Attachment BlackSky Global - Gr

BlackSky Global - Gr

DECISION submitted by IB, FCC

Grant

2019-05-16

This document pretains to SAT-MOD-20190314-00015 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2019031400015_1684723

                                                             —   -       ~   .,;I   P~C#i~S~flT.~    ~
S3032       SAT-MOD2Oj9O314~OOlS        1B20 19000755
BlackSky Global, LLC
Global 1, 2, 3, & 4

                                                                                           identifier~           ~“

                                                                                                         TermDates     ~       ~   Approved by 0MB
                                                                                                              To.                         3060—0678
                                                            GRANTED                                       /./~//
   Date & Time Filed: Mar 14 2019 4:23:50:500AM           lnlcrmtinnal l3urcau      Approved:
   File Number: SAT MOD 20190314 00015                  •~Lh~ ~c~yFflcn~                                  F-          z3:D.&~tu
                                                                                                                             ~

        FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD                        -   MAIN FORM             FCC Use Only

                            FCC 312 MAIN FORM FOR OFFICIAL USE ONLY

   APPLICANT INFORMATION
   Enter a description of this application to identify it on the main menu:
   Modification of space station
   1—8. Legal Name of Applicant

               Name:        BlackSky Global. LLC              Phone Number:                              206—399—2325
               DBA                                            Fax Number:
               Na me:
               Street:       1505 Westlake Ave. North. Ste 600 E—Mail:                                   khloptsidis~Spacet1ightlndustries.
                                                                                                         coni


               City:         Seattle                           State:                                    WA
               Country:      USA                              Zipcode:                                   98109
               Attention:    Ms Kristina Hloptsidis


                                         ATTACHMENT TO GRANT
                                              BlackSky Global LLC
                                    IBFS File No. SAT-MOD-20190314-00015

  IBFS File No(s):       SAT-MOD-20190314-00015’                                                  GRANT         —


 Licensee/Grantee:       BiackSky Global LLC (BiackSky)                                          With Conditions
 Call Sign:              S3032
 Satellite Name:         Global-i, Giobal-2, Giobal-3, & Giobal-4
 Orbital Location:       Non-Geostationary Orbit (NGSO) (see scope of grant
 (required station-      below)
 keeping tolerance)
 Administration:         United States of America
 Nature of Service:      Earth Exploration Satellite Service (EESS)
                                                                                             International Bureau
                                                                                               Satellite_Division
 Scope of Grant:         Modification of authority to construct, deploy and operate a non-geostationary orbit Earth
                         Exploration Satellite Service constellation to include:
                         (i) a change in the propulsion system to be employed for Global-4 from a butane-based to
                         water-based system; and
                         (ii) authority to construct, deploy, and operate a constellation of up to 4 NGSO space
                         stations, initially deployed to orbital apogee altitudes ranging from 435 km to 585 km and
                         with inclinations ranging from 42 degrees to polar sun-synchronous (nominal 98 degrees).
 Previous Grant(s)       Authority to construct, deploy, and operate a constellation of up to 4 technically identical
                         NGSO space stations, initially deployed to orbital apogee altitudes ranging from 460 km to
                         585 km and with inclinations ranging from 42 degrees to polar sun-synchronous (nominal
                         98 degrees).2

                         Pursuant to this previous authorization, Global-i operates at a mean altitude of 487 km
                         with an inclination of 97.49 degrees, and Global-2 operates at a mean altitude of 581 km
                         with an inclination of 97.76 degrees.3

 Service Area(s):        Global. See Schedule S Tech Report and associated antenna gain contours.

 Frequencies:            8025-8400 (space-to-Earth) (remote sensing data)
        ~                1575.42 MHz (GPS) (receive-only)

                         Telemetry, Tracking, and Command (TI&C) frequencies:
                         2025-2110 MHz (Earth-to-space) (primary TT&C uplink)
                         401.5 MHz or 401.375 MHz (space-to-Earth) (secondary TT&C downlink)
                         449.75-450.25 MHz (Earth-to-space) (secondary TT&C uplink) (center carrier frequency
                         at 450.2 MHz)




‘The application was placed on Public Notice as accepted for filing on March 22, 2019. See Policy Branch Information,
Applications Acceptedfor Filing, Public Notice, Report No. SAT-0l379 (IBFS File No. SAT-MOD-201903l4-00015).
2 See Policy Branch Information, Satellite Space Applications Actions Taken, Public Notice, DA 18-1098, Report No.SAT

01356 (IBFS File No. SAT-LOA-20180320-00023).
~ Letter from Kristina Hloptsidis, Director of Regulatory and Compliance, to Marlene H. Dortch, Secretary, FCC, IBFS File
No. SAT-LOA-20180320-00023 (filed Dec. 28, 2018) (December28 Letter).
                                                      Page 1 of 3


                                        ATTACHMENT TO GRANT
                                            BlackSky Global LLC
                                  IBFS File No. SAT-MOD-20 1903 14-000 15

Operations under this grant must comport with the legal and technical specifications set forth by the
applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This
grant is also subject to the following conditions:
1.       BlackSky must prepare the necessary information, as may be required, for submission to the International
Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due diligence,
and notification process for these space stations, in accordance with the ITU Radio Regulations. BlackSky shall
be held responsible for all cost-recovery fees associated with ITU filings. No protection from interference caused
by radio stations authorized by other administrations is guaranteed unless coordination and notification
procedures are timely completed or, with respect to individual administrations, by successfully completing
coordination agreements. Any radio station authorization for which coordination has not been completed may be
subject to additional terms and conditions as required to effect coordination with the frequency assignments of
other administrations. See 47 CFR § 25.111(b).
2.       BlackSky must coordinate physical operations of spacecraft with any operator using similar orbits, for the
purpose of eliminating collision risk and minimizing operational impacts. The orbital parameters specified in this
grant are subject to change based on such coordination.
3.      Upon receipt of a conjunction warning from the JSpOC or other source, BlackSky must review the
warning and take all possible steps to assess and, if necessary, to mitigate collision risk, including, but not limited
to: contacting the operator of any active spacecraft involved in si.~ch warning; sharing ephemeris data and other
appropriate operational information with any such operator; modifying spacecraft attitude and/or operations.
4.      BlackSky shall tune T]E&C UHF links to 401.5 MHz or 401.375 MHz as this represents the agreed
transmit frequencies with NOAA to minimize interference to NOAA GOES Data Collection System (DCS), and
radiosonde operations and continue to work closely with NOAA to identify and implement any further measures
needed to avoid RFI to the systems mentioned earlier. For future mission planning, transition out of 40 1-406
MHz to avoid interference to DCS and radiosondes is recommended by October 2021. BlackSky and NOAA
shall work jointly to explore future mitigation strategies to avoid interference to NOAA missions.
5.      Operations in the 449.75-450.25 MHz (Earth-to-space) frequency band are limited to telecommand and
must be consistent with footnote US87 to the U.S. Table of Frequency Allocations, 47 CFR § 2.106. BlackSky
must take all practical steps to keep the telecommand carrier frequency close to 450 MHz.
6.      Operations pursuant to this authorization must not cause harmful interference to stations operating in the
2025-2110 MHz band in accordance with the U.S. Table of Frequency Allocations. See 47 CFR § 2.106,
Footnote US347.
7.       Transmissions of remote-sensing data in the 8025-8400 MHz frequency band may only be made to earth
stations coordinated with the National Aeronautics and Space Administration (NASA). BlackSky shall provide
the FCC the list of coordinated earth stations.
8.      Power flux-density from operation in the 8025-8400 MHz band must not exceed the limits in No. 22.5
and Table 21-4 of the International Telecommunication Unions Radio Regulations, the limits/protection criteria
in Recommendation ITU-R SA.1157-1 must be met, and the guidelines in Recommendation ITU-R SA.1810
must be followed.
9.      Given the opportunity for additional entrants to operate in the 8025-8400 MHz band, we grant
BlackSky’ s request for waiver of the modified processing round requirements of 47 CFR § § 25.156 and 25.157.
See DigitalGiobe, Inc., Order and Authorization, 20 FCC Red 15696 (Sat. Div., Int’l Bur. 2005), at paragraph 8.
10.     Because BlackSky must comply with technical requirements in Part 2 of the Commission’s rules and the
above-referenced power flux-density limits, which should prevent harmful interference to other operations in the
band, we grant its request for a waiver of the default service rules in 47 CFR § 25.2 17(b). See DigitalGiobe, Inc.,
supra at paragraph 15.


                                                    Page 2 of 3


                                           ATTACHMENT TO GRANT
                                                BlackSky Global LLC
                                      IBFS File No. SAT-MOD-20 190314-00015

 11.     BlackSky’s request for a waiver of Section 25.114(c) of the Commission’s rules, 47 CFR § 25.114(c), to
 the extent described in its application with respect to certain information to be provided in the Schedule S for
 Global-3, IS GRANTED. We find that a waiver is warranted for the requirement for orbital information on the
 Schedule S for Global-3 because the unique circumstances BlackSky detailed in its Narrative are sufficient good
 cause for waiver.
  12.    BlackSky must launch the remaining space stations necessary to complete its authorized service
 constellation, place them in their assigned orbits, and operate them in accordance with the authorization no later
 than October 3, 2027.~
 13.   Prior to commencing operations with the space stations authorized herein, BlackSky must file with the
 Commission the information required by Section 25.172 of the Commission’s rules, 47 CFR § 25.172.
 14.   Within 30 days after launching each satellite authorized herein, BlackSky must file a notification with the
 Commission specifying the satellite’s orbital altitude and inclination.
 15.      The license term expires on December 28, 2033.
 16.     BlackSky must launch the space stations no later than October 31, 2020. No authority is granted to
 deploy space stations after October 31, 2020.
 Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
 conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.

 This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 CFR § 0.261,
 and is effective upon release.

 Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
 amended, 47 U.S.C. § 309(h).

 Action           May 16, 2019
 Date:
 Term Dates       From: see conditions                  To: see conditions

 Approved:

                                  I   /
                  Ste .7’
                        J. Duall
                  Chie Satellite Policy Branch
                        ,




“BlackSky’s authorization was originally subject to milestone and bond conditions, but BlackSky subsequently informed that
that Global-l, Global-2 were launched, deployed, and in operation pursuant to the initial license and thus satisfied the
milestone and bond conditions, with the exception of the requirement to deploy and operate the remaining two satellites in its
proposed constellation by October 3, 2027. See December28 Letter.
                                                        Page 3 of 3


9—16. Name of Contact Representative

           Name:        Jonathan L. Wiener           Phone Number:   202—429—4900
           Company:     Goldberg, Godles, Wiener &   Fax Number:
                        Wright LLP
           Street:      1025 Connecticut Aye, NW     E—Mail:         jwiener~g2w2.com
                        Ste 1000
           City:        Washington                   State:          DC
           Country:     USA                          Zipcode:        20036—
           Attention:                                Relationship:   Legal Counsel


CLASSIFICATION OF FILING


17. Choose the button next to the
classification that applies to this filing for   (N/A) bi. Application for License of New Station
both questions a. and b. Choose only one         (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for I 7b.                    0  b3. Amendment to a Pending Application
                                                      b4. Modification of License or Registration
   0      al.Earth Station                       b5. Assignment of License or Registration
          a2. Space Station                      b6. Transfer of Control of License or Registration

                                                  0   b7. Notification of Minor Modification
                                                  (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                 Satellite
                                                  (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                 States
                                                  (N/A) b 10. Other (Please specify)
                                                    (N/A) bI I. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized
                                                 to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                    (N/A) b12. Application for Database Entry
                                                  o b13. Amendment to a Pending Database Entry Application
                                                  o bl4. Modification of Database Entry
   17c. Is a fee submitted with this application?
• If Yes, complete and attach FCC Form 159.            If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
0       Governmental Entity       ~ Noncommercial educational I icensee
o Other(please explain):
I 7d.

Fee Classification CGW        —   Space Station Modification(Non—
Geostationary)


 18. If this filing is in reference to an    19. If this tiling is an amendment to a pending application enter both fields. if this filing is a
 existing station, enter:                    modification please enter only the file number:
 (a) Call sign of station:                   (a) Date pending application was tiled:              (b) File number:
     S3032
                                                                                                  SATLOA2O 18032000023



TYPE OF SERVICE
20. NATURE OF SERVICE: This tiling is for an authorization to provide or use the following type(s) of service(s): Select all that apply:


Q a. Fixed Satellite
Q h. Mobile Satellite
    c. Radiodetermination Satellite
    d. Earth Exploration Satellite

Q e. Direct to Home Fixed Satellite
Q f. Digital Audio Radio Service
Q g. Other (please specify)
21. STATUS: Choose the button next to the applicable status. Choose        22. If earth station applicant, check all that apply.
only one.                                                                  Q    Using U.S. licensed satellites
0   Common Carrier             Non—Common Carrier                          Q Using Non—U.S. licensed satellites
23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
0   Connected to a Public Switched Network           Not connected to a Public Switched Network              N/A


  24. FREQUENCY BAND(S): Place an ‘X. in the box(es) next to all applicable frequency band(s).
Q a. C—Band (4/6 GHz) Q b. Ku—Band (12/14 GHz)
     c.Other (Please specify upper and lower frequencies in MHz.)
        Frequency Lower: 401              Frequency Upper: 8400         (Please specify additional frequencies in an attachment)

TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.

 0   a. Fixed Earth Station
 o b. Temporary—Fixed Earth Station
 o c. 12/14GHz VSAT Network
 o d. Mobile Earth Station
     e. Geostationary Space Station

 • f. Non—Geostationary Space Station
 o g. Other (please specify)
26. TYPE OF EARTH STATION FACILITY:
o   Transmit/Receive ~ Transmit—Only            ~ Receive—Only      • N/A
“For Space Station applications, select N/A.”


PURPOSE OF MODIFICATION


27. The purpose of this proposed modit~cation is to: (Place an ‘X’ in the box(es) next to all that apply.)



    Qa       ——     authorization to add new emission designator and related service
         b   ——      authorization to change emission designator and related service

     Q c authorization to increase EIRP and EIRP density
             —---



     Q d authorization to replace antenna
             ——



     Q e authorization to add antenna
             ——



     Q f—— authorization to relocate fixed station
     Q g authorization to change frequencv(ies)
             ——



     Q h authorization to add frequency
              —



     Q i authorization to add Points of Comm unication (satellites &amp~ countries)
             ——



     EJ ~ authorization to change Points of Communication (satellites & countries)
             ——



     Q k authorization for facilities for which environmental assessment and
             ——

radiation hazard reporting is required
             ——     authorization to change orbit location

    Qm        ——     authorization to perform fleet management
    Qn       —      authorization to extend milestones
         o   —      Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental          o Yes         No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1 .1308 and 1.1 31 1 of
the Commission’s rules, 47 C.F.R. 1. 1308 and 1 .131 1, as an exhibit to this application.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
aeronautical fixed radio station services are not required to respond to Items 30—34.


29. Is the applicant a foreign government or the representative of any foreign government?                              o   Yes       No




 30. Is the applicant an alien or the representative of an alien?                                                       0   Yes       No   N/A




 31. Is the applicant a corporation organized under the laws of any foreign government?                                 0   Yes   0   No   N/A




 32. Is the applicant a corporation of which more than one—fifth of the capital stock is ow’ned of record or voted by   o   Yes   0   No   N/A
 aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
 under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          o   Yes         No    N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?



34. If any answer to questions 29,30,31.32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules?                                  0     Yes        No
If Yes. attach as an exhibit, copies of the requests for waivers or exceptions w’ith supporting documents.




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license              o Yes            No
revoked or had any application for an initial. modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.


37. Has the applicant, or any party to this application or amendment. or any party directly or indirectly controlling        o Yes   No
the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,            o Yes   No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication. directly or
indirectly, through control of manufacture or sale of radio apparatus. exclusive traffic arrangement or any other
means or unfair methods of competition?lf Yes, attach as an exhibit. an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending       o Yes   No
matter referred to in the preceding two items? If yes. attach as an exhinit, an explanation of the circumstances.




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names.
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of    Exhibit 2
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.


41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is                Yes          No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of &quot~party to the application&quot: for these purposes.



42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes,        o Yes            No
answer 42h and attach an exhibit providing the information specified in 47 C.F.R. 25.137. as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?



43. Description. (Summarize the nature of the application and the services to be provided).    (If the complete description does not appear in this
box. please go to the end of the form to view it in its entirety.)
    Applicant seeks to modify its small-sat non-geostationary orbit Earth                                         Exploration
    Satellite Service system. See Narrative in Exhibit 1 hereto.



Exhibit I


43a. Geographic Service Rule Certification
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25.


By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.
                                                                                                                              OC
By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so. or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.




CERTI F I CATI ON
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to he in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned. individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.


44. Applicant is a (an): (Choose the button next to applicable response.)


o Individual
0    Unincorporated Association
o Partnership
0    Corporation
0    Governmental Entity
• Other (please specify)




    45. Name of Person Signing                                              46. Title of Person Signing
    Nick Merski                                                             VP, Space Operations
      ——>




            WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                     (U.S. Code, Title I 8, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 31 2(a)( I)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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Document Created: 2019-05-16 16:58:26
Document Modified: 2019-05-16 16:58:26

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