Before the FEDERAL COMMUNICATIONS COMMISSION Washington, DC 20554

In the Matter of ) ) Mitigation of Orbital Debris in the New Space ) IB Docket No. 18-313 Age )

REPLY COMMENTS OF PLANET LABS INC.

Planet Labs Inc. (“Planet”)1 files these reply comments urging the Federal

Communications Commission (“FCC” or “Commission”) not to adopt a maneuverability requirement applicable to all satellite systems.2 The comments overwhelmingly support the rejection of a blanket, mandatory maneuverability requirement for all satellites operating above

400 km.3 The 400 km to 600 km region of low-Earth orbit (“LEO”) is an incredibly important

1 Planet is an integrated aerospace and data analytics company that operates a constellation of satellites that image the entire Earth daily to make global change visible, accessible, and actionable. Founded in 2010, Planet designs, builds, and operates small satellites, as well as online platforms that serve data to users, helping decision-makers solve our world’s toughest challenges and entrepreneurs build new businesses. Planet is headquartered in , California. For more information, visit https://www.planet.com/. 2 See generally Mitigation of Orbital Debris in the New Space Age, Further Notice of Proposed Rulemaking et al., 35 FCC Rcd 4156 (2020). In a previously filed white paper, Planet and others explained why a maneuverability requirement, if adopted, should not apply to certain systems. See Comments of Commercial Smallsat Spectrum Management Association, IB Docket No. 18-313, at Attachment (filed Oct. 9, 2020) (“CSSMA Comments”); Letter from Mike Safyan, Vice President, Launch, Planet, to Marlene H. Dortch, Secretary, FCC, IB Docket No. 18-313 (filed July 29, 2020) (“Planet July 29 Letter”). That paper is attached to this filing for the Commission’s convenience. 3 See Comments of Academic Small Satellite Researchers, IB Docket No. 18-313, at 5-14 (filed Oct. 9, 2020) (“Smallsat Researchers Comments”); Comments of Aerospace Corporation, IB Docket No. 18-313, at 10-13 (filed Oct. 8, 2020) (“Aerospace Corp. Comments”); Letter from Michael J. French, Vice President, Space Systems, Aerospace Industries Association, to Marlene H. Dortch, Secretary, FCC, IB Docket No. 18-313, at 1 (filed Oct. 9, 2020); Comments of Blue Canyon Technologies Inc., IB Docket No. 18-313, at 1-3 (filed Oct. 9, 2020) (“Blue Canyon Comments”); Comments of The Boeing Company, IB Docket No. 18-313, at 14 (filed Oct. 9, 2020); Comments of Commercial Spaceflight Federation, IB Docket No. 18-313, at 2-4 (filed Oct. 9, 2020); CSSMA Comments at 9-13; Comments of Eutelsat, IB Docket No. 18-313, at 6-7 (filed Oct. 9, 2020); Letter from Tony DeTora, VP, Government Affairs, Lynk Global, Inc., to component of the new space industry, and especially small satellites, that is driving innovation and competition in the provision of diverse satellite missions. Indeed, in 2019, start-up space companies received investments totaling $5.7 billion—approximately 61% more than the $3.5 billion in investments received in 2018.4 Analysts report that on average twenty-nine new companies secured financing each of the past five years and that the satellite industry generated global revenues of $271 billion in 2019.5 Much of this innovation and industry growth would be jeopardized by the proposed prescriptive satellite maneuverability requirement, which strikes an unacceptable and unnecessary blow to education, research, innovation, and competitiveness in the U.S. space industry, especially for small satellites, as numerous commenters have explained.6

A tailored maneuverability requirement, instead of the proposed blanket requirement, would facilitate space safety while still allowing for the advancement of the commercial space industry. Planet’s proposal requires non-geostationary orbit (“NGSO”) systems operating above

600 km altitude and “Large NGSO Systems” — i.e., those systems with a total fleet mass greater

Marlene H. Dortch, Secretary, FCC, IB Docket No. 18-313, at 2, 4-5 (filed Oct. 9, 2020); Letter from Janek Kaucz, Spectrum and Regulatory Specialist, Myriota Pty. Ltd., to Marlene H. Dortch, Secretary, FCC, IB Docket No. 18-313, at 2-6 (filed Oct. 9, 2020) (“Myriota Letter”); Comments of PicoSat and Nanosatellite Developers Group, IB Docket No. 18-313, at 1-2 (dated Oct. 9, 2020); Comments of ARRL, the National Association for Amateur Radio, IB Docket No. 18- 313, at 4 (filed Oct. 9, 2020) (“ARRL Comments”); Comments of Radio Amateur Satellite Corporation, IB Docket No. 18-313, at 3-4 (filed Oct. 9, 2020) (“AMSAT Comments”). 4 See Start-Up Space Update on Investment in Commercial Space Ventures, Bryce and Space Technology, at 20 (2020), https://bit.ly/3kAmDZU (“Start-Up Space Report”); see also Aaron Gregg, Defense giants bet big on small satellites, Washington Post (Sept. 16, 2018), https://wapo.st/31N0b8q (observing that space industry veterans Boeing, Raytheon, and Lockheed Martin have capitalized various small satellite ventures). 5 See Start-Up Space Report at 3 (clarifying also that the average excludes new firms yet to obtain financing); SIA State of the Satellite Industry Report, Bryce Space and Technology (June 2020), https://bit.ly/2J3yCBl. 6 See, e.g., Boeing Comments at 4-5, 13; CSSMA Comments at 9; Smallsat Researchers Comments at 9-11; Myriota Letter at 2, 4; AMSAT Comments at 3. 2 than 1,800 kg — operating in altitudes between 400 km to 600 km to have maneuvering capabilities.7 This proposal recognizes that “smaller” systems without propulsion and with less mass create less risk than other types of NGSO systems. It is agnostic to mission type and eliminates the need for the Commission to specifically exempt amateur, academic, research, or experimental small satellites from any maneuverability requirement.8

Indeed, the groundwork for a more reasonable small satellite exemption appears in the

Smallsat Order adopted by the Commission just last year.9 In that decision, the Commission established streamlined rules for small satellite systems, basing eligibility on neutral factors such as satellite mass, surface area, fleet size, the potential consequences of a collision, and other criteria that serve as a proxy for risk posed by the system.10 Specifically, a system qualifies for the “small satellite” licensing process, among other things, if each satellite weighs no more than

180 kg and there are no more than ten satellites in the system.11 Additionally, if the system will operate over 600 km, then it must possess maneuvering capability.12

Planet’s proposal tracks this Commission model. Following the logic of the Smallsat

Order, only satellite systems operating above 600 km and Large NGSO Systems operating in the

400 km to 600 km range should be required to have maneuvering capability, as a result of the

7 See Planet July 29 Letter. 8 See, e.g., Smallsat Researchers Comments at 13-14; ARRL Comments at 4; AMSAT Comments at 3-4. 9 See Streamlining Licensing Procedures for Small Satellites, Report and Order, 34 FCC Rcd 13077 (2019). 10 See id. ¶ 19 and Appendix A; see also 47 C.F.R. § 25.122. 11 See Smallsat Order ¶¶ 19, 49. 12 See id. ¶ 42. 3 potential risk they pose.13 Other commenters support this proposal.14 In particular, Planet notes that very small satellites (e.g., 6U and 3U ) have the most difficulty incorporating meaningful propulsion systems in their volume and power constrained form factors but simultaneously pose lower environmental risk by the nature of their small size and selection of orbits below 600 km. The market for effective and reliable propulsion systems for 6U and 3U cubesats remains nascent and limited. Further, as noted by Aerospace Corp.,15 there are many scenarios where a activating a propulsion system could increase the risk of collision given the inexperience of some operators and the uncertainty of how some systems might behave.

Many of the parties that support adoption of a blanket or overly prescriptive maneuverability requirement are flawed or misguided, believing that maneuverability is the primary or only factor that mitigates potential orbital debris. For example, Maxar suggests

“operator[s] should be able to affect a 500 meter radial offset relative to a secondary space object at the time of close approach, as late as four hours prior to the upcoming time of close approach.”16 However, Maxar makes no justification as to why collision avoidance should be limited to solely radial maneuvers. While it is true that positional uncertainties in the radial

13 See Planet July 29 Letter. Any maneuverability requirement, if adopted, will succeed only if space situational awareness and modeling capabilities improve. Better atmospheric models and a constantly refreshed open architecture data repository of active and derelict debris will be necessary to predict positional uncertainties and assess collision avoidance possibilities. Operators must also share ephemeris data and maintain ongoing coordination of physical operations with NGSO operators deployed at similar altitudes. 14 See, e.g., Blue Canyon Comments at 2; CSSMA Comments at 11-12; Comments of , Inc., IB Docket No. 18-313, at 5-12 (filed Oct. 9, 2019) (“Spire Comments”). 15 See Aerospace Corp. Comments at 10. 16 Comments of Maxar Technologies Inc., IB Docket No. 18-313, at 5 (filed Oct. 9, 2020) (internal quotations omitted). 4 direction can be much smaller than in the along-track direction, it is wholly untrue that “a radial position offset is necessary to avoid collision with certainty.”17 Operators should be able to conduct collision avoidance maneuvers in whichever direction would result in the safest outcome.

As another example, one commenter suggests that only propulsion-based spacecraft could successfully maneuver during an emergency, particularly at 400 km.18 In support, the commenter poses a hypothetical scenario of a satellite at 400 km making a propulsive maneuver over 24 hours to add “hundreds of meters of separation between two objects.” 19 But this example fails to account for variables such as positional uncertainties of the objects at the time of closest approach, which may be much larger than “hundreds of meters” when predicted 24 hours out (especially in the along-track direction).20 Using differential drag, a 3U cubesat with fold-out solar arrays operating at 400 km could just as easily create hundreds of meters of separation between itself and another object within 24 hours. But the more fundamental issue at stake is the positional uncertainties of those two objects. Those uncertainties can sometimes be as high as several kilometers when predicted that far in advance, which would make a maneuver of hundreds of meters nonsensical. Rather than greater propulsive capability, space operators need better atmospheric models and space situational data to reduce those positional uncertainties,

17 Id. 18 See Comments of Accion Systems, Inc., IB Docket No. 18-313, at 2-3 (filed Aug. 31, 2020). 19 Id. at 3. 20 Although certain more powerful propulsion systems could create a larger miss distance in this timeframe, simply adding a propulsion system may not actually achieve sufficient collision avoidance if the predicted positional uncertainties are too high and the propulsion system too weak. 5 weed out “false positive” conjunction alerts, and minimize the maneuver distances required in the event of potential collisions.

The 2009 Iridium-Kosmos collision is a perfect example of how, even if a satellite does have a propulsion system and can conduct collision avoidance, operator error and bad space tracking data can still result in a catastrophic collision.21 The example further illustrates that debris mitigation responsibilities should be proportional to the consequences of a collision and that Large NGSO Systems, which create greater risk, should shoulder a greater burden of collision avoidance. The sources of additional risk are not evenly distributed among satellite operators, as some commenters would suggest,22 and the Commission’s rules should recognize that.

The goal of space safety in LEO can be achieved through a variety of means, including selecting a safer satellite system design and orbit combination to minimize the probability of collision, limiting the post-mission disposal timeline to five (5) years, openly publishing refined satellite ephemeris data and planned maneuvers for other operators to evaluate, and improving ground- and space-based space object tracking capabilities. The Commission could also rely on a multi-factor test—considering both the probability and consequences of a collision—to better quantify risk and reduce on-orbit collision concerns.

ARCLab, Astroscale, and Kuiper, for example, urge the Commission to focus on evaluating the probability of collision and risk posed by systems rather than imposing specific

21 See Brian Weeden, 2009 Iridium-Cosmos Collision Fact Sheet, Secure World Foundation (Nov. 10, 2010), https://bit.ly/3dP31i1. 22 See, e.g., Further Comments of Space Exploration Technologies Corp., IB Docket No. 18-313, at 13 (filed Oct. 9, 2020). 6 maneuverability requirements.23 If structured correctly, a probability of collision risk approach

(coupled with other improvements in space safety) could avoid the harmful and undue burden that a blanket maneuverability requirement would impose on small satellite systems.

In the event that the Commission does choose to impose a maneuverability requirement, the Commission should allow licensees sufficient time to meet that requirement. Planet requests that the Commission grant an existing licensee with satellites already in orbit a grandfathering period until the expiration of its current satellite license term or five (5) years from the date of the final order, whichever is longer, to implement the maneuverability requirement. A licensee that has not yet deployed any satellites should have a period of five (5) years from the date of the final order before having to implement the maneuverability requirement.24 The proposed grandfather periods provide a reasonable amount of time for licensees to redesign and modify their current systems and allow for a smoother business transition in response to significant regulatory change.25 Indeed, in analogous situations where the Commission has required

23 See Comments of Astrodynamics, Space Robotics, and Controls Laboratory and Space Enabled Research Group, IB Docket No. 18-313, at 3-7, 14-15 (filed Oct. 8, 2020) (suggesting the FCC replace “single-factor rules, thresholds, and bright-line distinctions” for collision risk and maneuverability with a “quantitative index that better captures the significant, complex, and non-linear relationships between factors of a particular mission”); Comments of Astroscale U.S. Inc., IB Docket No. 18-313, at 18 (filed Oct. 9, 2020) (capping the aggregate probability of collision of a system to 1/1000 eliminates the need for a maneuverability requirement for spacecraft below 600 km); Comments of Kuiper Systems LLC, IB Docket No. 18-313, at 6 (filed Oct. 9, 2020) (urging adoption of a “universal lifetime collision standard for collisions with large objects on a per-satellite basis to all satellites” instead of a blanket maneuverability requirement). 24 See Letter from Mike Safyan, Vice President, Launch, Planet, to Marlene H. Dortch, Secretary, FCC, IB Docket No. 18-313, at 1 (filed Apr. 16, 2020) (“Planet Apr. 16 Letter”); Spire Comments at 12. 25 See Planet Apr. 16 Letter at 9 (“Planet would need to immediately: [r]edirect substantial resources from current and near-term projects to R&D[; r]edesign . . . the satellite (and deployers) to fit propulsion: design work, prototyping, test facility, upgrades, and ongoing safety and operations expenses[; and a]bsorb significant increase in mass & launch costs.”). 7 licensees to modify their operations as a result of a change in the rules, the Commission has allowed those operators several years to transition in order to minimize disruption to existing services, enabled full amortization of the licensee’s equipment costs, and facilitated a stable investment environment for operators.26 The Commission should adhere to those long-standing principles here, as well.

* * *

For the reasons stated above, Planet requests that the Commission not adopt a blanket maneuverability requirement for all satellite systems operating above 400 km. Consistent with the Smallsat Order, any maneuverability requirement should apply only to NGSO systems operating above 600 km or to Large NGSO Systems operating in the 400 km to 600 km orbital altitude range. A more flexible maneuverability rule takes into consideration differences in the

26 See, e.g., Amendment to the Commission's Rules Regarding a Plan for Sharing the Costs of Microwave Relocation, First Report and Order and Further Notice of Proposed Rule Making, 11 FCC Rcd 8825, 8860 ¶ 67 (1996) (establishing a ten-year sunset period in the transition of the 2 GHz band from existing fixed microwave services to broadband Personal Communications Services to allow incumbent fixed service licensees to amortize the full costs of their purchased equipment); Amendment of Part 2 of the Commission’s Rules to Allocate Spectrum Below 3 GHz for Mobile and Fixed Services to Support the Introduction of New Advanced Wireless Services, including Third Generation Wireless Systems; Service Rules for Advanced Wireless Services in the 1.7 GHz and 2.1 GHz Bands, Ninth Report and Order, 21 FCC Rcd 4473, 4497-98 ¶ 44 (2006) (establishing a fifteen-year sunset period in the transition of spectrum bands from Broadband Radio Service and Fixed Microwave Service to Advanced Wireless Service and Mobile Satellite Service); Redevelopment of Spectrum to Encourage Innovation in the Use of New Telecommunications Technologies, First Report and Order and Third Notice of Proposed Rule Making, 7 FCC Rcd 6886, 6891 ¶ 27 (1992), clarified by, Third Report and Order, 8 FCC Rcd 6589 (1993), modified on reconsideration, Memorandum Report and Order, 9 FCC Rcd 1943 (1994) (“The transition period should . . . provide for the relocation of the incumbents without undue disruption of services.”); Redesignation of the 17.7-19.7 GHz Frequency Band, Blanket Licensing of Satellite Earth Stations in the 17.7-20.2 GHz and 27.5-30.0 GHz Frequency Bands, and the Allocation of Additional Spectrum in the 17.3-17.8 GHz and 24.75-25.25 GHz Frequency Bands for Broadcast Satellite-Service Use, Report and Order, 15 FCC Rcd 13430 ¶ 71 (2000) (“We believe that it is contrary to the public interest and not conducive to a stable investment environment to make terrestrial fixed operators, who currently serve the public, pay for relocation costs after . . . a short [three-year to five-year] period of time.”). 8 orbital debris risk associated with systems with less total mass and lower consequences of collision.

Respectfully submitted,

/s/ Mike Safyan

Mike Safyan Vice President, Launch PLANET LABS INC. 645 Harrison Street 4th Floor San Francisco, CA 94107

November 9, 2020

9

ATTACHMENT

DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

July 24, 2020

Maneuverability Considerations for Satellites Operating in Low Earth Orbit

Authors: Mike Safyan, VP of Launch, Planet Labs Inc. Vivek Vittaldev, Lead Orbits R&D, Planet Labs Inc. Michelle McClure, Regulatory and Legislative Affairs Counsel, Spire Global Tony DeTora, VP of Government Affairs, Lynk

Summary and Introduction In this paper, the authors recommend that the FCC not adopt any specific maneuverability requirement. Nonetheless, to the extent the FCC elects to do so, the threshold for such a requirement should be consistent with the criteria adopted in the FCC’s 2020 Streamlining Licensing Procedures for Small Satellites (“Streamlining Procedures”). Specifically, if the FCC were to adopt a maneuverability requirement, it should do so only for: (i) non-geostationary satellite orbit (“NGSO”) systems, which operate at altitudes above 600 km; or (ii) NGSO systems, which have an aggregate satellite system mass over 1,800 kg and operate at altitudes over 400 km (i.e., “large” NGSO systems). See Table 1 below. For a satellite system subject to the maneuverability requirement, we propose a minimum maneuverability threshold equal to the predicted positional uncertainty forecasted with a 3-standard deviation confidence for the period of time at which it would be necessary for an operator to initiate a maneuver relative to the Time of Closest Approach (TCA).

The topic of satellite propulsion, and more generally satellite maneuverability, has been raised in several rounds of public comment regarding orbital debris mitigation for NGSO systems. Prescribing a specific type of technology that satellite operators are forced to utilize, e.g. propulsion systems, is out of sync with general U.S. regulatory practice. That alone is sufficient to dismiss such a requirement outright, in addition to several other reasons discussed in this paper, but a more generalized requirement for maneuverability could be considered under certain conditions. Due to the wide variety of satellite operators and satellite mission types that

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currently operate in Low Earth Orbit (LEO) and plan to do so in the future, a one-size-fits-all approach will not be sufficient. In keeping with the approach taken in the Streamlining Procedures, satellite fleet size, aggregate mass, and operating orbit must be taken into account.

We propose the following tiered approach for maneuverability requirements for all NGSO systems:

Maneuverability Requirement

System Characteristics Below 400 km 400 - 600 km Above 600 km

Total mass of the system is no more than 1,800 kg None None Yes

Total mass of the system is greater than 1,800 kg None Yes

Propulsion Systems are Not a Panacea When it comes to the construction of a satellite system, the FCC’s requirements have never been prescriptive, but rather define a capability or performance threshold that must be met. This gives the satellite manufacturer the flexibility to meet the criteria in a way that makes sense for that particular mission. For instance, the FCC does not mandate what type of antenna or amplifier technology a satellite operator must use, but rather operators are free to choose whatever technology suits their mission as long as they can demonstrate that their system meets the relevant requirements (e.g. power flux density thresholds, etc.). For this same reason, the FCC should not require operators to include propulsion systems on their satellites.

For one, there are several ways to alter a satellite’s orbital position in addition to propulsion, including solar sails, differential drag, electrodynamic tethers, and even ground based systems.1 In addition, not all propulsion systems are capable of the same performance. A propulsion system that fires once and can only produce a few Newtons of thrust would “check the box” of a

1 Although not common practice at the time of writing, ground-based lasers for orbital collision avoidance has been studied by various research groups. As an example, see NASA’s LightForce Photon-Pressure Collision Avoidance (Stupl, 2015) https://ntrs.nasa.gov/archive/nasa/casi.ntrs.nasa.gov/20150000244.pdf

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propulsion requirement, but would certainly not meet the intention behind a collision avoidance capability that is sufficient and reliable under a variety of conditions. For all these reasons, a technology-agnostic maneuverability requirement must be employed.

Considerations for Small Systems The Streamlining Procedures already took into consideration many of these issues with respect to “small” NGSO systems in low orbits and any further orders must maintain consistency with those original conclusions. The Streamlining Procedures adopted rules that allow streamlined processing for systems with up-to 10 satellites, a mass of each individual satellite less than 180 kg, an orbital lifetime of maximum 6 years, and an operational altitude below 600km without any special requirement for maneuverability. Such streamlined treatment relies on the understanding that even if there were to be a collision involving a “small” NGSO system, a) the severity of that collision and the number of debris objects generated would be relatively low given the small size of the satellite(s), and b) the orbital lifetime of the debris fragments would also be relatively low since the satellite(s) were operating below 600 km, which is essentially the “self-cleaning” portion of orbit due to the force of atmospheric drag.2 It follows logically that the considerations with respect to number of satellites and satellite mass should be considered here.

It is also important to note that below a certain satellite size threshold, it would be impractical to adopt a meaningful propulsion system while maintaining the advantages that are unique to small satellites. For example, most satellites that adopt the 3U cubesat form factor or smaller do not have mass, volume, or power capacity to incorporate a meaningful propulsion system in addition to the main payload and the essentials of a satellite bus. Requiring a meaningful propulsion system would force satellite manufacturers to increase the size of the satellite, resulting in significant increases in material and launch costs. The additional design, testing, manufacturing, and operations costs would also be significant. Such a misguided propulsion requirement would essentially regulate a huge portion of small sats out of existence and put the U.S. industry at an extreme disadvantage.

2 Daniel Faber and Arthur Overlack. “Nanosatellite Deorbit Monitor.” 27th Annual AIAA/USU Conference on Small Satellites (2013). https://digitalcommons.usu.edu/cgi/viewcontent.cgi?article=2916&context=smallsat

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General NGSO Threshold for Maneuverability The altitude threshold for a maneuverability requirement should be above 600 km, and this bears out from operational experience. For example, Planet has launched and operated over 300 Flock satellites in the orbital regime below 600 km since 2013 with no collisions to date. Spire has also launched over 100 Lemur satellites in a similar timeframe, also with no known collisions to date. Although both operators receive many notifications of predicted conjunctions, the predictions are based on very conservative assumptions and most are such low probability that no action is needed or taken.3 As an example, in 2019 Planet received a total of 78,443 Conjunction Data Messages (CDMs) from the 18th Space Control Squadron (SPCS) between a Flock satellite as the primary object and a non-Planet operated object as the secondary. Of that total, only 2,284 (2.9%) were above the “considerable risk” threshold of 1E-05 (one in one hundred thousand), and none of which resulted in an actual collision. In most cases, Planet did not need to take any action as the probability of collision decreased over time as trajectory predictions for one or both of the objects were refined with more observations.4 In a minority of cases, Planet would rotate its satellite to present the minimum surface area towards the potential collision in order to further reduce the probability of collision. Similarly, Spire has historically received conjunction notices above an actionable threshold of 1E-04 (one in ten thousand) approximately twice per week. When these notices are received, Spire coordinates with the other party (if an active satellite) to share ephemeris data. Data sharing between parties refines the conjunction analysis and allows the other party, if capable of maneuvering, to take evasive actions, and no cases resulted in an actual collision.

While Planet and Spire’s operational experiences are statistically relevant based on what the orbital environment below 600 km has been like to-date, it’s well known that a number of Large NGSOs, including “megaconstellations” with thousands of planned satellites, have either already begun operations at altitudes below 600 km, or have plans to do so. These systems are fundamentally changing the sub-600 km orbital regime and are addressed in the next section.

3 Probability of Collision in the Join Operations Center (2016) https://www.space- track.org/documents/How_the_JSpOC_Calculates_Probability_of_Collision.pdf 4 Planet makes all of its updated satellite ephemeris data publicly available at https://ephemerides.planet- labs.com/

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Considerations for Large NGSO For Large NGSO systems, e.g. SpaceX’s or Amazon’s Kuiper, we believe that maneuverability should be a requirement for any orbit above 400 km. As of yet, there has been no widely agreed on definition of what constitutes a Large NGSO. We propose to follow the logic of the Streamlining Procedures and recommend the following definition:

A Large NGSO system is a satellite fleet whose total free-flying mass at any given time, including any non-operational satellites remaining in orbit, is above 1,800 kg.5

For example, a system of 20 on-orbit 1U cubesats with a mass of 1 kg each would have a total fleet mass of 20 kg and thus would not require maneuverability if operating below 600 km. On the other hand, a fleet of 5 satellites at 500 kg each or a fleet of 500 satellite at 300 kg each would require maneuverability if operating anywhere above 400 km. In line with the logic followed in the Streamlining Procedures, such a delineation addresses the difference in severity of collisions between different types of systems, i.e. the severity of impact with a 1 kg cubesat is much lower than with a 500 kg satellite, both in terms of number of debris fragments likely to be generated, and the orbital lifetime of those fragments. Given that Large NGSO systems as defined have such outsized impacts on whatever orbital regime they operate in, it only follows that they should be held to a higher standard of operation.

Proposed Threshold for Maneuverability If the exact size, shape and position of every object in orbit could be precisely known, and the trajectory could be perfectly forecasted several days into the future, then all potential collisions could be identified with very high confidence and a maneuver of tens of meters by one of the objects would be sufficient to avoid any collision in almost all cases. In practice, each object has some degree of positional uncertainty and prediction uncertainty, thus forcing satellite operators to take a probabilistic approach in assessing conjunctions; an approach that is heavily influenced by the degree of positional and predictive uncertainties.

Currently, publicly available TLEs provided by the 18th SPCS via the Space-Track space catalogue can range from hundreds of meters to several kilometers. However, satellite operators often have much better positional estimates of their satellites using a number of

5 1,800 kg comes from multiplying 10 (satellites) by 180 (kilograms).

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refining techniques, including radio ranging, on-board GPS, or supplemental tracking measurements from third party sources. As an example, Planet’s SkySat satellites maintain a positional uncertainty of approximately 100 meters by continuously running onboard GPS, and Planet’s Flock satellites maintain a positional uncertainty of 100 to 300 meters when running periodic onboard GPS measurements and radio ranging, a clear improvement over the worst- case scenarios from the space catalogue TLEs. Furthermore, the positional uncertainty of any on-orbit object, functional or otherwise, can be reduced to the low 100s of meters by activating additional observations by the 18th SPCS, or utilizing supplemental tracking data from a commercial service provider such as LeoLabs.6

Prediction uncertainty, another major factor of calculating probability of collision, depends on a variety of variables including satellite ballistic coefficient, orbital altitude, and solar activity. Very large satellites at high altitudes are less susceptible to perturbing forces, such as fluctuations in atmospheric drag, compared to small satellites at lower altitudes. For example, ICESat, with a mass of 970 kg and operating at approximately 595 km, was shown to have 3 to 4 day prediction uncertainties of approximately 300 meters under 2003 solar conditions (modest solar flux).7 On the other hand, Planet Flock-series satellites that are 3U cubesats with mass of approximately 5 kg and operate close to 500 km altitude, were shown to have a 3-standard deviation (or 3-sigma) 48 hour prediction uncertainty of approximately 5 km under 2017 solar conditions (modest solar flux) and 2.7 km under 2019 solar conditions (low solar flux). These are only point examples, and predictive uncertainty is even higher under maximum solar flux conditions, however it should be noted that the effectiveness of differential drag also increases under high solar activity conditions, which is not true of systems solely relying on traditional propulsion. Regardless, each satellite system will have different predictive uncertainties under different conditions, and a one-size-fits-all approach for defining predictive uncertainty does not make sense.

Taking the above into account, it follows that if a satellite has the ability to maneuver farther out than its predictive uncertainty in the relevant time period, it should be able to successfully mitigate most conjunction scenarios. Thus, for a satellite system subject to the

6 From LeoLab’s website: How is What LeoTrack provides different than a TLE? https://www.leolabs.space/tracking-and-monitoring/#how-is-what-leotrack-provides-different-than-a-tle2 7 David Vallado. “An Analysis of State Vector Prediction Accuracy.” (https://www.agi.com/getmedia/60f1f2a7-3a41-4a7c-8d48-2de7d58a0d71/An-Analysis-of-State-Vector- Prediction-Accuracy.pdf?ext=.pdf))

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maneuverability requirement, we propose a minimum maneuverability threshold equal to the predicted positional uncertainty forecasted with a 3-standard deviation confidence for the period of time at which it would be necessary for an operator to initiate a maneuver relative to the Time of Closest Approach (TCA). In other words, the satellite “must be able to move outside its uncertainty bubble in time to avoid the conjunction.”

For example, a satellite system with a high thrust propulsion capability could have a go/no-go maneuver decision point at 3 hours before TCA, and the predicted positional uncertainty with 3- sigma confidence for that satellite at TCA minus 3 hours is 500 meters. Thus, the minimum maneuverability for that system under those solar conditions would be 500 meters within 3 hours. As another example, a satellite with a low-thrust electric propulsion system or a satellite using differential drag may require a 48 hour go/no-go decision timeline since those types of maneuvers take longer, and thus the minimum maneuverability requirement would correlate with the 3-sigma predicted uncertainty at TCA minus 48 hours for that system. The satellite operator would have to demonstrate sufficient maneuverability under all orbital and solar conditions encompassing the mission duration.

Instead of imposing a blanket maneuverability threshold (e.g. 1 km in 48 hours) that may not be appropriate for all orbits, solar conditions, and satellite types, the above described criteria is “tailor fitted” to the particulars of each mission and also naturally evolves as better tracking and predictive capabilities come online. Full implementation of the Space Fence, better atmospheric models, and the expansion of commercial providers like LeoLabs, etc. could improve positional predictions in the future.

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Summary and Conclusion Small satellite systems have been operating at altitudes below 600 km for many years without issue. As was already decided in the FCC Streamlining Procedures, maneuverability should not be a requirement for small satellite systems operating below 600 km given the low severity and environmental impact if there were to be a collision. Large NGSO systems, including megaconstellations, will fundamentally change the nature of any orbit they occupy, and thus should be held to a higher standard. We propose the following tiered maneuverability system, with the required maneuverability threshold being equivalent to the predicted positional uncertainty forecasted with a 3-standard deviation confidence for the period of time at which it would be necessary for an operator to initiate a maneuver relative to the Time of Closest Approach (TCA):

Maneuverability Requirement

System Characteristics Below 400 km 400 - 600 km Above 600 km

Total mass of the system is no more than 1,800 kg None None Yes

Total mass of the system is greater than 1,800 kg None Yes

8 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Planet - Spire - Lynk Presentation to FCC IB on NGSO Maneuverability July 28, 2020 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Planet Labs Inc. (Planet)

Planet is a space and data analytics company that designs, manufactures and operates the world’s largest fleet of remote sensing satellites. Planet licenses its and derived products to a variety of government, commercial, non- profit and research customers around the world.

● U.S. company headquartered in San Francisco, CA with offices in Washington D.C. and Berlin, Germany ● Founded in 2010, approximately 500 employees globally ● Flock constellation (Call Sign S2912) ○ 3U cubesats, 5 kg, 358 launched, 229 on-orbit, 134 currently active ● SkySat constellation (Call Sign S2862*) ○ Mini-fridge size, 110 kg, 18 on-orbit & active (3 more planned) ● The two fleets operate primarily between 400 and 600 km 2 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Spire Global, Inc.

Spire is a next generation data and predictive analytics company that collects data from space to solve problems on Earth. Spire identifies, tracks and predicts the movement of the world’s resources and weather systems.

● US company, headquarters in San Francisco; offices in DC, Boulder, Luxembourg, Glasgow & Singapore ● Founded in 2012, approximately 225 employees ● Holds U.S. earth station license for its LEMUR constellation and market access grant for its MINAS constellation allowing for not more than 175 simultaneously operational satellites (S2946; SAT-AMD-20180102-00001; S3045; SAT-PDR-20190321-00018)

● Currently 88 satellites on orbit; 4.5 kg max total mass of satellites at launch 3 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Lynk Global, Inc.

Lynk is a mobile network technology company focused on providing universal connectivity for the mobile phone. Lynk’s patented and proven technology allows standard mobile phones, without any changes in hardware or software, to be connected virtually anywhere on the globe using our low-earth-orbit nanosatellites. The growing Lynk network represents the best way forward to broadband connectivity everywhere, including the most isolated areas. We are the world’s safety net.

● US company, headquarters in Falls Church, VA ● Founded in 2017 ● Approximately 35 employees

● Currently 1 test satellite on orbit, many more planned 4 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Maneuverability Considerations for NGSO Systems

5 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Propulsion is not a Panacea

1. Other FCC requirements are not technology specific. a. E.g. Part 47 PFD limits do not require specific types of antenna or amplifier technology. 2. Maneuverability can be achieved via solar sails, differential drag, electromagnetic tethers, etc. 3. Very small propulsion systems may not be able to provide meaningful thrust or an adequate number of firings for collision avoidance. 4. Requiring propulsion systems may regulate U.S. commercial cubesats out of existence. 5. Instead, maneuverability capability should be considered.

6 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

NGSO Systems Operating Below 600 km

1. Small satellite systems at altitudes below 600 km have largely been operating without issue to-date. 2. Severity/Consequence of collisions with small objects is comparatively low. a. Collision with a small object may be mission-terminating for an individual satellite, but the environmental impact to the surrounding orbit is low. b. ~1 million objects > 1 cm estimated in LEO; small sats are a drop in the bucket and the environmental risk is already prevalent. 3. Below 600 km is the “self-cleaning” portion of LEO due to atmospheric drag. 4. Following the logic of the FCC’s 2019 Streamlining License Procedures for Small Satellites, we maintain that small satellite systems operating below 600 km should be exempt from any maneuverability requirement. 5. "Large NGSOs”, and espically megaconstellations, should be held to a higher standard. 7 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Definition of “Large NGSO” and Additional Responsibilities

1. Large NGSO systems, e.g. SpaceX Starlink or Amazon Kuiper, have a disproportionately sized impact to the 400 - 600 km orbital regime. a. Both in terms of number of objects, and also consequence of collision(s) due to larger satellites carrying propellant. 2. Must be held to a higher standard and require maneuverability anywhere above 400 km. 3. Following the logic of the FCC’s 2019 Streamline Order (up-to 10 satellites, up-to 180 kg individual satellite mass), we propose the following definition: A Large NGSO system is a satellite fleet whose total free-flying mass at any given time, including any non-operational satellites remaining in orbit, is above 1,800 kg.

8 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Probability of Collision

1. Positional estimates and prediction uncertainties are important factors in calculating probability of collision 2. 18th SPCS space catalogue is the standard, but positional estimates can be refined by onboard GPS, radio ranging, ground based laser measurements, or 3rd party commercial sources (e.g. LeoLabs) 3. Prediction uncertainties vary by orbit, satellite characteristics, solar conditions, and uncertainties grow the farther out you predict a. A 1 ton satellite at 600 km is less perturbed by atmospheric forces compared to 5 kg satellite at 500 km where the atmosphere is thicker and more dynamic 4. Satellite operators commonly use 1E-04 or 1E-05 as threshold for “concerning” probability of collision a. Operators may also take into account predicted severity of collision 9 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Proposed Threshold for Maneuverability

For a satellite system subject to the maneuverability requirement, we propose a minimum maneuverability threshold equal to the predicted positional uncertainty forecasted with a 3-standard deviation confidence for the period of time at which it would be necessary for an operator to initiate a maneuver relative to the Time of Closest Approach (TCA).

In other words, the satellite “must be able to move outside its uncertainty bubble in time to avoid the conjunction.”

10 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Example - 2017 Flock Conjunction Alerts

Under 2017 solar conditions, in-track estimate 48 hours in the future with 3-sigma (99.7%) confidence is 5 km.

11 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Example - 2019 Flock Conjunction Alerts

Under 2019 solar conditions, in-track estimate 48 hours in the future with 3-sigma (99.7%) confidence is 2.7 km.

12 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Maneuverability Threshold - Further Discussion

1. The goal should be to define the minimum maneuverability requirement to minimize the burden on satellite operators. 2. A static requirement (e.g. 1 km in 48 hours) might not be appropriate in all cases. a. Different systems have different maneuvering timelines (e.g. a high-thrust propulsion system may have a go/no-go at TCA minus 3 hours, but a low-thrust electric propulsion system may need several days). b. Prediction uncertainty varies with timeline, satellite characteristics, solar activity, etc. 3. The “move outside your bubble” rule tailor-fits each mission. 4. Also allows for improved tracking and predictive capability (e.g. Space Fence, LeoLabs expansion, etc.) to naturally evolve the rule in the future. 13 DocuSign Envelope ID: B86E2333-EF7C-442D-AA08-7EEC971A9CB5

Summary of Recommendation

Maneuverability Requirement System Characteristics Below 400 km 400 - 600 km Above 600 km Total mass of the system is no more than 1,800 kg None None Yes Total mass of the system is greater than 1,800 kg None Yes

Maneuverability Threshold: Must be able to move outside your uncertainty bubble in time to avoid the collision.

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