Planet Labs Ex Parte

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by Planet Labs Inc.

Ex Parte Letter

2016-08-24

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

IBFS_SATMOD2015080200053_1147289

                 REQUESTS FOR SPECIAL TEMPORARY AUTHORITY

       Spaceflight Inc. (“Spaceflight”), pursuant to Section 25.120 of the Commission’s
Rules, hereby requests Special Temporary Authority (“STA”) to permit it to
communicate with a spacecraft, known as SHERPA, and corresponding earth stations
for a duration of up to twelve (12) hours to take place in a single occurrence between
January 15, 2016 and April 15, 2016. 1

        As described in greater detail in the attached Technical Annex, SHERPA is a non-
propulsive, free-flying spacecraft intended to deploy auxiliary spacecraft from each of
five ports. SHERPA itself is proposed to be affixed to the payload on a Falcon 9 launch
that is currently scheduled to occur within above-stated launch period. SHERPA will
be placed in a sun synchronous elliptical orbit of 720 x 450 km, 97.4 degree inclination.
After its deployment from the launch vehicle, SHERPA will initiate a sequence of
procedures to begin the deployment of its own payload and the communication that is
the subject of the instant requests will commence.

       Spaceflight seeks authority to permit it to establish communications between
SHERPA and three earth stations during the twelve-hour operational of the SHERPA
payload. 2 The communications links, which will consist of two-way data transmissions,
will permit the Spaceflight technical crew to track the launch and download status
information from SHERPA. The proposed frequencies for communication to and from
SHERPA are UHF frequencies authorized under the FCC’s Table of Frequency
Allocations for space operations.

      The payload of SHERPA will consist of small spacecraft that are owned and to be
operated by Spaceflight’s customers. Each customer is expressly required under its
agreement with Spaceflight to obtain all licenses, authorization, clearances, and permits
that may be necessary to operate its individual spacecraft.

       Spaceflight asserts that grant of the instant requests for Special Temporary
Authority will be in the public interest. Such grant will permit Spaceflight to initiate a
new and innovative deployment technology for small spacecraft, thereby providing a
cost-efficient means for placing them into their designed orbits.


1 Recent developments in the spacecraft launch industry have resulted in a number of launch delays and
uncertainties as to when future launches will occur. The timeframe set forth above reflects the current
launch period assigned for the Spaceflight launch. Spaceflight has not yet been assigned an exact date of
the SHERPA launch. Accordingly, Spaceflight is herein seeking STA to cover a period of three (3)
months. However, as described herein, the actual communications for which STA is sought will occur
over a period of only twelve (12) hours. Spaceflight will notify the Commission as its launch period is
narrowed to a particular day as soon as that information is confirmed to it by the launch provider.
2 Spaceflight is submitting concurrently unique applications for space station STA to cover the

communications of SHERPA and earth station STA to cover the ground station locations.


        Technical Annex: Spaceflight SHERPA Spacecraft Description
The Spaceflight SHERPA spacecraft is a non-propulsive, free-flying spacecraft intended to deploy
auxiliary spacecraft from each of five ports. The spacecraft is primarily composed of commercial off the
shelf (COTS) hardware, with the core structure being a custom ESPA Grande ring. Auxiliary satellites are
integrated to each port using simple plates and separated using proven separation systems, such as the
Planetary Systems Corporation (PSC) Motorized Lightband (MLB) and the Innovative Solutions in Space
(ISIS) QuadPack. The configuration, shown in Figure 1, is
intended to deploy three microsatellites using MLBs as well
as several CubeSats and nanosatellites from twenty-one
(21) QuadPack dispensers. Each QuadPack holds 12U worth
of CubeSat payload. A CubeSat, based on the Cal Poly
CubeSat standard, has nominal dimensions 10 x 10 x 10 cm.
SHERPA runs flight software on COTS Andrews Space
CORTEX avionics and it is equipped with its own power and
power distribution system to deploy each auxiliary
spacecraft in a pre-programmed sequence. The primary
mission is satisfied by successful deployment of each
auxiliary payload. The confirmation of successful payload
deployment is given by the transmission of telemetry
containing SHERPA state vectors taken upon each discrete
deployment event.
The SHERPA mission itself is expected to last approximately
                                                                       Figure 1. SHERPA Spacecraft shown
twelve (12) hours. At launch, SHERPA is integrated beneath
                                                                    integrated with the Payload Attach Fitting
the primary payload. The primary payload is launched into           (below) and the Primary Payload Adapter
720 km circular sun synchronous orbit and then separated.                            (above)
The upper stage, with SHERPA attached, executes a
maneuver to lower the perigee of the orbit to 450 km and
change the inclination to 97.4 degrees. At this orbit, SHERPA is separated from the upper stage. The
separation event activates the SHERPA spacecraft through the closing of separation switches, which will
turn on for the first time. After initialization, SHERPA begins a pre-programmed sequence of
deployments. No uplink is necessary to begin deployments. For each deployment event time, position,
and velocity (determined via GPS receiver) are logged in the form of a state vector to be transmitted.
Upon completion of deployments, SHERPA transmits the telemetry to a ground station. SHERPA’s
communication system utilizes an onboard UHF radio with 4 antenna.
SHERPA batteries are expected to last for duration less than 20 hours until they’re expended. Ultimately,
SHERPA de-orbits through orbital decay due to atmospheric drag approximately 20 years after launch.


Location                         SHERPA (space segment)           North Pole, Alaska         Tukwila, Washington          NASA Wallops
Link direction                           Downlink                 Uplink                     Uplink                       Uplink
                                                                  M2 Antenna Systems
Antenna Manufacturer             Spaceflight Systems Inc          Inc                        M2 Antenna Systems Inc MIT Lincoln Labs
Antenna Model                    n/a                              450CP34                    450CP34                n/a

Antenna Size                     n/a                              3.05‐m boom length         3.05‐m boom length           18.3‐m diameter
Number of Antennas                                            1                          1                            1                                     1
                                 Mobile, LEO                      1625 Richardson
                                 Orbit: 720 x 450 km, 97.4°       Highway, North Pole,       3415 S 116th St #123,        Building U‐25, Mainland Road
Address, City, State             inclination                      Alaska                     Tukwila, WA                  Wallops Island, VA 23337
Lat/Long coordinates in                                           64° 47' 37.0" N,           47° 29' 55.44" N, 122°       37° 51' 18'' N
minutes,seconds                  Mobile, LEO                      147° 32' 10.8" W           17' 23.64" W                 75° 30' 47'' W
Site Elevation AMSL              Mobile, LEO                      144 m AMSL                 15.9 m AMSL                  12.6 m AMSL
Frequencies                      401.5 MHz                        450.2 MHz                  450.2 MHz                    450.2 MHz
Output Power (W)                 2W                               5W                         5W                           8W
ERP (W)                          2.07 W                           63 W                       63 W                         15,310 W
Frequency tolerance              *                                *                          *                            *
Emissions (bandwidth of signal
plus emission type)              825KG1D                     27K6G1D                         27K6G1D                      27K6G1D
                                                             A single channel                A single channel
                                 A single channel containing containing digital              containing digital           A single channel containing digital
Modulating Signal                digital information         information                     information                  information

*In lieu of frequency tolerance, the occupied bandwidth of
the emission shall not extend beyond the band limits set



Document Created: 2016-08-24 17:33:44
Document Modified: 2016-08-24 17:33:44

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