ODAR Update Letter 0

LETTER submitted by Hiber, Inc.

Letter

2019-03-01

This document pretains to SAT-PDR-20180910-00069 for Petition for Declaratory Ruling on a Satellite Space Stations filing.

IBFS_SATPDR2018091000069_1631845

Hogan Lovells US LLP Columbia Square 555 Thirteenth Street, NW Washington, DC 20004 T +1 202 637 5600 F +1 202 637 5910 www.hoganlovells.com March 1, 2019 VIA ELECTRONIC FILING Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street S.W. Washington, D.C. 20554 Re: Hiber, Inc., Supplement to Orbital Debris Assessment Report IBFS File No. SAT-PDR-20180910-00069; Call Sign S3038 Dear Ms. Dortch: Hiber, Inc. (“Hiber”), through its counsel, submits this letter to update its orbital debris assessment report (“ODAR”) submitted on February 22, 2019.1 In Section 3.7 of the ODAR, Hiber calculated that two components of spacecraft were expected to survive reentry, the S-band antenna and the GPS antenna. With respect to the S-band antenna, Hiber had erroneously based its calculations assuming the antenna is made of ceramic when, in fact, the S-band antenna is made of anodized aluminum. Recalculating the reentry analysis using the correct material shows that the S-band antenna does not survive reentry. With respect to the GPS antenna, Hiber recalculated the impact energy for the GPS antenna using more precise measurements for its mass, rather than the worst- case assumptions originally used, and determined that the impact energy of the antenna with the more precise mass value is 7.62 joules, which is below the 15-joule NASA threshold.2 If you have any questions regarding this letter, please do not hesitate to contact me. Very truly yours, /s/Tony Lin Tony Lin Counsel to Hiber, Inc. cc: Karl Kensinger Stephen Duall 1 See Letter from Lynne Montgomery, Counsel to Hiber, Inc., to Jose Albuquerque (February 22, 2019). 2 See NASA Technical Standard, Process for Limiting Orbital Debris, NASA-STD-8719.14A (with Change 1) (May 25, 2012). Although not stated in the ODAR, using the worst-case mass assumption, the impact energy associated with the GPS antenna was calculated to be ~18 joules. Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia. “Hogan Lovells” is an international legal practice that includes Hogan Lovells US LLP and Hogan Lovells International LLP, with offices in: Alicante Amsterdam Baltimore Beijing Birmingham Boston Brussels Colorado Springs Denver Dubai Dusseldorf Frankfurt Hamburg Hanoi Ho Chi Minh City Hong Kong Houston Johannesburg London Los Angeles Luxembourg Madrid Mexico City Miami Milan Minneapolis Monterrey Moscow Munich New York Northern Virginia Paris Perth Philadelphia Rio de Janeiro Rome San Francisco São Paulo Shanghai Silicon Valley Singapore Sydney Tokyo Warsaw Washington DC Associated offices: Budapest Jakarta Shanghai FTZ Ulaanbaatar Zagreb. Business Service Centers: Johannesburg Louisville. For more information see www.hoganlovells.com


Document Created: 2019-03-01 08:49:55
Document Modified: 2019-03-01 08:49:55
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