Attachment DA 09-2278

DA 09-2278

LETTER submitted by IB,FCC

DA 09-2278

2009-10-23

This document pretains to SAT-LOA-20080910-00173 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2008091000173_751167

                                Federal Communications Commission
                                          Washington, D.C. 20554

                                                                                                DA 09—2278

                                                 October 23, 2009

Karis A. Hastings, Esq.
Hogan & Hartson LLP
555 Thirteenth Street, NW
Washington, DC 20004

         Re: IBFS File No. SAT—LOA—20080910—00173 (Call Sign: $2763)


Dear Ms. Hastings:

This letter concerns SES Americom, Inc.‘s (SES Americom) pending request to construct, launch, and
operate a 17/24 GHz Broadcasting—Satellite Service (BSS) space station at the 67.5° W.L. orbital location
using the 17.3—17.8 GHz (space—to—Earth) and the 24.75—25.25 GHz (Earth—to—space) frequency bands, with
the 17.7—17.8 GHz (space—to—Earth) frequency band limited to international service only. For reasons
discussed below, we partially dismiss the application as defective, without prejudice to refilling.

Section 25.112‘ of the Commission‘s rules requires the Commission to return, as unacceptable for filing, any
space station application that is not substantially complete, contains internal inconsistencies, or does not
substantially comply with the Comumission‘s rules. In its application, SES indicates that the space station
will provide service to the Continental U.S. (CONUS) using a fixed antenna beam, to South America using
two fixed antenna beams (one covering Brazil and the other covering the remainder of South America), and
to Mexico using a steerable antenna beam. Section 25.114(d)(3) of the Commission‘s rules provides that the
application shall include in narrative form, the "[pJredicted space station antenna gain contour(s) for each
transmit and each receive antenna beam and nominal orbital location requested. These contour(s) should be
plotted on an area map at 2 dB intervals down to 10 dB below the peak value of the parameter and at 5 dB
intervals between 10 dB and 20 dB below the peak values, with the peak value and sense of polarization
clearly specified on each plotted contour...."" While SES Americom provided antenna gain contours for the
steerable Mexico transmitting and receiving beams in both polarizations, it failed to include the requisite
number of intervals for each diagram. Specifically, SES Americom only provided —4 dB, —10 dB, and —20 dB
gain contours. SES Americom did not seek a waiver of Section 25.114(d)(3) with respect to the requirement
to provide antenna gain contour diagrams for the steerable Mexico transmitting and receiving beams and
accordingly this aspect of its application is subject to dismissal.*




147 CFR. § 25.112.
247 CFR. § 25.114(d)(3).
‘ We note that in its application, SES Americom requests a limited waiver of Section 25.114(d)(3) of the Commission‘s
rules with respect to the submission of predicted antenna gain contours in .gxt format for the non—Brazilian South
American uplink beams. This waiver request does not address the steerable antenna beams covering Mexico. Narrative
at 4—5.


                                   Federal Communications Commission                           DA 09—2278




Accordingly, pursuant to Section 25.112(a)(1) of the Commission‘s rules, 47 C.F.R. § 25.112(a)(1), and
Section 0.261 of the Commission‘s rules on delegations of authority, 47 C.F.R. § 0.261, we partially dismiss
the application of SES Americom with respect to the portion of its application relating to the steerable
antenna beam without prejudice to refiling.


                                                                 Sincerely,




                                                                 Robert G. Nelson
                                                                 Chief, Satellite Division
                                                                 International Bureau



Document Created: 2019-04-19 16:38:06
Document Modified: 2019-04-19 16:38:06

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