Cover Letter

0705-EX-PL-2015 Text Documents

Spire Global, Inc.

2015-11-24ELS_169701

                                                                                                             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




November 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. 0705-EX-PL-2015

To Whom It May Concern:

Spire Global, Inc. (“Spire”) hereby requests authority from the Office of Engineering and Technology
(“OET”) to launch and operate an additional four satellites as part of Spire’s Lemur-2 satellite
system.1 The OET has authorized already the launch and operation of the initial eight Lemur-2
satellites and associated ground stations,2 and Spire also has pending applications for the launch of
additional satellites.3




1
  The instant application reflects the corrected emission designator for the 2020-2025 MHz downlink
band (5M00G1D), ERP for the 400-403 MHz uplink band (860W), and addresses for the ground
stations located in the U.S. Virgin Islands and Guam, all of which were identified in a previous
application. See Application, ELS File No. 0684-EX-PL-2015 (filed November 4, 2015). The instant
application also reflects the following: (i) the decommissioning of the Shady Grove, Texas ground
station; (ii) the addition of two new stations located in Richardson, Texas and Salt Lake City, Utah,
respectively; (iii) a revised width of beam at the half-power point for all earth stations; and (iv) the
updated latitude and longitude coordinates for the ground stations located in the U.S Virgin Islands
and Guam.
2
  See Application, Call Sign WH2XQT, ELS File No. 0041-EX-PL-2015 (granted June 9, 2015)
(applicant should seek approval for subsequent launches in separate applications); see also
Application, Call Sign WH2XQT, ELS File No. 0129-EX-ML-2015 (granted July 17, 2015).
3
 See Application, Call Sign WH2XQT, ELS File No. 0171-EX-ML-2015 (filed August 24, 2015); ELS
File No. 0684-EX-PL-2015 (filed November 4, 2015).
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Marlene H. Dortch                                   -2-                               November 24, 2015


Spire is submitting this application to replace four of its satellites, which had been authorized by the
OET for an Atlas V launch.4 As a result of the failure of the integrator and launch service provider to
complete certain environmental testing, the Spire satellites will not be a part of that launch.

The satellites subject to this application, which are technically identical to the prior authorized
satellites,5 are scheduled to launch aboard a Falcon-9 launch vehicle from Cape Canaveral, Florida
on January 3, 2016, as a secondary payload.

For the OET’s convenience, Spire is including in this application the following attachments:

      •   Exhibit A – the narrative filed with the initial experimental application regarding the Lemur-2
          system.6
      •   Exhibit B – the Orbital Debris Assessment Report (“ODAR”) showing that the proposed four
          satellites are fully compliant with NASA orbital debris guidelines.

The four satellites will be deployed from the International Space Station at an altitude of 400 km and
with an inclination of 51.6 degrees. 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:

“Falcon-9: ORB, 51.6IN00400AP00400PE001.60H04NRT01.”

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

Very truly yours,

          /s/

Trey Hanbury

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




4
    See Application, Call Sign WH2XQT, ELS File No. 0129-EX-ML-2015 (granted July 17, 2015).
5
 All of the satellites have the same relevant radiofrequency characteristics (e.g., transmit power,
out-of-band emissions, antenna patterns and gain, and transmit and receive frequencies).
6
 See Narrative Statement attached to Application, Call Sign WH2XQT, ELS File No. 0041-EX-PL-
2015 (granted June 9, 2015).



Document Created: 2019-04-25 08:54:28
Document Modified: 2019-04-25 08:54:28

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