Attachment Exhibit A

This document pretains to SAT-STA-20160803-00076 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2016080300076_1145388

Terra Bella Technologies Inc. Request for Special Temporary Authority EXHIBIT A - NARRATIVE STATEMENT Terra Bella Technologies Inc. (Terra Bella), pursuant to Section 25.120 of the Federal Communications Commission’s (FCC’s or Commission’s) Rules, 47 C.F.R. § 25.120, hereby requests Special Temporary Authority (STA) for short-term modification of the telemetry downlink frequencies on four commercial remote sensing satellites, SkySat-4 through SkySat-7, while they are brought into service after launch. The satellites are scheduled to be launched on September 15, 2016 (pending Commission approval in File No. SAT-MOD-20150408-00019). To accommodate possible launch delays, the STA is sought for a period of 30 days commencing on September 15, 2016. The requested temporary authority, however, would be utilized only until routine communications links with the satellites are established, which is likely to be a period of no more than two weeks after launch. Terra Bella outlines below its need for the requested STA and the reasons that this request should be granted expeditiously. Terra Bella currently operates three commercial remote sensing satellites, SkySat-1 through SkySat-3, under FCC Call Sign S2862, as part of a non-geostationary orbit (NGSO) Earth Exploration Satellite Service (EESS) high-resolution imagery satellite system.1 An application to modify the authorization to include 12 additional satellites, SkySat-4 through SkySat-15, on the system is pending.2 The requested STA would apply to SkySat-4 through SkySat-7, which are expected to be launched on September 15, 2016, subject to the Commission’s approval of the license modification. The primary earth station for the system is located in Fairbanks, Alaska (Call Sign E120025).3 On the launch date, SkySat-4 through SkySat-7 will be released by the launch vehicle in a cluster that is so closely spaced that ordinary telemetry transmissions from the different satellites—which will use the same frequencies—would be indistinguishable at earth stations for the first few days on-orbit. To facilitate the identification and monitoring of each individual satellite, Terra Bella therefore requests authority to temporarily modify the telemetry downlink frequency (Channel ID TTC1) for each of the new satellites to a frequency that is unique but close to the frequency authorized for operations under Call Sign S2862. Without the requested modification, all four satellites could be transmitting at the same time, on the same frequency, and thus interfering with each other. Specifically, Terra Bella requests authority to assign each of the four new satellites one of the following frequencies for telemetry transmissions immediately after launch: ● 8374.50 MHz ● 8374.75 MHz ● 8375.25 MHz ● 8375.50 MHz 1 File No. SAT-LOA-20120322-00058 (SkySat-1 and SkySat-2) and File No. SAT-MOD-20150408-00019 (SkySat-3). 2 File No. SAT-MOD-20150408-00019. The launch and operation of SkySat-3 was approved on June 6, 2016, when the Commission granted Terra Bella’s request in part and deferred it in part. Approval of SkySat-4 through SkySat-15 remains outstanding. 3 File No. SES-LIC-INTR2012-00457. 1

Terra Bella Technologies Inc. Request for Special Temporary Authority Each of the proposed frequencies is within the 8025-8400 MHz band allocated to EESS as well as within 500 kHz of the telemetry downlink frequency of 8375.00 MHz currently authorized for Call Sign S2862. Assuming nominal conditions, after approximately two weeks the satellite orbits will have diverged enough so that the earth stations are able to distinguish each individual satellite. At that time, the satellites will be commanded to transmit on the licensed frequency of 8375.00 MHz for permanent operations. Terra Bella incorporates by reference all of the technical showings it made in the license modification application (both on Form 312, Schedule S, and in Exhibit 43), and confirms that operation under this STA will not vary from such parameters with the exception of narrowband telemetry signals identified herein. The temporary frequencies would be no less compatible with other satellite missions than the licensed frequency, since they are narrowband and in close proximity to the currently authorized telemetry downlink frequency of 8375.00 MHz. There would also be no changes to other parameters currently authorized for operations under Call Sign S2862, including modulation, bandwidth, and power of the telemetry transmitters. Grant of this STA will serve the public interest by facilitating Terra Bella’s operation of four additional, high-resolution imagery satellites that are complementary to the existing satellites, SkySat-1, SkySat-2, and SkySat-3, thereby enhancing competition and expanding U.S. capabilities in the market for commercial remote sensing data. Terra Bella’s innovative approach—using small, lightweight, and low-cost satellites—allows the company to meet the growing demand for high resolution imagery in a cost-effective, timely manner, and deployment of the proposed satellites will further enhance Terra Bella’s EESS capabilities. In summary, and on the basis of the information provided herein and in File No. SAT-MOD-20150408-00019, Terra Bella requests special temporary authority to modify the telemetry downlink frequencies on four commercial remote sensing satellites, SkySat-4 through SkySat-7, for a period of 30 days commencing on the expected launch date of September 15, 2016. 2


Document Created: 2016-08-03 17:48:35
Document Modified: 2016-08-03 17:48:35
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