Planet Labs Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Planet Labs Inc.

Planet Labs Ex Parte

2016-08-18

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

IBFS_SATMOD2015080200053_1146635

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Description of Application Spire Global, Inc. (“Spire”) requests authority to launch and operate a constellation of low-earth orbit, non-geostationary orbit (“NGSO”) cubesats to provide maritime monitoring, meteorological monitoring, and earth imaging services.1 As detailed in this narrative description (“Narrative”), the Spire satellite system, i.e. the LEMUR constellation, will be constructed in two phases. Phase I will employ 29 technically identical2 cubesats operating at a number of different orbital altitudes and inclinations (the LEMUR-2 constellation). These satellites will use the 2020-2025 MHz band for downlink3 and the 402-403 MHz band for uplink and telemetry, tracking, and command (“TT&C”).4 Phase II will employ up to 175 technically identical satellites, operating at orbital altitudes from 400 to 650 km and inclinations ranging from equatorial to polar sun-synchronous (98 degrees) (the LEMUR-3 constellation).5 These cubesats will use the 8025-8400 MHz band for downlink, including TT&C, and the 2025-2110 MHz band 1 Cubesats are also referred to as nanosatellites, small satellites, small sats, or picosats, depending on context. 2 The satellites have the same relevant radiofrequency characteristics (e.g., transmit power, out- of-band emissions, antenna patterns and gain, and transmit and receive frequencies). 3 The Phase I satellites will also use the 402-403 MHz band for backup downlink. See Frequency Bands, Exhibit B (identifying the proposed frequency bands to be used on the LEMUR constellations); see also infra Part II.A.4 (discussing the frequency bands used by the LEMUR constellations). 4 As discussed below, Spire already has received experimental authority for the launch and operation for several of the 29 Phase I satellites and is not seeking further authorization with respect to those previously authorized satellites or any subsequent Phase I satellite for which Spire receives experimental authorization. 5 Spire expects the constellation, at any point in time, to be comprised of approximately 125 satellites.

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 for uplink, including TT&C. 6 Both the Phase I and Phase II satellites also will have equipment capable of receiving two Automatic Identification System (“AIS”) signals, AIS 1 (161.9625- 161.9875 MHz) and AIS 2 (162.0125-162.0375 MHz),7 and also the Global Positioning System (“GPS”) L1 signal (centered at 1575.42 MHz) and the L2 signal (centered at 1227.60 MHz). Spire also requests launch authority for a total of up to 900 satellites to be deployed over the 15-year term of the requested satellite license. This authority will cover both the Phase I satellites (that have not been granted experimental authorizations as of the date of the grant of this application) and the Phase II satellites. Spire would have no more than 175 satellites operational at any given time and would only launch additional satellites, as necessary, to replenish its on-orbit fleet. In support of its request for authorization, Spire provides the following information concerning its proposed satellite system. I. Description of the Applicant Spire, which was formerly known as NanoSatisfi, Inc. and formed in Delaware in August 2012, is a private U.S. company headquartered in San Francisco, California, with offices in Glasgow and Singapore. The enterprise grew out of a volunteer effort by four graduate students 6 The Phase II satellites will also use the 2020-2025 MHz band for backup downlink band and the 402-403 MHz band for backup uplink and downlink, including for backup TT&C. See Frequency Bands, Exhibit B (identifying the proposed frequency bands to be used on the LEMUR constellations); see also infra Part II.A.4 (discussing the frequency bands used by the LEMUR constellations). 7 See, e.g., Amendment of Parts 1, 2, 15, 25, 27, 74, 78, 80, 87, 90, 97, and 101 of the Commission’s Rules Regarding Implementation of the Final Acts of the World Radiocommunication Conference (Geneva, 2007) (WRC-07), Other Allocation Issues, and Related Rule Updates, et al., Report and Order, Order, and Notice of Proposed Rulemaking, 30 FCC Rcd 4183 ¶ 106 (2015) (“WRC-07 Implementation Order”). 2

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 at the International Space University who began building a prototype nanosatellite as a platform for making space accessible and affordable to students. Early funding for the concept came from the crowdfunding website Kickstarter, where the original ArduSat (short for “Arduino-based satellite”) concept raised more than $100,000 from nearly 700 private space enthusiasts.8 Two ArduSats were released into orbit from the International Space Station on November 19, 2013 pursuant to an experimental authorization granted by the Office of Engineering and Technology (“OET”).9 Kickstarter funders and others used these satellites to test experiments, play games, take pictures, and run applications. For this pioneering work related to the ArduSats, the Obama Administration recognized Spire Co-founder and CEO Peter Platzer as a “Champion of Change.”10 Building on the success and experience of the ArduSat satellites, Spire subsequently sought and received Federal Communications Commission (“FCC” or “Commission”) authority to conduct a market trial with two, more advanced satellites, ArduSat-2 and LEMUR-1.11 These satellites, which have more equipment and greater functionality than the prior ArduSats, were designed to explore the potential commercial viability of providing services for educational, 8 ArduSat—Your Arduino Experiment in Space, KICKSTARTER, https://www.kickstarter.com/projects/575960623/ardusat-your-arduino-experiment-in-space (last accessed May 27, 2015). 9 See Application of Ardusat Inc., ELS File No. 0917-EX-ST-2012, Call Sign WG9XFC (granted Apr. 26, 2013); Application of Ardusat Inc., ELS File No. 0787-EX-PL-2013, Call Sign WG2XZS (granted Mar. 14, 2014). 10 Peter Platzer, Creating Next Generation Innovators Through Space Education, WHITEHOUSE.GOV BLOG (Jun. 6, 2013), https://www.whitehouse.gov/blog/2013/06/06/creating- next-generation-innovators-through-space-education. 11 See Application of NanoSatisfi, Inc., ELS File No. 0532-EX-PL-2013, Call Sign WG2XXW (granted Dec. 6, 2013); Application of Spire Global, Inc., ELS File No. 0213-EX-PL-2014, Call Sign WH2XCV (granted Apr. 25, 2014). 3

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 meteorological, aeronautical, and maritime markets. Both satellites also have earth-imaging capabilities and have been authorized by the National Oceanic and Atmospheric Administration (“NOAA”).12 In 2015, Spire sought additional experimental authority for commercial validation of a more robust satellite system with more frequent revisit times.13 The FCC has authorized the launch and operation of several of the satellites in that system, as well as the associated ground segment.14 Four of those satellites have been successfully launched, and the other launches are scheduled for early 2016.15 As a result of the commercial validation of its system, Spire now seeks authority to begin deployment of a more robust cubesat system to provide maritime monitoring, meteorological monitoring, and earth imaging services.16 Spire has a license with NOAA for its Phase I satellites and will submit another application to NOAA for the Phase II satellites prior to the launch of those satellites. 12 See About the Licensing of Private Remote Sensing Space Systems, NOAA, http://www.nesdis.noaa.gov/CRSRA/licenseHome.html (last accessed Sep. 22, 2015). 13 See Application of Spire Global, Inc., Call Sign WH2XQT, ELS File No. 0041-EX-PL-2015 (granted Jun. 10, 2015). Spire initially sought experimental authorization for the limited satellite deployment, because of the frequencies proposed and the experimental nature of some of the equipment, including the S-band transmitter. OET partially granted the initial experimental application, noting that it would authorize only the initial launch, but invited Spire to modify the experimental authorization to include additional launches. 14 See Application of Spire Global, Inc., ELS File No. 0041-EX-PL-2015, Call Sign WH2XQT (granted Jun. 10, 2015); Application of Spire Global, Inc., ELS File No. 0129-EX-ML-2015, Call Sign WH2XQT (granted Jul. 17, 2015). 15 See Peter B. de Selding, PSLV Rocket Launches India’s 1st Astronomy Satellite, 4 Spire Cubesats, SPACENEWS (Sep. 28, 2015), http://spacenews.com/pslv-rocket-launches-indias-1st- astronomy-satellite/. 16 Spire has commenced construction of this system at its own risk. See Attachment 1 to this Narrative. 4


Document Created: 2016-08-18 17:08:29
Document Modified: 2016-08-18 17:08:29
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