Attachment letter

letter

LETTER submitted by FCC,IB

letter

2005-08-29

This document pretains to SAT-LOA-20050622-00133 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2005062200133_452721

                               Federal Communications Commission
                                      Washington, DC 20554
inormatonaBuronu
                                                August29, 2005


 Naney J. Eskenazi, Bsq.
 Vice President and Associate General Counsel
 SES Americom, Inc.
 Four Research Way
 Princcton, NJ 08540

                   Re:    Appliation of SBS Americom, Inc.for Authority to Launch and Operate
                          A Ku—Band Expansion Satelite at the 125° W.L. Orbital Location
 Dear Ms. Eskenazl:
         On June 22, 2005, SES Americom, Inc.(SES Americomfiledan application for suthority to Iaunch
 and operate a Ku—band expansion satelite at the 125° W.L. orbital location, which is to be designated AMC—
 21.\ We find that, although the application is substantally complete as file, certain additional information
 would assist us in completing our eview of the appliation
          Section 25.140(b)(2) ofthe Commission‘s rulesrequires applicantsfor space sation suthorizations
 in thefixed—sateliteserviceto demonstrat their proposed systems are compatile with the Commission‘s
 two—degree orbtal spacing framework." Dus to uncertintyregarding this rule, the Commission hasissued
 two Public Notices to providefrther nformation to potental aplicants. Specifially, in 2003, the
 Commission issued a Public Notice that provided guidance asto the type oinformation that must be
 included in the "two—degree interference analysis" and notifed potentalaplicants thatfalure t submitthis
 information would render the applications incomplet."In 2004, the Commission issued a Public Notice that
 clarified that applicants must submit a two—degree interference analysis evenifthere are no currently
 authorized space stations within two degrees ofthe proposed space sation"
         SES Americom has provided link noise budgets, modulation parameters, and overall ink
 performance analyses for both is analog and digial cariers, consistent with the requirements of Section
 25.140(b)(2). In addiion, SES Americom provided an inerference analysis which demonstrtes thatthe
 digial signals from ts proposed space sation are compatible with those ofspace sations located two
 degreesaway. This analysis complies with Section 25.40(b)) and the 2003 and 2004 Public Noties.
 * Aplication ofSES Amercom,Inc. for Authority t Launch and Operatea Ku—band ExpansionSatelit at the 125°
 W.L Orbital Location,File No. SATLOA—20050622.00133 (iled June 22 2005)(‘Application)
‘arore52s 14000
* Inermational Boreau Satlite Division Information: Clarfication of 47 CFR.§ 25.140(b)(), Space Suation
Application Inrference Analysis, Public Noic, 18 FCC Red 25099 (2003).
* Inermational Bureau Satlite Divsion Information: Clafiation of47 CFR.§ 25.140(b)(2),Space Suation
Interference Analysis, Public Noric, 19 FCC Red 10682 (2004)
* See Americom Application t Amex 3, p. 26.
                                                  Page tor2


Nevertheless,the analysis does no address analog TV/FM signals because, according to SES Americom, it
coortinates analogsignals with adjacent satelite operators on a case—by—case basis* While Section
25.140(b)2) provides discretion to applicants regarding the radiofrequency carriers for which interference
analyses are provided," we believe thatan interference analysis that includes the analog TV/PM signals
would be usefulto future applicants and should be ncluded withthe appliction. Accordingly,we require
SES Americom to amend its application to include such an analysis by Seprember 12, 2005. Fuilure to
respond in timely manner will result in dismissal of the appliation:
         "This action is taken pursiant t the Commission‘s rules on delegated authority, 47 C.FR. $ 0.261



                                                            Sincerely,
                                                           //j aA—
                                                            Robert G. Nelson
                                                            Chict, Satelite Enginecring Branch
                                                            Satelite Division
cc: Karis A. Hastings, Bxg.
Hogan & Hartson L L P
555 13Streeu, N. # 800E
Washington, D.C. 20004—1109




*h
" See 47 C.BR. §25.140(B)()(*...An applicant should provide details of ts proposed rf.carriers which t beieves
should b taken io account in this analysis....)
"47 CRR.§25.1 120(‘ilf an applicantis requested bythe Commision to file any additonal infrmation oany
supplementay or explanatoy information no specfcallyrequired in the prescribed applcation form orthese rulesa
fallre to comply with trequest wthin a specified imperiod willbe deemed to render theapplication defecive
and will subjecit o dismisal")
                                                  Page 2o2



Document Created: 2005-08-29 11:31:50
Document Modified: 2005-08-29 11:31:50

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