Ex Parte Notice_3Aug

Ex PARTE PRESENTATION NOTIFICATION LETTER submitted by ORBCOMM License Corp.

Ex Parte Letter

2016-08-05

This document pretains to SAT-STA-20150821-00060 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2015082100060_1145788

                                         August 5, 2016



VIA IBFS

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20556


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


Dear Ms. Dortch:

         On August 3, 2016, ORBCOMM, represented by the undersigned, participated in a
telephone call with Jose Albuquerque, Chief of the Satellite Division, to address the timing of
ORBCOMM’s planned response to the July 26, 2016 submissions relating to the above-
referenced applications filed by Planet Labs Inc. (“Planet Labs”) and Spire Global, Inc.
(“Spire”). ORBCOMM indicated that it would file its response by early next week.
ORBCOMM also observed that the August 15 integration date referred to in Spire’s new
submission as establishing an imminent deadline for Commission action does not appear to still
be operative due to the reported slippage of the launch date for the proposed Spaceflight, Inc.
SHERPA mission. In addition, ORBCOMM indicated that the above-referenced applications,
along with the possibility of other future applications for authority to deploy large numbers of
non-geostationary satellites using opportunistic launches and other cost-saving measures,
counsels the Commission to initiate a rulemaking proceeding to consider non-geostationary
satellite rule and policy updates that inter alia might better accommodate these types of systems,
which clearly do not fit well into the current rules. While the Commission can and should
address the above-referenced applications under the current rules, carefully-tailored
modifications to the rules could substantially improve the process for future applicants,
incumbents, and the Commission.


Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
August 5, 2016
Page 2 of 2


        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
submission to the undersigned.

                                             Respectfully submitted,



                                             Walter H. Sonnenfeldt, Esq.
                                             Regulatory Counsel
                                             ORBCOMM License Corp. &
                                             Vice President, Regulatory Affairs
                                             ORBCOMM Inc.
                                             Direct Tel: (585) 461-3018
                                             E-Mail: sonnenfeldt.walter@orbcomm.com


cc: Dr. Jose Albuquerque



Document Created: 2016-08-05 16:47:22
Document Modified: 2016-08-05 16:47:22

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