Planet Labs Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Planet Labs, Inc.

Planet Labs Ex Parte Notification - 012516

2016-01-25

This document pretains to SAT-MOD-20150802-00053 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015080200053_1123891

                                                                                                             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 25, 2016

VIA IBFS

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re:              Ex Parte Letter
                 File No. SAT-MOD-20150802-00053

Dear Ms. Dortch:

On January 21, 2016, Mike Safyan, Director of Launch and Regulatory Affairs of Planet Labs, Inc.
(“Planet Labs”), and Tony Lin, Counsel for Planet Labs, met with Stephen Duall, Chip Fleming, and
Cindy Spiers, each of the International Bureau (“Bureau”), to discuss the above-referenced
application and the Petition to Dismiss, Deny, or Hold in Abeyance (“Petition”) submitted by
ORBCOMM License Corp. (“ORBCOMM”) in this application proceeding.1

Planet Labs expressed surprise by the Petition and disappointment that ORBCOMM did not first
attempt to resolve its concerns operator-to-operator. Both Planet Labs and ORBCOMM are
members of the Space Data Association, which is a non-profit association of satellite operators,
having the primary goals of facilitating “improvements in the safety and integrity of satellite
operations through wider and improved coordination among satellites operators [and] improved
management of the shared resources of the space environment.”2

Planet Labs also explained its risk collision assessment and NASA’s Debris Assessment Software or
DAS. Given the expected launch of a number of its satellites in the spring of 2016, Planet Labs
urged the Bureau to act expeditiously.

Pursuant to Section 1.1206(b) of the Commission’s rules, this letter is being filed electronically in the
above-referenced proceeding.3 Please direct any questions regarding this submission to the
undersigned.




1
    See Petition to Dismiss, Deny, or Hold in Abeyance (filed Jan. 19, 2016).
2
  See SDA Overview, Space Data Association, http://www.space-data.org/sda/about/sda-overview/
(last accessed Jan. 25, 2016).
3
 On January 20, 2016, the Bureau, on its own motion, changed the status of the application
proceeding to “permit-but-disclose” effective January 21, 2016. See Report No. SAT-01131, DA 16-
80 (Jan. 22, 2016).

Hogan Lovells US LLP is a limited liability partnership registered in the District of Columbia. “Hogan Lovells” is an international legal practice that includes Hogan Lovells US
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www.hoganlovells.com


Ms. Marlene H. Dortch   -2-            January 25, 2016




                                 Respectfully submitted,

                                            /s/ Tony Lin

                                                Tony Lin
                                                Counsel
                              tony.lin@hoganlovells.com
                                      D 1+ 202 637 5795

cc:    (via email)
       Stephen Duall
       Chip Fleming
       Cindy Spiers



Document Created: 2016-01-25 12:06:31
Document Modified: 2016-01-25 12:06:31

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