Swarm Ex Parte Lette

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Swarm Technologies, Inc.

Swarm Ex Parte - Rosenworcel

2019-02-08

This document pretains to SAT-LOA-20181221-00094 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2018122100094_1622774

Timothy L. Bransford
Partner
+1.202.373.6140
timothy.bransford@morganlewis.com



February 8, 2019


Via IBFS & ECFS

Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Re:      Notice of Ex Parte Communication - IBFS File No. SAT-LOA-20181221-00094;
         Call Sign S3041; IB Docket No. 18-313, Mitigation of Orbital Debris in the New
         Space Age

Dear Ms. Dortch:

       On February 6, 2019, Dr. Sara Spangelo, Chief Executive Officer, and Mr. Kalpak Gude,
General Counsel, of Swarm Technologies, Inc.            (Swarm), met with Commissioner Jessica
Rosenworcel of the Federal Communications Commission (Commission), as well as Umair Javed,
Legal Advisor, and Jessica Martinez, Special Advisor, to Commissioner Rosenworcel.

        The meeting participants discussed Swarm’s above-referenced satellite system application
pending before the Commission. Specifically, the participants discussed the benefits of Swarm’s
revolutionary satellite technology, which will facilitate low-cost communications to underserved or
unserved areas of the United States. In addition, Swarm discussed orbital debris issues and
mitigation strategies, including the viability of future requirements to affirmatively deorbit spacecraft
positioned in low earth orbits at altitudes above 650 kilometers, which are not self-cleaning, and
where spacecraft may continue to orbit for periods in excess of 25 years without propulsive or other
special de-orbit capabilities. Swarm further elaborated on the self-cleaning nature of lower orbits,
where spacecraft and debris re-enter the Earth’s atmosphere absent affirmative de-orbiting
maneuvers. Swarm also urged that the Commission take an analytical approach to the orbital debris
issue.

        To the extent you have questions or concerns, please feel free to contact the undersigned.

                                           Very truly yours,
                                           /s/
                                           Timothy Bransford
                                           (Outside Counsel to Swarm Technologies, Inc.)

cc (via email): Hon. Jessica Rosenworcel
                Umair Javed
                Jessica Martinez




                                                     Morgan, Lewis & Bockius        LLP

                                                     1111 Pennsylvania Avenue, NW
                                                     Washington, DC 20004                 +1.202.739.3000
                                                     United States                        +1.202.739.3001



Document Created: 2019-02-08 18:33:00
Document Modified: 2019-02-08 18:33:00

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