSAT-2 currently does not carry customer
traffic. MSAT-2 remains capable of operation and continues to be a suitable backup satellite for
SkyTerra 1 customers,2 some of which provide service to government and public safety entities.
MSAT-2 recently has been moved to 106.5 W.L. and has authority to operate from this location
until December 31, 2018.3

        Ligado estimates that the end of fuel life for MSAT-2 operations is June 2028. Ligado
has confirmed that, at the conclusion of the requested extension period, MSAT-2 will have
sufficient fuel to de-orbit to a disposal altitude that complies with the Inter-Agency Space Debris
Coordination Committee standard, as stated in the MSAT-2 orbital debris mitigation plan.4 In
addition, the MSAT-2 satellite telemetry, tracking, and command (“TT&C”) system and
associated hardware continue to perform nominally with full redundancy available. Ligado has
assessed the current health and performance status of the MSAT-2 satellite and reviewed
possible risks associated with continued satellite operational activities. At this time, Ligado has
no knowledge of any single point of failure or other malfunctions, defects, or anomalies that
have occurred to date that would affect its ability to conduct and complete the required end-of-
life and de-orbit procedures.

        The proposed extension therefore would not impact the orbital debris mitigation plan for
the satellite. The Commission previously has granted similar requests to extend the license term
of MSAT-2,5 and granting the instant request similarly would serve the public interest.




1
       See Report No. SAT-00759 (Feb. 18, 2011).
2
       See, e.g., Annual Satellite Status Report, Call Signs AMSC-1 and S2358 (June 29, 2012)
       (documenting the transition of SkyTerra 1 customers to MSAT-2 when unusually intense
       solar activity temporarily impacted operations of SkyTerra 1).
3
       See Stamp Grant, IBFS File No. SAT-MOD-20180912-00070 (granted Nov. 29, 2018).
4
       See IBFS File No. SES-MFS-20070530-00731, Technical Narrative at 35-36.
5
       See Stamp Grant, IBFS File No. SAT-MOD-20171215-00172 (granted Jan. 23, 2018);
       Stamp Grant, IBFS File No. SAT-MOD-20151218-00083 (granted Feb. 11, 2016); Stamp
       Grant, IBFS File No. SAT-MOD-20141212-00128 (granted May 14, 2015); Stamp Grant,
       IBFS File No. SAT-MOD-20131204-00143 (granted Feb. 11, 2014); Stamp Grant, IBFS
       File No. SAT-MOD-20121128-00203 (granted Jan. 24, 2013).



Document Created: 2018-12-14 10:05:34
Document Modified: 2018-12-14 10:05:34

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