Reply to Questions

0864-EX-CN-2017 Text Documents

BlackSky Global, LLC

2017-12-06ELS_201971

                                                     LAW OFFICES
                             GOLDBERG, GODLES, WIENER & WRIGHT LLP
                                     1025 CONNECTICUT AVENUE, N.W., SUITE 1000
                                            WASHINGTON, D.C. 20036-2413


HENRY GOLDBERG                                                                                        (202) 429-4900
JOSEPH A. GODLES                                                                                      TELECOPIER:
JONATHAN L. WIENER                                                                                    (202) 429-4912
DEVENDRA (“DAVE”) KUMAR                                                                                  e-mail:
       ________
                                                                                                 jwiener@g2w2.com
HENRIETTA WRIGHT                                                                             website: www.g2w2.com
THOMAS G. GHERARDI, P.C.
COUNSEL
      ________

THOMAS S. TYCZ*
SENIOR POLICY ADVISOR

*NOT AN ATTORNEY                              December 6, 2017


      FILED ELECTRONICALLY VIA ELS
      Ms. Leann Nguyen
      Office of Engineering & Technology
      Federal Communications Commission
      445 12th Street, SW
      Washington, DC 20554

                                              Re: BlackSky Global, LLC,
                                                  Response to OET Request for Information,
                                                  Correspondence Reference #39711
                                                  Application for New Experimental License
                                                  FCC File No. 0864-EX-CN-2017

      Dear Ms. Nguyen,

             Submitted herewith is BlackSky Global, LLC’s (“BlackSky”) response to your
      request for information dated November 15, 2017, regarding the above referenced
      application. For clarity, questions are included below in italics with BlackSky’s response
      is regular type thereafter.

      Please submit the all following information below for us to process your application

            1. - Spacecap data file (send file directly to Jeanette.spriggs@fcc.gov and cc
               Leann.Nguyen@fcc.gov).

         This file was sent to Joseph Hill by email through this office on November 22, 2017 per
      Ms. Spriggs.

            2. - Spacecap letter


Ms. Leanne Nguyen
November 29, 20117
Page 2 of 3


   Attached is a draft letter for the Commission to request ITU Advanced Publication to
submit along with the SpaceCap information.

   3. - Cost recovery letter

   The cost recovery letter was filed via ULS on the same day the application was
submitted. Attached is a copy of the letter.

   4. - A NOAA license is required for satellites with imaging capabilities.

    BlackSky has a NOAA license covering the satellite for which an FCC experimental
license is being sought. A copy of the public information published by NOAA in
connection with that license was included with the experimental license application and
another copy is attached hereto for reference. The license itself contains information that
is highly confidential and is not made available for public release by NOAA. BlackSky
notes that it was not required to file with the Commission more than the public summary
of its NOAA license with the last experimental license that was issued to it by the
Commission and hopes that this will be sufficient for the current application.


   5a. - The experiment uses federal or shared government frequencies must submit additional
   technical data.

        -Transmitter Antenna:
       - Location:
       - Apogee and Perigee
       - Polarization
       - Orientation
       - Dimension: Gain (dbi),
       - Beamwidth (degree),
       - Azimuth (degree clockwise from True North),
       - Elevation (in meter above MSL)
       - Height (in meter above MSL).
       - Receiver Antenna:
       - Location: lat/long, city, state.
       - Polarization - Orientation
       - Dimension: Gain (dbi), Beamwidth (degree), Azimuth (degree clockwise from True
       North), Elevation (in meter above MSL) , Height (in meter above MSL).

      See attached Exhibit 5 attached hereto.



                                                   GOLDBERG GODLES WIENER & WRIGHT, LLP


Ms. Leanne Nguyen
November 29, 20117
Page 3 of 3


    5b. - Orbital characteristics
        - Inclination angle (in degree)        Approximately 97°
        - Apogee (in km) - Perigee (in km)     Circular Orbit; between 500 & 550 km
        - Period (in hour)                     1.6 hours
        - Number of satellite in the system.   One (1)
        - Number of transmitting satellite     One (1)
        - Number of receiving satellite        One (1)

   6.- Name and phone of person who will terminate the system if interference occurs.

    As described in the previously submitted Exhibit 1, the Mission Control hotline is 844-
332-3318 and is available 24 hours/ 7 day-per-week. The person on the receiving end of
this phone number is rotating. Their supervisor is John Springmann.

      Questions with respect to this matter should be referred to the undersigned.

                                                     Sincerely,




                                                     Jonathan L. Wiener
                                                     Attorney for BlackSky Global, LLC



Attachments




                                                     GOLDBERG GODLES WIENER & WRIGHT, LLP


                                         [FCC]


Atila Matas, Head of SPR
Radiocommunication Bureau
International Telecommunication Union
Place des Nations
CH-1211 Geneva 20

Subject: Advance Publication Information for the Global-1 Satellite network.

Dear Sir:

In accordance with the provisions of Article 9.1 and Appendix 4 of the Radio
Regulations, the Administration of the United States is submitting a request for the
Advance Publication Information of the Global -1 satellite.

Enclosed is a diskette containing an electronic copy using Space Capture v8.03 of the
information for the Global -1 satellite.

In addition we would like to provide the cost recovery billing information under
Agency code 528 in the Preface to the International Frequency List (IFL) for U.S.A.
commercial operators.

Cost-recovery invoices associated with this filing should be sent to the following point
of contact:

H. Indra Hornsby
1505 Westlake Avenue North, Suite 600
Seattle, Washington 98109, U.S.A.
E-Mail: indrah@spaceflightindustries.com
Phone: (866) 342-9934
Fax: N/A

Technical questions regarding this submission should be directed to:
John Springmann
BlackSky Global LLC
1505 Westlake Avenue North, Suite 600
Seattle, Washington 98109, U.S.A.
E-Mail: johns@spaceflightindustries.com
Phone: (866) 342-9934
Fax: N/A


We request that a courtesy copy of all correspondence be sent to our Administration
also.

Please acknowledge receipt of this information.

Thank you for your kind consideration in this matter.

Sincerely,




Chief, Strategic Analysis and
Negotiations Division
International Bureau
Enclosure


 BLACK (SKY

                                              November 13,2017

Jose Albuquerque
Chief, Satellite Division-International Bureau
Federal Communications Commission
445 12th Street, S.W.
Washington, DC 20554

                                   Re:   BlackSky Global, LLC - Application for Authority to
                                         Launch and Operate Experimental Space Station Global-
                                         1 (FCC File No. 0864-EX-CN-2017) (the" Application")

Dear Mr. Albuquerque:

       BlackSky Global, LLC ("BlackSky"), proposed licensee of an experimental space
station ("Globall"), hereby submits this letter in connection with the above-referenced
Application. The information set forth below tracks the information Section 25.111(d) of
the Commission's rules.

       BlackSky hereby certifies and declares that it unconditionally accepts all
consequent International Telecommunication Union (ITU) cost recovery responsibility
associated with the Application and with the related ITU filings identified below.
BlackSky also acknowledges that payment of these ITU cost recovery fees by the
applicant to the ITU grants no right to the orbit or spectrum identified in the associated
ITU filings.

      In order for the International Bureau to assist the ITU in implementing its cost
recovery, BlackSky provides the following information:

          (1)        Name of Contact: H. Indra Hornsby
          (2)        Name of Applicant: BlackSky Global, LLC
          (3)        Address:      1505 Westlake Avenue North, Suite 600, Seattle, Washington
                     98109, U.S.A.
          (4)        Email address: indrah@sp aceflightindustires.com
          (5)        Telephone number: 866-342-9934



1505 Westlake Avenue Nort h, Suite 600
Seat tle, Washi ngt on 98109, U. S.A.


                                          -2-



      Please contact the undersigned if you have any questions or need an y additional
information.




1505 W estlake Avenue North, Suite 600
Seattle, Washi ngton 98109, U.S.A.


BlackSky Global, LLC                                                                              Exhibit 4
FCC Form 442

                    Global 1‐4 Constellation Private Remote Sensing Space System

On August 28, 2017, the Commercial Remote Sensing Regulatory Affairs Office of the National Oceanic
and Atmospheric Administration, an agency of the Department of Commerce, granted a license to
BlackSky Global, LLC to operate the first phase of the Global Constellation, satellites 1‐4, a private,
commercial, space‐based, remote sensing system (the “Global Constellation”).

These first four satellites, which make up the initial phase of the Global Constellation, are licensed to
collect images of the Earth and will operate in circular orbits with altitudes ranging from 500‐575 km and
inclinations near 97 degrees. The first phase will be followed by additional launches, culminating in the
planned constellation of sixty satellites total, operating in mid‐inclination and sun‐synchronized orbits
and at altitudes near 500 km.

Inquiries should be directed to legal@spaceflightindustries.com or

H. Indra Hornsby
General Counsel
BlackSky Global LLC
1505 Westlake Avenue North, Suite 600
Seattle, Washington 98019, U.S.A.


BlackSky Global, LLC                                                                     Additional Technical Data                                                                                        Exhibit 5
FCC Form 442


Link:                                              UHF uplink                                 UHF downlink                             S-band uplink                               X-band downlink

Center frequency:                                   450.2 MHz                                    401.5 MHz                             2071.875 MHz                                     8125 MHz
                                    Invercargill, New                            Invercargill, New                                           Invercargill, New           Invercargill, New
Ground Station Used:                Zealand              North Pole, AK          Zealand             North Pole, AK       North Pole, AK     Zealand                     Zealand           North Pole, AK
Transmitter Antenna:
                                    ground-based          ground-based                                                    ground-based          ground-based
  Location:                         (details below)       (details below)                    low-earth orbit              (details below)       (details below)                     low-earth orbit
                                    46° 31' 43" S         64° 47' 38" N                                                   46° 31' 43" S         64° 47' 38" N
    Latitude , Longitude:           168° 22' 52" E        147° 32' 09" W                           n/a                    168° 22' 52" E        147° 32' 09" W                             n/a
                                    Invercargill,                                                                         Invercargill,
    City:                           Southland             North Pole                               n/a                    Southland             North Pole                                 n/a
    State:                          (New Zealand)         Alaska, USA                              n/a                    (New Zealand)         Alaska, USA                                n/a

                                                                                        500-550 km apogee (TBD)                                                                500-550 km apogee (TBD)
                                                                                        500-500 km perigee (TBD)                                                               500-500 km perigee (TBD)
  Apogee & Perigee:                 n/a                   n/a                                    circular                 n/a                   n/a                                     circular
  Polarization:                     RHCP                  RHCP                                    Linear                  RHCP                  RHCP                                     Linear
                                    varies -- LEO         varies -- LEO                                                   varies -- LEO         varies -- LEO tracking
  Orientation:                      tracking antenna      tracking antenna                   varies (in-orbit)            tracking antenna      antenna                             varies (in-orbit)
                                    yagi-style, 120"      yagi-style, 120"
  Dimensions:                       boom length           boom length                    whip antenna, 8" length          7.3 m diameter        3.7 m diameter                 patch antenna, 4.1" x 5.9"

                                                                                 1.1 dBiC peak*, -5 dBiC for 95% spherical
    Gain (dBi):                     16 dBiC               16 dBiC                                coverage                  48 dBi               34.4 dBi                                15 dBiC


                                                                                      not applicable. Apporiximately
    Beamwidth (deg):                30 deg                30 deg                             omnidirectional              1.2 deg               approx. 2.7 deg                  16 x 30 deg full width
  Azimuth (degrees clockwise from    0 to 360 deg (LEO-    0 to 360 deg (LEO-                                              0 to 360 deg (LEO-    0 to 360 deg (LEO-
  true north):                      tracking)             tracking)                                n/a                    tracking)             tracking)                                  n/a
  Elevation (angle relative to       5 to 90 deg (LEO-     5 to 90 deg (LEO-                                               5 to 90 deg (LEO-     5 to 90 deg (LEO-
  horizon):                         tracking)             tracking)                                n/a                    tracking)             tracking)                                  n/a
  Height (in meter above MSL):                       24                    151                     n/a                                     24                    144                       n/a
Receiver Antenna:

  Location:                                   low-Earth orbit (LEO)                                                                 low-Earth orbit (LEO)
                                                                                 ground-based       ground-based                                                         ground-based      ground-based
    Latitude , Longitude:                               n/a                      (details below)    (details below)                           n/a                        (details below)   (details below)
                                                                                 46° 31' 43" S      64° 47' 38" N                                                        46° 31' 43" S     64° 47' 38" N
    City:                                               n/a                      168° 22' 52" E     147° 32' 09" W                            n/a                        168° 22' 52" E    147° 32' 09" W
                                                                                 Invercargil,                                                                            Invercargil,
    State:                                               n/a                     Southland          North Pole                                 n/a                       Southland         North Pole
  Polarization:                                        Linear                    New Zealand        Alaska, USA                              Linear                      New Zealand       Alaska, USA


BlackSky Global, LLC                                                                    Additional Technical Data                                                                                 Exhibit 5
FCC Form 442


                                                                              varies -- LEO       varies -- LEO tracking                                            varies -- LEO    varies -- LEO
  Orientation:                                       Varies                   tracking antenna    antenna                                  Varies                   tracking antenna tracking antenna
                                                                              yagi-style, 133     yagi-style, 133 inch
  Dimensions:                               whip antenna, 8" length           inch boom length    boom length                          patch, 4" x 4"               7.3 m diameter    3.7 m diameter
                                        1.1 dBiC peak*, -5 dBiC for 95%
    Gain (dBi):                               spherical coverage              19 dBiC             19 dBiC                                 6 dBiC                    55 dBiC           43 dBiC
                                         not applicable. Apporiximately
    Beamwidth (deg):                            omnidirectional               30 deg              30 deg                                  70 deg                    0.3 deg           approx 0.7 deg
  Azimuth (degrees clockwise from                                              0 to 360 deg (LEO- 0 to 360 deg (LEO-                                                 0 to 360 deg      0 to 360 deg (LEO-
  true north):                                         n/a                    tracking)           tracking)                                 n/a                     (LEO-tracking)    tracking)
                                                                               5 to 90 deg (LEO- 5 to 90 deg (LEO-                                                   5 to 90 deg (LEO- 5 to 90 deg (LEO-
  Elevation (meter above MSL):                         n/a                    tracking)           tracking)                                 n/a                     tracking)         tracking)
  Height (in meter above MSL):                         n/a                                     24                  151                      n/a                                    24                  144

                                    * note that the UHF antenna on the spacecraft is linear, but it's gain is reported in dBiC because it was characterized against a RHCP (circularly-polarized) ground
                                    antenna



Document Created: 2017-12-06 10:58:54
Document Modified: 2017-12-06 10:58:54

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