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March 14, 2002

RE: Mitigation of Orbital Debris, Notice of Proposed Rulemaking (adopted March 14, 2002).

I want to commend the International Bureau for its hard work on this item, and Chairman Powell and International Bureau Chief Don Abelson for issuing such a forward-looking item.

It is important as the United States' expert agency in communications that we sometimes look over the horizon and try to head off problems before they occur, rather than waiting for the problems find us unprepared. An ounce of prevention is worth a pound of cure, and if we come up with the right orbital debris mitigation rules now, we can head off a potentially very costly problem with far less costly precautions.

While our satellite communications system is not immediately threatened by orbital debris, if we don't act I believe that the threat will become real. Other government agencies are moving ahead with regard to government systems. Given the long planning and construction periods for satellite fleets, the rules we set in place now will affect satellites that will not be deployed for years to come. So moving ahead expeditiously is a prudent course.