Attachment Narrative

This document pretains to SAT-MOD-20120629-00109 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012062900109_958105

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SAT-MOD-___________ ) Call Sign S2162 Application for Modification of AMC-3 ) Fixed-Satellite Space Station License ) APPLICATION OF SES AMERICOM, INC. SES Americom, Inc. (“SES Americom,” doing business as “SES”) hereby respectfully requests a modification of its license for the AMC-3 fixed-satellite space station to extend the satellite’s license term to September 30, 2017, and authorize the deorbit of the satellite at end of life. The requested extension will serve the public interest by enabling SES Americom to continue to offer services using AMC-3, thus promoting efficient use of satellite and orbital resources. Grant of deorbit authority for AMC-3 is consistent with Commission precedent and will facilitate orderly removal of AMC-3 to a disposal orbit at its end of life. A completed FCC Form 312 is attached, and SES incorporates by reference the technical information previously provided in support of AMC-3.1 AMC-3 is a hybrid C/Ku-band satellite that is licensed to operate pursuant to FCC authority at 67° W.L. with a license term that expires on September 30, 2012.2 SES requests a five-year extension of the AMC-3 license term to September 30, 2017. SES has calculated that there is sufficient fuel onboard the AMC-3 spacecraft for the spacecraft to continue providing reliable service during the proposed extended license term and to deorbit the spacecraft to a 1 See File Nos. SAT-LOA-19950215-00028 & SAT-MOD-20111220-00243. 2 See File No. SAT-MOD-20111220-00243 (grant-stamped June 28, 2012).

disposal altitude of 150 km above geostationary orbit (see below).3 As a result, extending the license term for AMC-3 will serve the public interest by allowing SES to continue to use the spacecraft to provide service to customers, promoting the efficient use of satellite and orbital resources. SES also seeks Commission authority to relocate AMC-3 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-3 was launched before March 18, 2002, the spacecraft is not subject to the minimum perigee requirements of Section 25.283(a).4 The Commission has previously authorized the use of a 150-km deorbit altitude for spacecraft launched prior to March 18, 2002.5 Calculations performed by SES 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-3 in a disposal orbit at its end of life. 3 SES developed the nominal lifetime prediction by estimating future fuel consumption, including for the planned deorbiting maneuvers, and taking into account fuel usage predictions based on data from previous maneuvers. SES’s calculations use lifetime models that incorporate uncertainty in a number of variables including initial tank loading, fuel usage efficiency and the oxidizer to fuel ratio. 4 See 47 C.F.R. § 25.283(d). 5 See, e.g., SES Americom, Inc., Application for Modification of Satcom SN-4 Fixed Satellite Space Station License, DA 05-1812, 20 FCC Rcd 11542 (Sat. Div. 2005) at ¶ 15. 2

For the foregoing reasons, SES seeks an extension of the AMC-3 license term and authority to deorbit the satellite 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 SatCom Law LLC SES Americom, Inc. 1317 F Street, N.W., Suite 400 Four Research Way Washington, D.C. 20004 Princeton, NJ 08540 Tel: (202) 599-0975 Dated: June 29, 2012 3


Document Created: 2012-06-29 15:39:28
Document Modified: 2012-06-29 15:39:28
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