Planet Labs Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Planet Labs Inc.

Ex Parte

2016-07-01

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

IBFS_SATMOD2015080200053_1142019

                                                               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




July 1, 2016


VIA IBFS

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

Re:        Ex Parte Letter
           IBFS File Nos. SAT-MOD-20150802-00053; SAT-STA-20150821-00060; SAT-LOA-
           20151123-00078

Dear Ms. Dortch:

On June 30, 2016, representatives of Planet Labs Inc. (“Planet") spoke with representatives of the
FCC’s International Bureau (“Bureau”) regarding the above-referenced proceedings. The following
individuals participated in the conference call on behalf of Planet: Rich Leshner, Vice President
Government Affairs; Mike Safyan, Director of Launch and Regulatory Affairs; and Tony Lin, outside
counsel for Planet Labs. The following people participated in the call on behalf of the Bureau: Jose
Albuquerque, Satellite Division Chief; Stephen Duall, Policy Branch Chief; Chip Fleming, Satellite
Division Chief Engineer; and Cindy Spiers, Policy Branch Attorney Advisor.

Planet discussed the status of the negotiations with ORBCOMM License Corp. (“ORBCOMM”) and
the company’s conclusion that a negotiated resolution of the issues ORBCOMM has raised in the
above-referenced proceedings is unlikely.1 Planet stated that it will soon submit in-plane collision
analysis for the secondary payloads aboard the SHERPA mission, demonstrating that the risk of
collision meets the NASA standard and is also well below any other reasonable measure of risk.
Planet informed the Bureau of the revised, mid-October 2016 launch date for the Sherpa mission
and asked that the Bureau grant the Planet application, with respect to that launch, in advance of
that deadline.2


1
 See, e.g., ORBCOMM License Corp. Petition to Dismiss, Deny or Hold in Abeyance, File No. SAT-
MOD-20150802-00053 (filed Jan. 19, 2016); see also Letter from Walter H. Sonnenfeldt, Regulatory
Counsel, ORBCOMM License Corp., and Vice President, Regulatory Affairs, ORBCOMM Inc., to
Marlene H. Dortch, Secretary, FCC, File No. SAT-MOD-20150802-00053 (May 13, 2016).
2
 The Bureau has already granted the other portions of the application. See Public Notice, DA No.
16-688 (June 17, 2016).


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


                                                                Respectfully submitted,


                                                                /s/ Tony Lin

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


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



Document Created: 2016-07-01 11:22:01
Document Modified: 2016-07-01 11:22:01

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