Letter

0171-EX-ML-2015 Text Documents

Spire Global, Inc.

2015-08-24ELS_166338

                                                                Hogan Lovells US LLP
                                                                Columbia Square
                                                                555 Thirteenth Street, NW
                                                                Washington, DC 20004
                                                                T +1 202 637 5600
                                                                F +1 202 637 5910
                                                                www.hoganlovells.com




August 24, 2015


Via Electronic Filing
Experimental Licensing Branch
Office of Engineering and Technology
Federal Communications Commission
445 12th Street SW
Washington, DC 20554

Re:       Spire Global, Inc.
          ELS File No. 0171-EX-ML-2015
          Modification of License WH2XQT

To Whom It May Concern:

Spire Global, Inc. (“Applicant”) hereby requests a modification of the above-referenced experimental
license granted on June 9, 2015 and modified on July 17, 2105. The initial license grant provides
authority for the Applicant’s initial launch and operation of four satellites for its Lemur-2 system and
states that authority for Applicant’s subsequent launches should be sought in separate applications.1
Applicant hereby seeks authority for the additional launch and operation of two satellites, which will
be part of the Lemur-2 system. Because the launch is scheduled for December 2015 and Applicant
is required to demonstrate to the launch provider that it has obtained launch authority from the FCC
60 days in advance of the scheduled launch date, Applicant seeks expedited processing of this
application.

The Applicant’s two additional satellites will be launched, as secondary payloads, from Baikonur,
Kazakhstan, using a Roscosmos Soyuz launch vehicle. The satellites will be deployed at an altitude
of 600 km and with an inclination of 97.8 degrees. All other technical parameters specified in the
license are the same. Attached as an exhibit to this modification application is a revised Orbital
Debris Assessment Report (“ODAR”), which includes the orbital debris analysis for the two additional
satellites for which authority is sought in this application and shows that the satellites are fully
compliant with NASA orbital debris guidelines.

Additionally, Applicant seeks to update the uplink emission designator for the UHF bands (400-403
MHz) from 5K00F1D to 12K5F1D and the modulating signal from 2400 baud MSK to 9600 baud

1
 The subsequently approved modification to the license allows the launch and operation of four
additional satellites.


Marlene H. Dortch                                -2-                                  August 24, 2015


GMSK. Furthermore, Applicant seeks to change the modulating signal for the UHF downlinks from
2K50F1D to 12K5F1D.

With respect to the coordination of this application with NTIA, the revised response to inquiry 1B of
the NTIA coordination form, regarding inclination angle, apogee in kilometers, perigee in kilometers,
orbital period in hours and fractions of hours in decimal, and the number of satellites, should be as
follows:

“Soyuz: ORB, 97.8IN00600AP00600PE001.60H02NRT01.”

If there are any questions regarding this license modification application, please contact the
undersigned.


Very truly yours,

        /s/

Trey Hanbury

Partner
trey.hanbury@hoganlovells.com
D 202-637-5534

cc: Doug Young



Document Created: 2015-08-24 20:11:39
Document Modified: 2015-08-24 20:11:39

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