Attachment Spaceflight - Commis

Spaceflight - Commis

LETTER submitted by IB, FCC

Letter

2010-10-06

This document pretains to SAT-STA-20150821-00060 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2015082100060_1106765

                                Federal Communications Commission
                                           Washington, D.C. 20554


                                                 October 6, 2015




Jonathan L. Wiener
Goldberg Godles Wiener & Wright LLP
1229 19°" Street, NW
Washington, D.C. 20036

                                             Re: Spaceflight, Inc. Application for Special Temporary
                                             Authority to Communicate with the SHERPA spacecraft
                                             IBFS File No. SAT—STA—20150821—00060

Dear Mr. Wiener:

     On August 21, 2015, Spaceflight, Inc. filed an application for special temporary authority to
communicate with a non—geostationary orbit space station to be known as SHERPA. The application
describes SHERPA as a spacecraft with a payload consisting of auxiliary satellites for deployment, and
seeks to use the 401.5 MHz (space—to—Earth) and 450.2 MHz (Earth—to—space) frequencies for
communications with SHERPA while the deployments take place.‘ The request states that SHERPA will
be placed in a sun synchronous, elliptical orbit with an apogee of 720 kilometers and a perigee of 450
kilometers. To aid the Commission‘s evaluation of the application, please provide the following
supplemental information:*

     1.   Publicly—available information indicates that there will be approximately eighty—seven (87)
          satellites on board to be deployed from SHERPA. Please provide a list of the satellites planned
          for deployment. Please also indicate the authorizing administration or administrations, current or
          planned (under the United Nations Outer Space Treaties* and International Telecommunication
          Union Radio Regulations) for each space object to be deployed.

    2. The Technical Annex states that "[t}he confirmation of successful payload deployment is given
       by the transmission of telemetry containing SHERPA state vectors taken upon each discrete
       deployment event."" Please provide additional detail concerning the specific "state vectors."
       Will this information be shared with the Department of Defense‘s Joint Space Operations Center
       (JSpOC)?



! See Application, Technical Annex at 2.

2 See Application, Narrative.

347 CFR. § 25.111(a).

* See, eg., the Treaty on Principles Governing the Activities of States in the Exploration and Use of Outer Space,
Including the Moon and Other Celestial Bodies, Article 6.

* Application, Technical Annex at 1.


        3.   Please address whether SHERPA could accomplish its mission while attached to the upper stage
             of the launch vehicle. Does the physical configuration of SHERPA permit such deployment?

        4.    Please also provide the following supplemental information related to the orbital debris
             mitigation plan submitted with the application:
             a.   The Technical Annex states that the inclination of the spacecraft will be 97.4°, but the orbital
                  debris assessment states that the inclination will be 97.8°.° Please correct the discrepancy
                  and, if necessary, update affected portions of the orbital debris assessment.
                  The Narrative and Technical Annex state that the operational lifetime of the spacecraft will
                  be 12 hours, but the orbital debris assessment states that the operational lifetime will be 6
                  hours." Please correct the discrepancy.
                  Please indicate whether a casualty risk assessment using higher fidelity methods can be
                  reasonably expected to predict demise of all components during re—entry, except for
                  components that would impact with an energy of less than 15 joules. If so, please provide
                  that analysis. You may wish to take into consideration the breaking up into smaller
                  components of the spacecraft upon re—entry.
                  Please provide the estimated orbital lifetime of SHERPA assuming that none of the payload
                  spacecraft deploy from SHERPA.           f
             e.   What insurance will be obtained for SHERPA operations and spacecraft re—entry?

        To facilitate the Commission‘s timely evaluation of Spaceflight, Inc.‘s application, we ask that
you provide the requested information no later than November 2, 2015.

                                                                Sincerely,


                                                          ~Xose        NM%M uo
                                                           ~—*~Jose P. Albuquerque
                                                                Chief, Satellite Division
                                                                International Bureau

cc: Indra Hormsby, General Counsel, Spaceflight, Inc.




6 Application, SHERPA Orbital Debris Assessment Report (ODAR) at 5.

? 1d.



Document Created: 2015-10-06 13:29:40
Document Modified: 2015-10-06 13:29:40

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