Attachment Grant

This document pretains to SAT-MOD-20060410-00041 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2006041000041_504944

Approved by OMB 3060—0578 Date & Time Filed: Ape 10 2006 5:43:50:083PM File Number: SAT—MOD—20060410—00041 Coll § $2 ja6 FOC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AVD — MAIN FORM [FCC Use Only Fce 312 MAiN FoRM FoR OFRICIAL USE ONLY APPLICANT INEORMATION Enter a description ofthis application to identify t on the main menu: AMC—15 modification 1—KLegal Name ofApplicant Name: SES Americom,Inc Phone Number: 600—987—4000 xa187 oBa Fax Number: so0—987—4233 Name: Streets 4 Research Way nancyceskenazi@ses—americom. com City: Princcton State: BJ Country: USA Zipeode: ossso — Attention: Ms. NancyJ.Eskenazi m SET—MSU=Z5OGOHI0—con cats a 52145 omntpue SSvave § re06 (orother Hentfag) TemDates ekéEZ‘g uycondwed : rey§ Bresch Care®

SAT—MOD—20060410—00041 AMC—15 satellite Call—Sign: S2146 June 8, 2006 SES Americom, Inc.‘s (SES Americom) request for a modification, IBFS File No.SAT— MOD—20060410—00041, ofits authorization to relocateis in—orbit hybrid Ka/Ku—band. satellte, AMC—15, from 105° W.L.orbital location to the 105.05° W.L. orbital location IS GRANTED. Accordingly, SES Americom is authorized to operate its AMC—15 satelite at the 105.05° W.L. orbital location, with +0.05° longitudinal station—keeping, in the 11.7—12.2 GHz (space—to—Earth), 14.0—14.5 GHz (Earth—to—space), 18.6—18.8 GHz and 19.7—20.2 GHz (space—to—Earth) and 28.4—28.6 GHz and 29.5—30.0 GHz (Rarth—to—space) frequency bands. Other than the change in orbital location, the conditions contained in the prior authorization‘ otherwise remain in effect and the AMC—15 satellite will operate in accordance with the Commission‘s Rules, the terms, conditions, and technical specifications set forth in its application, the prior authorization, and this Attachment. 8. SES Americom is afforded thirty days from the date of this grant to decline this authorization as conditioned. Failure to respond within this period will constitute formal acceptance of the authorization as conditioned. 2. This Grant is issued pursuant to Section 0.261 ofthe Commission‘s rules on delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Petitions for reconsideration under Section 1106 or applications for review under Section 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date ofthe public notice indicating that this action was taken. mee S@T— mo—200604(0 Oc \Yromamieh thire ?\éfi ouch Chre" ‘ The modifiction appleation was placed on public notce on April 14, 2006. See Stelte Space Applications Accepted for Flig, Policy Branch Information, Public Notice, Report No. SAT—00354 (rl. April 14,2006) No comments were filed. * On August 18, 2004, he Policy Branch granted with conditions SES Americom‘s applications, SAT— Loa—20030219.00013, SAT—AMD—20030422.00069,SAT—AMD20040615—0117, SAT—MOD— 20030214—0011,and SAT—STA—20040622—00118 (CallSign S2180), elating to AMC—15, See Actions "Taken, Policy Branch Information, Public Nore, DA No. 04—2601, Report No. SAT—00236 (rel. August 20,2004)

9—16. Name of Contact Representaive Name: KarisA. Hastings Phone Number: an—err—s767 Company: Hogan & Hartson LLP. Fax Number: 2o2—627—5010 Streets 555 Thincenth Street, NW gom KAHastings@hhawccom City: Washington State: pe Countrys USA Zipeote: 20004—1109 Attention: Relationship: Legal Counsel CLASSINICATION OF HILING 17. Choose thbutton next t the classification that apliesto this fling for (NA) b1. Application for License of New Sation both questions a.and b. Choose only one (NA) b2. Application for Registation oNew Domestic Receive—Only Sution for 17a and only onefor17b & (N/A) 3. Amendmentto a Pending Application @ a1. Barth Sution @ (N/A) b4. Modifcation of License or Repistation bS. Assignment o License or Registation @ 2. Space Station b6. Transfer ofControl ofLicense or Repistation £ (N/A) b7. Notifation of Minor Modifcation (N/A) b8.ApplicationforLicense of New Receive—Only Sttion Using Non—U.. Licensed Suctite (NA) b9. Ltter of Itentto Use Non—US. Liensed Satelite to Provide Servie in the United Stres & (N/A) b10. Other (Please specify)

176.1 a fee submited with this appliation? @ 1Yos, complete and attach FCC Form 159. If No, indicatereason forfee eemption (see 47 C.ER.Section 1.1114). @ GovemmentalEntity qy Noncommerial educationallicensce & Otherfplease explain): 174. Fee Classifeation BE ~ Space Sution Modifeation(Geost 18. Ifths filing is in reference to an 19. fthis filing is an amendment t a pending application enter both fields,ifthis fing i a existing sttion, eter modifcation please enter only thfile number: (a) Cal sign ofstation: (@) Date pending application was Aied: (6) File number: S2180 sarioazons021900013

TVPE OF SERVICE 20. NATURE OF SERVICE: This ig is for an authorization to provide or use te fllowing type(s) oservices) Selectall that apply: [g] a Fived Sarelite [C] b. Mobile Srelite [] & Radiodetermination Sitelite [C] 4 Birth EplorationSatlite J 6 Direstto Home Fixed Satelite [C] 5 Disital Audio Radio Service [C] aOther (please specity) 21. STATUS: Choose thbatton next tothe applicablestatus. Choose |22. IFearth station applicant, check allthat apply orly one. [C] Using U.S. liensed satelites gp Comnen Carie: @ Ret—Gammen Conier [C] Using Non—U.S.lcensed stelites 23. Ifapplicant is providng INTERNATIONALCOMMON CARRIRR service, se instructons regarding Sec.214 flings. Choose one. Are these [nciliies > Comected t a Publi Switched Network @) Not connected to a Public Switched Nework @ N/A 24. FREQUENCY BAND(G: Place an °in the box(es)next t ll applicablfequency band). [C] s C—Band @6 GHt. gg b Ku—Bard (24Gite) [—] Ofher (Pleas specify upper and lower fequenciesin Mite) Frequency Lower: Frequency Upper: (Please specify additional requenciosin an atachment)

TVPE OF STATION 25. CLASS OF STATION: Chooseth button next thclas osation that applies. Choose only one. @ a. Fixed BarthStation @ b. Temporary—Fixed BarthStation @ c 12/14 Gitz VSAT Network @ 4. Mobile Eath Sution @ ©.Geostationary Space Sution & £ Not—Geostationry Space Station @ & Other (please specity) 26 TypE or Eaiem station raciumy: @ TransmitiReceive @p Transmit—Only gy Receive—Only @ NA "For Space Sution applications, select N/A."

PURPOSE OF MODIFICATION 27. The purpose ohis proposed modification is to:(Plac an X" i the box(es)next to all thatapply) [7] a— authorization to add new ermission designator and relted service [C] b —authorization to change emission designatorand related service [CJ eauthorization tincrease EIRP and EIRP density [CJ 4—authorzationto replace antenna [CJ e— suthoriztion t add antenna D f~ authorization to relocate fixed sution [C] e —authorization to change frequencyies [C] h —authorization to add frequency [C] i — authorization to add Points of Communication (stelites damp; countrics [CJi — authorization to change Poins ofCommunication (stelites & countris) [C]k—authorization for a s for which environmental assessment and radiation hazard reporting is required — authorizationto change orbit lcation [C] m —authorzationto perform flet management [C] n —authorization to extend milestones [CJ 0 — Other (Pease specity)

ENVIRONMENTAL POLICY 28, Would a Commission grit ofany proposa ithis application or amendment have a signifeant environmental y es @ No impact as defined by 47 CBR1.1307? IPYIES, submit th statement as required by Sections 11308 and 1.1311 of the Commission‘s rles, 47 CER. 1.1308 and 1.1311, exhibtto this applicationA Radiation Harard Study must accompany all applications for new transmiting ficlties, major modifications, or major amendments. ALIEN OWNERSHIP Earth station applicants not proposing to provide broadeast, common carrier, acronautical en route or aeronautical fixed radio station services are not required to respond to tems 30—34. 29. s th applicanta foreign government or the representaiveof any freign govemment? o Y# @ No 30. s th applicant an alien or th representativeof an alien? 0 Ys @ No o NA 31. Is the applicant a corporation organized undethe aws ofany foreign government? 0 Ys @ No q NA 32,Is the applicanta corporation of which more than one—fith ofthe capital stock is owned of record or voted by gy Yes @ No (y NA aliens or thirrepresentaives or by foreign govemment or representatve thereoror by any corporation organized under the lws ofa foreign country?

33. s th applicanta corporation diretly or indireatly cntralled by any other corporation of which more than @ Yes gy No @ NA one—fourth ofthe capitl stock is owned ofrecord or voted by alies,theirrepresentatives, or by a foreign govermment orrepresentatve thereofoby any corporation organized underthe lavs ofaforeign country? 34,If any answerto question 29, 30, 31, 32 and/or 33 is Yes,atach as n exhibit an identifation ofthe aliens or ExhibitA foreign entites, heir mationaliy, thei relationship to the applicant, and the percentage of stock they own or vot. BASIC QUALIFICATIONS 35, Doesthe Applicanrequest any waivers or exemptions from any ofthe Commission‘s Rules? qve @N 1fes, atich as an exhibit, copies ofthe requessforwalversor exceptions with supporting documents. 36. Has theapplicant or any party to this aplication or amendment had any FCC station authorization or Hcense ols e@N revoked or had any application foran initil, modifiation or renewal ofFCC sttion authorization, lcense, or construction permit denied by the Commission? IfYes, ttach asan extibt, an expliation ofircumstances.

37. Has th applicant, oany party to this applicaion oramendment, or any patydrectly orindirectly controling o1 @ No the applicant eve been convicted ofa felony by any state orfederl cour? If¥es,atach as an exhibi, an explination ofcircumstances. 38, Has any courtfinlly adjudged the applicant, or any person diretlor intiretly contolingthe applicant, o« xo of unlawfily monopolizing o atempting unlawfully to monopalize radio communication, directly or indirectl, through control of manufacture or sle of radio apparatus, exclusie trific arrangement or any other means o unfair methods ofcompettion?fYes, atiach as an exhbit, an explanation ofcicumstances 39. s the applicant, oany person directlor intirectlcontrallingthe applicant,currently a pary in y pending gvs @ xo matter refered to in the preceding two tems? If yes, atach asan exhinit,anexplanation othcrcumstances. 40. If the applicant is a carporation and is applying fora spacestation liense, atiach as an exhbitthe names, address, and ciizenship of thosestockhalders owning a recard and/or voting 10 percent or more of the Filer‘s voting stock and the percentages so held. In the case ofiduciary control,indicate the beneficary(is) or class of ExibicB beneficiaris. Also s the names and addresses of the oficers and directors ofthe Filer

41. By checking es, the undersigned certfes, that nether aplcant nor any other partyto the applicationis Yes No subject t a denial of Fedeal benefts that includes PCC benefits pursuant to Section $301 of the Anti—Drug Act of o 198, 21 U.S.C. Section H62, because ofa comvictionforpossession or distibution ofa contrlled substance. See 47 CFR 1.2002(b)forthe meaningof &quotparty o the application@iquot, forthese purposes. 42. Does the applicant itend to use a non—U.S. lcensed satlite to provideservice in the Unted States? If Yos, o1« en answer 42b and attach an exhibit roviding thinformation specified i 47 C.ER. 25.137,as appropriat. IfNo, proceedt question 43. 42b. What adminisration haslcensed oris in the process oTcensing th space station? Ifno icense will b issued, whatadministration has coordinated or is in the process ofcoordinating the space sttion? [3 Descripton. (Surmmanze henature of he appication and the servicesto b provided)._ (Ifthe complete descripton does not appear in this Ibos,please goto the end otheform to view it i ts entrety) lsee attachment 1. [Atachment T 10

CERTIFICATION [The Applicant waives any claim to the use oany particolar frequeney oro he lectromagnetic spectrum as againsthereulatory power ofte United Sates because othe previous use of thesame, whethe by eense orotherie, and requests anauthorization in accordance with this lapplication. The applicant cetifes thatgrant ofthis appliation would not cause the applicant to b in violition of the spectrum agaregation limit in 47 CFR Pat 20. All statements made in exhibits are a materalparthereorand ae incorporated herei asi set out in flln this application. ‘The undersigned,intividualy and for th applicant, hereby certfes that all statements made in ths application and in all atached exhibitsare iue, complete and correctto the best of is or her knowledac and blie, and are made in good faith. [¥3 Applicanis a m (Choose the btton next to appleable response) g Individual g Unincorponted Association g Parmership @ Cooration g Governmental Entity g Other (please specity) [i5. Name ofPerson Signing 6. Tule o Person Signing Nancy J. Eskenazi (Viee President and Associate General Counsel => WILLEUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Te 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code,Tile 47, Section 312(e¥(1)), AND/OR FORFEITURE (U.5. Code, Te 47, Secion 503. 11

ree NonIcE REQUIRED BY TiE rAPERWORK REDUCTION ACT "The public reportingforthis ollection oinformation i stimated to average 2 hours per response,includingthe time fo reviewing instictions, searching existing data sources, gxthering and maintiningthe required data,and completig and reviewing the colletion oinformation. Ifyou have any comments on thisburden estimate,or how we canimprove tcolletion and reduce th burden it uses you, lease writ t the Federal Communications Commission, AMD~PERM, Paperwork Reduction Project (3060—0678),Washington, DC 20554. We will also nccept your commentsregarding the Paperwork Reduction Actaspects o this colletion via the Itermet if you send them to iboley@fecgov. PLEASE o NoT SEND COMPLETED FORMS To THIS ADDRESS Remember —You are not required o respand to a collecion ofinformation sponsored by the Federl govermment,and the government may not conductor sponsor this callecton, unless it isplays a curently vlid OMB control numberoif wefil o provide you withthis notice.. This collectionhasbeenassigned an OMB control number of3060—0678 iE rorEGoNG Notice is REQuIRED By THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 101~13, OCTOBER 1, 199844 US.C. SECTION 3s07. 13

FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Application by SES AMERICOM, INC. File No. sAT—MOp. 2CO6O410—00°H For Modification of AMC—15 Fixed—Satellite Space Station License APPLICATION OF SES AMERICOM, INC. SES Americom, Inc. (‘SES Americom") hereby respectfully requests a modification of its liense for the AMC—15 fixed—satellite space station to assign the satellite permanently to the 105.05° W.L. orbital location. SES Americom seeks to operate AMC—15 at a slight offset from the nominal 105 W.L. orbital position in order to simplify stationkeeping at this location. No other change in the operation of the satelliteis proposed. SES Americom has requested authority to relocate its Satcom C—4 spacecraft to 104.95° W.L., where the satellite will be operated by SES Americom‘s wholly—owned subsidiary SES Satellites (Gibraltar) Ltd. (SES Gibraltar®) pursuant to a license granted by the Gibraltar Regulatory Authority CGRA").! The proposed offsets of AMC—15 and Satcom C—4 from the nominal 105° W.L. orbital position will eliminate any overlap of the stationkeeping volume, facilitating safe operation of hemaraarte * See File No. SAT—STA—20060330—00034. me s S6N o6 —M2e0604(0. oc cantsin $2446 onnpas_Suuve§,2006 otterientiieq

the satellite Accordingly, grant of the instant request will serve the public interest. A completed FCC Form 312 anda technical appendix are attached in support of this application. AMC—15 is a Ku/Ka—band satellite that was launched on October 14, 2004, and is authorized to operate at the 105° W.L. orbital position. SES Americom seeks a modification of the AMC—15 license to permit operation at an offset once Sateom C—4 arrives at 105° W.L. Both AMC—15 and Satcom C—4 could operate centered at 105.0° W.L. by flying the satellites in formation to permit sharing of the same stationkeeping volume. However, such an arrangement would require an increased number of maneuvers to maintain an appropriate separation between the spacecraft. Purthermore, AMC—15 is fully stationkept, but Satcom C—4 will be operating in inclined orbit, making it more difficult to synchronize the movement of the satellites and keep a safe distance between them. In order to simplify stationkeeping once Satcom C—4 arrives, SES Americom and SES Gibraltar propose to operate both satellites at slight offsets from the 105° W.L. nominal orbital position. The offeets will eliminate any overlap & In the event that the Commission has not acted on this license modification application at the time Satcom C—4 arrives at 105° W.L., SES Gibraltar and SES Americom will maintain their spacecraft with a tighter stationkceping tolerance. Specifically, pending action on the AMC—15 modification, SES Gibraltar will operate Sateom C—4 centered at 104.9375° W.L., with an East—West stationkeeping tolerance of +/ 0.0375 degrees. SES Americom will operate AMC—15 centered at 10.0125° W.L, also with an East—West stationkeeping tolerance of +0.0375 degrees. Thus, Satcom C—4 will operate within a stationkeeping box bounded by 104.900° W.L. and 104.975° W.L, and AMC—15 will operate within a stationkeeping box bounded by 104.975° W.L. and 105.050° W.L.

of the stationkeeping volumes of the two spacecraft, thereby facilitating joint operations. As demonstrated in the technical appendix, grant of the requested authority will not adversely affect any other operators. The nearest operational Ku— band satellites to 105° W.L. are SES Americom‘s AMC—1 at 103° W.L. and Telesat Canada‘s Anik FI and FIR at 107.3° W.L. The nearest operational Ka—band satellites to 105° W.L. are DirecTV‘s Spaceway—1 at 102.8° W.L. and Telesat Canada‘s Anik F2 at 111.1° W.L. The small proposed shift in AMC—15‘s orbital location will have a de minimis effect on the interference environmentin which adjacent satellites operate. For the foregoing reasons, SES Americom seoks a modification of the AMC—15 license to assign the spacecraft to the 105.05° W.L. orbital location. Respectfully submitted, SES Americom, Inc. By: J. Naney J. Eskenazi Counsel Vice President and Peter A. Rohrbach Associate General Counsel Karis A. Hastings SES Americom, Inc. Hogan & Hartson LL.P. Four Research Way Washington, D.C. 20004—1109 Princeton, NJ 08540 ‘Tel: (202) 687—5600 Dated: April 10, 2006

Technical Appendix 1. Introduction This technical appendix is submitted in support of the application of SES Americom,Inc. (‘SES Americom")for a modification ofits license for the AMC—15 Ku/Ka—band spacecraft. SES Americom seeks permanent assignment of the spacecraf to 105.05° W.L. instead of 105° WL. SES Americom incorporates by reference herein the technicalinformation it has already provided with respect to AMG—15, and provides here technicalinformation that is changing as a result of the proposed modification. 2. Gain Contours SES Americom is not submiting new contour maps with this application. The proposed shif in orbital location from 105° W.L. to 105.05° W.L. will produce no visible change in the gain contours from the maps already on fil. 3. Link Budgets and Interference Analysis The nearest operational Ku—band satelites to 105° W.L. are SES Americom‘s AMC—1 at 103° W.L. and Telesat Canada‘s Anik F1 and F1R at 107.3° W.L. The nearest operational Ka—band satelltes to 105° W.L. are DirecTV‘s Spaceway—1 at 102.8" W.L. and Telesat Canada‘s Anik F2 at 111.1° W.L. SES Americom has previously submitted interference analyses to the FCC demonstrating that operation of AMG—15 in the Ku—band and the Ka—band was compatible with adjacent satelltes and with the Commission‘s two—degree spacing requirements." The proposed offset operation of AMC—15 will not cause any material change to the interference environment. The proposed offset would resultin AMC—15 moving slightly closer to Anik F1 Anik FIR, and Anik F2, but the resulting change in the interference environment will be negigible. Specificall, as shown in the table below, SES Americom has calculated that implementation of the proposed offset would resultin a change of approximately * See File Nos. SAT—MOD—20030214—00011; SAT—LOA—2003021—00013; SAT— AMD—20030422—00068; SAT—AMD—200406 15—001 17. * File Nos. SAT—MOD—20030214—00011 & SAT—LOA—20030210—00013, Technical Appendix at Attachment B, Ku—Band Two Degree Spacing Analysis in Support of AMC— 15, and Aftachment C, Analysis with respect to Section 25.138 (Ka—Band Two Degree Spacing)in Support of AMC—15.

0.25 dB in the interference environment of two—degree compliant earth stations communicating in the Ku—band with Anik F1 or Anik F1R at 107.3° W.L." 1or3 Current Orbia! Position 105 Clasest Offset Angle,taking nto sccount 0.05 degree statonkeening 22 Gain(1) @ Offst angle 2oatcs Proposed Orkital Position (105.09 Closest Offset Ange,taking nto account 008 dagree statonkeesing 215 Gain (2) @ Offet angle 2060 08 4 (Gainl) = Gein ) 92548 Simirly, the small proposed shif in the AMC—15 orbital location will not materially change the interference environment for Ka—band operations. As noted above, the nearest operational Ka—band satelite to the west of AMC—15 is at 111.1° W.L., and thus will be greater than six degrees away from AMCG—15 even with the proposed offset. The impact of the proposed offset on any future satelite located at the immediately adjacent 107° W.L. orbitallocation would also be immaterial. Ka—band antennas and Ku—band antennas exhibit the same 29 — 25 log® sidelobe envelope for two—degree spacing, so the calculations in the above table can be applied to Ka—band operations as well. Thus, the proposed offset would result n a change of approximately 0.25 dB in the interference environment of two—degree compliant earth stations communicating in the Ka—band with a future satelite at 107° W.L. SES Americom has demonstrated that AMG—15 complies with the of—axis EIRP density imand PFD limitsin Section 25. 138 of the Commission‘s rules, and the proposed offset will have no effect on those values. Given that the proposed offset operation of AMC—15 wil not result in any material change to the interference environment with respect to AMCG—15 and existing or future adjacent satelites, no link budget analysis is provided herein. in the unicely event that any future concems arise concerning operations of AMC—15 at the proposed offsct location, SES Americom will coordinate with the adjacent operators in order to arrve at a mutually satisfactory solution. * Both Anik F1 and Anikc F1R have been placed on the Commission‘s Permitted Space Station List, authorizing routinely—icensed U.S. earth stations to communicate with the spacecraft in the Cand Ku—bands. Seo Telesat Canada, Order, 15 FCC Red 24828 (Sat. and Rad. Div. 2000) (placing Anikc F1 on the Permited List); File No. SAT— PDR—20050504—00094, grant stamped with conditions, July 21, 2005 (placing Anik FIR on the Permitted List).

4. Orbital Debris Miti This section provides the information required underSection 25.114(d)(14) ofthe Commission‘s Rules §25.114(d)(14)(): SES Americom has assessed and limited the amount of debris released in a planned manner during normal operations of AMG—15. No debris is generated during normal on—station operations, and the spacecraft will be in a stable confiquration. On—station operations require stationkeeping within the +/ 0.05 degree N— S and E—W control box, thereby ensuring adequate collsion avoidance distance from other satelltes in geosynchronous orbit. in the event that co—location of this and another satelite is required, use of the proven Inclination—Eccentriity (—E) separation method can be employed. This strategy is presently in use by SES ASTRA to ensure proper operation and safety of multple satelites within one orbital box. SES Americom has also assessed and limited the probablity ofthe space station becoming a source of orbital debris by colisions with small debris or meteoroids that could cause loss of control and prevent post—mission disposal. SES Americom requires that spacecraft manufacturers assess the probabilty of micrometeonte damage that can cause any loss of functionaliy. This probabilty is then factored into the ullmate spacecraft probabilty of success.. Any signficant probabilty of damage would need to be miligated in order for the spacecraft design to meet SES Americom‘s required probablity of success ofthe mission. The design of AMC—15 locates all sources of stored energy wihin the body of the structure, which provides protection from small orbital debris. SES Americom has taken steps to limit the effects of any collsions through shielding, the placement of components, and the use of redundant systems § 25.114(d)(14)(i}: SES Americom has assessed and limited the probabilty of accidental explosions during and after completion of mission operations. As part of the Safety Data Package submission for SES Americom spacecraft, an extensive analysis is completed by the spacecraft manufacturer,reviewing each potential hazard relating to accidental explosions. A matrix is generated indicating the worst—case effect, the hazard cause, and the hazard controls available to minimize the severity and the probablity of occurrence. Each subsystem is analyzed for potental hazards, and the Safety Design Package is provided for each phase ofthe program running from design phase, qualiication, manufacturing and operational phase ofthe spacecraft. Also, the spacecraft manufacturer generates a Fallure Mode Effects and Criicalty Analysis for the spacecraft to identiy all potential mission fallures.. The riskof accidental explosionis included as part of this analysis. This analysis indicates fallire modes, possible causes, methods of detection, and compensating features of the spacecraft design. The design of the AMC—15 spacecraft is such that the risk of explosion is minimized both during and ater mission operations. In designing and building the spacecraft, the manufacturer took steps to ensure that debris generation wl not result from the conversion of energy sources on board the satelite into energy thatfragments the satelite. All propulsion subsystem pressure vessels, which have high margins of 3

safety at launch, have even higher margins in orbit,since use of propellants and pressurants during launch decreases the propulsion system pressure. Burst tests were performed on all pressure vessels during qualiication testing to demonstrate a margin of safety against burst. Bipropellant mixing is prevented by the use of valves that prevent backwards flow in propellant and pressurization lines. All pressures, including those of the batteries, are monitored by telemetry. Atthe end of operational lfe, after the satelite has reached its final disposal orbit, all on—board sources of stored energy willbe depleted or secured, and the batteries will be discharged § 25.114(d)(14)(ii}: SES Americom has assessed and limited the probablity of the space station becoming a source of debris by collsions with large debris or other operational space stations. Specifically, SES Americom has assessed the possibiity of collsion with satelites located at, or reasonably expected to be located at, the requested orbital location or assigned in the vicinity of that location. Regarding avoidance of colisions with controlled objects, in general,if a geosynchronous sateliteis controlled within its specifed longitude and latitude stationkeeping limits, collsion with another controlled object (excluding where the sateliteis collocated with another object) is the direct result of that object entering the allocated space The instant application seeks authorty for operation of AMC—15 at a slight offset from the nominal 105° W.L.orbital location. SES Americom‘s subsidiary SES Satelites (Gibraltar) Ltd. proposes to operate Satcom C—4 in the C—band at 104.95° W.L. pursuant to a license from the Gibraltar Regulatory Authority. The two operators have already arrived at a plan forjoint stationkeeping ofthe spacecraft, which is described above. During regular operation there are no other satelites assigned to or reasonably expected to be located at 105° W.L. or to nearby orbital locations such that there would be an overiap wih the stationkeeping volume of AMC—15 at 106.05° W.L. SES Americom also has a contract with an external laboratory that is monitoring encounters between satelites under SES Americom‘s control and some 500 active and inactive drifing objects. Any close encounters (separation of less than 5 kim.) are flagged and investigated in more detail. If required, avoidance manewvers are performed to eliminate the possibiity of colisions. During relocation, the moving spacecraft is maneuvered such that itis at least 30 km away from the synchronous radius at all tmes. In most cases, much larger deviation from the synchronous radius is used. in addition, the external laboratory‘s assistance is used to ensure no close encounter occurs during the move. When de—orbit of a spacecraft is required, the infal phase is treated as a satelite move, and the same precautions are used to ensure colision avoidance. §25.114(d)(14)(iv): Post—mission disposal of the satelite from operational orbit wil be accomplished by carrying out maneuvers to a higher orbit. The upper stage engine remains part of the satelite, and there is no re—entry phasefor either component. The fuel budget for elevating the satelite to a disposal orbit is included in the satelite design. SES Americom plans to maneuver AMC—15 to a disposal orbit with a minimum perigee of 276 km above the normal operational alttude. This proposed disposal orbit alttude is based on the following calculation pursuant to § 25.283 of the Commission‘s a

Rules Area of the satelite (average aspect area); 56.35 m‘ Mass of the spacecraft: 1983.7 ky C« (solar radiation pressure conffcient}1.45 Therefore the Minimum Disposal Orbit Perigee Alltude, as calculated under the IADC formula is: 36,021 km + (1000 x Ca x A/m) = 36062 km, or 276 km above the GSO arc (35,786 km) SES Americom intends to reserve 13.3 kg of fuel in order to account for post—mission disposal of AMC—15. SES Americom has assessed fuel gauging uncertainty and has provided an adequate margin of fue! reserve to address the assessed uncertainty. 5. Schedule S As discussed above, the proposed modification of the AMC—15 license to offset the satelite by 0.05 degrees from 105° W.L. wll not resultin any material changes to the spacecraft‘s operating characteritics or to the interference environment. As a result, the information requested in Schedule S duplicates information that is already on file with the Commission concerning the technical parameters of AMG—15‘s operation. in simiar cases involving requests for slight offsets from the nominal orbital position, the Satellte Division has not required the submission of a new Schedule S." Accordingly, SES Americom is not fling a new Schedule S with this application. SES Americom will nevertheless prepare and submit a Schedule S if requested to do so by the Satelite Division. * See, e.g., File No. SAT—MOD—20040405—00076 (PanAmSat request for authority to operate SBS—6 at 74.06° W.L. rather than 74.0° W.L.. 5

DECLARATION OF KRISH JONNALAGADDA 1, Krish Jonnalagadda, hereby certiy under penalty of perjury that I am the technically qualiied person responsible for preparation of the technical information contained in the foregoing exhioit; that | am familar with the technical requirements of Part 25; and that either prepared or reviewed the technical information contained in the exhibit and that it is complete and accurate to the best of my knowledge, information and belie. is! Krish Jonnalagadda Manager, Satelite Market Development SES Americom, Inc. Dated: April 10, 2006


Document Created: 2006-06-08 17:23:35
Document Modified: 2006-06-08 17:23:35
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