Attachment Planet Labs - Commis

Planet Labs - Commis

REQUEST submitted by IB,FCC

Commission Request For Additional Information

2015-11-13

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

IBFS_SATMOD2015080200053_1115353

                                 Federal Communications Commission
                                         Washington, D.C. 20554


                                              November 13, 2015




Mr. Michael Safyan
Director of Launch and Regulatory
Planet Labs Inc.
346 9°" St.
San Francisco, CA 94103

                  Re:       Planet Labs Inc. Application for Modification of NGSO
                            Authorization to Launch and Operate Earth Imagery Satellite Systems
                            IBFS File No. SAT—MOD—20150802—00053, Call Sign $2912

Dear Mr. Safyan:

        On August 2, 2015, Planet Labs Inc. (Planet Labs) filed an application to modify its license for a
non—geostationary orbit Earth Exploration Satellite Service constellation by requesting authority to launch
up to 600 satellites, with up to 200 satellites simultaneously operating at any given time.‘ The request
seeks to deploy and operate satellites in orbits ranging from 350 km up to 720 km, with the majority of
satellites being launched to a circular orbit at 475—km altitude." The application includes a plan to
mitigate the creation and effects of orbital debris. To evaluate whether the proposed the orbital debris
mitigation plan is in the public interest, we ask Planet Labs to provide supplemental information.*

    Specifically, we ask Planet Labs to provide information regarding the aggregate risk of accidental
collision with catalogued space objects from the proposed satellite constellation, both during operations
and disposal. In particular, please provide a worst case scenario for the risk of accidental collisions, for
example assuming all satellites are deployed in the longest—lived orbit, as well as any alternative scenarios
that model anticipated realistic deployment patterns. Please also address whether variations in the solar
cycle — particularly the possibility of lower than average sunspot activity in cycle 25 — would have any
impact on the orbital lifetimes of the proposed constellation or on the aggregate risk of accidental
collisions identified above.




\ See Application, Exhibit 43 at 1.
 Id. at 1—3. The application states that the proposed space segment will be comprised of up to 200 simultaneously
operating satellites with a minimum circular altitude of 350 km and a maximum circular altitude of 660 km. The
application also proposes elliptical orbits, with a maximum apogee of 720 km. Id. at 3.
347 C.FR. § 25.111(a)


                                       Federal Communications Commission




    We ask that Planet Labs provide this requested information by December 11, 2015, in order to
continue the consideration of Planet Lab‘s application.*

                                                 Sincerely,

                                             TEsL AUDMLW ie
                                                ~JFose P. Albuquerqu
                                                 Chief, Satellite Division
                                                 International Bureau




447 CFR. § 25.112(c).



Document Created: 2015-11-13 15:50:18
Document Modified: 2015-11-13 15:50:18

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