PAC 1_65 Letter 2016

LETTER submitted by Panasonic Avionics Corporation

Section 1.65 Letter

2016-01-12

This document pretains to SES-MFS-20150609-00349 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2015060900349_1122319

LMI Advisors 8601 James Creek Drive Springfield, VA 22152 Carlos M. Nalda T: +1 571 332 5626 cnalda@lmiadvisors.com January 7, 2016 Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, SW Washington, D.C. 20554 Re: Panasonic Avionics Corporation – Section 1.65 Submission, Response to FCC Letter dated Nov. 12, 2015, Call Sign E100089, File Nos. SES-MFS-20150609-00349 and SES-AFS-20150820-00538 Dear Ms. Dortch: Panasonic Avionics Corporation (“Panasonic”), in connection with the above-referenced earth station aboard aircraft (“ESAA”) application and pursuant to Section 1.65 of the Commission’s Rules, 47 C.F.R. § 1.65, hereby responds to a letter from the Commission dated November 12, 2015.1 In the letter, the Commission requested clarification of certain information in Panasonic’s ESAA application, including: (i) the orbital range associated with the Eutelsat 70B coordination letter; (ii) additional information regarding orbital debris mitigation for the Eutelsat 70B, Yamal 401 and NSS-6 satellites; (iii) given the relocation of Yamal 300K and resulting service to earth stations located in the United States, information showing that operation of the satellite is consistent with requirements for U.S.-licensed systems operating in the United States; and (iv) the name of the relevant ITU satellite network filings and administrations for the Eutelsat 70B, JCSAT-5A, Yamal 401, Yamal 300K and NSS-6 satellites.2 With the exception of item (iii), which must be addressed in a formal application amendment, this submission provides the requested clarifications and additional information. 1 See Letter from Jose Albuquerque, Chief, Satellite Division, International Bureau to Carlos M. Nalda, LMI Advisors, Call Sign E100089, File Nos. SES-MFS-20150609-00349 and SES-AFS- 20150820-00538 (Nov. 12, 2015). 2 See generally id.

Panasonic hereby confirms that the statement of Eutelsat regarding consistency of the proposed operations with “existing satellite coordination agreements with the adjacent satellites to Eutelsat 70B” includes adjacent satellites within +/-6 degrees of orbital separation from the Eutelsat 70B satellite in accordance with Section 25.227(b)(2)(ii) of the Commission’s rules. Panasonic also provides the following clarifications and additional information regarding the orbital debris mitigation plans for the Eutelsat 70B, Yamal 401 and NSS-6 satellites:  Eutelsat 70B: In the Eutelsat 70B Space Debris Mitigation Plan, Section 4.A contains a table which shows predicted masses of materials at end-of-life. The table summarises the amount of propellant and/or pressurant that cannot be expelled/used (the so-called “residuals”). As explained in the Mitigation Plan, once the orbit raise activity is completed, Eutelsat continues its efforts to empty fuel and oxidizer tanks as much as possible. As part of this exercise, some of the predicted residuals will be expelled so final mass of residuals should be smaller than those appearing in the table. However, Eutelsat cannot guaranty or quantify with specificity the amount that may be expelled during this process. For this reason, the predicted values in the table should be viewed as worst-case values for purposes of the Commission’s orbital debris mitigation assessment.  Yamal 401: The Commission requested that Panasonic confirm or correct the figures in the table in the appendix of the Yamal 401 Orbital Debris Mitigation Plan. Panasonic has communicated with the satellite operator and provides the following updated table (new information is reflected in bold/underlined text). Item Purpose Tank Number of Tanks / Initial End of life Tank End-of- Volume Interconnected mass of mass/ pressure life item per volume rating / pressure tank units Hydrazine Attitude 26 liters 3 Tanks / 25 kg 0.7 kg/ 8.1 atm NA (liquid) control BOL Interconnected 0.7 l 0.7 litre EOL Fuel and Nitrogen Pressurant 14 liters pressurant are 0.25 kg 0.25 kg/ 8.1 atm 2.9 atm BOL located in 39,3 l 39.3 liters common tank and EOL separated by internal membrane. Xenon Orbit 38 liters 4 / Yes 71 kg in 1 kg 140 atm 2.6 atm control each in each tank tank In addition, the Commission requested confirmation of the temperature(s) at which end- of-life pressures were calculated. The satellite operator informed Panasonic that the temperature for calculation of the updated end-of-life pressure (i.e., Nitrogen) is 291°K. 2

 NSS-6: The Commission requested that Panasonic provide the type and mass of any residual pressurant in the NSS-6 satellite’s oxidizer tanks, and the type of oxidizer in them. The pressurant in the tanks is Helium with a mass of 1.398 kg. The type of oxidizer is MON-3 (N2O4 with 3% NO2). Panasonic further provides the chart below to summarize the relevant ITU satellite network filings and administrations requested by the Commission: Satellite ITU satellite network Administration name E70B EUTELSAT 3-70.5E France JCSAT-5A N-STAR-A Japan Yamal-300K NSS-19 Netherlands Yamal-401 EXPRESS-7C Russia NSS 6 NSS-9 Netherlands Finally, with respect to the information showing that operation of the Yamal 300K satellite is consistent with requirements for U.S.-licensed systems operating in the United States, Panasonic has filed a separate application amendment to formally submit this information (including Schedule S data) in the docket of its ESAA application.3 Please do not hesitate to contact the undersigned with any questions regarding this submission. Thank you very much for your continued consideration. Respectfully submitted, Carlos M. Nalda LMI Advisors cc: Jose Albuquerque, FCC Paul Blais, FCC 3 See IBFS Submission ID IB2016000036 (Jan. 7, 2016). 3


Document Created: 2016-01-12 20:57:47
Document Modified: 2016-01-12 20:57:47
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