SEH Reply (FINAL).pd

REPLY submitted by WorldVu Satellites Limited

Reply of WorldVu Satellites Limited

2019-03-05

This document pretains to SAT-MOD-20181108-00083 for Modification on a Satellite Space Stations filing.


                                  Before the
                   FEDERAL COMMUNICATIONS COMMISSION
                             Washington, DC 20554


In the Matter of                         )
                                         )
Space Exploration Holdings, LLC          )         Call Signs S2983 and S3018
                                         )
Application for Modification of          )         File No. SAT-MOD-20181108-00083
Authorization for the SpaceX NGSO        )
Satellite System                         )




                   REPLY OF WORLDVU SATELLITES LIMITED




Mariah Dodson Shuman                         Brian Weimer
Head of Regulatory Affairs, Americas         Douglas Svor
WorldVu Satellites Limited                   Samuel Swoyer
1785 Greensboro Station Place, Tower 3       Sheppard Mullin Richter & Hampton LLP
McLean, VA 22102                             2099 Pennsylvania Ave NW, Suite 100
                                             Washington, DC 20006
                                             (202) 747-1930
                                             bweimer@sheppardmullin.com



March 5, 2019


                             INTRODUCTION AND SUMMARY

         In its Further Opposition, SEH fundamentally fails to address the serious concerns—

raised by OneWeb and other interested parties—created by the major changes proposed in the

SEH Modification Application. 1 The Commission appears to have recognized some of these

very serious concerns by issuing a request for further information to SEH. 2 The Commission is

rightly focused on the risk of physical collisions presented by the Modification Application.

         Until SEH fully addresses the serious concerns raised by OneWeb, the Commission itself,

and all other interested parties, the Commission should withhold grant of the Modification

Application. Hasty action by the Commission at this very important juncture in the development

of real satellite systems like OneWeb—which successfully launched its first six satellites just last

week—and the many existing small satellite constellations could be nothing short of

catastrophic.

         Notably, no commenter or petitioner has stated or even suggested any level of comfort

with the Commission granting the Modification Application in its current form. 3 To the

contrary, the record in this proceeding demonstrates widespread industry opposition to SEH’s

proposed modifications and reinforces OneWeb’s prior determination that the Commission

should not grant the Modification Application. OneWeb respectfully restates its request that the




1
 See Space Exploration Holdings, LLC, Further Consolidated Opposition to Petitions and
Response to Comments of Space Exploration Holdings, LLC, IBFS File No. SAT-MOD-
20181108-00083 (filed Feb. 21, 2019) (“Further Opposition”).
2
  See Letter from Jose P. Albuquerque, Chief, Satellite Division, to William M. Wiltshire and
Paul Caritj, Counsel to SpaceX, IBFS File No. SAT-MOD-20181108-00083 (Feb. 26, 2019)
(“Commission Letter”).
3
    See generally IBFS File No. SAT-MOD-20181108-00083.

                                                 i


Commission deny the Modification Application or, at a minimum, consider it only within the

context of a subsequent NGSO FSS processing round.




                                              ii


                                                TABLE OF CONTENTS

                                                                                                                                     Page



I.     SEH’S UPDATED INTERFERENCE ANALYSIS IS CRITICALLY FLAWED
       AND FAILS TO ADDRESS THE SUBSTANTIAL INTERFERENCE CONCERNS
       RAISED IN THE RECORD ............................................................................................ 1

II.    THE COMMISSION MUST CAREFULLY EVALUATE THE IMPACT OF
       SEH’S PROPOSED OPERATIONS AT 550 KM PRIOR TO ANY GRANT OF
       THE MODIFICATION APPLICATION ....................................................................... 7

III.   SEH’S SCANT SUPPORT FOR ITS REQUEST FOR A WAIVER OF THE EPFD
       VALIDATION REQUIREMENT REMAINS UNCONVINCING AND FAILS TO
       SATISFY THE COMMISSION’S STANDARD FOR GRANTING A RULE
       WAIVER............................................................................................................................ 9

       A.         SEH Has Failed to Adequately Provide its EPFD Validation Files for
                  Verification ............................................................................................................ 9

       B.         Launch of SEH’s System Without an ITU “Favorable” or “Qualified
                  Favorable” Finding Would Undermine the ITU Review Process .................. 10

IV.    CONCLUSION ............................................................................................................... 12


                       REPLY OF WORLDVU SATELLITES LIMITED

         WorldVu Satellites Limited (“OneWeb”) submits this reply to the Further Opposition

filed by Space Exploration Holdings, LLC (“SEH”) and other comments and petitions submitted

regarding SEH’s application to modify the license for its non-geostationary, fixed-satellite

service (“NGSO FSS”) system to move 1,584 satellites from an authorized altitude to 550 km

and increase actual interference to current and future NGSO FSS systems by, among other

things, utilizing the Ku-band for both gateway and user links. 4

I.       SEH’S UPDATED INTERFERENCE ANALYSIS IS CRITICALLY FLAWED
         AND FAILS TO ADDRESS THE SUBSTANTIAL INTERFERENCE CONCERNS
         RAISED IN THE RECORD

         In its Petition to Deny or Defer, OneWeb identified serious analytical flaws inherent to

SEH’s technical analysis, which incorrectly claimed the Modification Application would not

increase interference to other NGSO FSS systems. 5 In the Further Opposition, SEH doubles

down on the ill-conceived notion that its original technical analysis—claiming to demonstrate the

impact of the Modification Application against a paper constellation 6 not authorized in the

current processing rounds—is somehow sufficient to show a lack of increased interference to

other co-frequency NGSO FSS systems authorized or under review pursuant to the current

NGSO FSS processing round. 7 Nevertheless, SEH grudgingly supplies new analyses of the




4
    See Further Opposition.
5
 See OneWeb, Petition to Deny or Defer of WorldVu Satellites Limited, IBFS File No. SAT-
MOD-20181108-00083, at 2-8 (filed Feb. 8, 2019) (“OneWeb Petition”).
6
    IK-NGSO-A10K-1.
7
    See Further Opposition at 4.



                                                  1


interference impact to the SES/O3b and OneWeb systems (the “New Interference Analysis”) in

the Further Opposition. 8

          However, the New Interference Analysis SEH reluctantly pulled together opens up many

new issues, including misleading operational assumptions, an incomplete analysis parameter set,

and highly misleading conclusions with respect to the interference caused to other NGSO FSS

systems. 9 Nothing contained in the New Interference Analysis alters OneWeb’s prior conclusion

that a grant of the Modification Application will result in increased interference to OneWeb and

other NGSO FSS systems.

          In its New Interference Analysis, SEH carefully crafts a dubious artificial scenario which

is unlikely to occur and unjustifiably biases results in its favor. OneWeb is not the only Ku-band

operator to have noticed these severe analytical flaws; Kepler properly concludes SEH’s claim

that the modification “will cause no additional interference at all” is “not supported by adequate

evidence.” 10

          This New Interference Analysis is critically flawed for at least two reasons.




8
    Id. at A-1 – A-5.
9
  SEH’s continued reliance on Teledesic for the proposition that a reduction in satellites and
power is on its face evidence of reduced interference is likewise misleading. The Teledesic
modification was granted in an environment in which nascent NGSO systems were less
advanced and ultimately failed to successfully launch. Today’s NGSO interference environment
is much more technically complex and includes two operators (O3b and OneWeb) who have
launched and placed into orbit components of their authorized systems. The factors recognized
in Teledesic cannot be solely relied on in determination of whether a modification will present
“significant interference” to the current NGSO environment. See Teledesic LLC, 14 FCC Rcd.
2261 (IB 1999).
10
  Kepler Communications, Inc., Reply Comments of Kepler Communications, Inc. to
Consolidated Opposition of Space Exploration Holdings, LLC, IBFS File No. SAT-MOD-
20181108-00083, at 4 (filed Feb. 24, 2019) (“Kepler Reply Comments”).

                                                   2


       First, in the New Interference Analysis SEH attempts to portray an interference

environment in which the absolute I/N values are maximized, claiming this to be a worst-case

scenario. SEH appears to misunderstand that the purpose of the required analysis is to identify

the worst-case difference in I/N statistics between SEH’s previously licensed operational

envelope and its proposed modified operations. This means the absolute values are irrelevant to

the conclusion SEH is straining to demonstrate. In fact, the absolute worst-case method of

simulation serves to bias results in favor of SEH.

       To illustrate this point, consider a victim earth station (shown as an antenna receive

pattern) that can receive interference from four SEH satellites (A, B, C, D) coming from various

directions.




              Figure 1: Four simultaneous interfering signals arriving at victim earth station from various angles




                                                               3


          The “worst-case” analysis of SEH’s licensed operations always chooses the single worst-

case link, coming from satellite A, which then results in the highest I/N value at each timestep.

Next, consider that in SEH’s analysis of its proposed modified operations, the simulation will

choose the same worst-case link (A) at this same timestep. However, the simulation will also

include three additional links (B, C, D) that, by definition, will have lower I/N values than that of

the single worst-case link. The averaging effect (i.e. aggregating each link, but with 6 dB of

reduction) of incorporating all four links into each timestep’s I/N calculation will always yield a

final value that is lower than that of the single worst-case link in the licensed operation. The

simulation results thus give the false appearance of less interference in the proposed modified

operations than in the licensed operations.




                               Figure 2: Simulation I/N calculation at each timestep

          SEH’s analysis does not accurately reflect their own operations – as they say: “in a real

deployment, it is highly unlikely that the SpaceX earth station will transmit to all worst-case

satellites with the smallest off-axis sepration [sic] angle from a victim satellite at each time

step.” 11 If the as-licensed SEH constellation were to actually choose the worst-case link (A) at

each timestep, then perhaps the provided analysis would more accurately reflect actual

operations. However, the I/N curves show that this method of operation would be impossible

because of nearly constant unacceptable interference.




11
     Further Opposition at A-5.



                                                        4


          Instead, the Commission should consider the more likely and spectrally efficient

scenario where SEH would prefer to choose the link with the lowest I/N in each timestep,

depicted as satellite D. In this more realistic scenario, the averaging effect of then including

additional I/N values from A, B, and C, as proposed by SEH, will increase the actual

interference to the OneWeb system.




                                 Figure 3: Simulation I/N calculation at each timestep

          The Commission should recognize that SEH’s New Interference Analysis therefore

considers only the best-case difference in I/N through a painstakingly tailored scenario which

will not happen in the real world. A more complete analysis would instead capture the worst-

case difference in I/N. Thus, SEH’s New Interference Analysis fails to substantiate SEH’s claim

that the “proposed modification will not result in increased interference” to the OneWeb

system. 12

          Second, the New Interference Analysis barely scratches the surface of the analyses that

SEH should have performed. In alignment with the requests in the Commission Letter, the

Commission should request SEH provide a complete interference analysis, consistent with

current ITU guidance. 13 For example, such an analysis would include:


12
     Further Opposition at 10.
13
  ITU, Non-GSO subject to coordination and potential steps for their modifications (Dec. 8,
2018), https://www.itu.int/en/ITU-R/space/WRS18space/WRS18-
Non_GSO_subject_to_CR_and_potential_steps_for_their_mods-06122018.pdf (“[I]t should be
explained why [the analysis] leads to worst-case situations so that the analysis based on this
assumption guarantees that the I/N levels are not increased by the proposed changes”).

                                                          5


      •    true worst-case differences in I/N, which would represent a better understanding of the
           true impact of SEH’s proposed modifications on the NGSO interference environment. At
           a minimum, SEH should provide the additional analysis of I/N into OneWeb’s smallest
           user terminals. SEH has only considered I/N into a victim antenna with a gain of 53.6 dB
           in the Ku-band, which is a five-meter antenna and does not represent the consumer size
           terminal with which OneWeb will provide service;

      •    “all or several types of earth stations characterized by their antenna pattern used,
           maximum gain and noise temperature – one with maximum gain/lowest beam width and
           another with a minimum gain/highest beam width for a range of different antenna
           patterns used” 14;

      •    analyses for additional latitudes, or if providing only one, explain why the chosen latitude
           represents the worst-case difference in I/N value (and not absolute I/N value) which will
           not be exceeded; and

      •    I/N curves considering different satellite selection strategies, or if providing only one,
           explain why the chosen method represents the worst-case difference in I/N value (instead
           of a fabricated case which biases results in SEH’s favor, as is currently provided). In the
           latter case, the selection strategy should then become a condition of any future grant, as
           any departure from this operation will not have been tested for its interference impact on
           other NGSO FSS systems.

           OneWeb also has concerns stemming from statements by SEH regarding the maximum

EIRP of earth stations, number of gateway sites, and number of satellites operating with Ku-band

gateways. 15 For example, SEH has not stated that the maximum EIRP level of its gateways will

be identical to that of its user terminals. This should be an explicit condition of any future grant

of the Modification Application. If SEH’s gateway earth stations are permitted to have higher

EIRP as a result of the proposed modification, interference into other NGSO FSS systems will

increase, rendering the foregoing I/N analyses moot.

           OneWeb is not alone in its views on the New Interference Analysis presented by SEH. In

the words of Kepler, the New Interference Analysis is “fundamentally misleading” and “do[es]



14
     Id.
15
     See generally Further Opposition.


                                                    6


not adequately address the interference concerns of the parties.” 16 Thus, SEH’s new technical

analysis does no more to support its modification request than its “patently inadequate” technical

showing in the Modification Application. 17 As SEH has utterly failed to demonstrate that its

proposed modifications will not increase interference to other NGSO FSS systems, the

Modification Application should be denied, or, at a minimum, considered only in a subsequent

processing round.

II.       THE COMMISSION MUST CAREFULLY EVALUATE THE IMPACT OF
          SEH’S PROPOSED OPERATIONS AT 550 KM PRIOR TO ANY GRANT OF
          THE MODIFICATION APPLICATION

          In the OneWeb Petition, numerous orbital debris issues were noted related to SEH’s

proposed relocation of 1,584 satellites from the 1,150 km altitude to the 550 km altitude. 18 SEH

cavalierly dismissed OneWeb’s concerns, variously characterizing them as “curious,” the result

of “misconceptions,” and “clutch[ing] at…threads.” 19 Notably, the Commission appears to share

OneWeb’s concerns, as evidenced by the recent request for information sent to SEH regarding

the Modification Application. 20 The Commission’s request touches on many of the issues

highlighted in the OneWeb Petition.

          In particular, the OneWeb Petition pointed out the apparent orbital stasis of SEH’s

experimental satellites. 21 SEH responded that leaving these satellites at the 550 km orbit was a


16
     Kepler Reply Comments at 7.
17
  SES Americom, Inc. and O3b Limited, Comments of SES Americom and O3b Limited, IBFS
File No. SAT-MOD-20181108-00083, at 2 (filed Feb. 8, 2019).
18
     See OneWeb Petition at 12-22.
19
     Further Opposition at 11-12, 14.
20
     See Commission Letter.
21
     See OneWeb Petition at 14.

                                                  7


“conscious decision” that ultimately “validated” SEH’s technology. 22 However, OneWeb agrees

with the Commission that SEH must update the Modification Application with a collision risk

assessment “assuming a propulsion or other system failure that renders the satellite incapable of

collision avoidance immediately following orbital injection.” 23 This is precisely the kind of

information that OneWeb and other operators (in particular, the small satellite community) need

to review and assess in order to provide comments prior to any further Commission action on the

Modification Application. 24

          Similarly, SEH brushed aside OneWeb’s concern about SEH’s troubling casualty risk

profile. 25 Yet the Commission has further inquired about SEH’s controlled re-entry capabilities

and casualty risk, as well as their potential effects on human populations. 26 OneWeb commends

the Commission for seeking this information and respectfully reserves the right to provide

further comments subsequent to any responsive submission by SEH.

          OneWeb agrees with other petitioners in this proceeding that critical questions regarding

the impact of the Modification Application on the orbital environment remain unanswered. Any



22
  Further Opposition at 12-13. OneWeb notes that if this was a conscious decision, it is curious
that SEH did not notify the Commission of such a drastic change in its mission parameters.
23
     Commission Letter at 1.
24
  The CSSMA Joint Reply details how CSSMA requests an SEH “collision risk analysis” that
“demonstrates that SpaceX’s commitment to assume the burden of conducting collision
avoidance maneuvers is operationally practical and credible.” Commercial Smallsat Spectrum
Management Association, Joint Reply, IBFS File No. SAT-MOD-20181108-00083, at 2 (filed
Feb. 22, 2019).
25
     See Further Opposition at 14.
26
  See Commission Letter at 1 (asking SEH to describe whether “the proposed satellites are
capable of a controlled re-entry, i.e., re-entry specifically and reliably targeted at broad ocean
areas, away from human populations”).



                                                  8


consideration of the Modification Application by the Commission before these issues are

resolved would be premature.

III.       SEH’S SCANT SUPPORT FOR ITS REQUEST FOR A WAIVER OF THE EPFD
           VALIDATION REQUIREMENT REMAINS UNCONVINCING AND FAILS TO
           SATISFY THE COMMISSION’S STANDARD FOR GRANTING A RULE
           WAIVER

           In the Further Opposition, SEH fails to provide a compelling justification for why its

request for a waiver of the ITU EPFD validation requirement should be granted. SEH does not

adequately address the importance of the ITU performing its compliance verification and the

troubling precedent that granting the SEH waiver request would set. OneWeb successfully

obtained a favorable finding for its EPFD compliance prior to commencing launch of its NGSO

FSS constellation; there is no reason SEH should be entitled to bypass this process. As such,

SEH’s waiver request should be denied.

A.         SEH Has Failed to Adequately Provide its EPFD Validation Files for Verification

           In the Further Opposition, SEH claims that it provided the input data files used for an

EPFD analysis of its modified constellation. 27 SEH also suggests OneWeb may have “simply

overlooked” the inclusion of these files. 28 It appears the EPFD input files SEH references are

currently not available in IBFS. 29 Setting aside the unavailability of the EPFD input files, SEH

once again provides no justification for its waiver request aside from the desire for an “expedited




27
     See Further Opposition at 17.
28
     Id.
29
  The Commission should include a request for these EPFD input files into any subsequent
request for information from SEH.



                                                    9


deployment schedule.” 30 SEH plainly fails to satisfy the Commission’s well-established waiver

standard, and its request for waiver of the EPFD compliance requirement should be denied.

B.        Launch of SEH’s System Without an ITU “Favorable” or “Qualified Favorable”
          Finding Would Undermine the ITU Review Process

          The Further Opposition relies on a series of sleights-of-hand and equivocations to

obfuscate the importance of the EPFD validation requirements that SEH is attempting to bypass.

The OneWeb Petition details how Section 25.146(c)’s requirement that NGSO FSS licensees

receive a “favorable” or “qualified favorable” finding by the ITU Radiocommunication Bureau

regarding compliance with EPFD limits is the only substantive emission assessment that NGSO

FSS systems must undergo before launch and operation. 31

          Contrary to SEH’s assertion, OneWeb does not question the Commission’s competency

to substantively review EPFD compliance; OneWeb merely points out that such review is no

longer a part of the Commission’s rules. Because the Commission eliminated this review,

granting SEH a waiver of the ITU validation requirement would set a troubling precedent for the

FSS environment going forward.

          Waiver of this condition would harmfully relegate EPFD compliance to a post hoc

obstacle that NGSO FSS operators must address, potentially after they have begun launching and

operating their constellations. This potential abdication of any role for either the Commission or

the ITU is simply not in the public interest and, as OneWeb explained in the OneWeb Petition,




30
     Further Opposition at 17.
31
     See 47 C.F.R. § 25.146(c); OneWeb Petition at 23.


                                                  10


could jeopardize both NGSO and GSO operations. 32 As SEH itself has stated, “waivers cannot

come at the expense of other licensed NGSO systems.” 33

          SEH attempts to minimize the troubling precedent a grant of its waiver request would set

by highlighting various half-measures and self-determinations. For instance, SEH notes that it

“recognizes that it must comply with the ITU’s EPFD limits” and “has certified that its

constellation (as modified) will do so,” 34 yet fails to address the very real need for the ITU to

conduct the analysis necessary to complete certification by the ITU, not by SEH. If SEH’s

waiver request is granted, it would effectively be held to a standard of compliance centered on

self-certification—a standard that should then apply to all NGSO FSS systems. Likewise, SEH

stresses the similarity of the EPFD compliance proposed in its Modification Application to that

of its licensed constellation. 35 However, the ITU’s EPFD compliance verification of SEH’s

licensed constellation is irrelevant to OneWeb’s concerns regarding SEH’s attempt to bypass

ITU certification of the EPFD compliance for SEH’s modified constellation.

          The Commission may waive application of its rules for “good cause shown” or if waiver

would “better serve the public interest.” 36 As the GSO Satellite Operators have noted, SEH’s

“expedient deployment should not be valued over the assurance of a safe operational



32
     See OneWeb Petition at 24.
33
   Space Exploration Holdings, LLC, Reply of Space Exploration Holdings, LLC, IBFS File Nos.
SAT-LOA-20170301-00028, SAT-AMD-20170929-00137, SAT-AMD-20180131-00013, at 4
(filed Mar. 4, 2019).
34
     Further Opposition at 18.
35
     Id. at 17.
36
  47 C.F.R. § 1.3; GE American Communications, Inc., 16 FCC Rcd 11038, 11041 ¶ 9 (IB
2001).



                                                 11


environment for all satellite operators.” 37 SEH has failed to provide the justification necessary

for the Commission to grant its waiver request because it has not shown that bypassing ITU

validation requirements would serve the public interest better than enforcement of the

Commission’s recently relaxed rule regarding EPFD compliance. 38

          Without seeking a waiver from the Commission, OneWeb sought and received a

favorable rating for ITU compliance well in advance of the momentous launch of OneWeb’s first

production satellites last week. Meanwhile, SEH’s paper-thin justification for its waiver request

continues to fall far short of the Commission’s waiver standard. Thus, SEH’s waiver request is

not in the public interest and should be denied.

IV.       CONCLUSION

          As demonstrated above, the Further Opposition fails to resolve OneWeb’s fundamental

concerns about SEH’s proposed modifications causing increased RF interference to other NGSO

FSS systems and the potentially serious consequences with respect to the generation of space

debris. These concerns are particularly justified given the significant impact SEH’s proposed

satellite system could have on the satellite systems currently in orbit, including OneWeb, and the

systems of other operators opposed to the Modification Application. Presently, these concerns

remain unaddressed and unresolved, and a Commission request to SEH for additional

information regarding the Modification Application remains outstanding. Therefore, OneWeb

restates its request that the Commission deny the Modification Application or defer any

consideration until a subsequent processing round is initiated.



37
  GSO Satellite Operators, Reply of EchoStar Satellite Operating Corporation, Hughes Network
Systems, LLC, and Intelsat License LLC, IBFS File No. SAT-MOD-20181108-00083, at 4 (filed
Mar. 5, 2019).
38
     See 47 C.F.R. § 25.146.

                                                   12


Respectfully submitted,

 WorldVu Satellites Limited

 /s/ Mariah Dodson Shuman                  Brian Weimer
 Mariah Dodson Shuman                      Douglas Svor
 Head of Regulatory Affairs, Americas      Samuel Swoyer
 WorldVu Satellites Limited                Sheppard Mullin Richter & Hampton LLP
 1785 Greensboro Station Place, Tower 3    2099 Pennsylvania Ave. NW, Suite 100
 McLean, VA 22102                          Washington, D.C. 20006
                                           (202) 747-1930
                                           bweimer@sheppardmullin.com

                                           Counsel to WorldVu Satellites Limited
 March 5, 2019




                                          13


  CERTIFICATION OF PERSON RESPONSIBLE FOR PREPARING ENGINEERING
                           INFORMATION

       I hereby certify that I am the technically qualified person responsible for preparation of

the engineering information contained in this Reply of WorldVu Satellites Limited, that I am

familiar with Part 25 of the Commission’s rules, that I have either prepared

or reviewed the engineering information submitted in this pleading, and that it is complete and

accurate to the best of my knowledge and belief.


Date: March 5, 2019

                                             By /s/ Michael Lindsay___________
                                             Principal, Advanced Mission Design
                                             WorldVu Satellites Limited
                                             West Works Building
                                             195 Wood Lane
                                             London, W12 7FQ United Kingdom


                                CERTIFICATE OF SERVICE

I, Samuel Swoyer, hereby certify that on this 5th day of March 2019, a copy of this Reply of

WorldVu Satellites Limited is being sent via first class, U.S. Mail, postage paid, to the following:


Patricia Cooper                                              Petra A. Vorwig
Vice President, Satellite Government Affairs                 Senior Legal and Regulatory
David Goldman                                                Counsel
Director, Satellite Policy                                   SES Americom, Inc.
SPACE EXPLORATION TECHNOLOGIES CORP.                         1129 20th Street, NW
1155 F Street, N.W.                                          Suite 1000
Suite 475                                                    Washington, DC 20036
Washington, DC 20004

William M. Wiltshire                                         Karis A. Hastings
Paul Caritj                                                  SatComLaw LLC
HARRIS, WILTSHIRE & GRANNIS LLP                              1317 F Street, NW
1919 M Street, N.W.                                          Suite 400
Suite 800                                                    Washington, DC 20004
Washington, DC 20036                                         Counsel for SES Americom, Inc. and
Counsel to Space Exploration Holdings, LLC                   O3b Limited

Nick G. Spina                                                Suzanne Malloy
Director, Launch & Regulatory Affairs                        Vice President, Regulatory Affairs
Kepler Communications Inc.                                   Noah Cherry
675 King Street West                                         Legal and Regulatory Counsel
Suite 204                                                    O3b Limited
Toronto, Ontario M5V 1M9                                     1129 20th Street, NW
Canada                                                       Suite 1000
                                                             Washington, DC 20036

Craig Scheffler                                              Jan King
President, Commercial Smallsat                               Chief Technology Officer
Spectrum Management Association                              Astro Digital U.S., Inc.
555 Thirteenth Street, NW                                    3171 Jay Street
Washington, DC 20004                                         Santa Clara, CA 95054

Rich Leshner                                                 George John
Vice President, Government and Regulatory Affairs            Lead Legal and Regulatory Counsel
Planet Labs Inc.                                             Spire Global, Inc.
645 Harrison Street, Floor 4                                 575 Florida Street, Suite 150
San Francisco, CA 94107                                      San Francisco, CA 94110


Tony Lin
Daniel Landesberg
Hogan Lovells US LLP
555 Thirteenth Street, NW
Washington, DC 20004

/s/ Samuel Swoyer______________________
Samuel Swoyer



Document Created: 2019-03-05 20:48:43
Document Modified: 2019-03-05 20:48:43

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