Attachment Exhibit A

This document pretains to SES-LIC-20160317-00255 for License on a Satellite Earth Station filing.


                                                                                          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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