Attachment Spire - Grant in par

Spire - Grant in par

DECISION submitted by IB, FCC

Grant with conditions

2018-11-29

This document pretains to SAT-AMD-20180102-00001 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2018010200001_1584439

‘4 GAT I P9Y File# 5T-BI4D- 2øii1.- oOj__ S2946 SAT -AM D-20180102-00001 182018000001 Spire Global Inc. OflS!gn5ZG::tDfZ/ LEMUR (or other identifier) Term Dates See Approved by 0MB caiic*1S 3060—0678 To: Date & Time Filed: Jan 22018 3:26:50:640AM tern lanai Bureau Approved:....... File Number: SAT—AM D—20 1 80102—00001 +wth con S Sqidl& ‘o)j ranth FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD - MAIN FORM FCC Use Only FCC 312 MAIN FORM FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: Phase lB/IC and Phase II Space Station License Amendment Application 1—8. Legal Name ofApplicant Name: Spire Global, Inc. Phone Number: 202—747—2619 DBA Fax Number: Name: Street: 575 Florida Street E—Mail: Suite 150 City: San Francisco State: CA Country: USA Zipcode: 941 10 — Attention:

ATTACHMENT TO GRANT Spire Global, Inc. IBFS File No. SAT-LOA-20151 123-00078 & SAT-AMD-20180102-0000l IBFS File No(s): SAT-LOA-20l5 1 123-00078 GRANT IN PART / SAT-AMD-20 180 lO2OOOOl1 DEFER IN PART - Licensee/Grantee: Spire Global, Inc. With Conditions Call Sign: 52946 % Satellite Name: LEMUR constellation Orbital Location: NGSO at altitudes up to 600 km (see scope of grant f( (required station- below) keeping tolerance) . Administration: United States of America Nature of Service: Earth Exploration Satellite Service (EESS) International Bureau Satellite Division Scope of Grant: Authority to construct, deploy, and operate up to 872 LEMUR Phase II satellites, initially deployed to altitudes from 385 to 650 km with inclinations ranging from equatorial to polar sun-synchronous (98 degrees).2 Previous Grant(s) Authority to construct, deploy, and operate up to 72 Phase IC satellites, initially deployed to circular orbits of no greater than 600 km in altitude.3 Authority to construct, deploy, and operate up to 24 technically identical Phase TB satellites, initially deployed to circular orbits of no greater than 600 km in altitude.4 Authority to constmct, deploy, and operate up to 4 technically identical Phase lB satellites, initially deployed to circular orbits of no greater than 500 km in altitude.5 Authority to construct, deploy and operate 28 technically identical satellites for what the applicant describes as “Phase IA” deployment, initially deployed to orbital altitudes of no greater than 650 km.6 Service Area(s): Global. See Schedule S Tech Report at Item S6 Frequencies: 8025-8400 MHz (space-to-Earth) (primary data downlink) 2020-2025 MHz_(space-to-Earth)_(data_downlink) The application was placed on Public Notice as accepted for filing on June 29, 2018. See Policy Branch Information, Applications Accepted for Filing, Public Notice, Report No. SAT-0 1325 (IBFS File No. SAT-AMD-20 180102-00001). 2 In its application, Spire states that it plans to host payloads on its satellites for educational, government, and commercial customers, and will work with the Commission to license such payloads when it has sufficient details. Amendment at 9-10. Accordingly, Spire does not seek authorization for satellites with hosted payloads as part of its application, and no authority is granted. Accordingly, our action here is with respect to satellites having a nominal mass configuration 4.5 kg, rather than the maximum mass of 6 kg that Spire contemplates for satellites with hosted payloads. In addition, we defer action on Spire’s request to construct, deploy, and operate satellites in the 3999-400.05 MHz (Earth-to-space) frequency band. See Policy Branch Information, Satellite Space Applications Actions Taken, Public Notice, DA 17-673, Report No.SAT 01253 (IBFS File Nos. SAT-AMD-20161 114-00107). We deferred action on the remainder of Spire’s application as amended to add Phase II satellites and to operate in additional frequency bands. IBFS File No. SAT-AMD-20161 114-00107 (granted in part May 18, 2017). Spire was also permitted to elect to use Phase TB satellites for the Orbital/Minotaur4 launch, initially deployed to 400x600 km orbital altitude. IBFS File No. SAT-AMD-20161 114-00107 (granted in part Apr. 7, 2017). 6 IBFS File No. SAT-LOA-20151 123-00078 (granted in part Mar. 18, 2016); IBFS File No. SAT-LOA-20151 123-00078 (granted in part June 16, 2016): IBFS File No. SAT-LOA-20151123-0007$ (granted in part Oct. 14, 2016). Spire has deployed all 28 of its Phase IA satellites and has not sought any change to the parameters of these satellites. Application at 5 &6. Page 1 of 6

ATTACHMENT TO GRANT Spire Global, Inc. IBFS File No. SAT-LOA-20151 123-00078 & SAT-AMD-20l80l02-0000l 2025-2110 MHz (Earth-to-space) (primary data uplink) 2200-2290 MHz (space-to-Earth) (data downlink) (Phase TB and IC and Phase II only) 402-403 MHz (Earth-to-space) (space-to-Earth (data back up only)) Telemetry, Tracking, and Command: 401-402 MHz (space-to-Earth) 402-403 MHz (Earth-to-space and space-to-Earth) 449.75-450.25 MHz (Earth-to-space) (Phase IC and Phase II only) 2025-2110 MHz (Earth-to-space) Receive Only Freciuencies: 156.7625-156.7875 MHz (Automatic Identification System (AIS) (AIS 3)) (Phase lB and IC and Phase II only) 156.8 125-156.8375 MHz (AIS 4) (Phase TB and IC and Phase II only) 161.9625-161.9875 MHz (AIS 1) 162.0 125-162.0375 MHz (AIS 2) 161.9375-161.9625 MHz (Application Specific Messages (ASM) (ASM 1)) (Phase TB and IC and Phase II only) 161.9875-162.0125 MHz (ASM 2) (Phase TB and IC and Phase II only) 1087.7-1092.3 MHz ((Earth-to-space) Automatic Dependent Surveillance-Broadcast (ADS-B)) (Phase IC and Phase TT only) 1575.42 MHz and 1227.60 MHz (center frequencies, GPS reception) 1559-159 1 MHz (Galileo El signal) (Phase lB and TC and Phase II only) 1164-1219 MHz (Galileo ES signal) (Phase lB and TC and Phase II only) Unless otherwise specified herein, operations under this grant must comport with the legal and technical specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This grant is also subject to the following conditions: 1. Spire must prepare the necessary information, as may be required, for submission to the International Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due diligence, and notification process for these space stations, in accordance with the ITU Radio Regulations. Spire will be held responsible for all cost-recovery fees associated with ITU filings. No protection from interference caused by radio stations authorized by other administrations is guaranteed unless coordination and notification procedures are timely completed or, with respect to individual administrations, by successfully completing coordination agreements. Any radio station authorization for which coordination has not been completed may be subject to additional terms and conditions as required to effect coordination of the frequency assignments of other administrations. See 47 CFR § 25.111(b). 2. Upon receipt of a conjunction warning from the Joint Space Operation Center or other source, Spire must review the warning and take all possible steps to assess and, if necessary, to mitigate collision risk, including, but not limited to: contacting the operator of any active spacecraft involved in such warning; sharing ephemeris data and other appropriate operational information with any such operator; modifying spacecraft attitude and/or operations. 3. The number of simultaneously operational satellites must not exceed 175. 4. The information provided by Spire supports a finding that some portion of the requested number of satellites is in the public interest, but it does not resolve all material questions of fact concerning whether We note that the total number of simultaneously operational satellites refers specifically to those satellites operating in frequencies other than TT&C frequencies and does not include non-operational satellites that continue to operate in TT&C frequency bands as part of approved post-mission disposal plans. Page 2 of 6

ATTACHMENT TO GRANT Spire Global, Inc. IBFS File No. SAT-LOA-20151 123-00078 & SAT-AMD-20180102-00001 deployment of the full constellation over the 15-year license term would involve debris mitigation plans sufficient to support a finding that the full deployment is in the public interest. Accordingly, prior to deploying Phase IT satellites in excess of 100 satellites, Spire must supplement the information provided in its orbital debris mitigation plan and must obtain FCC approval of the supplemented orbital debris mitigation plan. In particular, the supplement should clarify and expand the information provided regarding the aggregate collision risk for its proposed system at all altitudes requested, based on launches completed and planned. 5. Spire must comply with any new rules adopted by the Commission as a result of the rulemaking in lB Docket No. l813.8 6. Spire must notify the Commission in writing at least 30 days prior to launch of a satellite that will be part of the Lemur constellation, but which is licensed by another Administration. This notification must include the name of the Administration that has licensed the satellite, the anticipated launch date and launch vehicle, as well as the apogee, perigee, and inclination of the satellite, as intended to be deployed and intended to be operated. Any satellite in the Lemur constellation, whether licensed by the U.S. or another Administration, will count towards the number of satellites authorized under this grant and such satellites licensed by other Administrations will count towards the maximum number of simultaneously operational satellites allowed under Condition 3 of this grant and towards the maximum number of satellites that may be deployed prior to the additional approval specified in condition 4 of this grant. 7. Deployment into an orbit with an inclination of 51.6 degrees, plus or minus 0.1 degree, other than directly from the ISS, is only authorized for satellites to be launched on Cygnus re-supply missions and is subject to the following: a. Deployment shall be into an orbit that, if from below the ISS altitude, is not closer than 15 km below and 15 km in front of ISS and, if above the 155 altitude, is to an orbit acceptable to NASA, which is currently defined as a co-elliptic orbit above the ISS semi-major axis with a relative perigee greater than 45km. If deployment is planned from an altitude above the ISS, not later than 10 business days prior to launch of the resupply mission, Spire shall provide documentation from NASA confirming that deployment from the Cygnus capsule is acceptable to NASA. b. Deployment above the ISS altitude may proceed only if it is confirmed in a manner acceptable to NASA that, following launch and docking operations, there is sufficient fuel on Cygnus to execute both the planned satellite deployment and planned Cygnus disposal operations. 8. Spire’s request for waiver of the U.S. Table of Frequency Allocations, Section 2.106, to receive ASM transmissions in the 161.9375-161.9625 MHz (ASM 1), and 161.9875-162.0125 MHz (ASM 2), frequency bands, on a non-conforming, non-harmful interference basis, IS GRANTED. In addition, we waive Section 25.11 2(a)(3) to permit consideration of Spire’s request for operations on the channels 161.9375-161.9625 MHz (ASM 1), and 16 1.9875-162.0125 MHz (ASM 2), which are not allocated internationally for satellite service. In 2003, the Commission determined to return as “premature” such applications seeking to operate in frequencies for which there is no international allocation, because it can take several years for the ITU to adopt an international frequency allocation. The Commission also expressed concern that such applications would constitute “place holders.”9 In this case, however, the lack of a current MSS allocation in these bands does not necessarily preclude initiation of service, as transmissions may be conducted under other allocations.’0 Accordingly, we do not believe it would serve the public interest to prohibit Spire the flexibility of including the capability to receive ASM messages on frequencies not allocated to satellite services. We note that all reception in this band must 8Mitigation of Orbital Debris in the New Space Age, Notice of Proposed Rulemaking, FCC 18-159 (tel. Nov. 19, 2018). Amenthnent of the Cootmission’s Space Station Licensing Rules and Policies, First Report and Order, 1$ FCC RcU 10760, 10783 and 10809, paras. 49 and 124 (2003). ‘o Iridium Constellation LLC, Order and Authorization, 31 FCC Rcd 8675, 8683-84, para. 22. Page 3 of 6

ATTACHMENT TO GRANT Spire Global, Inc. IBfS File No. SAT-LOA-20151 123-00078 & SAT-AMD-20180102-0000l comport with the requirements on unauthorized publication or use of communications in Section 705 of the Communications Act of 1934, as amended1’ 9. Spire may claim protection for reception in the 156.7625-162.0375 MHz or 1087.7-1092.3 MHz bands only to the extent permitted under the U.S. Table of frequency Allocations for domestic operations or the ITU Radio Regulations for international operations, as of the time of operation. Operations in the 156.7625- 162.0375 MHz and 1087.7-1092.3 MHz bands must be in accordance with any Commission rulemakings subsequent to the release of this license that implement any new domestic allocations or service rules for these bands.’2 10. Spire may not claim any harmful interference protection rights for receiver operations with the Galileo El signal beyond that already afforded to non-federal receivers that operate with the GPS LI signal.’3 11. We find it is in the public interest to grant a waiver of the U.S. Table for Spire’s receiver operations with the Galileo ES signal in the 1215-1219 GHz frequency band (space-to-space), where such operations would be on a non-conforming basis and Spire’s Galileo E5 receivers must accept harmful interference from authorized services in the 12 15-1240 MHz band.’4 12. Spire shall tune TT&C UHF links in the 40 1-403 MHz frequency band to an agreed frequency range with the National Oceanographic and Atmospheric Administration (NOAA) as soon as possible to minimize interference to NOAA GOES Data Collection System and radiosonde operations and to work closely with NOAA to identify and implement any further measures needed to avoid radiofrequency interference to the systems mentioned earlier. This initial tuning would be an interim frequency range for Spire to use for upcoming launches. For future mission planning, transition out of 401-406 MHz to avoid interference to DCS and radiosonde is recommended. Spire and NOAA shall work jointly to explore future mitigation strategies to avoid interference to NOAA missions. 13. Spire’s request for a waiver of the United States Table of Frequency Allocations, 47 CFR § 2.106, is GRANTED to permit operations in the 402-403 MHz (Earth-to-space and space-to-Earth (TT&C and data back up only)) and 2020-2025 MHz (space-to-Earth) frequency bands on a non-conforming, non-harmful interference basis. Spire must immediately terminate non-conforming operations upon notification of harmful interference. 14. Operations in the 449.75-450.25 MHz band may be used for space telecommand (Earth-to-space) at specific locations, subject to conditions as may be applied on a case-by-case basis, pursuant to US$7 of the Table of frequency Allocations, 47 CFR 2.106. Spire must take all practical steps to keep the carrier frequency between 450.15 and 450.25 MHz. 15. Based upon information provided by the National Telecommunication and Information Administration (NTIA) as part of the frequency coordination process, future non-federal licenses for additional satellites will only be exceptionally considered for requests of downlink operations in the band 402-403 MHz, and Spire shall have no expectations that future licenses will be approved. Spire and DOC/NOAA shall work jointly to explore mitigation strategies to avoid interference to NOAA missions. for future missions, transition of TT&C links out of the 402-403 MHz band is required such that operations within the frequency band do not 47 U.S.C. § 605. 12 Iridium Order and Authorization, 3 1 FCC Rcd at 8689, para. 50. 13 See Waiter of Part 25 Licensing Requirements for Receive-Only Earth Stations Operating with the Gatiteo Radionavigation-Satettite Service, lB Docket No. 17-16, Order, FCC 18-158, para. 31, fn. 121 (Nov. 16, 2018). 14 To the extent that Spire receivers have a front end that receives transmissions outside of the bands allocated for RNSS in the U.S. Table of Frequency Allocations (in bands between 1240 MHz and 1559 MHz), such receivers will not be afforded any harmful interference protection rights with respect to the signals received outside of these RNSS bands. Id. at para. 41, fn. 161. Page 4 of 6

ATTACHMENT TO GRANT Spire Global, Inc. IBFS File No. SAT-LOA-20 151123-00078 & SAT-AMD-20 180102-00001 extend beyond October 31, 2020. Spire shall coordinate new ground station locations operating in 402-403 MHz with DOC/NOAA by providing the location of such stations for DOC/NOAA’s review for interference concerns and approval prior to operation of those ground stations. 16. Spire must maintain a U.S. point of contact available by telephone 24 hours per day, seven days per week, with the authority and ability to terminate operations authorized herein. The telephone number for this U.S. point of contact must be provided to NTTA (bmitchell@ntia.doc.gov) and DOCINOAA (dfranc@doc.gov). 17. The maximum bandwidth of any transmission in the 402-403 MHz frequency band is limited to 15 kllz, and all transmissions in these frequencies shall be within a 200 kHz frequency band centered on 402.7 MHz, i.e., within the 402.6-402.8 MHz frequency band, except as necessary for a period immediately following (i) the deployment of the satellites or (ii) a satellite software reset, resulting in satellite transmissions returning to the default transmission channels, in both cases to allow for the retuning of transmissions, or unless otherwise agreed in a Memorandum of Agreement with DOCINOAA. 18. Operations pursuant to this authorization must not cause harmful interference to stations operating in the 2025-2110 MHz band in accordance with the United States Table of Frequency Allocations. See 47 CFR § 2.106, Footnote US347. 19. Spire’s request for a waiver of the United States Table of Frequency Allocations, 47 CFR § 2.106, to permit United States and Possessions (US&P) operations in the 2200-2290 MHz (space-to-Earth) frequency band is DEFERRED. Operations in the 2200-2290 MHz frequency band are permitted for use only outside of the US&P. Spire is required to successfully coordinate with NTIA prior to submitting any ITU filing involving any ground stations outside of the US&P that operate in the frequency band 2200-2290 MHz. NTIA will consider the request by Spire for accessing to the 2200-2290 MHz for ground stations located outside of US&P on a case-by-case coordinated basis with appropriate EMC analysis to NTIA (binitchell@ntia.doc.gov), AFSMO (jimmy.nguyen@us.af.mil), NASA (john.e.zuzek@nasa.gov) and DOC (david.franc@doc.gov) to ensure compatibility of operations with the Federal government. Transmissions in the 2200-2290 MHz band to any single earth station must have a bandwidth no greater than one megahertz. 20. Transmissions of remote-sensing data in the 8025-8400 MHz frequency band may only be made to earth stations coordinated with the National Aeronautics and Space Administration (NASA). Spire shall provide the FCC the list of coordinated earth stations. 21. Power flux-density limits from operation in the 8025-8400 MHz band must not exceed the limits in No. 22.5 and Table 21-4 of the International Telecommunication Union’s Radio Regulations, the limits/protection criteria in Recommendation IUT-R SA. 1157-1 must be met, and the guidelines in Recommendation ITU-R SA.1810 must be followed. 22. This authorization will become null and void if, at any time during the license term, there are no Spire satellites operating. 23. Spire is subject to milestone and bond obligations imposed as conditions to a previous grant of authority to operate up to nine NGSO satellites in the 2020-2025 MHz frequency band. See sltpra, note [7]. We find that, following the discharge of the bond requirement associated with this previous grant, warehousing concerns are addressed in this situation through the imposition of condition [1$] above. 24. Within 30 days after deployment of each satellite pursuant to this authorization, Spire must file a notification with the Commission specifying its apogee and perigee altitudes and orbital inclination. 25. The license term is 15 years, which commenced upon Spire’s notification of the deployment of the first four Spire satellites on May 23, 2016.15 ‘ Letter from Trey Hanbury, Counsel to Spite Global, Inc., to Marlene H. Dortch, Secretary, FCC, IBFS File No. SAT-LOA 20151123-00078 (filed May 23, 2016). Page 5 of 6

ATTACHMENT TO GRANT Spire Global, Inc. IBFS File No. SAT-LOA-20 151 123-00078 & SAT-AMD-20 180102-00001 26. Spire’s request for a waiver of Section 25.114(c) of the Commission’s rules, 47 CFR § 25.114(c), to the extent described in its application with respect to certain information to be provided in the Schedule 5, IS GRANTED. We find that a waiver is warranted for the requirement for orbital information on the Schedule $ for each satellite because the information Spire provided in its Narrative is sufficient to fulfill the relevant informational requirements. 27. Spire’s request for processing of its amendment on a first-come, first-serve basis pursuant to Section 25.158 of the Commission’s rules, is GRANTED. Spire’s request for waiver of Sections 25.156 and 25.157 of the Commission’s rules, IS MOOT. Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as conditioned. failure to respond within this period will constitute formal acceptance of the grant as conditioned. This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 CFR § 0.261, and is effective upon release. Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as amended, 47 U.S.C. § 309(h). Action November 29, 2018 Date: Term Dates From: November 29, 2018 To: see conditions Duall tellite Policy Branch Page 6 of 6

9—16. Name of Contact Representative Name: George John Phone Number: 202—747—2619 Company: Spire Global. Inc. Fax Number: Street: 575 Florida Street f—Mail: george.john@spire.com Suite 150 City: San Francisco State: CA Country: USA Zipcode: 94110— Attention: Relationship: CLASSIFICATION OF FILING 17. Choose the button next to the classification that applies to this filing for (N/A) bI. Application for License ofNew Station both questions a. and b. Choose only one (N/A) b2. Application for Registration of New Domestic Receive—Only Station for I 7a and only one for 1 7b. b3. Amendment to a Pending Application b4. Modification of License or Registration al. Earth Station b5. Assignment of Licelise or Registration a2. Space Station b6. Transfer of Control of License or Registration o b7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States (N/A) blO. Other (Please specify) (N/A) bI 1. Application for Earth Station to Access a Non—U.S.satel]ite Not Currently Authorized to Provide the Proposed Service in the Proposed frequencies in the United States (N/A) b] 2. Application for Database Entry o b13. Amendment to a Pending Database Entty Application o b14. Modification of Database Entry 9

17c. Is a fee submitted with this application? If Yes. complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114). Governmental Entity Noncommercial educational licensee 0 Q o Other(please explain): 17d. Fee Classification CAW — Space Station Amendment(Non— Geostationary) 18. If this filing is in reference to an 19. If this filing is an amendment to a pending application enter both fields. if this filing is a existing station, enter: modification please enter only the file number: (a) Call sign of station: (a) Date pending application was filed: (b) File number: S2946 1 1/23/2015 SATLOA2OI5I 12300078

TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply: Q a. Fixed Satellite b. Mobile Satellite c. Radiodetermination Satellite U. Earth Exploration Satellite Q e. Direct to Home Fixed Satellite Q f. Digital Audio Radio Service g. Other (please specify) METS and Space Ops 21. STATUS: Choose the button next to the applicable status. Choose 22. If earth station applicant, check all that apply. only one. Using U.S. licensed satellites 0 Common Carrier Non—Common Carrier Q Using Non—U.S. licensed satellites 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these facilities: Q Connected to a Public Switched Network Not connected to a Public Switched Network N/A 24. FREQUENCY BAND(S): Place an ‘X’ in the box(es) next to all applicable frequency band(s). a. C—Band (4/6 GHz) b. Ku—Band (12/14 GHz) fJ c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: 399.9 Frequency Upper: 8325 (Please specify additional frequencies in an attachment) 4

TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. Q a. Fixed Earth Station o b. Temporary—Fixed Earth Station o c. 12/14 GHz VSAT Network o d. Mobile Earth Station 0 e. Geostationary Space Station f Non—Geostationary Space Station o g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: o Transmit/Receive Transmit—Only Receive—Only ® N/A “For Space Station applications, select N/A.” 5

PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an ‘X in the box(es) next to all that apply.) a—— authorization to add new emission designator and related service b —— authorization to change emission designator and related service c —— authorization to increase EIRP and EIRP density Qd — authorization to replace antenna e —— authorization to add antenna Q f—— authorization to relocate fixed station g authorization to change frequency(ies) h — authorization to add frequency QI —— authorization to add Points of Communication (satellites &arnp; countries) QJ —— authorization to change Points of Communication (satellites & countries) Qk authorization for facilities for which environmental assessment and radiation hazard reporting is required authorization to change orbit location —— Q rn —— authorization to perform fleet management authorization to extend milestones Q Ii —— o —— Other (Please specify) 6

ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental impact as defined by 47 CFR 1.1307? IfYES. submit the statement as required by Sections 1.1308 and 1 .131 1 of o Yes No the Comrnissions rules, 47 C.E.R. l.130$ and 1.1311. as an exhibit to this application.A Radiation Hazard Sttidy must accompany all applications for new transmitting facilities, major modifications, or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station services are not required to respond to Items 30—34. 29. Is the applicant a foreign government or the representative of any foreign government? o Yes No 30. Is the applicant an alien or the representative of an alien? o Yes No N/A 31. Is the applicant a corporation organized under the laws of any foreign government? Yes No N/A 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by Yes No N/A aliens or their representatives or by a foreign government or representative thereof or by any corporation organized under the laws of a foreign country? 7

33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than Yes No N/A one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign government or representative thereof or by any corporation organized tinder the laws of a foreign country? 34. If any answer to questions 29. 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATIONS 35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules? Yes No lfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents. 36. Has the applicant or any party to this application or amendment had any FCC station authorization or license revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or o Yes No construction permit denied by the Commission? lfYes, attach as an exhibit, an explination of circumstances. 8

37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling Yes No the applicant ever been convicted of a felony by any state or federal court? If Yes. attach as an exhibit, an explination of circumstances. 3$. Has any cotirt finally adjudged the applicant, or any person directly or indirectly controlling the applicant. guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio commtinication, directly or o Yes No indirectly, through control of manufacttire or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of competition?lfYes, attach as an exhibit, an explanation of circumstances 39. Is the applicant. or any person directly or indirectly controlling the applicant, currently a party in any pending matter referred to in the preceding two items? If yes. attach as an exhinit, an explanation of the circumstances. o Yes No 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names. address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of Exhibit D beneficiaries. Also list the names and addresses of the officers and directors of the Filer. 9

41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is Yes No subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of 198$. 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled stibstance. See 47 CFR 1.2002(b) for the meaning of "party to the application&quot: for these purposes. 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes, answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No, o Yes No proceed to question 43. Exhibit C 42b. What administration has licensed or is in the process of licensing the space station? Ifno license will be issued, what administration has coordinated or is in the process of coordinating the space station?N/A 43. Description. (Summarize the nature of the application and the services to be provided). (Ifthe complete description does not appear in this box, please go to the etid of the form to view it in its entirety.) Applicant seeks to amend its pending applications and requests authority to (1) measure signals (readily accessible to the general public) for the purpose of inferring atmospheric and land surface properties and (ii) deploy Phase II satellites, which have updated technical information. Exhibit B 10

43a. Geographic Service Rule Certification By selecting A. the undetsigned certifies that the applicant is not subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25. By selecting B. the undersigned certifies that the applicant is subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements. OC By selecting C. the undersigned certifies that the applicant is subject to the geographic service ot geographic coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not feasible as a technical matter to do so, or that, while technically feasible, such services would require so many compromises in satellite design and operation as to make it economically unreasonable. A narrative description and technical analysis demonstrating this claim are attached. Exhibit A CERTIFICATION The Applicant waives any claim to the itse of any particular frequency or of the electromagnetic spectrum as against the regulatoiy power of the United States because of the previous use of the same. whether by license or otherwise, and requests an authorization in accordance with this application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit in 47 CER Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application. The undersigned. individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are true, complete and correct to the best of his or her knowledge and belief, and are made in good faith. ii

44. Applicant isa (an): (Choose the button next to applicable response.) o Individual Unincorporated Association Q o Partnership Corporation ® Governmental Entity o Other (please specify) 45. Name of Person Signing 46. Title of Person Signing George John Legal & Regulatory Counsel ——> WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18. Section 1001). AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 3 12(a)( 1)). AND/OR FORFEITURE (U.S. Code, Title 47, Section 503). 12

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 hours per response, including the time for reviewing insttuctions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. lfyou have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes yoct, please write to the Federal Communications Commission, AMD—PERM. Paperwork Reduction Project (3060—0678). Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRAfcc.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember —You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection. unless it displays a currently valid 0MB control number or if we fail to provide you with this notice. This collection has been assigned an 0MB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507. 13


Document Created: 2018-11-30 13:43:24
Document Modified: 2018-11-30 13:43:24
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