Attachment Panasonic - Commissi

Panasonic - Commissi

REQUEST submitted by IB, FCC

Request for additional information

2015-11-12

This document pretains to SES-AFS-20150820-00538 for Amendment Foreign Satellite App on a Satellite Earth Station filing.

IBFS_SESAFS2015082000538_1115230

                             Federal Communications Commission
                                      Washington, D.C. 20554




                                            November 12, 2015

Mr. Carlos M. Nalda
LMI Advisors
8601 James Creek Drive
Springfield, VA 22201

                                     Re:      Panasonic Avionics Corporation
                                              IBFS File Nos. SES—MFS—20150609—00349,
                                              SES—AFS—20150820—00538
                                              Call Sign: E100089

Dear Mr. Nalda:

        On June 6, 201 5, Panasonic Avionics Corporation (Panasonic) filed the above—captioned
application to modify its existing blanket license for earth stations aboard aircraft (ESAA)
operating in the Ku—band. An amendment to the application was subsequently filed on August
20, 2015. In its modification application, among other things, Panasonic seeks to designate the
Eutelsat 70B, Galaxy 16, JCSAT—5A, Yamal 401, Yamal 300K, and NSS—6 satellites as points of
communication. To facilitate our processing of the application and associated amendment, we
request that Panasonic supplement its application as described below.

        In its application, Panasonic has provided a letter from Eutelsat relevant to communications
with Eutelsat 70B, as required pursuant to Section 25.227(a)(2) and 25.227(b)(2) of the
Commission‘s rules.‘ This letter includes a statement that the proposed operations of Panasonic‘s
transmit/receive terminals at the power density levels defined in the agreement between
Panasonic and Eutelsat are "consistent with existing satellite coordination agreements with the
adjacent satellites to Eutelsat 70B."" Consistent with Section 25.227(b)(2)(ii) of the
Commission‘s rules, we ask that Panasonic confirm with Eutelsat that these coordination
agreements include adjacent satellite systems within + 6 degrees of orbital separation from
Eutelsat 70B




! See Application of Panasonic Avionics Corp. to Modify Ku—Band Earth Stations Aboard Aircraft (ESAA)
Blanket License, Technical Appendix at A—1:C (Panasonic Modification Application). IBFS File No. SES—
MFS—20150609—00349.
2 Id.
> 47 CFER. § 25.227(b)(2)(ii). Section 25.227(b)(2)(ii) requires a "statement from the target satellite
operator certifying that the power density levels that the ESAA applicant provided to the target satellite
operator are consistent with the existing coordination agreements between its satellite(s) and the adjacent
satellite systems within 6° of orbital separation from its satellites."


                                 Federal Communications Commission



    As part of its request, Panasonic also requests waiver of Section 25.283(c)* of the
 Commission‘s rules for Eutelsat 70B, JCSAT—5A, Yamal 401K, and NSS—6. We ask that
Panasonic provide the following additional information regarding orbital debris mitigation to
enable us to determine whether the public interest is served by grant of its request to designate the
Eutelsat 70B, Yamal 401, and NSS—6 satellites as points of communication:

               (1) Eutelsat 70B. In the Eutelsat 70B Orbital Debris Mitigation and Satellite End—of—
Life Statement, Section 4.A of the Eutelsat 70B Space Debris Mitigation Plan provides a table
showing the predicted masses of materials at End of Life, which we understand to be the masses
before passivation, and states that the fuel and oxidizer tanks will be emptied as far as possible
during passivation." We request that Panasonic provide the predicted masses of remaining
materials after passivation, when the spacecraft has been switched off.

            (2) Yamal 401. We request that Panasonic confirm or correct the figures inthe table
in the appendix of the Yamal 401 Orbital Debris Mitigation Plan for the nitrogen pressurant and
xenon propellant, and state the temperature(s) at which the end—of—life pressures were computed.

           (3) NSS—6. The NSS—6 Orbital Debris Mitigation Plan contains a table in the section
addressing 47 C.F.R. §25.114(d)(14)(ii) that lists the volumes of the two oxidizer tanks, and the
pressures, temperatures, and masses of oxidizer in the these tanks." This table does not appear to
account for residual pressurant that may remain in the oxidizer tanks, nor is the type of oxidizer
specified. We request that Panasonic provide the type and mass of any residual pressurant in
these tanks, and the type of oxidizer in them.

     Further, we note that Panasonic has requested to communicate with the Yamal 300K satellite
at its new orbital location of 177 degrees W.L., including for service to earth stations in the
United States. Panasonic has also indicated that it will employ an associated gateway earth
station located in Brewster, Washington, for operations with the Yamal 300K. satellite." We view
the proposed operations as a request for access to the United States market by a non—U.S.—licensed
space station.‘" Accordingly, Panasonic must provide the Commission with information showing
that the operations of Yamal 300K are consistent with all the Commission requirements for a
U.S.—licensed system operating in the United States, including, but not limited to, an FCC Form
312 Schedule S."

447 C.F.R. § 25.283(c). Section 25.283(c) requires that upon a spacecraft completing its mission, a space
station licensee shall ensure, unless prevented by technical failures beyond its control, that all stored energy
sources on board the satellite are discharged, by venting excess propellant, discharging batteries, relieving
pressure vessels, and other appropriate measures.
* Panasonic Modification Application at Technical Appendix at A—1:D: "Eutelsat 70B Orbital Debris
Mitigation and End—of—Life Statement" at 6—7 of 7 and Table.
6 Id. at A—4:D: "Yamal—401 Orbital Debris Mitigation Plan" at Appendix.
? Id. at A—6:D:; "NSS—6 Orbital Debris Mitigation Plan" at 3 of 5.

8 Panasonic Modification Application, Narrative at 3, Table 1.
* Id. at 9, Table 2.
i0 See 47 C.F.R. § 25.137; In the Matter ofAmendment ofthe Commission‘s Regulatory Policies to Allow
Non—U.S. Licensed Space Stations to Provide Domestic and International Satellite Service, Report and
Order, IB Docket 96—111, 12 FCC Red 24094, 24175, at 189 (1997) (DISCO I7).
U See 47 C.FR. § 25.137(d); 47 C.F.R. § 25.114.


                              Federal Communications Commission


     Additionally, please submit the name of the relevant International Telecommunication Union
(ITU) satellite network filing and administration‘* for the following requested points of
communication: Eutelsat 70B, JCSAT—5A, Yamal 401, Yamal 300K, and NSS—6.

     Please submit the requested information by December 14, 2015. Failure to do so may result
in the dismissal of the portion of the application that seek to designate the Eutelsat 70B, JCSAT—
5A, Yamal 401, Yamal 300K, and NSS—6 satellites as points of communication pursuant to
Section 25.112(c) of the Commission‘s rules."

                                                 Sincerely,




                                               _ Jobe P. Albuquerqtie
                                                 Chief, Satellite Division
                                                 International Bureau




2 See ITU Radio Regulations, No. 1.2.
147 CFR. § 25.112(c).



Document Created: 2015-11-12 14:37:57
Document Modified: 2015-11-12 14:37:57

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