Letter

0780-EX-PL-2015 Text Documents

Spire Global, Inc.

2016-01-07ELS_171131

                                                                                                             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




January 7, 2016


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. 0780-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 five satellites as part of Spire’s Lemur-2 satellite
system.1 The OET has already authorized the launch and operation of a number of the Lemur-2
satellites and associated ground stations,2 and Spire also has pending applications for the launch of
additional satellites.3

The satellites subject to this application, which are technically identical to the prior authorized
satellites,4 are scheduled to launch aboard an Atlas V launch vehicle from Cape Canaveral, FL on
March 10, 2016, as a secondary payload. Spire requests that the Commission grant this application
by March 7, 2016, which will allow Spire to provide the necessary documentation to the launch
provider prior to the launch.
1
 The instant application reflects the same technical parameters as specified in a prior application
and includes a new earth station located in Tukwila, Washington. See Application, ELS File No.
0705-EX-PL-2015 (filed November 24, 2015).
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 WI2XBX, ELS File No. 0684-EX-PL-2015 (granted November 25, 2015).
3
 See Application, Call Sign WH2XQT, ELS File No. 0171-EX-ML-2015 (filed August 24, 2015);
Application, ELS File No. 0705-EX-PL-2015 (filed November 24, 2015).
4
 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).
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www.hoganlovells.com


Marlene H. Dortch                                 -2-                                   January 7, 2016


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.5
       Exhibit B – the Orbital Debris Assessment Report (“ODAR”) showing that the proposed
        satellites are fully compliant with NASA orbital debris guidelines.

The five satellites will be launched using an United Launch Alliance (“ULA”) launch vehicle and will
be deployed at an altitude between 400 - 500 km with a target altitude of 500 km and 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:

“Atlas V: ORB, 51.6IN00500AP00500PE001.60H05NRT01.”

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




5
 See Narrative Statement attached to Application, Call Sign WH2XQT, ELS File No. 0041-EX-PL-
2015 (granted June 9, 2015).



Document Created: 2016-01-07 19:48:02
Document Modified: 2016-01-07 19:48:02

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