Attachment grant

This document pretains to SAT-MOD-20080520-00107 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2008052000107_657116

       S2676        SAT-MOD-2008052040 107     IB2008001213
       SES Americom, Inc.


                                                                                                  Approved by OMB
                                                                                                         3060-0678

Date & Time Filed: May 20 2008 5:50:40:426PM
File Number: SAT-MOD-20080520-00 107


    FCC APPLICATION FOR SPACE AND EARTH STATI0N:MOD OR AMD - MAIN FORM         FCC Use Only

                       FCC 3 12 MAIN FORM FOR OFFICIAL USE ONLY




1-8. Legal Name of Applicant

          Name:         SES Americom, Inc.                Phone Number:   609-987-4000x4187
          DBA                                             Fax Number:     609-987-423 3
          Name:
          Street:      4 Research Way                     E-Mail:         nancy.eskenazi@ses-americom.
                                                                          corn


          City:        Princeton                          State:          NJ
          Country:      USA                               Zip eode:       08540      -

          Attention:   Ms Nancy J Eskenazi




1


                                        Attachment
                         IBFS File No. SAT-MOD-20080520-00107
                                       July 30,2008

SES Americom, Inc. ("SES Americom") request, IBFS File No. SAT-MOD-20080520-
00107,' IS GRANTED. Accordingly, SES Americom is authorized to operate its Fixed
Satellite Service (FSS) space station, AMC-21 (Call Sign: S2676), at the 124.9' W.L.
orbital location using the 14.0- 14.5 GHz (Earth-to-space) and 11.7-12.2 GHz (space-to-
Earth) conventional Ku-band frequencies. Other than operating AMC-21 at a slight
offset from original authorization at 125" W.L orbital location, the conditions contained
in the prior authorizations2for the AMC-21 space station continue to apply. This
authorization is subject to the terms of the application, the previously authorized
technical specifications for AMC-2 1 for operational parameters other than orbital
location, the conditions of this attachment, and the Federal Communication
Commission's rules.

    1. SES Americom shall maintain the spacecraft with an east/west longitudinal
       station keeping tolerance of 0.05 degrees.

    2. SES Americom has 30 days from the date of this grant to decline the authorization
       as conditioned. Failure to respond within this period will constitute formal
       acceptance of the authorization as conditioned.

    3. This grant is issued pursuant to 47 C.F.R. 5 0.261 of the Commission's rules on
       delegated authority and is effective immediately. Petitions for Reconsideration
       under Section 1.106 or Applications for Review under Section 1.115 of the
       Commission's rules, 47 C.F.R. §§ 1.106 and 1.115, may be filed within 30 days
       of the date of the public notice announcing this action.




 Application was placed on Public Notice for filing on May 23,2008 (Report No. SAT-00525). No
comments were filed.

* IBFS File Nos. SAT-LOA-20050622-00133, amended by SAT-AMD-20050908-00 175, modified by
SAT-MOD-20071 128-00 165.


3- 16. Name of Contact Representative

                Name:            Karis A. Hastings, Esq,              Phone Number:                       202-637-5767
                Company: Hogan & Hartson LLP                          Fax Number:                         202-637-5910
                Street:          555 Thirteenth Street, NW            E-Mail:                             kahastings@hhlaw.corn
                                 Columbia Square
                City:            Washington                           State:                              DC
                Country:         USA                                  Zipcode:                            20004-
                Attention:                                            Relationship:                       Legal Counsel


CLASSIFICATION OF FILING
    17. Choose the button next to the
    classification that applies to this filing for   @/A) b 1. Application for License of New Station
    both questions a. and b. Choose only one         @/A) b2. Application for Registration of New Domestic Receive-Only Station
    for 17a and only one for 17b.                       b3. Amendment to a Pending Application
                                                           b4. Modification of License or Registration
       Q   a l . Earth Station
                                                     b5. Assignment of License or Registration
           a2. Space Station                         b6. Transfer of Control of License or Registration
                                                     0 b7. Notification of Minor Modification
                                                      (N/A) b8. Application for License of New Receive-Only Station Using Non-U.S. Licensed
                                                     Satellite
                                                      @/A) b9. Letter of Intent to Use Non-U.S. Licensed Satellite to Provide Service in the United
                                                     States
                                                      @/A) b 10. Other (Please specify)
                                                        (N/A) b 11. Application for Earth Station to Access a Non-U.S.satellite Not Currently Authorized
                                                     :o Provide the Proposed Service in the Proposed Frequencies in the United States
                                                        (N/A) b 12. Application for Database Entry
                                                      0 b 13. Amendment to a Pending Database Entry Application
                                                     0 b14. Modification of Database Entry

2


      17c. Is a fee submitted with this application?
       IfYes, complete and attach FCC Form 159. If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
    Q   Governmental Entity       0 Noncommercial educational licensee
    0 Other(p1ease explain):
    17d.

    Fee Classification BFY - Space Station Modification(Geostationary)




    18. If this filing is in reference to an    19. If this filing is an amendment to a pending application enter both fields, if this filing is a
    existing station, enter:                    modification please enter only the file number:
    (a) Call sign of station:                   (a) Date pending application was filed:              (b) File number:
        S2676
                                                                                                     SATMOD2007112800165




3


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

    IXl a. Fixed Satellite
        b. Mobile Satellite
        c. Radiodetermination Satellite
    0d. Earth Exploration Satellite
    IXle. Direct to Home Fixed Satellite
I       f. Digital Audio Radio Service
        g. Other (please specify)


121. STATUS: Choose the button next to the applicable status. Choose        122. If earth station applicant, check all that apply.
 only one.                                                                  0     Using U.S. licensed satellites
 0 Common Carrier          Non-Common Carrier                               0Using Non-U.S.         licensed satellites

23. If applicant is providng JNTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
0 Connected to a Public Switched Network 0 Not connected to a Public Switched Network @ N/A
                                    ~~~~~~~~~~                     ~    ~




     24. FREQUENCY BAND(S): Place an 'X' in the box(es) next to all applicable frequency band(s).
      a. C-Band (4/6 GHz)   b. Ku-Band (12/14 GHz)
        c.Other (Please specify upper and lower frequencies in MHz.)
           Frequency Lower: Frequency Upper: (Please specify additional frequencies in an attachment)




4


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
    Q   a. Fixed Earth Station
    Q   b. Temporary-Fixed Earth Station
    Q   c. 12/14 GHz VSAT Network
    Q   d. Mobile Earth Station
    @   e. Geostationary Space Station
    Q   f. Non-Geostationary Space Station
    Q   g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY
0 TransmitIReceive 0 Transmit-Only              0 Receive-Only         N/A
"For Space Station applications, select N/A."




5


PURPOSE OF MODIFICATION

27. The purpose of this proposed modification is to: (Place an 'X' in the box(es) next to all that apply.)


    0a -- authorization to add new emission designator and related service
        b - authorization to change emission designator and related service
         c -- authorization to increase EIRP and EIRP density
    0d - authorization to replace antenna
    0e -authorization to add antenna
         f - authorization to relocate fixed station
         g -- authorization to change frequency(ies)
         h -- authorization to add fiequency
         i -- authorization to add Points of Communication (satellites & countries)
    0j -- authorization to change Points of Communication (satellites & countries)
         k - authorization for facilities for which environmental assessment and
radiation hazard reporting is required
         1 -- authorization to change orbit location
         m - authorization to perform fleet management
    0n    -- authorization to   extend milestones
    0o    --   Other (Please specifj)




6


ENVIRONMENTAL POLICY

28. Would a Commission grant of any proposal in this application or amendment have a significant environmental         Q   Yes   No
impact as defined by 47 CFR 1.1307? If YES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission’s rules, 47 C.F.R. 1.1308 and 1.131 1, as an exhibit to this app1ication.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
aeronautical fixed radio station services are not required to respond to Items 30-34.

29. Is the applicant a foreign government or the representative of any foreign government?                             Q   Yes   No



30. Is the applicant an alien or the representative of an alien?                                                       Q   Yes   No   0 N/A



3 1. Is the applicant a corporation organized under the laws of any foreign government?                                Q   Yes   No   0 N/A



32. Is the applicant a corporation of which more than one-fifth of the capital stock is owned of record or voted by    0 Yes     No   0 N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?




7


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          e   Yes    Q    No   Q   N/A
one-fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?



34. If any answer to questions 29, 30, 3 1, 32 andor 33 is Yes, attach as an exhibit an identification of the aliens or   Exhibit
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS

35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules?                                  Q     Yes        No
If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license              Q     Yes        No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.




8


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling   Q   Yes   No
the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,       Q   Yes   No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition?IfYes, attach as an exhibit, an explanation of circumstances




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.




9


41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is                Yes     0 No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti-Drug Act of
1988,21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.



42a. Does the applicant intend to use a non-U.S. licensed satellite to provide service in the United States? IfYes,         Q   Yes         No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?



43. Description. (Summarize the nature of the application and the services to be provided). (If the complete description does not appear in this
lox, please go to the end of the form to view it in its entirety.)
     Request to assign AMC-21              (call sign S 2 6 7 6 ) to the 1 2 4 . 9 WL orbital location.




rechnical Narrative




10


43a. Geographic Service Rule Certification
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
                                                                                                                              elA
coverage requirements specified in 47 C.F.R. Part 25.

By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.

                                                                                                                              Q C
By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.



CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.




11


44. Applicant is a (an): (Choose the button next to applicable response.)

 Q    Individual
 0 Unincorporated Association
 Q    Partnership
      Corporation
 0 Governmental Entity
 Q    Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Nancy J. Eskenazi                                                      Vice President & Assoc. General Counsel



            WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                     (U.S. Code, Title 18, Section lOOl), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                  (U.S. Code, Title 47, Section 3 12(a)(l)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




12


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER
1,1995,44 U.S.C. SECTION 3507.




13


                                        Attachment
                         IBFS File No. SAT-MOD-20080520-00107
                                       July 30,2008

SES Americom, Inc. (“SES Americom”) request, IBFS File No. SAT-MOD-20080520-
00107,’ IS GRANTED. Accordingly, SES Americom is authorized to operate its Fixed
Satellite Service (FSS) space station, AMC-21 (Call Sign: S2676), at the 124.9’ W.L.
orbital location using the 14.0- 14.5 GHz (Earth-to-space) and 11.7-12.2 GHz (space-to-
Earth) conventional Ku-band frequencies. Other than operating AMC-2 1 at a slight
offset from original authorization at 125O W.L orbital location, the conditions contained
in the prior authorizations2 for the AMC-21 space station continue to apply. This
authorization is subject to the terms of the application, the previously authorized
technical specifications for AMC-2 1 for operational parameters other than orbital
location, the conditions of this attachment, and the Federal Communication
Commission’srules.

    1. SES Americom shall maintain the spacecraft with an east/west longitudinal
       station keeping tolerance of 0.05 degrees.

    2. SES Americom has 30 days from the date of this grant to decline the authorization
       as conditioned. Failure to respond within this period will constitute formal
       acceptance of the authorization as conditioned.

    3. This grant is issued pursuant to 47 C.F.R. § 0.261 of the Commission’s rules on
       delegated authority and is effective immediately. Petitions for Reconsideration
       under Section 1.106 or Applications for Review under Section 1.115 of the
       Commission’s rules, 47 C.F.R. 55 1.106 and 1.115, may be filed within 30 days
       of the date of the public notice announcing this action.




’Application was placed on Public Notice for filing on May 23,2008 (Report No. SAT-00525). No
comments were filed.

 IBFS File Nos. SAT-LOA-20050622-00 133, amended by SAT-AMD-20050908-00 175, modified by
SAT-MOD-2007 1128-00165,


                                     Before the
                      FEDERAL COMMUNICATIONS COMMISSION
                               Washington, D.C. 20554


In the Matter of                                          )
                                                          )
SES AMERICOM, INC.                                        )     File No. SAT-MOD-
                                                          1
Application for Modification of AMC-2 1                   1
Fixed-Satellite Space Station License                     )


                          APPLICATION OF SES AMERICOM, INC.

                SES Americom, Inc. (“SES Americom”) hereby requests modification of its

license for the AMC-21 fixed-satellite space station (call sign S2676) to assign the satellite to the

124.9”W.L. orbital location. SES Americom seeks to operate AMC-21 at a slight offset in order

to simplifL stationkeeping at the nominal 125”W.L. orbital position by eliminating any overlap

of the stationkeeping volumes of AMC-2 1 and Intelsat’s Galaxy 14. Grant of the instant request

will facilitate safe joint operation of the satellites, and therefore serve the public interest. A

completed FCC Form 3 12 and a technical appendix are attached in support of this application.

                SES Americom was granted a Commission license to launch and operate the

AMC-2 1 Ku-band expansion satellite in September 2005.1 In its application for the license, SES

Americom indicated that prior to launch of the spacecraft, SES Americom might seek an offset

from 125”W.L. in order to simplifL stationkeeping.2 SES Americom has constructed AMC-21




1
        See File Nos. SAT-LOA-20050622-00133; SAT-AMD-20050908-00175 (Int’l Bur. Sat.
Div., grant-stamped Sept. 16,2005). The Commission recently granted a modification of the
license to reflect a change in the beam configuration of the satellite. See File No. SAT-MOD-
20071 128-00165 (Int’l Bur. Sat. Div., grant-stamped May 16,2008).
2
        File No. SAT-LOA-20050622-00133, Narrative at 1 n. 1 .


on an accelerated schedule, and launch is scheduled to occur during late July or early August of

this year.

               SES Americom has been in discussions with Intelsat, which is licensed to operate

Galaxy 14 at 125.0" W.L. and Galaxy 12 at 125.1' W.L. Intelsat also operates the satellites with

Ku-band payloads that are adjacent to the 125" W.L. orbital location on either side, Galaxy 10R

at 123" W.L. and Galaxy 13/Horizons 1 at 127" W.L. Intelsat has agreed to SES Americom's

proposal to seek assignment of AMC-21 to 124.9" W.L., which will avoid an overlap in

stationkeeping volumes at 125" W.L. and will have no material effect on the interference

environment for the adjacent Intelsat satellites. Accordingly, grant of the instant modification

will not adversely affect any other party and will promote the safe operation of satellites assigned

to the same nominal location.

               For the foregoing reasons, SES Americom requests that the Commission modify

the AMC-21 license to assign the spacecraft to 124.9" W.L.

                                              Respecthlly submitted,

                                              SES Americom, Inc.

                                              By: /s/ Nancy J: Eskenazi
                                                 Nancy J. Eskenazi
Of Counsel                                       Vice President and
Peter A. Rohrbach                                   Associate General Counsel
Karis A. Hastings                                SES Americom, Inc.
Hogan & Hartson L.L.P.                           Four Research Way
Washington, D.C. 20004-1 109                     Princeton, NJ 08540
Tel: (202) 637-5600

Dated: May 20,2008




                                                 2


                                 Technical Appendix

1.     Introduction
This technical appendix is submitted in support of SES Americom's modification
application seeking assignment of the AMC-21 Ku-band spacecraft to 124.90" W.C.
instead of 125" W. L. SES Americom incorporates by reference herein the technical
information it has already provided with respect to AMC-21,' and provides here
technical information that is changing as a result of the modification.

2.      Gain Contours
SES Americom is not submitting new contour maps with this application. The proposed
shift in orbital location from 125" W.L. to 124.9" W.L. will produce no visible change in
the gain contours from the maps already on file.

3.    Link Budgets and Interference Analysis
The nearest operational Ku-band satellites to 125' W.L. are Intelsat's Galaxy 10R at
123" W.L. and Intelsat's Galaxy 13/Horizons 1 at 127" W.L.

SES Americom has previously submitted interference analyses to the FCC
demonstrating that operation of AMC-21 in the Ku-band was compatible with adjacent
satellites and with the Commission's two-degree spacing requirements. The proposed
offset operation of AMC-21 will not cause any material change to the interference
environment. The proposed offset would result in AMC-21 moving slightly closer to
Galaxy IOR, but the resulting change in the interference environment will be negligible.
Furthermore, SES Americom has coordinated the proposed reassignment of AMC-21 to
124.9' W.L. with Intelsat, which has agreed to the offset.

As shown in the table below, SES Americom has calculated that implementation of the
proposed offset would result in a change of 0.58 dB in the interference environment of
two-degree compliant earth stations communicating in the Ku-band with Galaxy IOR at
123" W.L.




                     ~~~




1
    See File Nos. SAT-LOA-20050622-00133; SAT-AMD-20050908-00175; SAT-
MOD-20071128-00165.


                                                        123" W.L.
           CurrentlvAssiqned Position (125)
             Closest Offset Angle, taking into
           account 0.05 degree stationkeeping              1.9

                 Gain* (1) @ Offset angle               22.03 dB

           Proposed Orbital Position (124.9)
            Closest Offset Angle, taking into
           account 0.05 degree stationkeeping              1.8

                 Gain (2)*@ Offset angle                22.62 dB

                   A (Gain(?)- Gain (2))                -0.58dB

            Gain of a 29-25 log (theta) compliant
           intenna

Given that the proposed offset operation of AMC-21 will not result in any material
change to the interference environment with respect to AMC-21 and existing or future
adjacent satellites, no additional link budget analysis is provided herein. In the unlikely
event that any future concerns arise concerning operations of AMC-21 at the proposed
offset location, SES Americom will coordinate as necessary with the adjacent operators
in order to arrive at a mutually satisfactory solution.

4.     Orbital Debris Mitigation
This section supplements the information provided in the original AMC-21 application
concerning the elements required under Section 25.114(d)(14) of the Commission's
Rules.

5 25.114(d)(14)(i): SES Americom has assessed and limited the amount of debris
released in a planned manner during normal operations of AMC-21.

SES Americom has also assessed and limited the probability of the space station
becoming a source of orbital debris by collisions with small debris or meteoroids that
could cause loss of control and prevent post-mission disposal. SES Americom requires
that spacecraft manufacturers assess the probability of micrometeorite damage that can
cause any loss of functionality. This probability is then factored into the ultimate
spacecraft probability of success. Any significant probability of damage would need to
be mitigated in order for the spacecraft design to meet SES Americom's required
probability of success of the mission. SES Americom has taken steps to limit the effects
of any collisions through shielding, the placement of components, and the use of
redundant systems.

§ 25.114(d)(14)(ii): SES Americom has assessed and limited the probability 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


                                                    2


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
probability of occurrence. Each subsystem is analyzed for potential hazards, and the
Safety Design Package is provided for each phase of the program running from design
phase, qualification, manufacturing and operational phase of the spacecraft. Also, the
spacecraft manufacturer generates a Failure Mode Effects and Criticality Analysis for
the spacecraft to identify all potential mission failures. The risk of accidental explosion
is included as part of this analysis. This analysis indicates failure modes, possible
causes, methods of detection, and compensating features of the spacecraft design.

The design of the AMC-21 spacecraft is such that the risk of explosion is minimized
both during and after mission operations. In designing and building the spacecraft, the
manufacturer took steps to ensure that debris generation will not result from the
conversion of energy sources on board the satellite into energy that fragments the
satellite. All propulsion subsystem pressure vessels, which have high margins of safety
at launch, have even higher margins in orbit, since use of propellants and pressurants
during launch decreases the propulsion system pressure. Burst tests are performed on
all pressure vessels during qualification 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, will be monitored by telemetry.

§ 25.1 14(d)(l4)(iii): SES Americom has assessed and limited the probability of the
space station becoming a source of debris by collisions with large debris or other
operational space stations. Specifically, SES Americom has assessed the possibility of
collision with satellites located at, or reasonably expected to be located at, the
requested orbital location or assigned in the vicinity of that location.

The instant application seeks authority for operation of AMC-21 at the 124.9' W.L.
orbital location. lntelsat is licensed to operate Galaxy 14 at 125.0° W.L. and Galaxy 12
at 125.1O W.L. Northrop Grumman Space & Mission Systems Corporation has a
pending application to operate a geostationary satellite at 125' W.L. SES Americom is
not aware of any other FCC- or non-FCC licensed spacecraft that are operational or
planned to be deployed at 125' W.L. or to nearby orbital locations such that there would
be an overlap with the requested stationkeeping volume of AMC-21.

5 25.114(d)(l4)(iv):   Post-mission disposal of the satellite from operational orbit will be
accomplished by carrying out maneuvers to a higher orbit. SES Americom plans to
maneuver AMC-21 to a disposal orbit with a minimum perigee of 268 km above the
normal operational altitude. The proposed disposal orbit altitude complies with the
altitude resulting from application of the IADC formula based on the following
calculation:
              Area of the satellite (average aspect area): 25 m2
              Mass of the spacecraft: 1144 kg


                                             3


              CR(solar radiation pressure coefficient): 1.5

Therefore the Minimum Disposal Orbit Perigee Altitude, as calculated under the IADC
formula is:

36,021 km + (1000 x CRx N m ) = 36,054 km, or 268 km above the GSO arc
(35,786 km)

SES Americom intends to reserve 7 kg of fuel in order to account for post-mission
disposal of AMC-21. SES Americom has assessed fuel gauging uncertainty and has
provided an adequate margin of fuel reserve to address the assessed uncertainty.

5.     Schedules
As discussed above, the proposed reassignment of AMC-21 to offset the satellite by 0.1
degrees from 125" W.L. will not result in any material changes to the spacecraft's
operating characteristics 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 AMC-21's operation. In similar
cases involving requests for slight offsets from the nominal orbital position, the Satellite
Division has not required the submission of a new Schedule S.* Accordingly, SES
Americom is not filing a new Schedule S with this application. SES Americom will
nevertheless prepare and submit a Schedule S if requested to do so by the Satellite
Division.




       See, e.g., File No. SAT-MOD-20040405-00076 (PanAmSat request for authority
to operate SBS-6 at 74.05" W.L. rather than 74.0" W.L.).


                                            4


                     DECLARATION OF KRlSH JONNALAGADDA

              I, Krish Jonnalagadda, hereby certify under penalty of perjury that I am the
technically qualified person responsible for preparation of the technical information
contained in the foregoing exhibit; that I am familiar with the technical requirements of
Part 25; and that I 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 belief.

                                                /s/ Krish Jonnalaaadda
                                                Manager, Satellite Market Development
                                                SES Americom, Inc.

Dated: May 20, 2008




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Document Created: 2008-07-30 13:18:42
Document Modified: 2008-07-30 13:18:42

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