Attachment 1997ORBCOMM modifica

1997ORBCOMM modifica

APPLICATION submitted by ORBCOMM

Modification

1997-09-26

This document pretains to SAT-MOD-19970926-00164 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD1997092600164_1086704

O¥ /A ) READ INSTRUCTIONS CAREFULLY rcememron sp2ssy ORIGINAL APPROVED 8Y OmsS 3060—0589 BEFORE PROCEEDING FEDERAL COMMUNICATIONS COMMISSION SPECIAL Use A.D VICE REMITTANCE ‘ 1 FCC USE ONLY PaGEa>NO 1 ;« (1) LOCXKBOX # SECTION A — PAYER INFORMATION (2) PAYER NAME(d paying oy creart card, anter name exactiv as it appears on your cara) . (3) TOTAL AMOUNT PA(aouars ana cents) Halprin, Temple, Goodman & Sugrue j 18,220.00 Ehemeien (4) STREET ADORESS LINE NO. 1 P 1100 New York Avenue, N.W. — Suite 650 East inthraidd n state (8) as cooe Washington DC 20005 9) DAYTIME TELEPHONE NUMBER (Inctude area code) (10) COUNTRY CODE {if not in U.S.A) 202/371—9100 PAYERNAME—AND: THE APPLICANTNAME—AREDIFFERENT, COMPLETE SECT!ON B :IEMORETHAN:ONEAPPUCANT,.USE.CONTINUATION SHEETS.: (FORM 159—C) +%:~ SECTION 8B — APPLICANT INFORMATION (11) APPLICANT NAME(H paying oy creaxt card, enter name exactly as it appears on your card) Orbital Communications Corporation (12) stReet AporessLing 1 21700 Atlantic Boulevard (13) STREET ADDRESS LINE NO, 2 (14) CTY Dull es . (15) stATe VA (18) 2P cope 2 0]_ 6 6 (17) DAYTIME TELEPHONE NUMBER (Inciude area code) (13) COUNTRY CODE (if not in U.SA.) 703/406—-5000 ED;:USECONTINUATIONSHESTS:(FEORM189—C): ~—=se=ffonc _Parment lNFORMATION (13A) FCC CALL SIGN/OTHER ID (20A) PAYMENT TYPE CODE (PTC) (21A) QUANTITY (22A) FEE DUE FOR (PTC) iN BLOCK 20A € a w 1 1 18,220.00 (Z22) Fec cooE i — (Zexyrec cooez [198)roe call. siemiotheR 10 (Zoa) pavhent Type coue (pro; (218) auannty |(228) DUE FOR (PTo) iN SLoGK 208 > $ 238) FCC cooe i [248) roc cope 2 [19G) FCC caLL sionvoTHeR io (20C) PAYMENTTYyPEcobe (PTC] (21C) auanTTy ((22G) FEE DUEFOR (PTC) N ALOCK 20G 23C; Foc cone i [ [ | s [2i6) rec coor 2 (190) roc caLL siexiorheR io (200) PAYMENTcooe (PTC) TZi0) auantity —|(22D) FeE DUe FOR (Pro) in alock 210 ~~ Tz 230) Fec coog 1 [ [ | s 240) FCc cour 2 SECTION D — TAXPAYER — INFORMATION _(REQUIRED) — T3 ~7 TGsicomptere tms acooRr onuy in appUicaNT mME in a—i is oirrenent FROM PAYER NamE IN A—2) PAYER TIN APPLICANT TIN SECTION e — CSRTIFICATION (27) CERTIFICATION STATEMENT 1 Stephen L. Goodman , Certify under penaity of perjury that the foregoing and supporting information (PRINT NAME] ) are true and correct to the best of my knowledge. infomation and belief. SIGNATURE 1\&70//?(\/\ ?f /21:77)#4'\ oattfraprrena. set=on*~ CRESiIT CaRD ParMenxn? NroRmaion (231 asaiercartiviee mceuUN i (—UMbir: carina uon baie: MASTERCARD ] l |_| [ ! | o | | O O 1 i | ! [ | | YONTH [ ] EAR [ | honnnzmmamees.., OaTE AUTHORLED SIGNATURE VISA | hereoy authorize the FCC to charge my VISA or MASTERCARO tor the servicersi/authonzationsts) nerein uescrined. >

NOTICE TO INDIVIDUALS REQUIRED BY THE existing records, gather and maincain PRIVACY ACT OF 1974 AND THE PAPERWORK required data, and actually review REDUCTION ACT and complets the form. If you have any ccomments on this estimate, or on The solicitation of the personal how we can improve the collection of information requestsd in this form is this data to reduce the burden it autrorized by the Communications Act, —causes you, please writs the Federal Sections 8 & 9, and other debts under Communications Commission, AMD—DERM, the Debt Collection Improvement Act Washington, DC 20554, Paperwork of 1996. P.L. 104—134. The form will Recuction Project (3060—0589) . We be_ used primarily to capture will also accsept your comments via information to maintain required the Intsrnet if you send them to accounts receivable, . and q:olJ.-ect jboley@fcc.gov. Please DO NOT SEND fines and debts due the Commission. COMPLEITED APPLICATION FORMS TO THIS As part of the Debt Collection ADDRESS. Improvement Act, agencies are authorized to refer _ specific ‘Remember —— You are not required to Taxpayers Identification information respond to a collection of which includes Employer information sponsored by the Federal Identification NMumbers and Social government, and the government may Security Numbers to the Department of not comduct or sponsor this Treasury for further investigation collection, unless it displays a and possible enforcement of a currently valid COMB control number or statute, rule, requlation or order. if we fail to provide you with this If we believe there may be _ a notice. This collection has been violation or potential violation of a assigqned an COMB conmntrol number of FCC statute, requlation, rule or 3060—0589. order, your application may be referred to the Federal, _ state, or This notice is required by . the local agency responsible for Privacy Act of 1974, Public Law 93— investiqgating, prosecuting, enforcing 579, December 31, 1974, 5 U.S.C. or implementing the statute, rule, Section 552a(e) (3) and the Paperwork requlation or order. — In certain Reduction Act of 1995, ‘Public Law cases, the information in your 104—13, October 1, 1995, 44 U.S.C. application may be disclosed to the 3507 . Department of Justice or a court or adjudicative bedy when (a) the FCC; . or (b) any employee of the FCC; or (c) the United States Covernment, is a party to a procseding before the body or has an interest in the procseding. If information requested on the form is not provided, processing of the application/filing «may be delayed or returned without action pursusant to Commission rules. If you owe a past due debt to the Federal Covermment, the taxpayer idemntification nmumber (such as your social secqcurity number) and other information you provide may also be disclosed to the Department of the uieeasury, Financial Management alamrer federal agenciesSy. iployer to cffset yo es We=~ ~wefund or * other * C payments to collect that dept. 4I_’he FCC may also orsvide this information to _these agencies through the metching of compucsr records when auchrorized We have estimatsd thac each response to this csllsection of information will taks, on aversge, 30 minutss. Cur estimats includes the Ctime to rase the inser:etioens, leck through

HALPRIN, TEMPLE, GOODMAN & SuUcRUE 1100 NEW YORK AVENUE, N.W., SUITE 650 EAST WASHINGTON, D.C. 20005 (202) 371—9100 TELEFAX: (202) 371—1497 HTTP:YWWW.HTGS.COM ALBERT HALPRIN THoMmaAS J. SUgRUE RILEY K. TEMPLE JoEL BERNSTEIN STEPHEN L. GOODMAN MELANIE HARATUNIAN J. RANDALL COOK WILLIAM F. MAHER, JR. September 26, 1997 Via Overniqght Mail Federal Communications Commission Satellite and Radiocommunication Division P.0. Box 358210 Pittsburgh, PA 15251—5210 Re: Modification of ORBCOMM‘s NVNG License Dear Sirs/Madams: Enclosed please find the original plus nine copies of ORBCOMM‘s request for modification of its NVNG Satellite Service license, Forms 159 and 312, and a check for $18,220.00. In addition, enclosed is a copy for "Stamp and Return" purposes so that we can verify the receipt of the filing. ORBCOMM also requests expedited treatment of this minor modification request in light of the imminent launch of its satellites. It is not clear whether Public Notice is required,~ but the need for resolution prior to the launches scheduled in the next two months renders the application within Section 25.151(b)‘s provisions allowing for a special public notice "where speed is of the essence." ORBCOMM thus requests a shortened Public Notice period to the extent the Commission deems it necessary to provide Public Notice of this modification request.* 1 The Commission‘s Rules indicate that "major modifications" are to be placed on Public Notice (47 C.F.R. § 25.151(a) (3)), but the Rules do not define what constitutes a "major modification." By analogy, however, the definition of a "major amendment" refers to increases in the potential for interference (47 C.F.R. § 25.117(b) (1)), and as demonstrated in the modification request, the change will not result in any increase in potential interference. 2 ORBCOMM also observes that the entities most likely to be directly affected —— Iridium and NOAA —— have been informed of ORBCOMM‘s proposed modification in advance of filing in an effort (continued...)

Federal Communications Commission September 26, 1997 Page 2 Should you have any questions concerning this material, please contact me at (202) 371—9100. Sincerely, n /*kyt '/? /4 7yzA_—— Stephen L. Goodman Counsel for ORBCOMM oc:— Tom Tycz Cecily Holiday Cassandra Thomas Harold Ng Alext Roytblat Dan Connors Karl Kensinger Philip L. Malet Dick Barth 2 (...continued) to reach agreement on this issue, and also are being served with copies of this filing. Thus, they will not be prejudiced by a compressed comment cycle. Indeed, ORRCOMM had delayed the filing of this modification request while those discussions took place, which accounts for the somewhat short period between submission of the request and the scheduled launch of the satellites.

September 26, 1997 Mr. William F. Caton Acting Secretary Federal Communications Commission 1919 M Street, N.W. Room 222 Washington, D.C. 20554 Re: Request for Expedited Modification of ORBCOMM‘s License for an NVNG Mobile Satellite System Dear Mr. Caton: Orbital Communications Corporation ("ORBCOMM"), pursuant to Section 25.117(d) of the Commission‘s Rules, hereby submits a request for expedited modification of its authorization to construct, launch and operate a Non—Voice, Non—Geostationary Mobile—Satellite System ("License") .‘ ORBCOMM seeks to make two minor changes to its satellite constellation, namely (i1) increasing the altitude of the satellites to approximately 815 km from the currently licensed altitude of approximately 775 km,* and (ii) changing the inclination of one of the two high— inclination planes from 70 degrees to 108 degrees.? As explained in greater detail in the attached analysis, the slight increase in altitude will enhance the reliability of ORBCOMM‘s satellite services and reduce the likelihood of any collisions with the Iridium system. At the same time, the increase in altitude will not create any additional potential for harmful interference to terrestrial services or to other satellite systems. The second modification —— a change in the inclination V Orbital Communications Corporation, 9 FCC Red 6476 (1994), recon. denied, 10 FCC Red 7801 (1995) . 2 Orbital Communications Corporation, 10 FCC Red 6572 (1995) at J 4; see also ORBCOMM Amendment filed December 21, 1993 at p. 14: "The ORBCOMM system will employ satellites at an orbit altitude of approximately 775 km (482 statute miles) ..." 3 ORBCOMM‘s constellation includes two planes of satellites in a high inclination. The satellites in the other high inclination plane have already been launched and have been providing service. ORBCOMM also notes that, consistent with the needs of the primary military payload on the launch, the two satellites in the high inclination plane to be launched at an inclination of 108 degrees will be inserted into an elevation of approximately 780 km.

Mr. William F. Caton September 26, 1997 Page 2 of the other high inclination plane —— will allow ORBCOMM to take advantage of a launch opportunity as a more efficient "piggy— back" launch. ORRBRCOMM is proposing to make this change in altitude in order to enhance compatibility with other licensed low—Earth orbit systems and to additionally increase system reliability.* The change in inclination of one of the high—inclination planes will allow ORBCOMM to launch those two satellites more rapidly and at a lower cost than the original plan. ORBCOMM thus believes the proposed modification will well serve the public interest. The attached technical appendix includes an interference analysis concluding that the proposed modifications will not adversely impact the other first round NVNG licensee or the meteorological satellites operating in this band. Because the modification will not increase the power flux density ("PFD") for the ORBCOMM system, there will not be any greater chance of harmful interference as a result of the change.?" The technical appendix additionally demonstrates that the increase in altitude will decrease the risk of collision to other LEO systems.* Likewise, the change in inclination will not adversely affect coordination with the other satellite systems. 4 Increasing the elevation will reduce potential problems resulting from higher atmospheric density during solar maximum, a recurring phenomenon. It is projected that the change in elevation will reduce the potential adverse effects of this phenomenon, and thereby improve service reliability. 5 ORBCOMM is not required to predict the impact of its modification on the second round NVNG applicants (47 C.F.R. § 25.142(b) (3)), and indeed cannot precisely calculate the potential impact in light of the uncertainty of what spectrum will be licensed to the new entrants and their system designs. Because the modification will not increase the PFD of the ORBCOMM system, however, it does not believe that the proposed change will create any increased risk of harmful interference to the new NVNG satellite systems to be licensed in the second processing round . 6 ORBCOMM has initiated discussions concerning this change with Iridium, the LEO licensee that proposes to operate nearest to ORRBCOMM. ORBCOMM anticipates successful resolution of these discussions with Iridium in light of the reduced risk of collision that will result from the change. ORBCOMM will keep the Commission apprised of the status of these talks.

Mr. William F. Caton September 26, 1997 Page 3 Finally, ORRCOMM observes that the proposed modifications to the ORBCOMM system will further the public interest. The requested changes will enhance the satellite services‘ reliability, thereby ensuring that ORBCOMM‘s beneficial services remain available to the public. The change in inclination will also reduce ORBCOMM‘s costs. As a result of these changes, ORRCOMM will have a more competitive satellite system. The modifications will thus facilitate export opportunities and enhance economic efficiency, which will lead to an increased number of jobs in the United States. Also appended to this filing are the required certifications: an engineering certificate and an anti—drug abuse certification. Other than the change in elevation and inclination, the other parameters for the ORBCOMM system remain unchanged from the nrev1cusly granted ORBCOMM authorlzatlon, and thus will not be repeated in this modification request.* In sum, ORBCONMM believes that the public interest will be well served by the proposed modifications. ORBCOMM will be able to operate more efficiently and more reliably, and the risk of collision with Iridium will be reduced. WHEREFORE, ORBCCMM respectfully requests that the Commission expeditiously issue a modilfication of the ORBCOMM NVNG satellite system license as described herein. Sincefely, Alan L. Parkey Executive Vice—President Orbital Communications Corporation I ORBCOMM thus certifies that the remaining information with respect to its authorized system is not changing. See 47 C.F.R. § 25.117{(d) .

CERTIFICATION Orbital Communrications Corporation certifies that it is not subject to denial of Federal benefits that include Federal Communications Commission benefits pursuant to Section 5301 of the Anti—Drug Abuse Act of 1988. Orbital Comm orstion By: Alan L. Parker Executive Vice—President Datad: September 26, 1997

ENGINEERING CERTIFICATE I herseby certify that I am the technically qualified person responsible for preparation of the engineering information contained in this proposed modification, that I am familiar with Part 25 of the Commission‘s Rules, that I have reviewed the engineering information submitted in this proposed modification, and that it is complete and accurate to the best of my knowledge. Dated this 256th day of September, 1997. By : QM %’ //%/ FPful A. Locke Senior Director Systems Engineering and Spectrum Management Orbital Communications Corporation

Technical Appendix Reduction of Collision Potential and Interference Analysis 1. Constellation position management for the reduction of collision potential Throughout the design and development of the IRIDIUM and ORBCOMM systems, Motorola and Orbital have shared concerns regarding collision avoidance and the reduction of orbital debris generation. In the interest of mutual system survival and preservation of the orbital environment, Motorola initiated a Memorandum of Understanding (MOU) with ORBCOMM for the cooperative, periodic exchange of satellite position information. The proposed MOU is a proactive step in the absence of regulatory guidance in the area of position management for LEO constellations, and it represents a welcome opportunity for cooperation and mutual benefit. However, ORBCOMM believes that implementation of the current MOU does not adequately address and reduce the collision risk. Consequently, ORBCOMM proposes that the main ORBCOMM constellation targeted for 775 km be retargeted for 815 km. At a mean altitude of 775 km, natural orbital perturbations will result in an actual operational altitude range for ORBCOMM of approximately 764 — 786 km. From recent two—line element sets available from Goddard, it appears that IRIDIUM‘s operational mean altitude and altitude range are approximately 778 +/—3 km, which are consistent with the design orbit filed with the FCC. Therefore, the two constellations will overlap completely in altitude, with IRIDIUM residing entirely within ORBCOMM‘s altitude range. The probability that a collision will occur between the two constellations is on the order of 3.5x10¢ per year, or about one chance in 3,000 per year. This represents about 10% of the overall annual collision risk for IRIDIUM (considering the entire USSPACECOM catalog), whereas it constitutes a significantly larger portion of ORBCOMM‘s total collision risk.} The chief difficulties with the current position management plan are as follows: 1. At a mean altitude of 775 km, operational factors will require ORBCOMM to counteract atmospheric decay and maintain 775 km. Therefore, IRIDIUM (775 — 781 km) and ORBCOMM (764 — 786 km) will be in a perpetual state of overlap throughout the lives of both constellations and will be exposed to this elevated collision risk not only for first—generation satellites, but presumably for subsequent generations as well. 2. ORBCOMM and IRIDIUM will not have sufficiently accurate information (individually, nor collectively) to perform collision avoidance analyses and maneuvers. State vector uncertainties and propagation errors prevent keep—out zones from being defined tight enough to warrant disruption of constellation formation, making collision avoidance maneuvers infeasible in the event of a predicted close encounter. *"—Recause of the smaller number of ORBCOMM satellites and their smaller size, the risk from other resident space objects is smaller for ORBCOMM than for IRIDIUM.

3. Without this active avoidance component, the effort described in the MOU is effectively reduced to one of passive monitoring. The collision risk associated with being coorbital remains unmitigated. ORBCOMM therefore proposes moving the ORBCOMM constellation to a mean altitude of 815 km. The advantages of this arrangement are three—fold. 1. The collision potential between the two constellations is eliminated for the entire operational lives of the first generations of both systems. The attached plot shows ORBCOMM‘s anticipated orbital decay profile. With an initial mean altitude of 815 km (and corresponding range of ~805 — 825 km), the altitude regimes of the two constellations do not begin to overlap until at least the year 2005. 2. The long—term collision probability between the two constellations is greatly reduced. The timing of the 11 year solar cycle and the choice of 815 km together result in a rapid decay of ORBCOMM‘s initila satellite constellation through IRIDIUM‘s operational altitude regime. The total overlap time is only 5—7 years, as compared to the perpetual overlap which would occur by targeting the current ORBCOMM constellation, and all subsequent generations, at 775 km. 3. The need for the daily exchange of state vector information is eliminated. The time and cost associated with these coordination efforts is also saved. In addition, ORBCOMM intends to employ a more active means of end—of—life disposal in the design of next—generation satellites. 2. Interference impact on other first round licensees The other first round licensee, VITA, does not operate co—frequency with ORBCOMM, and so will not be affected by the inclination or altitude modification. 3. PFD produced by the ORBCOMM system ORBCOMM will continue to meet the pfd limit of —125 dB W/min 4 kHz. The increase in altitude will have a small effect on the PFD incident at the Earth‘s surface for different angles of elevation. Figure 2 illustrates these variations with the new pfd shown as a dashed line. The satellite transmit power has been set to produce the maximum pfd of —125 dB W/m*. As can be seen in the figure, the PFD curves for 775 km and 815 km altitude orbits are nearly coincident. Since ORBCOMM continues to meet the PFD limit, there will be no interference to terrestrial receivers. 4. Compatibility with Meteorological—satellite systems operating in the 137 — 138 MHz band ORBCOMM and NOAA are in the final stages of discussions with respect to maintaining compatibility between the ORBCOMM system and the current and planned Meteorological— satellite systems operating in the 137 — 138 MHz band. The proposed minor changes of altitude and inclination will be considered in that agreement. ORBCOMM is confident that an agreement will be reached.

5. Affects of the change in inclination angle The change in inclination angle for one of the two high—inclination planes is a very minor change. The 108° inclination is equivalent to —72° inclination, and so the dynamic interference statistics will nearly identical to those for the 70° inclination case. The orbit will not be synchronous with either the Earth or the Sun since it will precess by 0.22° per day (80° per year). Orbcomm Apogee/Perigee Decay Predictions Four Sample Histories Using Daily Monte Carlo Solar Activity Predictions 830 820 . 810 . 800 1 Altitude (km) 790 1 ~ o o 770 . 760 . 750 + 0.0 5.0 10.0 15.0 30.0 Time (years) Figure 1. ORBCOMM Decay predictions

—125 PFD (dBW/m2 in 4 kHz) 130 / —135 0 10 20 30 40 50 60 70 80 90 Hevation Angle (degrees) Figure 2. PFD versus angle of Elevation for 775 and 815 km altitude orbits

FCC 312 °m"Sothons Main Form FEDERAL COMMUNICATIONS COMMISSION P icfonarToi. Per Responne: 10 Hre. APPLICATION FOR SATELLITE SPACE AND EARTH STATION AUTHORIZATIONS PAYOR AND FILING FEE INFORMATION A. Halprin, Temple, Goodman & Sugrue 202/371—9100 c. or P.0. 1100 New York Avenue, N.W. — Suite 650 East 0521764279 e. Citi'1 . . Code h. Country not U.S.A.) Washington 20005 Ype TC CGW 18 ,220 APPLICANT INFORMATION 1. Legal Name of Applicant , 2. Voice Telephone Number Orbital Communications Corporation 703/406—5300 3. Other Name Used for Doing Business (if any) 4. Fax Telephone Number ORBCOMM . 703/406—3508 5. Mailing Street Address or P.O. Box 6. City 21700 Atlantic Blvd. Dulles 7. State / Country (if not U.S.A.) 8. Zip Code ATTENTION: Alan Parker VA 20166 9. Name of Contact Representative (Ifother than applicant) 10. Voice Telcphone Number 11. Firm or Company Name 12. Fax Telephone Number 13. Mailing Street Address or P.O. Box 14. City 15. State / Country (if not U.S.A) 16. Zip Code ATTENTION: CLASSIFICATION OF FILING 17. Place an "X" in the box next to the classification that applies to this filing for both questions a. and b. Mark only one box for 17a and only one box for 17b. D al. Earth Station I:I :;— 2pp:fcntfon :ar !:cc'nse of Nc:vI:(alion b4. Modificoar(il({en;;];:tci%:se . Application for Registration of New b5. Assignment of License (fnag & (Pent m a2. Space Station D Domestic Receive—Only Station D or Registration D b7. Notification of Minor Modification [_] b3. Amendmentto a Pending Application [] bfi-&‘:efl;ggf:‘;{(éogflgfi%f; D b8. Other (Please Specify): 18. If this filing is in reference to an existing station, enter: 19. If this filing is an amendment to a pending application enter: Call sign of station: (a) Date pending application was filed: (b) File number of pending application: Satellite license granted at 9 FCC Red 6476 (1994) FCC 312, Main Form — Page 1 April, 1997

TYPE OF SERVICE 20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Place an "X" in the box(es) next to all that apply. & & . & : eak & . & e. Other D a. Fixed Satellite D b. Mobile Satellite D c. Radiodetermination Satellite D d. Earth Exploration Satellite @ (please specify) Non—Voice Non—Geostationary MSS 21. STATUS: Place an "X" in the box next to the applicable status. Mark only one box. 22. If earth station applicant, place an "X" in the box(es) next to all that apply. D a. Common Carrier @ b. Non—Common Carrier D a. Using U.S. licensed satellites D b. Using Non—U.S. licensed satellites 23. If applicant is providing INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Mark only one box. Are these facilities: [__] a. Connected to the Public Switched Network [_] b. Not connected to the Public Switched Network 24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s). [_] a. C—Band (4/6 GHz) [_] 6. Ku—Band (12714 GHz) KX] c. Other (Please specify) 137—138 MHz; 148 149.9 MHz; 400 MHz TYPE OF STATION 25. CLASS OF STATION: Place an "X" in the box next to the class of station that applies. Mark only one box. [_] a. Fixed Earth Station [__] b. Temporary—Fixed Earth Station [__] c. 12/14 GHz VSAT Network [__] d. Mobile Earth Station [__] e. Space Station £(Specify) Other If space station applicant, go to Question 27. 26. TYPE OF EARTH STATION FACILITY Mark only one box. D a. TransmitUReceive D b. Transmit—Only D c. Receive—Only PURPOSE OF MODIFICATION OR AMENDMENT 27. The purpose of this proposed modification or amendment 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 d —— authorization to replace antenna e —— authorization to add antenna f —— authorization to relocate fixed station g —— authorization to change assigned frequency(ies) h —— authorization to add Points of Communication (satellites & countries) i —— authorization to change Points of Communication (satellites & countries) j —— authorization for facilities for which environmental assessment and radiation hazard reporting is required [XX k —— Other (Please Specify) Modify LEO Constellation 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 1.13077 YES XZNO If YES, submit the statement as requze% by Sections l?fim and 1.1311 of the Commissiog's rules, 47 C.F.R. §§ 1.1308 and 1.1311, as Exhibit A to this application. D A Radiation Hazard Study must accompany all applications as Exhibit B for new transmitting facilities, major modifications, or major amendments. Refer to OET Bulletin 65. FCC 312, Main Form — Page 2 April, 1997

ALIEN OWNERSHIP 29. Is the applicant a foreign governmentor the representative of any foreign government? [] ves [{g no 30. Is the applicant an alien or the representative of an alien? [_] ¥Es [ no 31. Is the applicant a corporation organized under the laws of any foreign government? [_] vEes y No 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or [] vyEs y no voted by aliens or their representatives or by a foreign governmentor representative thereof or by any corporation organized under the laws of a foreign country? 33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than [] ¥Es [53 No 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 under the laws of a foreign country? 34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as Exhibit C 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? If Yes, attach as Exhibit D, copies of the requests for waivers or exceptions with supporting documents. [_] ves EJ no 36. Has the applicant or any party to this application had any FCC station authorization or license revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or construction [_] ves EJ no permit denied by the Commission? If Yes, attach as Exhibit E, an explanation of the circumstances. 37. Has the applicant, or any party to this application, or any })arty directly or indirectly controlling the applicant ever been convicted of a felony by any state or federal court? [] xes E] no 38. Has any court finally adjudged the applicant, or any person directly or indirectly conmolling the applicant, guilty of unlawfully monopolizing or attempting unlawfully to monopolize radio communication, directly or indirectly, through control of [_] vEs KA NO manufacture or sale of radio apparatus, exclusive traffic arrangement or any other means or unfair methods of competition? 39. Is the applicant, or at:]\; person directly or indirectly controlling the applicant, currently a party in any pending matter referred to in the preceeding two items? [] ¥yEs [ no 40. By checking Yes, the undersigned certifies, that neither the applicant nor any other party to the a; gligxlatil?nsiéstébjegt t08:16gegg:laof Federal benefits that includes FCC benefits pursuantto Section 5301 of the Anti—Drug Act of 19 > .S.C. Section 862, because [¥ ves [ no of a conviction for possession or distribution of a controlled substance. See 47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes. 41. Description. (Summarize the nature of the application and the services to be provided). ORBCOMM seeks to modify its LEO satellite constellation to increase the altitude of the non—high inclination planes from approximately 775 km to approximately 815 km, and to change the inclination of one of the high inclination planes from 70—degrees to 108 degrees FCC 312, Main Form — Page 3 April, 1997

CERTJIFICATION The Applicant waives any claim to the use of any particuier {requency or of the electromagnetic spectrum as against the reguiatory power of the United States because of the lnevious use of the same, whether by ficense or otherwise, and requests an authorization in accordance with this application. applicant certifies that grant of this application would not cause the applicant to be in vioalation of the spectrum aggregation limit in 47 CFR Part 20. All statements made in exhibits are a material pait hereof and are incorporated herein as if set out in full in this application, ‘The undersigned, individeally and for the applicant, hereby certifies that all statements made in this application and in ali anached exhibits are true, complete and correct to the best of filp or her knowledge and belief, and are made in good faith. 42. Applicant is a (anJ: (Place an *X" in the boxk next to appiicabie response.) €us kss 1 a + (_] a. todividual {D] b, Unincorporated Association [_] c. Parinership [5:] 6. Corporation {[_] e. Governmental Entity [_] {.(Please Other specify) 43. Typed Name of Pesson Signing 44. Title of Person Signing Alan L. Parker //7 O ' Executive Vice President 45. Signature 46. Date September 26, 1997 WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND/OR IMPRISONMENT gU.S. Code, Title 18, Seclion 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.8. Code, Title 47, ection 3li(a)(l)), ND/OR FORFEITURE (U.S, Code, Title 47, Section 503). PCC 112. Maln Form — Page 4 April, 1997


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