Attachment Exhibit 43 SAT-MOD-20150802-00053

Attachment Exhibit 43

This document pretains to SAT-MOD-20150802-00053 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015080200053_1098243

EXHIBIT 43
Planet Labs Inc.
License Application
FCC Form 312
July 2015

Description of Application

With this application, Planet Labs Inc. (“Planet Labs”) requests modification of its authorization to
operate a non-geostationary (“NGSO”) Earth imagery satellite system, Call Sign S2912. As detailed in the
application below, Planet Labs requests authorization to continuously maintain and operate a constellation
(a.k.a. a “Flock”) of up to two hundred (200) technically identical satellites across a variety of launches
to enable whole Earth, daily coverage by its imaging fleet. Due to the low altitudes of the planned
deployments, and thus the short orbital lifetime of the Planet Labs satellites, a continuous series of
replenishment launches is required to maintain such a constellation. In light of this need, Planet Labs
further requests authorization to launch a total of up to six hundred (600) technically identical satellites
over the next 10 years, with the number of simultaneously operational satellites not exceeding two
hundred (200). This two hundred (200) operational satellite limit includes the currently authorized eleven
(11) satellites of Flock 1c,1 and maximum fifty six (56) satellites authorized to be launched and deployed
from the International Space Station.2 The proposed additional satellites are technically identical to the
currently authorized satellite systems, and Planet Labs incorporates by reference the technical information
provided previously.3

Currently, Planet Labs is authorized to use the 401-402 MHz and the 449.75-450.25 MHz “UHF” bands
as TT&C links (downlink and uplink, respectively) for the early commissioning phase, as well as for
emergency back-up communications. Planet Labs requests modification to use these bands on a more
regular basis throughout the mission lifetime in order to perform ranging and refine the orbit
determination of the satellites. The UHF links are operated at very low data rates with an omnidirectional
antenna on the satellite, and thus ranging and orbit determination can occur no matter what the orientation
of the satellite. Planet Labs openly publishes its orbital ephemerides so that other satellite operators may
more accurately assess potential collision risks and avoid false positive warnings.4 Enabling ranging and
refined orbital determination throughout the mission lifetime of the Planet Labs satellites will greatly
increase the safety of all space stations operating in the affected regions.

Planet Labs anticipates launching the next wave of technically identical satellites into Low Earth Orbit as
early as January 2016. The satellites will be launched to orbits ranging from 350 km altitude, up to 720
km altitude, with the semi-major axis never exceeding 7,031 km (660 km above sea level), with

1
See File No. SAT-MOD-20140321-00032 (granted 06/18/2014, Call Sign S2912)
2
See File No. SAT-MOD-20140912-00100 (granted 10/23/2014, Call Sign S2912)
3
See File No. SAT-LOA-20130626-00087 (granted 12/03/2013, Call Sign S2912), File No. SAT-MOD-20140321-
00032 (granted 06/18/2014, Call Sign S2912) and File No. SAT-MOD-20140912-00100 (granted 10/23/2014, Call
Sign S2912).
4
See Planet Labs Public Orbital Ephemerides (Access at http://ephemerides.planet-labs.com/)

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inclinations of 30 degrees and above.5 The majority of satellites will be launched to 475 km circular
altitude, 97.3 degree inclination (Sun Synchronous Orbit). As the satellite orbits naturally decay over
time, operations of the X-band and S-band links will continue down to 300 km altitude, and operations of
the UHF links will continue down to 200 km altitude.

Planet Labs has already submitted applications for license from the National Oceanic and Atmospheric
Administration (“NOAA”) to operate its satellites, which are private remote sensing space systems, and
will continue to seek license from NOAA for all future launches. Planet Labs has previously received
license to operate from NOAA for previous launches.6

Timely deployment of the proposed satellite systems will enable Planet Labs to guarantee uninterrupted
operations of the unique imaging services being provided to customers in the U.S. and around the world.
To the extent necessary to enable Commission action prior to the earliest expected launch in January
2016, Planet Labs respectfully requests expedited consideration of this request for launch and operation
authority. In support of its request for authorization, Planet Labs offers the following information
concerning its proposed satellite system.

5
The highest circular altitude a satellite will be launched to is 660 km. Elliptical orbits may be utilized with an
apogee greater than 660 km, however the semi-major axis will never exceed 7,031 km (660 km above sea level).
6
See Planet Labs Inc. Licenses from National Oceanic and Atmospheric Administration to Operate a Private
Remote Sensing Space System (Access at http://www.nesdis.noaa.gov/CRSRA/licenseHome.html).

2

I. Description of the Applicant
Planet Labs Inc. is a U.S. company funded by private investment and is headquartered in San Francisco,
California. Planet Labs was initially incorporated in Delaware in December, 2010 under the name
Cosmogia Inc., and the name of the corporation was legally changed to Planet Labs Inc. in June 2013.
Planet Labs designs, constructs and operates small Earth imagery satellites, and provides Earth imagery
products on a commercial basis to a variety of customers.

Planet Labs launched and operated two successful experimental missions, Dove 1 and Dove 2, in April
2013.7 Planet Labs also launched, and continues to operate, a third successful experimental mission, Dove
3, in November 2013.8

Once the satellite technology was matured via the experimental missions, Planet Labs began launching
operational constellations. Planet Labs launched Flock 1, an operational constellation of 28 identical
satellites, to the ISS in January 2014 under Call Sign S2912. Flock 1 was gradually deployed from the
ISS throughout the month of February 2014 and successfully operated for approximately 5 months until
the satellites began to deorbit and completely burn up via atmospheric decay. Planet Labs also launched
Flock 1c in June 2014, a constellation of 11 identical satellites, to a 620 x 620 km Sun Synchronous Orbit
(SSO), under Call Sign S2912, which continues to operate and has an expected operational lifetime of at
least 2 years. Planet Labs continued to launch a series of satellites to the ISS, also under Call Sign S2912.

Now that the technology has fully matured, Planet Labs is ready for the next phase of development -
simultaneous operation of up to 200 satellites to enable daily imaging of the whole Earth.

II. Information Required Under Section 25.114(d) of the Commission’s Rules

A. General Description of Overall Facilities, Operations and Services
The physical and technical design of the proposed future satellites are identical to that of previously
authorized “Flocks.” The proposed satellite system will consist of a space segment comprised of up to
200 simultaneously operating and launched within the following bounds:
• Minimum Circular Altitude: 350 km
• Maximum Circular Altitude: 660 km
• Maximum Apogee: 720 km altitude (semi-major axis never exceeding 7,031 km, or 660 km
above sea level)
• Inclination: 30 degrees and above
• Primary Orbit: 475 km circular altitude, 97.3 degree inclination (Sun Synchronous Orbit).

And a ground segment comprised of earth stations located in:
• Brewster, WA9

7
See FCC OET file number 0898-EX-ST-2012 and 0100-EX-PL-2012, respectively.
8
See FCC OET file number 0548-EX-PL-2012.
9
See SES-MOD-20140630-00551 (filed 06/30/2014, Call Sign E990069).

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B. Power Flux Density Calculation

1. Power Flux Density at the Surface of the Earth in the band 8025-8400 MHz
The worst case power flux density (PFD) levels at the surface of the Earth will be identical to that of
Flock 1, which was shown under all scenarios to be within the limits set forth in the ITU Radio
Regulations Table 21-4.19

2. Power Flux Density at the Geostationary Satellite Orbit
No. 22.5 of the ITU Radio Regulations specifies that in the frequency band 8025-8400 MHz, which the
EESS using non-geostationary satellites shares with the fixed-satellite service (Earth-to-space) or the
meteorological-satellite service (Earth-to-space), the maximum PFD produced at the geostationary
satellite orbit (“GSO”) by any EESS space station shall not exceed –174 dB(W/ m2) in any 4 kHz band.
The calculation below shows that the PFD produced by the transmissions from the proposed Planet Labs
satellites does not exceed the limit in No. 22.5, even in the worst possible hypothetical case.
The PFD is calculated as:
PFD [dB(W/m2/4 kHz)] = EIRP (dBW) - 71 - 20log10(D) - 10log10(BW) - 24
Where:
EIRP is the Maximum EIRP of the transmission, in dBW;
D is distance between the satellite and affected surface area, in km;
BW is the symbol bandwidth of the transmission, in MHz.

The minimum possible distance between a Planet Labs satellite and GSO is 35786 - 720 = 35066 km.
Under a hypothetical scenario of a Planet Labs satellite antenna radiating its peak EIRP toward GSO, the
worst case scenario is EIRP = 15.92 dBW, BW = 29.7 MHz, which produces a PFD at GSO of -184.78
dB(W/m2) in any 4 kHz band. This does not exceed the ITU limit.

C. Interference Analysis

1. Interference between EESS systems operating in the band 8025-8400 MHz
Interference between the Planet Labs satellites and those of other systems is unlikely, even with the
increase in number of satellites, because EESS systems operating in the 8025-8400 MHz band normally
transmit only in short periods of time while visible from the dedicated receiving earth stations. For the
interference to happen, satellites belonging to different systems would have to travel through the narrow
antenna beam of the receiving earth station and transmit at the same time. In such an unlikely event, the
interference can be still be avoided by coordinating the satellite transmissions amongst the various EESS
users so that they do not occur simultaneously.

D. Public Interest Considerations
The grant of this application will permit Planet Labs to continue to launch and operate a state-of-the-art
remote sensing satellite system. The data produced by the Planet Labs satellites will empower users to

19
See Planet Labs Inc., SAT-LOA-20130626-00087 (granted 12/03/2013).

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make better decisions and will help enable a more sustainable planet. Planet Labs will provide a unique
data set of global-coverage, frequently updated imagery that is currently unavailable from private sector
or government remote sensing providers. In addition to traditional consumers of remote sensing data,
Planet Labs will provide direct benefit to environmental and humanitarian organizations that historically
have not had access to this extent of imagery. This service will complement existing offerings in the
remote sensing market and will help promote new users and applications.

E. Orbital Debris Mitigation
Planet Labs has conducted an Orbital Debris Assessment Report (“ODAR”) for the additional Flock
satellites in compliance with NASA-STD-8719.14. The Flock satellite systems are compliant with all
applicable orbital debris requirements as listed in Section 25.114(d)(14).

The Flock satellites will not undergo any planned release of debris during their normal operations.
In addition, all separation and deployment mechanisms, and any other potential source of debris will be
retained by the spacecraft or launch vehicle. Planet Labs also has assessed the probability of the space
stations becoming sources of debris by collision with small debris or meteoroids of less than one
centimeter in diameter that could cause loss of control and prevent post-mission disposal and found the
risk to be Compliant. Planet Labs has assessed and limited the probability of accidental explosions during
and after completion of mission operations through a failure mode verification analysis and found the
system to be Compliant. The Flock satellites do not carry any onboard propulsion.

Planet Labs has assessed and limited the probability of the Flock satellites becoming a source of debris by
collisions with large debris or other operational spacecraft and found the risk to be Compliant. The orbital
bands that Planet Labs launches to are significantly lower than the densest LEO regions.20 Planet Labs
will work closely with the launch providers to ensure that the satellites are deployed in such a way as to
minimize the potential for collision with any other spacecraft.

Special care is also given to minimizing the potential for collision with manned spacecraft, including the
International Space Station (ISS) and China’s Tiangong-1. The operational altitude of the ISS is
approximately 400 km,21 and Tiangong-1 currently operates at an altitude of approximately 382 km.22
While both facilities are significantly below the baseline operational orbit altitude of 475 km for the Flock
satellites, Planet Labs will coordinate with NASA to assure protection of the ISS on an ongoing basis, and
with the China National Space Agency with respect to Tiangong-1 and successor vehicles.23

The Flock satellites do not carry onboard propulsion, however some orbital maintenance can be
performed using differential drag for phasing of the satellites along an orbital plane and for potential
collision avoidance (if needed). In any case, the orbits of the satellites will naturally decay over time until

20
See Keeping Space Clean: Responsible satellite fleet operations (Access at https://www.planet.com/pulse/keeping-
space-clean-responsible-satellite-fleet-operations/).
21
https://www.heavens-above.com/IssHeight.aspx (last visited July 29, 2015).
22
http://www.china.org.cn/china/2011-11/19/content_23957633.htm (last visited July 29, 2015).
23
Planet Labs will take identical proactive measures with respect to any other inhabitable orbiting objects that may
be introduced during the license term.

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the satellites reenter the atmosphere. An assessment of the survivability of satellite survivability upon
reentry and the resulting probability of human casualty has been found to be Compliant. At the worst case
scenario of 620 km circular altitude, the total time in orbit is expected to be 20.7 years. At the nominal
altitude of 475 km circular altitude, the expected time in orbit is 6.9 years. At the lowest altitude of 350
km, the expected lifetime is approximately 3 months. Planet Labs openly publishes its orbital
ephemerides, often more accurate than shown in the public TLE catalogs, so that other satellite operators
may more accurately assess potential collision risks and avoid false positive warnings.24

The Flock satellites are commercial remote sensing satellites subject to regulation by NOAA under Title
51 of the U.S. Code, as well as regulation by the Commission. Pursuant to licensing requirements
codified under Title 51,25 Planet Labs has requested review from NOAA on its plan for the post-mission
disposal of its satellites. Per 47 C.F.R. § 25.114 (14)(iv), Planet Labs has submitted its post-mission
disposal plans to NOAA for review and approval. Accordingly, no submission regarding the Planet Labs
post-mission disposal plans is required or included with this application.

III. Additional/General Considerations

A. Waiver Request of Modified Processing Round Rules
Planet Labs requests that this application be processed pursuant to the first-come, first-served procedure
adopted for “GSO-like satellite systems” under Section 25.158 of the Commission’s rules. 26 To the extent
necessary to allow for such processing, Planet Labs also requests waiver of Sections 25.156 and 25.157 of
the Commission’s rules, which stipulate the processing of “NGSO-like satellite systems” under a
modified processing round framework.2728 The Commission has previously waived the modified
processing round requirement and allowed a number of EESS NGSO satellite systems to be processed on
a first-come, first-served basis, including the original Planet Labs authorization.293031

Planet Labs’ system is fully capable of sharing with current and future NGSO systems operating in the
same frequency bands, even with the proposed additional satellites. Spectrum sharing will be possible
because the Planet Labs satellites and satellites in other systems transmit only in short periods of time
while visible from a limited number of dedicated receiving earth stations. For harmful interference to
occur, satellites belonging to different systems would have to travel through the narrow antenna beam of
the receiving earth station and transmit at the exact same time. In such an unlikely event, the resulting
interference can still be avoided by coordinating the satellite transmission so that they do not occur
24
See Planet Labs Public Orbital Ephemerides (Access at http://ephemerides.planet-labs.com/).
25
See 51 U.S.C. § 60122(b).
26
See 47 C.F.R. § 25.158.
27
See 47 C.F.R. §§ 25.156 & 25.157.
28
See 47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969) (“WAIT Radio”); Northeast Cellular
Telephone Co. v. FCC, 897 F.2d 1164 (D.C. Cir. 1990) (“Northeast Cellular”).
29
See Space Imaging, LLC, 20 FCC Rcd 11694, 11968 (2005). See also Stamp Grant, Skybox Imaging, Inc., SAT-
LOA-20120322-00058 (granted September 20, 2012).
30
Id. See also DigitalGlobe, Inc., 20 FCC Rcd 15696, 15699 (2005) (waiving Sections 25.156 and 25.157). See also
Stamp Grant, Skybox Imaging, Inc., SAT-LOA-20120322-00058 (granted September 20, 2012).
31
See Stamp Grant, Planet Labs Inc., SAT-LOA-20130626-00087 (granted December 03, 2013).

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simultaneously. For these reasons, the waiver request here is fully warranted because waiving Sections
25.156 and 25.157 will not undermine the policy objectives of those rules.

B. Waiver Request of Default Service Rules
Planet Labs requests a waiver of the default service rules under Section 25.217(b) of the Commission’s
rules.32 Although the Commission has not adopted band-specific rules for EESS NGSO operations in the
8025-8400 MHz band, the Commission has previously granted a waiver of the default service rules
contained in Section 25.217(b) to NGSO EESS system licensees, based on the fact that EESS operators in
the 8025-8400 MHz band are required to comply with technical requirements in Part 2 of the
Commission’s rules and applicable ITU rules.33 In these cases, the Commission concluded that because
the cited requirements had been sufficient to prevent harmful interference in the 8025-8400 MHz band,
there was no need to impose additional technical requirements on operations in that band, and therefore
granted the waiver requests. For these same reasons, the Commission should grant Planet Labs a waiver
of the default service rules contained in Section 25.217(b).

C. Form 312, Schedule S
As required by the Commission’s rules and policies, Planet Labs has completed the FCC Form 312,
Schedule S submission that reflects the orbital and physical/electrical characteristics of the Planet Labs
satellite network.

D. Implementation Milestones
Planet Labs intends to supply the Commission with information sufficient to demonstrate that it has
already satisfied the first three implementation milestones under Section 25.164(b) for NGSO systems in
a separate submission. Planet Labs understands that in the absence of a favorable Commission
determination of milestone compliance issued with the grant of this application or within 30 days
thereafter, the full amount of the bond specified in Section 25.165(a)(1) will be required.

E. ITU Advance Publication Materials and Cost Recovery
Planet Labs has prepared the International Telecommunication Union (“ITU”) Advance Publication
Information submission for its proposed non-geostationary EESS system, and has provided this
information to the Commission under separate cover. In particular, Planet Labs has provided an electronic
file with this information to the Satellite Engineering Branch of the Satellite Division of the
Commission’s International Bureau. Planet Labs has acknowledged that it is responsible for any and all
cost recovery fees associated with filings for the proposed system under ITU Council Decision 482
(modified 2008), as it may be modified or succeeded in the future.

In sum, Planet Labs respectfully requests the Commission to grant the application for launch and
operation authority as detailed herein. To the extent necessary, Planet Labs requests expedited

32
See 47 C.F.R. § 25.217.
33
See Space Imaging, 20 FCC Rcd at 11973; DigitalGlobe, 20 FCC Rcd at 15701-02 (2005). See also Stamp Grant,
Skybox Imaging, Inc., SAT-LOA-20120322-00058 (granted September 20, 2012).

8

consideration of this Application in order to ensure favorable Commission action in advance of the first
launch as early as January 2016.

9

ATTACHMENT A
Planet Labs, Inc.
FCC Form 312, Exhibit 43
July 2015

NOTIFICATION OF COMMENCEMENT OF SPACE STATION CONSTRUCTION

Planet Labs Inc. (“Planet Labs”), pursuant to Section 25.113(f) of the Commission’s rules, 47 C.F.R. §
25.113(f), hereby notifies the Commission that it has commenced construction, at its own risk, of the non-
geostationary orbit (“NGSO”) satellites it proposes to launch and operate in the Application to which this
statement is attached.34 Planet Labs intends to add these satellites to its licensed NGSO Earth Exploration-
Satellite Service system.

34
See 47 C.F.R. § 25.164 (b)(3).

1

ATTACHMENT B
Planet Labs, Inc.
FCC Form 312, Exhibit 43
September 2014

LINK BUDGETS
The proposed satellites will operate in a similar altitude band as Flock 1, and thus will have similar link
characteristics as the originally licensed system. The maximum operational altitude of 720 km results in
an increase in the path loss attenuation of up to 4.9 dB compared to Flock 1. This increase in path loss
attenuation is well within the system link margins, as the satellites were designed for a wide range of
operational altitudes. Considering all other link characteristics are identical, the link budgets are not
repeated in this application.35

35
See File No. SAT-LOA-20130626-00087 (granted 12/03/13, Call Sign S2912).

1

Attachment C
Planet Labs Inc.
FCC Form 312, Exhibit 43
September 2014

PREDICTED GAIN CONTOURS
The following figures represent gain contours that have not been submitted in past filings. The gain
contours are shown for the maximum and minimum operational altitudes for each respective frequency
band.

2

IV. TECHNICAL CERTIFICATE
I, Michael Safyan, hereby certify, under penalty of perjury, that I am the technically qualified person
responsible for the preparation of the engineering information contained in the technical portions of the
foregoing application and the related attachments, that I am familiar with Part 25 of the Commission’s
rules, and that the technical information is complete and accurate to the best of my knowledge and belief.

/s/ Michael Safyan
Michael Safyan
Director of Launch and Regulatory
Planet Labs Inc.
Dated: July 29, 2015

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Document Created: 1670-04-10 00:00:00
Document Modified: 1670-04-10 00:00:00

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