Attachment AMC-7 Ltr re Relaxat

AMC-7 Ltr re Relaxat

LETTER submitted by SES Americom, Inc.

Letter

2015-08-10

This document pretains to SAT-MOD-20150309-00010 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015030900010_1099107

SatCom Law LLC 1317 F St. NW, Suite 400 Washington, D.C. 20004 T 202.599.0975 www.satcomlaw.com August 10, 2015 By Electronic Filing Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12th Street, S.W. Washington, D.C. 20554 Re: Increased North-South Stationkeeping Tolerance for AMC-7 (Call Sign S2155) Dear Ms. Dortch: SES Americom, Inc. (“SES”), by its attorney and pursuant to Section 25.280(a) of the Commission’s rules, 47 C.F.R. § 25.280(a), hereby advises the Commission that its AMC-7 spacecraft will operate in an expanded north-south stationkeeping volume at the 135° W.L. orbital location. SES has determined that relaxation of the north-south stationkeeping parameters for AMC-7 will facilitate safe co-location of the satellite with AMC-10. 1 SES accordingly will allow AMC-7 periodically to exceed the +/ 0.05 degree north-south 2 stationkeeping tolerance specified in the most recent AMC-7 application, but will maintain AMC-7 within a +/ 0.1 degree north-south volume. At 135° W.L., AMC-7 is being flown in formation with AMC-10, which is constrained in its ability to perform inclination maneuvers during eclipse and solstice periods. Because of these constraints, the AMC-10 orbit is planned so that AMC-10 will begin an eclipse or solstice period at one side of the inclination window and end at the other. During times when AMC-10 is not able to perform inclination maneuvers, the need to maintain sufficient separation between AMC- 10 and AMC-7 will periodically cause AMC-10 to “chase” AMC-7 outside the +/ 0.05 degree north-south stationkeeping window. The flexibility to operate AMC-7 within an expanded north- south stationkeeping volume will enhance SES’s ability to safely fly its co-located spacecraft by permitting it to maintain an adequate separation distance between AMC-7 and AMC-10 during such periods. As discussed above, SES will not be terminating north-south stationkeeping of AMC-7, but will periodically be operating the spacecraft in a larger north-south stationkeeping volume. This 1 Earlier this year the Commission authorized SES to relocate AMC-7 to 135° W.L. so that it can provide back-up capacity as needed for AMC-10. See Call Sign S2155, IBFS File No. SAT- MOD-20150309-00010 (the “AMC-7 Modification”), grant-stamped May 21, 2015. 2 AMC-7 Modification, Schedule S item S3.f.

Ms. Marlene H. Dortch -2- August 10, 2015 change in the north-south stationkeeping practices is not projected to have any material impact on the expected end-of-life of AMC-7. Operations of AMC-7 within the expanded north-south stationkeeping volume will conform to the requirements of Section 25.280(b) of the Commission’s rules. Please address any questions regarding this matter to the undersigned. Respectfully submitted, /s/ Karis A. Hastings Karis A. Hastings Counsel for SES Americom, Inc. karis@satcomlaw.com cc: Stephen Duall Kathyrn Medley


Document Created: 2015-08-10 16:38:01
Document Modified: 2015-08-10 16:38:01
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