Planet Labs - ORBCOMM Agreement AGREEMENT by ORBCOMM License Corp. SAT-MOD-20150802-00053 Planet Labs-ORBCOMM

Planet Labs-ORBCOMM

AGREEMENT submitted by ORBCOMM License Corp.

Planet Labs - ORBCOMM Agreement

2016-09-14

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

IBFS_SATMOD2015080200053_1149478

September 14, 2016

Via Electronic Filing (IBFS)

Jose Albuquerque, Chief
Satellite Division, International Bureau
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Re: Modification Application of Planet Labs Inc.
File No. SAT-MOD-20150802-00053

Dear Mr. Albuquerque:

We are pleased to inform you that, in connection with the above-referenced application of Planet
Labs Inc. (“Planet”) to modify its satellite authorization (the “Planet Application”), ORBCOMM
License Corp. (“ORBCOMM”) and Planet have reached agreement (the “Agreement”)
concerning measures they will undertake to mitigate the risk of in-orbit collisions between the
Planet satellite system (FCC Call Sign S2912) and the ORBCOMM satellite system (FCC Call
Sign S2103) and to minimize the effect on operations of their respective satellite systems with
regards to any related conjunction alerts, as detailed in this letter.

Specifically, pursuant to the Agreement, Planet shall not launch or operate any satellite in an
orbit1 that intersects with the FCC-authorized 715 km target orbital altitude of the ORBCOMM
Generation 2 (“OG2”) satellites2 during the remaining term of Planet’s satellite authorization,
except for the fifty-six (56) Planet satellites (“Flock 2c”) manifested on the Spaceflight, Inc.
SHERPA secondary payload mission for deployment into a 450 x 720 km 98 degree inclined
elliptical orbit on the SpaceX Falcon 9 Formosat-5 launch. By a separate submission to be filed
with the Commission concurrently with the submission of this executed Agreement,
ORBCOMM is withdrawing its Petition to Dismiss, Deny, or Hold in Abeyance the Planet
Application, thereby removing its objection to the grant of the Planet Application.3

Additionally, pursuant to the Agreement, Planet and ORBCOMM shall use reasonable best
efforts to designate respective contact representatives and contact procedures to provide each
other GPS-derived spacecraft position data4 no later than 4 hours after the issuance of a
conjunction alert from the Joint Space Operations Center (“JSpOC”), the Space Data Association
(“SDA”), or any other duly recognized conjunction reporting entity involving any OG2 satellite

1
The maximum circular altitude requested in the Planet Application is 660 km. See Exhibit 43, Planet
Application, File No. SAT-MOD-20150802-00053, at 3 (filed August 2, 2015).
2
See, Application of ORBCOMM License Corp., File No. SAT-AMD-20140116-00006 (granted March
26, 2014).
3
See, ORBCOMM License Corp. Petition to Dismiss, Deny or Hold in Abeyance, File No. SAT-MOD-
20150802-00053 (filed Jan. 19, 2016).
4
The Planet Flock 2c satellites shall have onboard GPS with position determination accuracy of less than
20 meters.

Jose Albuquerque, Chief
Satellite Division, International Bureau
Federal Communications Commission
September 14, 2016
Page 2 of 3

and Flock 2c satellite to minimize the occurrence of “false positive” conjunction alerts, and to
maximize the effectiveness of any collision avoidance maneuvers that may need be performed.5
In the event that a conjunction alert occurs, the parties shall use their reasonable best efforts to
acquire and exchange GPS-derived position data for the involved spacecraft, which efforts shall
include any necessary interruption or alteration of spacecraft operation to prioritize the collection
and dissemination of GPS-derived spacecraft position data. Further, Planet and ORBCOMM
agree that Planet shall provide Spaceflight, Inc. and SpaceX a copy of this Agreement and
Planet’s FCC authorization relating to the launch and operation of the Flock 2c satellites. The
parties agree that the terms of the Agreement may be amended, but only by written mutual
agreement of the parties.

Planet and ORBCOMM therefore request the Commission to adopt the following text as license
conditions to the grant of the Planet Application:

• Planet and ORBCOMM have entered into an agreement concerning measures they will
undertake to mitigate the risk of in-orbit collisions between the Planet satellite system
(FCC Call Sign S2912) and the ORBCOMM satellite system (FCC Call Sign S2103) and
to minimize the effect on operations of their respective satellite systems with regards to
any related conjunction alerts. The launch and operation of the Flock 2c satellites in a
manner consistent with that agreement, as may be amended by mutual written agreement
of the parties from time to time, is a condition of the Commission’s grant of authorization
for the Flock 2c satellites.

• During the remaining term of this license, Planet is not authorized to launch or operate
any satellite in an orbit that intersects with the 715 km orbital altitude, except for the
fifty-six (56) Planet Flock 2c satellites manifested on the Spaceflight, Inc. SHERPA
secondary payload mission for deployment into a 450 x 720 km 98 degree inclined
elliptical orbit on the SpaceX Falcon 9 Formosat-5 launch.

• All Planet Flock 2c satellites shall have onboard GPS with position determination
accuracy of less than 20 meters.

5
A conjunction alert shall trigger the position data collection and exchange requirements set forth in this
Agreement if the resulting probability of collision exceeds 1:10,000 (calculated using Alfano’s method). In that
event, the parties shall collect and exchange GPS samples until the Probability of Collision (PoC) is reduced below
this threshold, or the time of closest approach has passed, and each party will exchange the most recent ephemerides
based on GPS-derived position estimates with each other via the SDA, or by an alternative mutually agreed method
of direct correspondence.

Document Created: 2016-09-14 18:28:50
Document Modified: 2016-09-14 18:28:50

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