Attachment Exhibit A

This document pretains to SES-MOD-20170804-00860 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017080400860_1256433

                                                                                             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, aircraft monitoring, and

meteorological monitoring.3 Spire requests authority to use the 402-403 MHz band for uplink

and telemetry, tracking, and command (“TT&C”),4 the 449.75-450.25 MHz band for TT&C, and

the 2020-2025 MHz band for downlink.5 Spire has requested additional frequencies for its Phase

II LEMUR satellites.6 However, Spire will be amending its request to use those frequencies in

the next couple of months, so it does not seek authority to use those frequencies with the

proposed earth stations at this time.7




1
  Spire is contemporaneously submitting separate applications for its ground stations. 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 Phase IA Application”); Amendment Application of Spire Global, Inc., File No. SAT-AMD-
20161114-00107 (filed Nov. 14, 2016) (“LEMUR Phase IB/IC 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 Phase IA Application, Exhibit A at 7; LEMUR Phase IB/IC Application, Exhibit A at 3.
4
  The 402-403 MHz band will also be used for backup downlink. See LEMUR Phase IA Application,
Exhibit A at 1; LEMUR Phase IB/IC Application, Exhibit A at 5-6.
5
  See Attachment 3.
6
  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 LEMUR Phase IA Application, Exhibit A at 1-2.
7
  Spire will modify its licenses accordingly prior to the deployment of the Phase II satellites.


                                                     1


                                                                                            Exhibit A
                                                                                     Spire Global, Inc.
                                                                               Response to Question 43
                                                                                       FCC Form 312

        Consistent with the LEMUR Phase IA Application and LEMUR Phase IB/IC Application

and to the extent necessary,8 Spire requests waiver of the rules listed below and submits that

good cause exists for grant of the requested waivers.9

        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.10 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).11 Spire’s use of the band for its LEMUR satellites

will be of limited duration.12 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



8
  See LEMUR Phase IA Application, Exhibit A at 23-24; LEMUR Phase IB/IC Application, Exhibit A at
12-23.
9
  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).
10
   See 47 C.F.R. §§ 2.102(a), 2.106. As a companion to Section 2.106, Spire also seeks waiver of 47
C.F.R. § 2.102(a). As the Commission recently stated, waiver of Section 2.102(a) is necessary to
authorize the requested operations that are not in conformance with the U.S. Table of Frequency
Allocations. See Iridium Constellation LLC Application for Modification of License to Authorize a
Second-Generation NGSO MSS Constellation, Order and Authorization, 31 FCC Rcd 8675 ¶ 21 n.77 (IB
and OET 2016) (granting on its own motion waiver of Section 2.102(a) to permit Iridium Constellation
LLC’s proposed MSS (Earth-to-space) use of very high frequency bands in which there is no MSS
allocation for the relevant use (domestic or international)). For convenience, all subsequent references to
requests for waiver of the U.S. Table of Frequency Allocations refer to both Sections 2.102(a) and 2.106
of the Federal Communication Commission’s (“Commission’s”) rules. See also LEMUR Phase IA
Application, Exhibit A at 23; LEMUR Phase IB/IC Application, Exhibit A at 15-16.
11
   See 47 C.F.R. § 2.106; see also id. at nn. 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 n. US64(a). The Meteorological Aids Service can operate associated ground
transmitters. Id. at n. US70. Finally, non-Federal EESS (Earth-to-Space) and METS (Earth-to-Space) are
permitted to transmit only to Federal space stations. Id. at n. US384.
12
   See LEMUR Phase IA Application, Exhibit A at 9-10. The antenna will transmit only on one carrier
frequency at a time.


                                                    2


                                                                                          Exhibit A
                                                                                   Spire Global, Inc.
                                                                             Response to Question 43
                                                                                     FCC Form 312

system.13 To the extent possible, Spire will coordinate with other operators in this band to ensure

there is no harmful interference. Per conditions imposed through Spire’s Phase IB/IC space

station license grants,14 Spire is required to coordinate and receive approval from Department of

Commerce/National Oceanic and Atmospheric Administration (“DOC/NOAA”) to operate all

new potential 402-403 MHz stations. As shown in Attachment 4, Spire has received

DOC/NOAA approval to operate 402-403 MHz stations at the locations listed in Attachment 1.

       Spire requests waiver of the U.S. Table of Frequency Allocations to use the 449.75-

450.25 MHz on a non-conforming, non-harmful interference basis.15 Footnotes 5.286 and US87

state that this band may be used for Space Operations Service (Earth-to-space), subject to

agreement obtained under No. 9.21.16 Spire has filed its coordination request with the

Commission, which has in turn filed the request with the International Telecommunication

Union. Spire requests to use this band on a non-conforming, non-harmful interference basis until

Spire has reached all necessary coordination agreements with other administrations. To the

extent possible, Spire will coordinate with other operators in this band to ensure there is no

harmful interference.

       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.17



13
   See id. at 23.
14
   See Stamp Grant, Spire Global, Inc., IBFS File No. SAT-AMD-20161114-00107 (granted in part and
deferred in part Apr. 7, 2017); Stamp Grant, Spire Global, Inc., IBFS File No. SAT-AMD-20161114-
00107 (granted in part and deferred in part May 18, 2017); Stamp Grant, Spire Global, Inc., IBFS File
No. SAT-AMD-20161114- 00107 (granted in part and deferred in part July 13, 2017).
15
   See 47 C.F.R. §§ 2.102(a), 2.106; see also LEMUR Phase IB/IC Application, Exhibit A at 23.
16
   See 47 C.F.R. § 2.106 nn. 5.286, US87.
17
   See 47 C.F.R. §§ 2.102(a), 2.106; see also LEMUR Phase IA Application, Exhibit A at 24; LEMUR
Phase IB/IC Application, Exhibit A at 13.


                                                   3


                                                                                        Exhibit A
                                                                                 Spire Global, Inc.
                                                                           Response to Question 43
                                                                                   FCC Form 312

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 U.S.18

Spire has been using this band since September 2015 in three countries, including the U.S.,

without reports of interference. Spire’s use of this fallow band on an interim basis as it designs,

builds, tests, and coordinates downlinks in 8025-8400 MHz in Phase II is an efficient use of

spectrum and serves the public interest.19




18
   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).
19
   See LEMUR Phase IA Application, Exhibit A at 9-10; LEMUR Phase IB/IC Application, Exhibit A at
13.


                                                 4


                                                                                                                            Exhibit A
                                                                                                                     Spire Global, Inc.
                                                                                                               Response to Question 43
                                                                                                                       FCC Form 312

                                                           Attachment 1
                                                 Earth Station Sites Characteristics
Modification of Existing Licenses

 Station       Call    File No.                   Site Address                  Latitude           Longitude          New Antenna at
  Name         Sign                                                                                                      Location
GUMGS        E160038 SES-LIC-           312 Route 2A                        13°24'56.3"N       144°41'15.1"E          UHF-3
                     20160317-          Shell Fuel Farm Road
                     00252              Piti, Guam 96925
ITOGS        E160037 SES-AMD-           93-1704 South Point Road            19°0'50.90"N       155°39'46.78"W         UHF-3
                     20160331-          Naalehu, HI 96772
                     00301
SLCGS        E160042 SES-LIC-           7202 South Campus View Drive        40°37'12.47"N      111°59'9.98"W          UHF-3
                     20160317-          West Jordan, UT 84084
                     00256

These three stations will maintain the UHF-1 and SBAND-1 antennas currently authorized for operations.
No Federal Aviation Administration notification is required for any of the proposed ground stations. 47 C.F.R. § 17.7(e).

Key –
   • 402-403 MHz antennas
        o M2 Antenna Systems 401CP14 (“UHF-1”)
        o Innov 405-18-R (“UHF-2”)
   • 449.75-450.25 MHz antenna
        o TACO H-105 (“UHF-3”)
   • 2020-2025 MHz antennas
        o ARA – Seavey C1502-800 (“SBAND-1”)
        o Elite 999001 (“SBAND-2”)




                                                                   5


                                                                                                                           Exhibit A
                                                                                                                    Spire Global, Inc.
                                                                                                              Response to Question 43
                                                                                                                      FCC Form 312

New License Request

 Station Name                  Site Address                       Latitude                  Longitude           New Antennas at
                                                                                                                    Location
CLTGS              5821 Fairview Road                     35°9'8.28"N                 80°50'29.62"W           UHF-1;
                   Suite G12/18                                                                               UHF-3;
                   Charlotte, NC 28209                                                                        SBAND-1
DLHGS              3401 Technology Drive                  46°49'39.38"N               92°07'49.82"W           UHF-2;
                   Duluth, MN 55811                                                                           UHF-3;
                                                                                                              SBAND-1
JNUGS2             1050 Harbor Way                        58°18'06.69"N               134°25'35.06"W          UHF-1;
                   Juneau, AK 99824                                                                           SBAND1
TUSGS              1215 E Pennsylvania Street             32° 10' 20.28''N            110° 57'14.94''W        UHF-2;
                   Tucson, AZ 85714                                                                           SBAND-2

No Federal Aviation Administration notification is required for any of the proposed ground stations. 47 C.F.R. § 17.7(e).

Key –
   • 402-403 MHz antennas
        o M2 Antenna Systems 401CP14 (“UHF-1”)
        o Innov 405-18-R (“UHF-2”)
   • 449.75-450.25 MHz antenna
        o TACO H-105 (“UHF-3”)
   • 2020-2025 MHz antennas
        o ARA – Seavey C1502-800 (“SBAND-1”)
        o Elite 999001 (“SBAND-2”)




                                                                  6


                                                                                       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 the following antennas at the

various ground stations identified in Attachment 1:

   •   Yagi antenna for its transmissions and reception of downlink transmissions in the 402-

       403 MHz band (“UHF-1” antenna or “UHF-2” antenna);

   •   Helical antenna for its transmissions in the 449.75-450.25 MHz band (“UHF-3” antenna);

       and

   •   Dual Circular Dish antenna for its reception of downlink transmissions in the 2020-2025

       MHz band (“SBAND-1” antenna or “SBAND-2” antenna).

The characteristics of the five antennas are provided below.

Table 1: UHF-1 Yagi Antenna Characteristics

Manufacturer & Model         Antenna Length (m)         3dB Beamwidth (deg)         Polarization
M2 Antenna Systems           1.85 x 0.38 x 0.38         60                          RHCP
401CP14


Table 2: UHF-2 Yagi Antenna Characteristics

Manufacturer & Model         Antenna Length (m)         3dB Beamwidth (deg)         Polarization
Innov                        1.85 x 0.38 x 0.38         45.8                        RHCP
405-18-R


Table 3: UHF-3 Helical Antenna Characteristics

Manufacturer & Model         Antenna Length (m)         3dB Beamwidth (deg)         Polarization
TACO                         2.46 x 0.23 x 0.23         35                          RHCP
H-105




                                                 7


                                                                           Exhibit A
                                                                    Spire Global, Inc.
                                                              Response to Question 43
                                                                      FCC Form 312

Table 4: SBAND-1 Dual Circular Dish Antenna Characteristics

Manufacturer & Model   Antenna Diameter (m)    3dB Beamwidth (deg)   Polarization
ARA – Seavey           1.2                     6.5                   RHCP
C1502-800


Table 5: SBAND-2 Dual Circular Dish Antenna Characteristics

Manufacturer & Model   Antenna Diameter (m)    3dB Beamwidth (deg)   Polarization
Elite                  1.8                     5.5                   RHCP
999001




                                         8


                                                               Exhibit A
                                                        Spire Global, Inc.
                                                  Response to Question 43
                                                          FCC Form 312

                            Attachment 3
                          Frequency Bands

           Frequency                            Use
402-403 MHz (Earth-to-space)         Primary TT&C uplink
402-403 MHz (space-to-Earth)         Primary TT&C downlink
                                     Backup data downlink
449.75-450.25 MHz (Earth-to-space)   Primary TT&C uplink
2020-2025 MHz (space-to-Earth)       Primary data downlink




                               9


                                                         Exhibit A
                                                  Spire Global, Inc.
                                            Response to Question 43
                                                    FCC Form 312

                   Attachment 4
DOC/NOAA Approval of New 402-403 MHz Ground Stations




                         10


wsrow                                          Spire Mail — Spire — Coordination of UHE Ground Stations



A Spire                                                                                        George John


 Spire — Coordination of UHF Ground Stations
 David Franc                                                                                              Mon, Jun 26, 2017 at 10:43 AM
 To: George John
 Ce: Brandon Mitchel

   George,

   We agree to the changes and additional stations, provided operations is stil on an non interference basis (NIB).

   Dave Franc

   On Fri, Jun 23, 2017 at 10:37 AM, George John,[R@@@iiiiiiiiiiiiiiiilwrote:
     Dave, Fred, Kellen —

     Happy Friday! Percondition 8 of ournewest FCC license(attached), we are required to coordinate and receive
     approval from DOC/NOAA to operate all new potential UHF stations. We have previously sent our ground station list of
     where we would like to operate these new stations but have not heard back. So, below I have pasted our proposed new
     UHEFsites for Spire.

     Please advise if you need any additionalinformation to complete coordination. Your consideration is greatly
     appreciated.

     Kind regards,
     George

     George John
     Legal & Regulatory Counsel
     Spire Global, Inc.
     575 Florida Street, Suite 150
     San Francisco, CA 94110 USA
     (202) 747—2619

     New stations (outsideof US)
     SupremeSAT Teleport
     Kandy, Sri Lanka      7°1629.01"N 80°4330.17"E
     National Space Centre
     Cork, Ireland         51°57"11.20" N 08°1030.29" W

     New stations (inside of US)

      Involta
      3401 Technology Drive
      Duluth, MN 55811                    46°4930.38" N 92°0749.82" W
      Charlotte Colocation Company
      5821 Fairview Road SuiteG12/18
      Charlotte, NC 28209                 35°08.28" N         80°50‘29.62" W
      Involta
      1215 E Pennsylvania Street
      Tucson, AZ 85714                    32° 10‘ 20.28"N 110° 57° 14.94" W

     Move stations (inside of US)

     We are already authorized to use a Juneau station for UHF operations; however, we would look to move the station to a
     new location 8—10 miles away for easier access and maintenance capabiliies. It‘s not a new station; we would just like
     to slightly move locations within Juneau.


7/28/2017                                                     Spire Mail - Spire - Coordination of UHF Ground Stations
         New location

         MXAK
         1050 Harbor Way
         Juneau AK 99824                                  58°18'06.69" N 134°25'35.06" W

         Old location

         58.364028 N, 134.606444 W                            58°21'50.65"N            134°36'21.52"W




    ­­

    David Franc
    Deputy Director for International Spectrum Activity

    Department of Commerce,
    Office of Radio Frequency Management

    National Oceanic and Atmospheric Administration
    1315 East­West Highway, Room 10601
    Silver Spring, MD 20910­3282




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Document Created: 2017-08-02 15:25:52
Document Modified: 2017-08-02 15:25:52

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