Attachment Attachment 1

This document pretains to SAT-MOD-20100525-00110 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2010052500110_819422

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


In the Matter of Application by                          )
                                                         )
SES AMERICOM, INC.                                       )    File No. SAT-MOD-___________
                                                         )    Call Sign S2156
For Modification of AMC-5                                )
Fixed-Satellite Space Station License                    )


                         APPLICATION OF SES AMERICOM, INC.

               SES Americom, Inc. (“SES Americom,” doing business as “SES WORLD

SKIES”1), hereby respectfully requests a modification of its license for the AMC-5 fixed-satellite

space station to assign the satellite permanently to 79.05º W.L., where it will serve as an in-orbit

spare. SES WORLD SKIES also requests drift authority to move the satellite to its new assigned

location from its current location of 78.95° W.L. Grant of the requested authority will simplify

stationkeeping at the nominal 79º W.L. orbital location and permit SES WORLD SKIES to make

efficient use of its space stations to provide service to customers.

               A completed FCC Form 312 is attached, and SES WORLD SKIES incorporates

by reference the technical information previously provided in support of AMC-5.2 In addition,

SES WORLD SKIES is providing information relating to the proposed modification to the

AMC-5 license in the attached technical appendix.




1
       On September 7, 2009, SES S.A. announced that the newly integrated operations of its
two indirect subsidiaries, New Skies Satellites B.V. and SES Americom would be conducted
under a single brand name, SES WORLD SKIES. The new brand name does not affect the
underlying legal entities that hold Commission authorizations or U.S. market access rights.
2
       See File Nos. SAT-MOD-20050609-00117; SAT-MOD-19980113-00002.


               SES WORLD SKIES currently operates two satellites at the nominal 79º W.L.

orbital location: AMC-5, a conventional Ku-band space station, is assigned to 78.95º W.L., and

Satcom C-3, a conventional C-band space station, is assigned to 79.05º W.L.3 SES WORLD

SKIES recently filed an application seeking authority to relocate its hybrid AMC-2 spacecraft to

78.95º W.L. to replace both AMC-5 and Satcom C-3 at the nominal 79º W.L. orbital location.4

SES WORLD SKIES intends to deorbit Satcom C-3 later this year, and in the interim is

separately requesting authority to relocate the spacecraft to 79.15º W.L. Once traffic has been

transferred from AMC-5 to AMC-2 and Satcom C-3 has been repositioned, SES WORLD

SKIES proposes to relocate AMC-5 to 79.05º W.L., the position that will be vacated by Satcom

C-3, and operate it there in inclined orbit. AMC-5 will thereafter serve as an in-orbit spare for

the Ku-band capacity of AMC-2.

               Accordingly, SES WORLD SKIES requests authority to relocate AMC-5 from

78.95º W.L. to 79.05º W.L. and to operate the Ku-band communications payload of AMC-5 at

the 79.05° W.L. location. Grant of such authority will enable operation of AMC-5, as needed, to

restore or supplement Ku-band capacity on AMC-2 at the nominal 79° W.L. orbital location.

Furthermore, relocating AMC-5 from 78.95º W.L. to 79.05º W.L. will eliminate any overlap of

the stationkeeping volumes of AMC-2 and AMC-5, facilitating safe operation of the satellites.

For these reasons, grant of the instant request will serve the public interest.

               As demonstrated in the technical appendix, relocation of AMC-5 will not

adversely affect any other operators. The small proposed shift in AMC-5’s orbital location will

have a de minimis effect on the interference environment in which adjacent satellites operate.

3
       The “conventional Ku-band” refers to the 11.7-12.2 GHz and 14.0-14.5 GHz frequencies.
The “conventional C-band” refers to the 3700-4200 MHz and 5925-6425 MHz frequencies.
4
       See File No. SAT-MOD-20100324-00056 (Call Sign S2134).


                                                  2


AMC-5 will be operated consistent with existing and future coordination agreements applicable

to SES WORLD SKIES’ operations at the nominal 79° W.L. orbital location, including the

coordination agreement addressing the Argentine Administration’s ITU filings at 81° W.L. SES

WORLD SKIES notes that the Venesat-1 satellite operates at 78° W.L. under a Uruguayan ITU

network filing that is lower in priority than the U.S. ITU filing at the nominal 79° W.L. location.

Coordination discussions with the Venesat-1 operator are in progress to ensure that operations at

78° W.L. will not negatively impact the co-frequency SES WORLD SKIES operations at the

nominal 79° W.L. orbital location.

               For the foregoing reasons, SES Americom seeks a modification of the AMC-5

license to assign the spacecraft to the 79.05º W.L. orbital location. SES Americom respectfully

requests action on this application by early July to enable timely completion of all contemplated

maneuvers.

                                              Respectfully submitted,

                                              SES AMERICOM, INC.

                                              By: /s/ Daniel C.H. Mah

Of Counsel                                       Daniel C. H. Mah
Karis A. Hastings                                Regulatory Counsel
Hogan Lovells US LLP                             SES Americom, Inc.
555 13th Street, N.W.                            Four Research Way
Washington, D.C. 20004-1109                      Princeton, NJ 08540
Tel: (202) 637-5600

Dated: May 25, 2010




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                                      Technical Appendix

1.     Introduction
This technical appendix is submitted in support of the application of SES Americom, Inc.
(“SES Americom,” doing business as “SES WORLD SKIES”) for a modification of its
license for the AMC-5 Ku-band spacecraft. SES WORLD SKIES seeks permanent
assignment of the spacecraft to 79.05° W.L. instead of 78.95° W.L. SES WORLD
SKIES incorporates by reference herein the technical information it has already
provided with respect to AMC-5,1 and provides here technical information that is
changing as a result of the proposed modification.

2.    Gain Contours
SES WORLD SKIES is not submitting new contour maps with this application. The
proposed shift in orbital location from 78.95° W.L. to 79.05° W.L. will produce no visible
change in the gain contours from the maps already on file.

3.      Link Budgets and Interference Analysis
An interference analysis was submitted to the FCC in connection with the initial
operation of AMC-5 at 79° W.L. demonstrating that operation of AMC-5 was compatible
with adjacent satellites and with the Commission’s two-degree spacing requirements.2
The proposed relocation of AMC-5 will not cause any material change to the
interference environment. Specifically, SES WORLD SKIES has calculated that
operation of AMC-5 at 79.05° W.L. rather than at the nominal 79° W.L. position
translates into a change of approximately 0.3 dB in the interference environment of two-
degree compliant earth stations communicating with a spacecraft at 77° W.L. or at
81° W.L., as shown in the table below.

                                                  77                 81
            Nominal Orbital Position (79)
                    Offset Angle                  2.00              2.00

                Gain (1) @ Offset angle           21.5              21.5

          Proposed Orbital Position (79.05)
                   Offset Angle                   2.05              1.95

                Gain (2) @ Offset angle           21.2              21.8


           Δ ( Gain(1) - Gain (2) )               0.3               -0.3

1
       See File Nos. SAT-MOD-20050609-00117; SAT-MOD-19980113-00002.
2
      File No. SAT-MOD-19980113-00002, Attachment C, Interference Analysis for
GE-5 Ku-Band Transponders.


Given that the proposed offset operation of AMC-5 will not result in any material change
to the existing interference environment with respect to AMC-5 and current or future
adjacent satellites, no link budget analysis is provided herein. SES WORLD SKIES will
operate AMC-5 in conformance with existing and future coordination agreements
applicable to operations at the nominal 79° W.L. orbital location, including its
coordination agreement with the Argentine Administration relating to operations at
81° W.L. In the unlikely event that any future concerns arise relating to operations of
AMC-5 at the proposed offset location, SES WORLD SKIES will coordinate with the
adjacent operators in order to arrive at a mutually satisfactory solution.3

4.     Schedule S
As discussed above, the proposed modification of the AMC-5 license 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-5’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.4 Accordingly, SES WORLD SKIES 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.




3
      As noted in the narrative, the Venesat-1 satellite operates at 78° W.L. under a
Uruguayan ITU network filing that is lower in priority than the U.S. ITU filing at the
nominal 79° W.L. location. Coordination discussions with the Venesat-1 operator are in
progress to ensure that operations at 78° W.L. will not negatively impact the co-
frequency SES WORLD SKIES operations at the nominal 79° W.L. orbital location.
4
       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.).

                                           2


                     DECLARATION OF KRISH 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 Jonnalagadda
                                                SES Americom, Inc.

Dated: May 25, 2010




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Document Created: 2010-05-25 18:09:57
Document Modified: 2010-05-25 18:09:57

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