ESAA Application Sup

SUPPLEMENT submitted by The Boeing Company

Satellite points of communication authorizations

2014-10-01

This document pretains to SES-LIC-20140922-00748 for License on a Satellite Earth Station filing.

IBFS_SESLIC2014092200748_1063502

                                                  51 LOUISIANA AVENUE, N.W. • WASHINGTON, D.C. 20001.2113

                                                  TELEPHONE: +1.202.879.3939 • FACSIMILE: +1.202.626.1700


                                                                                                                                                     Direct Number: (202) 879-3630
                                                                                                                                                         bolcott@jonesday.com


                                                                           October 1, 2014
BY ELECTRONIC FILING

Paul Blais
System Analysis Branch
Satellite Division
International Bureau
Federal Communications Commission
445 12th Street SW
Washington, DC 20554


                                      Re:           IBFS File No. SES-LIC-20140922-00748
                                                    Supplement Summarizing FCC Authorization
                                                    for Satellite Points of Communication

Dear Mr. Blais,

        In the above-captioned application, The Boeing Company (“Boeing”) seeks authority to
operate up to 100 Earth Stations Aboard Aircraft (“ESAA”) with nine satellites.1 Under Section
25.137 of the Commission’s rules, requests to communicate with non-U.S. licensed satellites
must either provide the orbital debris mitigation information required by Section 25.114(d)(14)
of the Commission’s rules or demonstrate that the space station has been previously authorized
through the listing of the satellite on the Permitted Space Station List (“Permitted List”) or its
inclusion as a point of communication in a granted authorization.2

        In the table on the following page, Boeing summarizes the apparent Commission
authority for communication with each of the requested satellite points of communication. One
of the requested satellites, Eutelsat 36B (“E36B”), does not appear to have been previously
authorized by the Commission as a point of contact. Accordingly, Boeing provides the orbital
debris mitigation plan for E36B as Attachment 1. Boeing also provides the coverage area of the
relevant E36B satellite beam as Attachment 2.


1
 Application of The Boeing Company for Authority to Operate Up to 100 Earth Stations Aboard Aircraft, File No.
SES-LIC-20140922-00748 (Filed Sep. 22, 2014) (“Boeing ESAA Application”).
2
 47 CFR § 25.137; 47 CFR § 25.114(d)(14); see also Disclosure of Orbital Debris Mitigation Plans, Public Notice,
DA 05-2698 (Oct. 13, 2005).




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October 1, 2014
Page 2


        Satellite     Orbital            Authorization for Access by U.S. Entity
                      Location
  AMC-15               105° W.                     U.S. Licensed
                                    SAT-LOA-20030219-00013 (Granted Aug. 18, 2004)
  E36B (formerly        36° E.
                                   Orbital debris mitigation information submitted herein
  Eutelsat W7)
  Eutelsat 7A           7° E.          Granted as authorized point of communication
                                       0137-EX-ST-2012 (Granted March 1, 2012).
  Eutelsat 172A        172° E.         Granted as authorized point of communication
                                     SES-MFS-20120913-00818 (Granted Jul. 24, 2013)
  Intelsat 907         27.5° W.                   U.S. Licensed
                                    SAT-LOA-20000119-00025 (Granted Aug. 2, 2000)
  SES-1                101° W.                     U.S. Licensed
                                    SAT-RPL-20100120-00014 (Granted Apr. 20, 2010)
  Superbird C2         144° E.        Granted as authorized point of communication
                                    SES-MFS-20130930-00845 (Granted Sept. 24, 2014)
  Telesat-11N          37.5° W.       Granted as authorized point of communication
                                    SES-MFS-20100715-00903 (Granted Dec. 23, 2010)
  E113WA (formerly     113 W.                      Permitted List
  SatMex 6)                          SAT-PPL-20060329-00030 (Granted Aug. 4, 2006)

      Please let us know if you have questions about any of the above.

                                                  Very truly yours,



                                                  _____________________
                                                  Bruce A. Olcott


     ATTACHMENT 1


Orbital Debris Mitigation Plan
      For Eutelsat 36B


                                         Eutelsat 36B Space                Issue/Rev No.: Issue 1, Rev. 0
    é,*     eutelsat
            emmuntinhizc bis sabétiile
                                             is Mitigation
                                         ebris    Miticati Plan                   Date: 23 July 2014
                                                                                                            Page 1




                  Eutelsat 36B Space Debris Mitigation Plan (prepared
                     for the Federal Communications Commission)




                                              ISSUE/REVISION: Issue 1, Rev. 0
                                                    ISSUE DATE: 23 July 2014




 Prepared by:                            Position                   Signature                     Date

D. Zamora                    Head of Flight
                             Dynamics                          S )».‘E %                   3/ C 2/wy11




Approved by:                             Position                   Signature                     Date

L.R. Pattinson              Director of Satellite
                            Operations                       f; %""/—_’                    2»| +/ 14
                                                                  w.1. Scuucte




   RESTRICTED TO EUTELSAT AND THE FEDERAL COMMUNICATIONS
                         COMMISSION


                    Eutelsat 36B Space             Issue/Rev No.: Issue 1, Rev. 0
                   Debris Mitigation Plan
                                                          Date: 23 July 2014
                                                                                    Page 2




                                   CHANGE RECORD




     Date   Issue/rev   Pages affected               Description



17/7/2014   1/0         All                          First issue.




 RESTRICTED TO EUTELSAT AND THE FEDERAL COMMUNICATIONS
                       COMMISSION


                                           Eutelsat 36B Space                                                    Issue/Rev No.: Issue 1, Rev. 0
                                          Debris Mitigation Plan
                                                                                                                             Date: 23 July 2014
                                                                                                                                                                                Page 3




                                                                    TABLE OF CONTENTS


1.   INTRODUCTION .................................................................................................................................................... 4
2.   RELATED DOCUMENTS........................................................................................................................................4
     2.1.     APPLICABLE DOCUMENTS .................................................................................................................................................... 4
     2.2.     REFERENCE DOCUMENTS...................................................................................................................................................... 4
3.   EUTELSAT 36B OPERATIONS ............................................................................................................................4
4.   EUTELSAT 36B END­OF­LIFE DISPOSAL ....................................................................................................... 5
5.   NOTIFICATIONS.................................................................................................................................................... 7




 RESTRICTED TO EUTELSAT AND THE FEDERAL COMMUNICATIONS
                       COMMISSION


                           Eutelsat 36B Space                Issue/Rev No.: Issue 1, Rev. 0
                          Debris Mitigation Plan
                                                                    Date: 23 July 2014
                                                                                              Page 4




1. Introduction
This document describes the space debris mitigation plan that Eutelsat shall apply to the
Eutelsat 36B (“E36B”) space station.
E36B is based on the Thales Alenia Space Spacebus 4000 bus and it was manufactured
according to European standards and specifications. The satellite is 3-axis stabilized and
uses bi-propellant chemical propulsion for attitude and on-station control.
E36B was launched in 2009 and the end of its operational life is not expected to be before
mid 2026.



2. Related documents
2.1. Applicable Documents
1. EUTELSAT Space Debris Mitigation Plan. Issue 1.3.
EUT_CTL_SAT_QMS_PLN_00021, 26 July 2010.
2. FCC. Orbital Debris Mitigation Standard Practices. FCC 04‐130. June 21, 2004.


2.2. Reference Documents
1. European Code of Conduct for Space Debris Mitigation. Issue 1.0. 28 June 2004.
2. IADC Space Debris Mitigation Guidelines. IADC‐02‐01. Revision 1. September 2007.
3. Space Product Assurance. Safety. ECSS‐Q‐40A. 19 April 1996.
4. Orbital Debris Mitigation Standard Practices. FCC 04‐130. 21 June 2004.
5. NASA Safety Standard. Guidelines and Assessment Procedures for limiting Orbital
   Debris. NSS 1740.14. Aug 1995.
6. ITU Environment Protection of the Geostationary Orbit. S.1003. 1993.
7. UNCOPUOS. Technical Report on Space Debris. 1999.


3. Eutelsat 36B operations
-     Eutelsat operates in order to control and limit the amount of debris released in a
      planned manner during normal operations, and assesses and limits the probability of the
      space station becoming a source of debris by collisions with small debris or meteoroids
      that could cause loss of control and prevent post-mission disposal.
    - Eutelsat has assessed the amount of debris released in a planned manner and no
      intentional debris will be released during normal operations of the E36B spacecraft. A safe
      operational configuration of the satellite system is ensured thanks to the hardware design
      and operational procedures


    RESTRICTED TO EUTELSAT AND THE FEDERAL COMMUNICATIONS
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                           Eutelsat 36B Space                 Issue/Rev No.: Issue 1, Rev. 0
                          Debris Mitigation Plan
                                                                     Date: 23 July 2014
                                                                                               Page 5

-    Eutelsat minimizes the probability of the satellite becoming a source of debris by
     collisions with large debris or other operational satellites. Eutelsat assessed for E36B
     whether there were any known satellites located at the requested orbital location or might
     overlap.
-    E36B is controlled within its ITU allocated orbit control window (35.9°E +/- 0.1°) by
     standard routine periodic orbit correction maneuvers. In case of anticipated violation of
     the window, correction maneuvers would be implemented to avoid such violation.
-    Eutelsat has assessed the probability of accidental explosions during and after completion
     of mission operations. Thanks to design safety margins and enough safety barriers, the
     probability of occurrence of accidental explosion of the E36B satellite is negligible.
-    Satellite design is such that high levels of thruster activity and orbit perturbation do not
     result when foreseeable on-board events occur.



4. Eutelsat 36B End­of­Life Disposal
The post‐mission disposal activities have been planned as follows:

     1. The orbit of the satellite will be raised by 300 km in order to ensure that the spacecraft
        will not re-enter into the GEO protected region (GEO height +/- 200 km) in the long
        term. A mass of 13.7 kg of propellant have been allocated and reserved with a
        confidence level of 99% to carry-out the post-mission disposal maneuvers. The FCC
        will be informed of any significant change to the above quantity of propellant.

        The minimum perigee height to avoid re-entering into the GEO protected region can
        be computed using the IADC formula applied to this satellite:

                            ÄH (km) = 235 + 1000.(A/m)eff = 272 km

        where the final term is the effective area/mass ratio of the satellite. Therefore, the
        planned 300 km above GEO height is sufficient to satisfy the 272 km requirement.

        During the satellite lifetime, Eutelsat determine the remaining propellant tanks.

     2. As part of the end of life (EOL) activities, E36B energy sources will be rendered
        inactive, such that debris generation will not result from the conversion of energy
        sources on board the spacecraft into energy that fragments the satellite. For E36B, this
        involves the following:




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                          COMMISSION


                     Eutelsat 36B Space                 Issue/Rev No.: Issue 1, Rev. 0
                    Debris Mitigation Plan
                                                               Date: 23 July 2014
                                                                                         Page 6



   A. Depleting the chemical propulsion system, and where possible leaving open fuel
   lines and valves. Eutelsat 36B satellite includes two (2) interconnected helium tanks.
   Before switch-off of the E36B satellite, thrusters will be fired as much as possible to
   deplete the propellant and depressurize the tanks. The Orbital Debris Plan for E36B
   satellite states that “where possible” fuel lines and valves will be left open.

   The following table shows the characteristics of the pressurant tank, propellant tanks
   and propellant lines at EOL. It shall be noted that during the passivation the four
   propellant tanks will be depressurized as much as possible.

                                   Total       Material         Predicted mass
               Element            Volume     contained at        of material at
                                    (l)         EOL                EOL (kg)
                                                MON-1                  9.5
        MON-1 Propellant tank      1391
                                                  He                   2.7
                                                 MMH                   2.2
         MMH propellant tank       1391
                                                  He                   2.8
              MON-1 lines           0.65        MON-1                  1.0
               MMH lines            0.65         MMH                   0.6
           Pressurant tank 1         90           He                   1.1
           Pressurant tank 2         90           He                   1.1

   Eutelsat employs a combination of methods, including bookkeeping and PVT
   measurements and, where possible, measurements of tanks thermal inertia, to
   calculate the predicted EOL mass values. The figures in the last column of the Table
   can be considered as worst-case post-passivation remaining mass for MON and MMH
   after final shutdown of the satellite. They correspond to the static residuals of MON
   and MMH at the end-of-life. The helium pass in the pressurant tanks corresponds to
   the value measured at the end of launch and early orbit phase (“LEOP”). The
   pressurant tank is isolated just after the completion of LEOP operations and cannot be
   passivated as part of the EOL operations.

   The residual pressure statement (less than 1 bar) corresponds to temperatures between
   20° C and 30° C. The predicted pressures at end-of-life for the remaining materials are
   as follows: 13.2 bars before passivation for MON-1 propellant tank; 12.7 bars before
   passivation for MMH propellant tank; and 79 bars for pressurant tank 1 and 2. The
   EOL values given for masses and pressures and temperatures are when the satellite is
   taken out of service. Then, Eutelsat starts the orbit raise activity and finishes the
   passivation exercise by emptying the fuel and oxidizer tanks as far as possible. During
   the satellite life, Eutelsat performs gauging activities to monitor the remaining liquid
   quantities to determine the remaining masses in the tanks.



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                      COMMISSION


                           Eutelsat 36B Space                  Issue/Rev No.: Issue 1, Rev. 0
                          Debris Mitigation Plan
                                                                      Date: 23 July 2014
                                                                                                Page 7




      The passivation exercise is not a closed system due to the fact that matter is
     expelled. Eutelsat expels the remaining liquid as it evaporates at lower pressures, then
     expels as much pressurant as possible to lower the tank pressures down to 1 bar or
     below. All the tanks have been designed, manufactured, and validated according to the
     MIL-STD-1522 standard with a break-up security coefficient of 1.5 for the whole mission;
     i.e., including full-load and maximum-pressure conditions. Clearly, the security coefficient
     is much higher than this (probably in orders of magnitude) for depleted conditions where
     the pressure is around 1 bar, but no analysis exists to provide the actual value.

     The design of the Eutelsat 36B spacecraft, fully consistent with EOL passivation
     requirements as existed at the time of construction, does not allow passive venting once
     the spacecraft has been switched-off. The thruster propellant flow control valves for the
     MMH and MON1 tanks are left closed after switching off the spacecraft because power is
     needed to open them. Therefore, none of the elements that appear on the previous Table
     can be vented over time once the spacecraft has been switched-off. Nevertheless, as part
     of the passivation of the spacecraft during the EOL operations, Eutelsat always makes
     best efforts to vent the propellant remaining in the propellant tanks and lines as much as
     possible.

     Additionally, it should be noted that the Lithium-Ion batteries mounted on this satellite
     cannot be depressurized. Nevertheless, they have been designed with a security
     coefficient greater than 3 and the batteries are “leak before burst” designed. The
     heatpipes, which use ammonia as working fluid, cannot be depressurized either. They
     have been designed with a security coefficient greater than 4, the risk of break-up is
     considered negligible.

     B. Leaving all batteries in a state of permanent discharge by isolation of the battery
     charge circuits and leaving certain loads connected to the batteries.


3.       The satellite tracking, TM and TC usage are planned so as to avoid electrical
     interference to other satellites and coordinated with any potential affected satellite
     networks.

4.       During the orbit raising maneuvers the tracking, TM and TC frequencies will be
     limited to those where the satellite is authorized to operate.

5. Notifications
EUTELSAT undertakes to provide the relevant bodies as required (UNCOPUOS, FCC,
ITU, French ANFR, etc) with all appropriate notifications as required by law or regulations
for Eutelsat satellites including but not limited to those concerning initial entry of service,
location, relocations, inclined orbit operations and re-orbiting operations.


 RESTRICTED TO EUTELSAT AND THE FEDERAL COMMUNICATIONS
                       COMMISSION


      ATTACHMENT 2


Eutelsat 36B Coverage Footprint



Document Created: 2014-10-01 11:27:14
Document Modified: 2014-10-01 11:27:14

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