Attachment SES Americom - Grant

This document pretains to SAT-MOD-20110718-00130 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2011071800130_921167

$2445 SAT—MOD—20110718—00130 1B2011003562 File # SAT—MoGDQ— 20(1071 8— 60130 SES Americom, Inc. AMC—1 Call Sign $2.445 Grant Date 10 A3/10 (or other identifier) Mme Term Dates / / Approved by OMB i From_10/1 5/11 To: 10/06/iG 3060—0678 CGRANTED* gsma y Date & Time Filed: Jul 18 2011 4:32:30:076PM 11‘-’{”“*“?‘"“11 Burcau_| Approved: File Number: SAT—MOD—20110718—00130 swith conditions FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM FCC Use Only FCC 312 MAIN FORM FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: License modification application for AMC—1 (call sign $2445) 1—8. Legal Name ofApplicant Name: SES Americom, Inc. Phone Number: (202)478—7183 DBA Fax Number: (202)478—7101 Name: Street: 1129 20th Street NW E—Mail: daniel.mah@ses.com Suite 1000 City: Washington State: DC Country: USA Zipcode: 20036 = Attention: Daniel C.H. Mah

Attachment to Grant IBFS File NO. SAT—MOD—20110718—00130 Call Sign 2445 October 13, 2011 The request of SES Americom, Inc. (SES Americom) for a modification of its authorization for the AMC—1 space station (Call Sign $2445), IBFS File No. SAT—MOD—20110718—00130, is granted. SES Americom is currently authorized to operate AMC—1 at the 103° W.L. orbital location in the 3700—4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), 11.7—12.2 GHz (space—to—Earth), and 14.0—14.5 GHz (Earth—to—space) frequency bands until October 15, 2011. We grant SES Americom an extension of its authorization to operate AMC—1 in these frequency bands at 103° W.L. by five years, until October 16, 2016. We also grant SES Americom authority to conduct telemetry, tracking and telecommand operations necessary to place AMC—1 into a disposal orbit at the end of its operational life. This authorization is granted in accordance with the technical specifications set forth in SES Americom‘s application, as modified, the rules of the Federal Communications Commission, and the following conditions: 1. SES Americom will continue to operate the AMC—1 space station at the 103° W.L. orbital location subject to the conditions in the prior authorization granted on March 1, 1994. See IBFS File No. SAT—MOD—19930805—00031. 2. We grant the request of SES Americom for waivers of Sections 25.114(d)(14)(ii) and 25.283(c) of the Commission‘s rules, 47 C.F.R. §§ 25.114(d)(14)(1i) and 25.283(c). These rules require an applicant to demonstrate that all stored energy will be vented at the spacecraft‘s end of life. AMC—1 is a Lockheed Martin A2100A model spacecraft that is not designed to vent all of its pressurized systems. Following launch of the spacecraft on September 8, 1996, two oxidizer tanks were permanently sealed by firing pyrotechnic valves. As a result, SES Americom states that at the end of AMC—1‘s operational life, there will be oxidizer remaining in the tanks that cannot be vented. SES Americom states that the residual oxidizer in AMC—1‘s two oxidizer tanks have masses of 7.9 kg each and volumes of 229 liters each at a temperature of 21° Celsius. The pressure of each of the oxidizer tanks is 18.75 bar at a temperature of 21° Celsius. We grant the requested waiver because AMC—1 was launched before Section 25.283(c) became effective and compliance would require direct retrieval of the spacecraft, which is not currently possible. In making this determination, however, we note that the information submitted in the application is not sufficient to support a finding that the intent of the rule would be satisfied by the described procedure for sealing the oxidizer tanks. 3. SES Americom is afforded thirty days from the date of release of this grant and authorization to decline this authorization as conditioned. Failure to respond within this period will constitute formal acceptance of the authorization as conditioned. 4. This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated authority, 47 C.F.R. 0.261, 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, 1.115, may be filed within 30 days of the date of the public notice indicating that this action was taken. [~~~~~*~~——~—| mis « "‘Spr—meap—zolloy|=_ noiro ecormn ,/_-f’c,c-um e Call Sign S2445_ Grant Date_ (O/3/(1 (or other identifiet) Term Dates e From ‘O/’S/'| 0; |O/No/l(a Fwih cendihons — 3. Puall | tional B ireau Approved: P vicf Sateileteo Qlicca Branch

9—16. Name of Contact Representative Name: Karis A. Hastings, Esq. Phone Number: (202)637—5767 Company: Hogan Lovells US LLP Fax Number: (202)637—5910 Street: 555 Thirteenth Street, NW E—Mail: karis.hastings@hoganlovells.com City: Washington State: DC Country: USA Zipcode: 20004— Attention: Relationship: CLASSIFICATION OF FILING

17. Choose the button next to the classification that applies to this filing for (N/A) b1. Application for License of New Station both questions a. and b. Choose only one (N/A) b2. Application for Registration of New Domestic Receive—Only Station for 17a and only one for 17b. 4 b3. Amendment to a Pending Application #&, b4. Modification of License or Registration 4 al. Earth Station b5. Assignment of License or Registration ) a2. Space Station b6. Transfer of Control of License or Registration «74 b7. Notification of Minor Modification (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States (N/A) b10. Other (Please specify) . (N/A) b11. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized to Provide the Proposed Service in the Proposed Frequencies in the United States (N/A) b12. Application for Database Entry 3 b13. Amendment to a Pending Database Entry Application C b14. Modification of Database Entry 17¢. 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). [d Governmental Entity 3 Noncommercial educational licensee {£74 Other(please 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: $2445 SATMOD2002110800204 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: Efl a. Fixed Satellite D b. Mobile Satellite D c. Radiodetermination Satellite E] d. Earth Exploration Satellite E e. Direct to Home Fixed Satellite D £. Digital Audio Radio Service D g. Other (please specify) 21. STATUS: Choose the button next to the applicable status. Choose |22. If earth station applicant, check all that apply. only one. D Using U.S. licensed satellites 474 Common Carrier @ Non—Common Carrier D Using Non—U.S. licensed satellites 23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these facilities: {3 Connected to a Public Switched Network 3 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). E a. C—Band (4/6 GHz) E b. Ku—Band (12/14 GHz) l:] c.Other (Please specify upper and lower frequencies in MHz.) Frequency Lower: Frequency Upper: (Please specify additional frequencies in an attachment) TYPE OF STATION 25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one. {74 a. Fixed Earth Station 4 b. Temporary—Fixed Earth Station £34 c. 12/14 GHz VSAT Network ¢34 d. Mobile Earth Station ) e. Geostationary Space Station 3 f. Non—Geostationary Space Station «74 g. Other (please specify) 26. TYPE OF EARTH STATION FACILITY: q4 Transmit/Receive g» Transmit—Only ;4 Receive—Only & N/A "For Space Station applications, select N/A."

PURPOSE OF MODIFICATION 27. The purpose of this proposed modification is to: (Place an °X" in the box(es) next to all that apply.) D a —— authorization to add new emission designator and related service D b — authorization to change emission designator and related service E] c —— authorization to increase EIRP and EIRP density D d —— authorization to replace antenna D e —— authorization to add antenna D f— authorization to relocate fixed station E] g —— authorization to change frequency(ies) D h —— authorization to add frequency D i —— authorization to add Points of Communication (satellites & countries) D j —— authorization to change Points of Communication (satellites & countries) k —— authorization for facilities for which environmental assessment and radiation hazard reporting is required E] 1 —— authorization to change orbit location D m —— authorization to perform fleet management D n —— authorization to extend milestones E o —— Other (Please specify)

ENVIRONMENTAL POLICY 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental «34 Yes g No impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of the Commission‘s rules, 47 C.F.R. 1.1308 and 1.1311, as an exhibit to this application.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 orthe representative of any foreign government? «y Yes @ No 30. Is the applicant an alien or the representative of an alien? ; Yes @ No 5; N/A 31. Is the applicant a corporation organized under the laws of any foreign government? C Yes @ No C 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 Cp Yes @ No C 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?

33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than @ Yes Cp No C 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 underthe laws of a foreign country? 34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or SES Exhibit A 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? @, Yes £4 No IfYes, 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 orlicense 3 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? IfYes, attach as an exhibit, an explination of circumstances.

37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling G‘ Yes @,No the applicant ever been convicted of a felony by any state or federal court? IfYes, 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, J 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 39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending C} Yes ,@No matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the 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 SES Exhibit B beneficiaries. Also list the names and addresses of the officers and directors of the Filer.

41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is Yes C 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, «4 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 box, please go to the end of the form to view it in its entirety.) SES Americom, Inc. hereby applies for a five—year extension, through October 15, 2016, of the license for its AMC—1 spacecraft, call sign $2445, and seeks authority to deorbit the satellite at its end of life. SES Narrative 10

43a. Geographic Service Rule Certification @ A By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic coverage requirements specified in 47 C.F.R. Part 25. , B 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. 4 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.) 3 Individual g73 Unincorporated Association ¢34 Partnership g@, Corporation C Governmental Entity g24 Other (please specify) 45. Name of Person Signing 46. Title of Person Signing Daniel C.H. Mah Regulatory Counsel ——> WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503). 12

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Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Application of SES AMERICOM, INC. File No. SAT—MOD— Call Sign $2445 For Modification of the AMC—1 License To Extend the License Term and Seek Deorbit Authority APPLICATION OF SES AMERICOM, INC. SES Americom, Inc. ("SES Americom") hereby applies for a five—year extension, through October 15, 2016, of the license for its AMC—1 spacecraft, call sign $2445, and seeks authority to deorbit the satellite at its end of life. Grant of the requested modification will serve the public interest by enabling SES Americom to continue to offer services using AMC—1, promoting efficient use of satellite and orbital resources. A completed FCC Form 312 is attached, and SES Americom incorporates by reference the technical information previously provided regarding operations of AMC—1.‘ In addition, SES Americom is providing information regarding orbital debris mitigation in the attached Technical Appendix. MODIFICATION AMC—1 commenced operations at 103° W.L. on October 15, 1996 and is licensed to operate in both the conventional C—band (3700—4200 MHz and 5925—6425 MHz) and the See File Nos. SAT—MOD—19930805—00031; SAT—MOD—19911114—00033.

. conventional Ku—band (11.7—12.2 GHz and 14.0—14.5 GHz)." The initial term of the AMC—1 license was ten years, but that term was extended to fifteen years when the Commission adopted revisions to Section 25.121 of its rules." By this application, SES Americom respectfully requests a further five—year extension of the spacecraft license term. Such an extension is warranted in the circumstances. SES Americom calculates that there is sufficient fuel onboard the AMC—1 spacecraft for the spacecraft to continue providing reliable service during the requested extended license term.* As a result, extending the license term for AMC—1 will serve the public interest by allowing SES Americom to continue to use the spacecraft to provide service to customers, promoting the efficient use of satellite and orbital resources. SES Americom also seeks Commission authority to relocate AMC—1 at its end of life to a disposal orbit with a minimum perigee altitude of at least 150 km above the geostationary arc. Because AMC—1 was launched before March 18, 2002, the spacecraft is not subject to the minimum perigee requirements of Section 25.283(a)." The Commission has previously authorized the use of a 150—km deorbit altitude for spacecraft launched prior to March See Applications of GTE Spacenet Corp. and GE American Communications, Inc., Order and Authorization, 9 FCC Red 1271 (Com. Car. Bur. 1994) (reassigning the GE—1 satellite from 85° W.L. to 103° W.L.). SES Americom was formerly known as GE American Communications, Inc., and AMC—1 was previously designated GE—1. 3 See 47 CFR. § 25.121(a). See also Amendment of the Commission‘s Space Station Licensing Rules and Policies, First Report and Order and Further Notice of Proposed Rulemaking, FCC 03—102, 18 FCC Red 10760 (2003) at [ 266 (clarifying that the increase of satellite license terms to fifteen years applies to existing licenses). * In estimating the satellite‘s fuel life, SES Americom has taken into account the possibility that the satellite may commence inclined orbit operations as permitted by Section 25.280(a) of the Commission‘s Rules during the requested extension period. °5 See 47 C.FR. § 25.283(d).

18, 2002.° Calculations performed by SES Americom indicate that at the conclusion of the requested extension period, the spacecraft will have sufficient fuel to reach the proposed deorbit altitude, barring a catastrophic failure of satellite components. Grant of the requested deorbit authority is consistent with Commission precedent and will facilitate placement of AMC—1 in a disposal orbit at its end of life. WAIVER REQUEST SES Americom seeks any necessary waiver of Sections 25.1 14(d)(14)(ii) and 25.283(c) of the Commission‘s rules in connection with the requested AMC—1 modification. Grant of the waiveris consistent with Commission policy: The Commission may waive a rule for good cause shown. Waiver is appropriate if special circumstances warrant a deviation from the general rule and such deviation would better serve the public interest than would strict adherence to the general rule. Generally, the Commission may grant a waiver of its rules in a particular case if the relief requested would not undermine the policy objective of the rule in question and would otherwise serve the public interest." Sections 25.114(d)(14)(ii) and 25.283(c) address requirements relating to venting stored energy sources at the spacecraft‘s end of life." AMC—1 is a Lockheed Martin A2100A model spacecraft and was constructed and launched before the venting requirement in Section 25.283(c) was even proposed. As described in more detail in the attached Technical Appendix, the oxidizer tanks on the spacecraft were sealed following completion of the launch 6 See, eg., SES Americom, Inc., Application for Modification of Satcom SN—4 Fixed Satellite Space Station License, DA 05—1812, 20 FCC Red 11542 (Sat. Div. 2005) at «[ 15. ‘ PanAmSat Licensee Corp., 17 FCC Red 10483, 10492 (Sat. Div. 2002) (footnotes omitted). 8 Section 25.283(c) contains the substantive venting requirement, and Section 25.114(d)(14)(i1) requires applicants to submit information that addresses "whether stored energy will be removed at the spacecraft‘s end of life." 47 C.F.R. § 25.114(d)(14)(i).

phase and will therefore retain residual pressure at end of life. Given the spacecraft design, it is physically impossible for SES Americom to vent the oxidizer tanks in order to comply with Section 25.283(c). Under Commission precedent, grant of a waiver is warranted. In a number of cases involving various spacecraft models with similarlimitations, the Commuission has waived Section 25.283(c) to permit launch and operation of spacecraft that do not allow for full venting of pressure vessels at end of life, based on a finding that modifying the space station design at a late stage of construction would pose an undue hardship.9 In the case of AMC—1, which was launched and operational before the venting requirements were even proposed, there is no question of bringing the satellite .into compliance with the rule. The Commussion has expressly recognized this, finding a waiver of Section 25.283(c) to be justified for in—orbit spacecraft that cannot satisfy the rule‘s requirements. For example, in a decision involving the SES Americom AMC—2 satellite, which like AMC—1 was launched before Section 25.283(c) was adopted, the Commussion waived the rule on its own motion, observing that venting the spacecraft‘s sealed oxidizer tanks "would require direct retrieval of the satellite, which is not currently possible.""" ° See, eg., EchoStar Satellite Operating Corp., File No. SAT—LOA—20071221—00183, Call Sign $2746, grant—stamped Mar. 12, 2008, Attachment at «| 4 (granting a partial waiver of Section 25.283(c) for AMC—14, a Lockheed Martin A2100 model spacecraft, on grounds that requiring modification of satellite would present an undue hardship); DIRECTY Enterprises LLC, File No. SAT—LOA—20090807—00086, Call Sign $2797, grant—stamped Dec. 15, 2009, Attachment at «[ 4 (same for DIRECTV 12, a Boeing 702 model spacecraft); PandAmSat Licensee Corp., File Nos. SAT—MOD—20070207—00027, SAT—AMD—20070716—00102, Call Sign $2237, grant—stamped Oct. 4, 2007, Attachment at «[ 7 (same for Intelsat 11, an Orbital Sciences Star model spacecraft). _ File No. SAT—MOD—20101215—00261, Call Sign $2134, grant—stamped Mar. 8, 2011, Attachment at [ 4. See also XMRadio Inc., File No. SAT—MOD—20100722—00165, Call Sign $2616, grant—stamped Oct. 14, 2010, Attachment at | 2 (waiving Section 25.283(c) for XM—4, a Boeing 702 model spacecraft, because "modification of the spacecraft would present an undue hardship, since XM—4 is an in—orbit space station and venting XM—4‘s helium and xenon tanks would require direct retrieval of the satellite, which is not currently possible").

The same practical obstacle is present here. Because AMC—1 is already in orbit, SES Americom can do nothing to enable full venting of residual pressure in the oxidizer tanks. Given this reality, waiver is clearly warranted,; there is no possible public interest benefit in requiring strict adherence to a rule with which the licensee is incapable of complying. CONCLUSION For the foregoing reasons, SES Americom hereby respectfully requests that the Commission modify the license for AMC—1 to extend its term through October 15, 2016 and authorize maneuvers to place AMC—1 in a disposal orbit at its end of life. 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 13"" Street, N.W. Four Research Way Washington, D.C. 20004—1109 Princeton, NJ 08540 Tel: (202) 637—5600 Dated: July 18, 2011

TECHNICAL APPENDIX 1. Introduction This technical appendix is submitted in support of the application of SES Americom, Inc. ("SES Americom") for a modification of its license for the AMC—1 spacecraft at 103° W.L. to extend the license term and seek authority to deorbit the satellite at its end of life. SES Americom incorporates by reference herein the technical information it has already provided with respect to AMC—1."" No changes to the satellite‘s operation are proposed. SES Americom provides here information regarding orbital debris mitigation. 2. Schedule S The proposed modification of the AMC—1 license will not result in any 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—1‘s operation. In similar cases involving requests extension of a satellite‘s license term, the Satellite Division has not required the submission of a Schedule S.!" Accordingly, SES Americom is not filing a 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. Orbital Debris Mitigation Statement This section provides the information required under Section 25.114(d)(14) of the Commission‘s Rules. §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—1. No debris is generated during normal on—station operations, and the spacecraft will be in a stable configuration. On—station operations require stationkeeping within the +/— 0.05 degree N—S and E—W control box, thereby ensuring adequate collision avoidance distance from other satellites in geosynchronous orbit. In the event that co—location of this and another satellite is required, use of the proven Inclination—Eccentricity (I—E) separation method can be employed. This strategy is presently in use by SES to ensure proper operation and safety of multiple satellites within one orbital box.. 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. The design of AMC—1 locates all sources of stored energy within the body of the structure, which provides protection from small orbital debris. SES Americom requires that spacecraft manufacturers assess the probability of micrometeorite damage that can cause any loss ‘! See File Nos. SAT—MOD—19930805—00031; SAT—MOD—19911114—00033. 2 See, e.g., File No. SAT—MOD—20090217—00024, grant—stamped May 5, 2009 (XM Radio request for extension of XM—1 satellite license).

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 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—1 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, are monitored by telemetry. At the end of operational life, after the satellite has reached its final disposal orbit, onboard sources of stored energy will be depleted or secured, and the batteries will be discharged. However, at the end of AMC—1‘s operational life, there will be oxidizer remaining in the tanks that cannot be vented. Following insertion of the spacecraft into orbit, the spacecraft manufacturer permanently sealed the oxidizer tanks by firing pyrotechnic valves. Information regarding the residual oxidizer in the tanks is as follows: ank olume re r . [deg C Oxidizer mass Ox 1 18.75 1 .9 Ox 2 18.75 1 .9 The oxidizer tanks are well shielded, and the residual pressure in the tanks will be well below their maximum rating. In the narrative portion of this application, SES Americom

requests any necessary waiver of Sections 25.114(d)(14)(ii) and 25.283(c) in connection with the residual oxidizer that will remain in these tanks at the end of the satellite‘s life. §25.114(d)(14)(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. Regarding avoidance of collisions with controlled objects, in general, if a geosynchronous satellite is controlled within its specified longitude and latitude stationkeeping limits, collision with another controlled object (excluding where the satellite is collocated with another object) is the direct result of that object entering the allocated space. The instant application seeks authority for continued operation of AMC—1 at the 103° W.L. orbital location. SES Americom is not aware of any other FCC— or non—FCC licensed spacecraft that are operational or planned to be deployed at 103° W.L. or to nearby orbital locations such that there would be an overlap with the requested stationkeeping volume of AMC—1. SES Americom uses the Space Data Center ("SDC®") system from the Space Data Association to monitor the risk of close approach of its satellites with other objects. Any close encounters (separation of less than 10 km) are flagged and investigated in more detail. If required, avoidance maneuvers are performed to eliminate the possibility of collisions. During any relocation, the moving spacecraft is maneuvered such that it is at least 30 km away from the synchronous radius at all times. In most cases, much larger deviation from the synchronous radius is used. In addition, the SDC system is used to ensure no close encounter occurs during the move. When de—orbit of a spacecraft is required, the initial phase is treated as a satellite move, and the same precautions are used to ensure collision avoidance. §25.114(d)(14)(iv): Post—mission disposal of the satellite from operational orbit will be accomplished by carrying out maneuvers to a higher orbit. The upper stage engine remains part of the satellite, and there is no re—entry phase for either component. The fuel budget for elevating the satellite to a disposal orbit is included in the satellite design. SES Americom plans to maneuver AMC—1 to a disposal orbit at end of life and has selected a target minimum perigee of 150 km above the normal operational altitude. SES Americom intends to reserve 10.3 kg of fuel in order to account for postmission disposal of AMC—1. SES Americom has assessed fuel gauging uncertainty and has provided an adequate margin of fuel reserve to address the assessed uncertainty.

AMC—1 is not subject to the minimum perigee requirement of Section 25.283(a) of the Commission‘s Rules because the satellite was launched prior to March 18, 2002. However, for the Commission‘s information, the disposal orbit altitude resulting from the IADC formula would be 287.6 km based on the following calculation: Area of the satellite (average aspect area): 55.15 m Mass of the spacecraft: 1306.15 kg CR (solar radiation pressure coefficient): 1.245 Therefore the minimum disposal orbit perigee altitude as calculated under the IADC formula is: > 36,021 km + (1000 x CR x A/m) = 36073.6 km, or 287.6 km above the GSO arc (35,786 1 km).

DECLARATION OF KRISH JONNALAGADDA 1, Krish Jonnalagadda, hereby certify under penalty of perjury that | 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: July 18, 2011


Document Created: 2011-10-13 16:32:42
Document Modified: 2011-10-13 16:32:42
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