Attachment Terra Bella Technolo

Terra Bella Technolo

DECISION submitted by IB, FCC

Grant with conditions

2018-09-13

This document pretains to SAT-STA-20180724-00055 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2018072400055_1532775

                                                                                    File #_SAT— sim— 2018 0724— 60055
$2862         SAT—STA—20180724—00055      1B2018004159
Terra Bella Technologies Inc.
                                                                                    Call Sign $2 862. Grant Date 68113[' 6
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                                                                                                                $ TCO : contmmemenii            33060—0678
                                                           3

                                                             International Bureau   Approved:__d
        Date & Time Filed: Jul 24 2018 2:34:10:880PM       |_International
        File Number: SAT—STA—20180724—00055                *with Condifion                                         3. Duall
        Callsign:                                                                                       Ch\    ,Sq‘}dmt Q’)\Kfl Branrh

                                                  FEDERAL COMMUNICATIONS COMMISSION
                                        APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY

                                                                 FOR OFFICIAL USE ONLY


          APPLICANT INFORMATION
        Enter a description of this application to identify it on the main menu:
         Skysat temporary change in Telemetry Frequency
        1. Applicant

                   Name:         Terra Bella Technologies Inc.      Phone Number:                             202—827—5152
                   DBA Name:                                         Fax Number:

                   Street:       346 9th St.                        E—Mail:                                   rich@planet.com


                   City:         San Francisco                      State:                                    CA

                   Country:       USA                               Zipcode:                                  94103         *«

                   Attention:    Craig Scheffler


                                          ATTACHMENT TO GRANT
                                            Terra Bella Technologies Inc.
                                      IBFS File No. SAT—STA—20170726—00109

 IBFS File No(s):          SAT—STA—20180724—00055                                                    GR A NTE D —
 Licensee/Grantee:         Terra Bella Technologies Inc.                                             With Conditions
 Call Sign:                $2862                                                                                         ;
 Satellite Name:          SkySat—14 and SkySat—15
 Orbital Location:        NGSO at altitudes between 400 km and 630 km
 (required station—
 keeping tolerance)
 Administration:           United States of America
 Nature of Service:        Telemetry, Tracking and Control                                         International Bureau
                                                                                                     Satellite Division
 Scope of Grant:           Special temporary authority for a period of 180 days to allow SkySat—14 and SkySat—15
                           satellites to conduct telemetry downlink while they are brought into service after launch
                           using the following center frequencies: 8374.75 MHz and §375.25 MHz.‘
 Service Area(s):       See Scope of Grant
 Frequencies:           See Scope of Grant
 Unless otherwise specified herein, 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.

      1.    Operations under this STA must be in compliance with the terms of the Memorandum of Agreement
           between Terra Bella and the National Aeronautics and Space Administration pertaining to operation in
           the frequency band 8025—8400 MHz.                                                                 ~
      2.   Transmissions of telemetry data in the 8025—8400 MHz frequency band may only be made to and when
           within the line of sight of the earth stations approved for such transmissions under the existing
           Memorandum of Agreement between Terra Bella and NASA, or any successor agreement.

 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            September 13, 2018
 Date:
 Term Dates       From: September 30, 2018              ] To: period of 180 days
 Approved:                             j




                  Chief, Satellite Policy Branch




‘ Terra Bella will assign each of the two new SkySat satellites one of the listed center frequencies immediately after launch.
After approximately 30 to 60 days, the satellite orbits will have diverged sufficiently so that earth stations will be able to
distinguish each individual satellite and all satellites will be commanded to transmit on the authorized center frequency of
8375.00 MHz for regular operations. Terra Bella requests special temporary authority for 180 days to accommodate possible
launch delays. Narrative at 1.               ‘
                                                         Page 1 of 1


2. Contact


             Name:            Craig Scheffler                  Phone Number:                        720—238—5634
             Company:         Planet Labs Inc.                 Fax Number:
             Street:          346 9th St.                      E—Mail:                              craig@planet.com


             City:            San Francisco                    State:                                CA
             Country:         USA                              Zipcode:                             94103      —
             Attention:                                        Relationship:                        Engineer


   (If your application is related to an application filed with the Commission, entereitherthe file number or the IB Submission ID of the related
application. Please enter only one.)
   3. Reference File Number SATMOD2015040800019 or Submission ID
 4a. Is a fee submitted with this application?
@ !f Yes, complete and attach FCC Form 159.       If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
3 Governmental Entity          ; Noncommercial educational licensee
g£34 Other(please explain):

4b. Fee Classification    —CXW — Space Station (Non—Geostationary)
5. Type Request


¢y Change Station Location                        {‘3 Extend Expiration Date                       & Other


6. Temporary Orbit Location                                               7. Requested Extended Expiration Date


 8. Description      (Ifthe complete description does not appearin this box, please go to the end of the form to view it in its entirety.)
          Request temporary authorization to change the telemetry downlink frequency during launch
          and satellite commissioning phase.




     9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @ Yes            gty No
     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 "party to the application" for these purposes.


 10. Name of Person Signing                                                    11. Title of Person Signing
 Craig Scheffier                                                               Spectrum Manager
     12. Please supply any need attachments.
      Attachment 1: Narrative Exhibit                  Attachment 2:                                     Attachment 3:



               WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                       (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).
U3


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                                                                                Terra Bella Technologies Inc.
                                                                     Request for Special Temporary Authority
                                                                                                   July 24, 2018


                                 EXHIBIT A — NARRATIVE STATEMENT

          Terra Bella Technologies Inc. (Terra Bella), a wholly owned subsidiary of Planet Labs Inc.
 (Planet), pursuant to Section 25.120 ofthe 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 ofthe telemetry downlink frequencies on two commercial remote sensing satellites,
 SkySat—14 and SkySat—15, while they are brought into service after launch. The satellites are scheduled to
be launched on September 30, 2018 on a SpaceX Falcon 9 launch vehicle as previously authorized by the
commission‘. Approval for this STA application would be consistent with a previous Commission action
in 2016 and 2017 for similar STA‘s with an identical purpose for Skysat—4 through Skysat—7" and Skysat—
8 through Skysat—13".

           To accommodate possible launch delays, Terra Bella seeks temporary authority for a period of
180 days commencing on the expected launch date (September 30, 2018). The requested temporary
authority, however, would be utilized only until routine communications links with the satellites are
established, which is expected to be a period of no more than 60 days after launch. Terra Bella outlines
belowits need for the requested STA and the reasons that this request should be granted expeditiously.

        Terra Bella (through its parent company Planet) currently operates thirteen commercial remote
sensing satellites, SkySat—1 through SkySat—13, under FCC Call Sign $2862, as part of a non—
geostationary orbit (NGSO) Earth Exploration Satellite Service (EESS) high—resolution imagery satellite
system‘. The requested STA would apply to SkySat—14 and SkySat—15, which are expected to be
launched in September 2018.

          On the launch date, SkySat—14 and SkySat—15 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 $2862. Without the requested temporary modification, both 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 two new satellites one of the
following frequencies for telemetry transmissions effective upon launch:

               e   8374.75 MHz
               e   §375.25 MHz

Each of the proposed frequencies is within the 8025—8400 MHz band allocated to EESS, as well as within
250 kHz of the telemetry downlink frequency of $375.00 MHz currently authorized for Call Sign $2862.
Assuming nominal conditions, after approximately 30 to 60 days, 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 §375.00 MHz for permanent operations.
——




     File number SAT—MOD—20150408—00019, granted August 31, 2016.
bJ




     File number SAT—STA—20160803—00076, granted Sept 14, 2016.
te




     File number SAT—STA—20170726—00109, granted Oct 12, 2017.
* File number SAT—LOA—20120322—00058 (SkySat—1 and SkySat—2) and File No. SAT—MOD—20150408—00019
(SkySat—3 through 15).


                                                                             Terra Bella Technologies Inc.
                                                                  Request for Special Temporary Authority
                                                                                             July 24, 2018

         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 $2862, including modulation, bandwidth, and power
of the telemetry transmitters.

         Grant ofthis STA will serve the public interest by facilitating Planet‘s operation of two
additional, high—resolution imagery satellites that are complementary to the existing satellites, SkySat—1
through Skysat—13, thereby enhancing competition and expanding U.S. capabilities in the market for
commercial remote sensing data. Planet‘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 Planet‘s EESS
capabilities.

        In summary, and on the basis ofthe information provided herein and in File No. SAT—MOD—
20150408—00019, Terra Bella requests special temporary authority to modify the telemetry downlink
frequencies on two commercial remote sensing satellites, SkySat—14 and SkySat—15, for a period of 180
days commencing on the expected launch date of September 30, 2018.




5 Ibid footnote 1.
                                                     bJ



Document Created: 2018-09-13 18:06:11
Document Modified: 2018-09-13 18:06:11

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