Attachment Exhibit A

This document pretains to SES-LIC-20160317-00246 for License on a Satellite Earth Station filing.

IBFS_SESLIC2016031700246_1130068

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Description of Application Spire Global, Inc. (“Spire”) hereby requests authority to operate the earth stations identified in Attachment 1 to this exhibit1 as part of the ground segment for the LEMUR satellite system.2 The LEMUR system will provide maritime monitoring, meteorological monitoring, and earth imaging services.3 Spire requests authority to use the 402-403 MHz band for uplink and telemetry, tracking, and command (“TT&C”) and to use the 2020-2025 MHz band for downlink.4 Spire has requested additional frequencies for its Phase II LEMUR satellites.5 However, because those satellites will not be deployed in the immediate future and coordination of the S-band uplink may require additional time, Spire does not seek authority to use those frequencies with the proposed earth stations at this time.6 1 Spire is contemporaneously submitting separate applications for each earth station. Except for location-specific information, including the number and height of the antennas, the applications are materially the same. See Attachment 1. 2 See Application of Spire Global, Inc., File No. SAT-LOA-20151123-00078 (filed Nov. 23, 2015) (“LEMUR Application”). Spire also plans to deploy unlicensed receive-only facilities— on a non-harmful interference and unprotected basis—as part of its ground system. See 47 C.F.R. 25.131; Regulation of Domestic Receive-Only Satellite Earth Stations, First Report and Order, 74 FCC 2d 205 ¶ 31 (1979); see also Amendment of Part 25 of the Commission's Rules and Regulations to Reduce Alien Carrier Interference Between Fixed–Satellites at Reduced Orbital Spacings and to Revise Application Processing Procedures for Satellite Communications Services, First Report and Order, 6 FCC Rcd 2806 (1991). 3 See LEMUR Application, Exhibit A at 7. 4 The 402-403 MHz band will also be used for backup downlink. See id. at 1. 5 The Phase II satellites will use the 8025-8400 MHz band for downlink, including TT&C, and the 2025-2110 MHz band for uplink, including TT&C. See id. at 1-2. 6 Spire will modify its licenses accordingly prior to the deployment of the Phase II satellites.

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Consistent with the LEMUR Application and to the extent necessary,7 Spire requests waiver of the rules listed below and submits that good cause exists for grant of the requested waivers.8 Spire requests waiver of the U.S. Table of Frequency Allocations to use the 402-403 MHz band on a non-conforming, non-harmful interference basis.9 The 402-403 MHz band is allocated to a number of satellite services, including earth exploration-satellite service (“EESS”) (Earth-to-space), meteorological-satellite service (“METS”) (Earth-to-space), and Meteorological Aids Service (radiosonde).10 Spire’s use of the band for its LEMUR satellites will be of limited duration.11 The wide beamwidth of the low-band frequencies can greatly facilitate the reestablishment of a lost communications link. In any event, there is unlikely to be harmful interference because of the infrequent nature and type of transmissions from the satellite system.12 Additionally, to the extent possible, Spire will coordinate with other operators in this band to ensure there is no harmful interference. 7 See LEMUR Application, Exhibit A at 23-24. 8 See 47 C.F.R. § 1.3; see also WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969), cert. denied 409 U.S. 1027 (1972); Northeast Cellular Tel. Co. v. FCC, 897 F.2d 1166 (D.C. Cir. 1990). 9 See LEMUR Application, Exhibit A at 23. 10 See 47 C.F.R. § 2.106; see also id. at notes US64(a), US70, US384. The mobile service, excluding aeronautical mobile, is allocated to the Medical Device Radiocommunication Service operations on a secondary basis. Id. at note US64(a). The Meteorological Aids Service can operate associated ground transmitters. Id. at note US70. Finally, non-Federal EESS (Earth-to- Space) and METS (Earth-to-Space) are permitted to transmit only to Federal space stations. Id. at note US384. 11 See LEMUR Application, Exhibit A at 9-10. The antenna will transmit only on one carrier frequency at a time. 12 See id. at 23. 2

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Spire also requests waiver of the U.S. Table of Frequency Allocations to use the 2020- 2025 MHz band (space-to-Earth) on a non-conforming, non-harmful interference basis.13 Although there is a co-primary mobile-satellite service allocation in the 2020-2025 MHz band for ITU Region 2, the frequency band is allocated only for fixed and mobile service in the United States.14 However, the spectrum is currently fallow and unlikely to be used until well after June 2016, the deadline for the adjacent band licensee to determine whether the 2000-2020 MHz band will be used for terrestrial uplinks or downlinks.15 Accordingly, Spire’s temporary use of this band, as a downlink for its LEMUR satellites, will not likely cause harmful interference to any authorized operator.16 13 See id. at 24. 14 See Amendment of the Commission’s Rules with Regard to Commercial Operations in the 1695-1710 MHz, 1755-1780 MHz, and 2155-2180 MHz Bands, Report and Order, 29 FCC Rcd 4610 ¶ 59 (2014). 15 See id. 16 See LEMUR Application, Exhibit A at 9-10. 3

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Attachment 1 Earth Station Sites Characteristics Site Address Latitude Longitude Antenna(s) at Location 2347 Azurite Court 61° 8’ 46.74” N 149° 50’ 16.31” W M2 Antenna Systems 401CP14 Anchorage, AL (“UHF-1”) 4680 Conference Way S #150 26° 23’ 21.30” N 80° 6’ 32.46” W UHF-1 Boca Raton, FL 3060 Flying View 38° 52’ 25.58” N 104° 24’ 26.10” W UHF-1; Ellicott, CO ARA – Seavey C1502-800 (“SBAND-1”) 155 Locust Street 41° 44’ 42.27” N 72° 39’ 54.66” W UHF-1 Hartford, CT 93-1704 South Point Road 19° 0’ 50.90” N 155° 39’ 46.78” W UHF-1; Naalehu, HI SBAND-1 N/A 58° 21’ 50.65” N 134° 36’ 21.52” W UHF-1 Juneau, AK 312 Route 2A 13° 24’ 56.30” N 144° 41’ 15.10” E UHF-1; Shell Fuel Farm Road SBAND-1 Piti, Guam 904 Quality Way 32° 57’ 58.38” N 96° 42’ 41.58” W UHF-1; Richardson, TX SBAND-1 23 Estate Northside 17° 45’ 43.12” N 64° 53’ 6.01” W UHF-1; Saint Croix, Virgin Islands SBAND-1 466 8th Street 37° 46’ 22.15” N 122° 24’ 27.80” W UHF-1; San Francisco, CA SBAND-1

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Site Address Latitude Longitude Antenna(s) at Location 33 Norfolk Street 37° 46’ 16.20” N 122° 24’ 50.42” W UHF-1; San Francisco, CA SBAND-1 3433 S 120th Place 47° 29’ 39.15” N 122° 17’ 18.55” W UHF-1; Tukwila, WA SBAND-1 7202 S. Campus View Drive 40° 37’ 12.47” N 111° 59’ 9.98” W UHF-1; West Jordan, UT SBAND-1 No Federal Aviation Administration notification is required for any of the proposed ground stations. 47 C.F.R. § 17.7(e).

Exhibit A Spire Global, Inc. Response to Question 43 FCC Form 312 Attachment 2 Additional Antenna Information Due to the limitations of the Commission’s Form 312 Schedule B form, Spire clarifies in this attachment some of its responses in that form. Spire will use a Yagi antenna for its transmissions in the 402-403 MHz band (the “UHF-1” antenna). As identified in Attachment 1, some of the earth stations also will have a Dual Circular Dish antenna for reception of downlink transmissions in the 2020-2025 MHz band (the “SBAND-1” antenna). The characteristics of both antennas are provided below. Table 1: UHF-1 Yagi Antenna Characteristics Manufacturer Antenna Length 3dB Beamwidth Polarization & Model (m) (deg) M2 Antenna Systems 1.85 x 0.38 x 0.38 60 RHCP 401CP14 Table 2: SBAND-1 Dual Circular Dish Antenna Characteristics Manufacturer Antenna Diameter 3dB Beamwidth Polarization & Model (m) (deg) ARA – Seavey 1.2 6.5 RHCP C1502-800


Document Created: 2016-03-16 18:29:09
Document Modified: 2016-03-16 18:29:09
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