Attachment Narrative

This document pretains to SAT-MOD-20170810-00115 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2017081000115_1259953

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SAT-MOD-___________ ) Call Sign S2445 Application for Modification of AMC-1 Fixed- ) Satellite Space Station License ) APPLICATION OF SES AMERICOM, INC. SES Americom, Inc. (“SES”) hereby respectfully requests modification of its license for the AMC-1 C/Ku-band fixed-satellite space station to reassign the spacecraft to 130.9º W.L. (“SES Modification Application”). Specifically, SES seeks authority to: (1) drift AMC-1 from its current position at 129.15° W.L. to 130.9º W.L. in the beginning of December 2017 in advance of the arrival of SES-15 at 129.15° W.L.; (2) allow SES to operate the AMC-1 Ku-band communications payload during the drift period; (3) maintain AMC-1 at 130.9° W.L. in inclined orbit using certain C-band and conventional Ku-band frequencies for Telemetry, Tracking and Command (“TT&C”);1 (4) operate AMC-1 in the C- and Ku-band frequencies at 130.9° W.L.; and (5) extend the license term for the satellite to June 30, 2021. AMC-1 will be replaced by SES-15 at 129.15° W.L. at the end of 2017 or early in 2018.2 Reassignment of AMC-1 in advance of SES-15’s arrival will serve the public interest by 1 The AMC-1 TT&C frequencies and nominal polarizations are as follows: Command: 6423.5 MHz (horizontal and vertical polarization; uplink) Telemetry: 3700.5 MHz (vertical polarization; downlink), 4199.5 MHz (vertical and horizontal polarization; downlink), and 12198.0 MHz (horizontal polarization; downlink). 2 SES Satellites (Gibraltar) Limited, (Call Sign S2951), File No. SAT-PPL-20160126-00007, granted July 12, 2016, and File No. SAT-MPL-20160718-00063, granted Dec. 14, 2016 (“SES- 15 Grant”).

allowing SES to continue serving customers currently using AMC-1 while SES-15 arrives at 129.15° W.L. and commences operations. As explained herein, transitioning traffic from a traditional wide beam satellite to a satellite with a spot beam configuration cannot be performed with co-located spacecraft as is traditionally done with two wide-beam satellites. Furthermore, operation of the AMC-1 Ku-band communications payload during the satellite’s drift to 130.9° W.L. will ensure services are not disrupted during the drift as there is no other available satellite to support the customer traffic while AMC-1 is drifting. Once SES-15 is fully operational at 129.15° W.L. and traffic is transferred to SES-15, AMC-1 will be available to provide additional Ku-band capacity at the nominal 131° W.L. orbital location and to supplement the C-band capacity currently provided by AMC-11 at that position. A completed Form 312 is attached, and SES incorporates by reference the technical information previously provided in support of AMC-1.3 In addition, SES is providing here technical information relating to the proposed modification to the AMC-1 license on Schedule S and in narrative form pursuant to Section 25.114 of the Commission’s Rules. MODIFICATION Re-assignment to 130.9º W.L.: AMC-1 is a U.S.-licensed hybrid C/Ku-band satellite that is assigned to 129.15° W.L. with a license term that expires on May 31, 2018.4 At that position, AMC-1 is operating under the ITU satellite network filings of the Gibraltar Administration. SES’s affiliate, SES Satellites (Gibraltar) Limited, has authority from the 3 The most recent technical information regarding AMC-1 is found in File No SAT-MOD- 20140730-00089; as amended by File No. SAT-AMD-20150219-00006. This application also incorporates by reference technical information submitted in File Nos. SAT-MOD-20110718- 00130 and SAT-MOD-20160816-00083. 4 See File No. SAT-MOD-20160816-00083, granted Oct. 5, 2016. 2

Gibraltar Administration to operate the SES-15 satellite at 129.15° W.L.5 SES-15 was launched on May 18, 2017 and is expected to arrive at 129.15° W.L. by the end of 2017 or early in 2018. The transfer of traffic from AMC-1 to SES-15 will be unusually complicated for several reasons. AMC-1 is a traditional wide-beam satellite, while SES-15 is a high throughput satellite with multiple spot beams. Dual illumination of the two spacecraft while co-located is not technically feasible as there will be interference between the wide area beam and the spot beams. In addition, the Ku-band payload of AMC-1 has a 26 degree polarization offset. Beyond interference issues, the customers’ network configuration is very different on the spot beam satellite, and customers need more time to properly configure and test their networks on SES-15 than on a traditional wide beam satellite. They will need to continue serving their end users during this configuration and testing period. In order to transition traffic with the least impact to customers, SES must provide overlapping services to customers from both orbital locations for an interim period. As a result, the satellites cannot be co-located with one another during the transition. SES therefore seeks authority to relocate AMC-1 to 130.9° W.L. before SES-15 is scheduled to arrive at 129.15° W.L. Additionally, because SES-15 will not yet have commenced operations at the time AMC-1 is relocated and there are no other satellites capable of taking over the service, SES seeks to operate the AMC-1 Ku-band communications payload during the drift to provide continuous service to certain aeronautical customers. The requested operating authority during drift is needed to prevent an interruption of service to those customers during the two weeks planned for AMC-1 to move from 129.15° W.L. to 130.9° W.L. 5 See SES-15 Grant. 3

Grant of the requested authority to relocate and operate AMC-1 will serve the public interest and is consistent with Commission precedent. The Commission has repeatedly observed that its policy is to allow “satellite operators to rearrange satellites in their fleet to reflect business and customer considerations where no public interest factors are adversely affected.”6 As the International Bureau has explained: the Commission attempts, when possible, to leave spacecraft design decisions to the space station licensee because the licensee is in a better position to determine how to tailor its system to meet the particular needs of its customers. Consequently the Commission will generally grant a licensee’s request to modify its system, provided there are no compelling countervailing public interest considerations.7 Here, the proposed reassignment will allow SES to make efficient use of AMC-1 in order to add Ku-band capacity and supplement C-band operations at the nominal 131° W.L. orbital location. Because SES intends to relocate AMC-1 in advance of SES-15’s arrival and proposes to operate the Ku-band communications payload during the drift, the relocation of AMC-1 will not have any impact on existing services. The Commission has previously authorized satellite operators to operate satellite communications payloads during drift maneuvers. For example, the Commission authorized XM Radio to continue operating the communications payload of the XM-4 satellite as it relocated 6 SES Americom, Inc., Order and Authorization, DA 06-757 (IB rel. Apr. 7, 2006) at 4, ¶ 8, citing Amendment of the Commission’s Space Station Licensing Rules and Policies, Second Report and Order, 18 FCC Rcd 12507, 12509, ¶ 7 (2003). 7 AMSC Subsidiary Corp., Order and Authorization, DA 98-493, 13 FCC Rcd 12316 (IB 1998) at 12318, ¶ 8 (footnote omitted). 4

from 115.0° W.L. to 115.25° W.L.8 The Commission has also recognized the public interest value in maintaining continuity of service.9 Reassignment of AMC-1 to 130.9º W.L. degrees will not adversely affect other operators. The only satellite positioned at the nominal 131° W.L. orbital location, AMC-11, is operated by SES, and SES will internally manage the joint stationkeeping of its spacecraft. Furthermore, there are no other satellites operating in the Ku-band fixed-satellite service frequencies between 129.15° W.L. and 130.9° W.L. and therefore, operations of the AMC-1 communications payload during the drift will not affect any other operators. SES will also follow standard industry practices for coordination of transmissions in advance of and during the relocation process. The Technical Appendix certifies that the AMC-1 network is compliant with Commission rules for operation in a two-degree spacing environment and is compatible with co- frequency satellites adjacent to the nominal 131° W.L. orbital location. License Extension: SES also requests a roughly three-year extension of the AMC-1 license term to June 30, 2021. SES has calculated that there is sufficient fuel onboard the AMC-1 spacecraft for the spacecraft to continue providing reliable service during the proposed extended license term and to deorbit the spacecraft consistent with the orbital debris 8 See XM Radio, Inc., (Call Sign S2616), File No. SAT-MOD-20100722-00165, granted Oct. 14, 2010. 9 See, e.g., DIRECTV Enterprises, LLC, Request for Special Temporary Authority to Conduct Telemetry, Tracking and Control During the Relocation of DIRECTV 1 to the 72.5º W.L. Orbital Location, Order and Authorization, DA 05-1890 (Sat. Div. rel. July 14, 2005) at ¶ 18 (granting STA to relocate spacecraft to a location where it will replace a satellite with failing solar panels “will enable DIRECTV to maintain continuity of DBS service to its customers”); DIRECTV Enterprises, LLC, Application for Authorization to Operate DIRECTV 5, a Direct Broadcast Satellite, at the 109.8º W.L. Orbital Location, Order and Authorization, DA 05-2654 (Sat. Div. rel. Oct. 5, 2005) at ¶ 8 (“DIRECTV’s proposal to provide DBS service from this location will serve the public interest, convenience and necessity in that it will ensure continuity of service to DIRECTV subscribers”). 5

plan the Commission has previously approved for the satellite.10 In making these calculations, SES has assumed inclined orbit operations at 130.9° W.L. and a stationkeeping tolerance of +/- 0.05 degrees. Furthermore, SES has made allowance in its fuel calculations for the possibility of a single relocation during the requested extension term of the AMC-1 license.11 The satellite’s overall health is good, with all satellite subsystems functioning nominally. There is no single point of failure in the satellite’s design; and there is no problem with the satellite’s TT&C links, including the back-up TT&C links. As a result, extending the license term for AMC-1 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. . 10 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. 11 Depending on whether there are any relocations during this time, and the distance and speed of such relocations, the expected lifetime of the satellite may be longer or shorter than estimated. In any case, SES will de-orbit the spacecraft to at least 150 km above the geostationary arc, regardless of the remaining term of the AMC-1 license. 6

CONCLUSION For the foregoing reasons, SES seeks modification of the AMC-1 license to reassign the spacecraft to 130.9º W.L. for operations in the C- and Ku- band frequencies and to extend the satellite’s license term, as described in the attached materials. Respectfully submitted, SES AMERICOM, INC. By: /s/ Petra A. Vorwig Of Counsel Petra A. Vorwig Karis A. Hastings Senior Legal & Regulatory Counsel SatCom Law LLC SES Americom, Inc. 1317 F Street, N.W., Suite 400 1129 20th Street, N.W., Suite 1000 Washington, D.C. 20004 Washington, D.C. 20036 Tel: (202) 599-0975 Tel: (202) 478-7143 Dated: August 10, 2017 7

TECHNICAL APPENDIX AMC-1 AT 130.9° W.L. 1

1.0 Overall Description (§25.114(d)(1)) This technical appendix is submitted in support of the modification application of SES Americom, Inc. (“SES”) seeking authority to relocate AMC-1 to 130.9° W.L. from its current orbital position of 129.15º W.L. SES incorporates by reference the technical information it has already provided with respect to AMC-1,1 and provides here technical information relating to operation of AMC-1 at 130.9° W.L. consistent with the proposed modification. AMC-1 is equipped with twenty-four 36 MHz C-band transponders and twenty-four 36 MHz Ku-band transponders. At 130.9° W.L., the spacecraft’s Ku-band transponders will provide coverage of the contiguous United States, Alaska, Hawaii, Mexico, and parts of Canada and the Caribbean. The C-band transponders will supplement and be available to provide back-up capacity for SES’s AMC-11 satellite at 131.0° W.L. The TT&C frequencies of AMC-1 are in C- band with a beacon in Ku-band. The Ku-band transponders have a 26° polarization shift away from nominal linear 0° and 90° polarizations.2 2.0 Schedule S (§25.114(c)) The Schedule S database is included with this filing. Note that the online Schedule S automatically rounds the orbital location to 131.0° W.L., but the requested orbital location is 130.9° W.L. Consistent with §25.114(c)(4)(vi)(A), the gain characteristics for the global horn antenna (“GBLH”) and (“GBLV”) are not provided in a GIMS-readable format with the Schedule S because the 8 dB contour does not fall on the Earth. In addition, the information for the 1 The most recent technical information regarding AMC-1 is found in File No SAT-MOD- 20140730-00089; as amended by File No. SAT-AMD-20150219-00006. See also File Nos. SAT-MOD-20160816-00083 & SAT-MOD-20110718-00130. 2 See GTE Spacenet Corp. and GE American Communications, Inc., 9 FCC Rcd 1271, 1273-74 (Com. Car. Bur. 1994). 2

minimum and maximum saturation flux densities is not applicable for the Global Horn Antenna, and as such, dummy values of -999.9 and -999 were entered in the Schedule S for the Min Saturation Flux Density and Max Saturation Flux Density, respectively. 3.0 TT&C frequencies and beams The telemetry and command subsystem consists of redundant receivers and transmitters which are able to operate through either an omnidirectional antenna system or through the communications antennas. Table 1 below shows the planned TT&C carrier center frequencies, polarizations and bandwidths through the communications antenna. Frequency, MHz Nominal polarization Command carriers (bandwidth: 800KHz, 1.2 MHz capture range) C-band 6423.5 V Beacons/Telemetry (bandwidth: 300 KHz) 3700.5 V C-band pair 4199.5 H Ku-band 12198 H Table 1: TT&C Carrier Frequencies and Polarizations through the Communications Antenna 3

Table 2 below shows the planned TT&C carrier center frequencies, polarizations and bandwidths through the Global Horn antenna. Frequency, MHz Nominal polarization Command carriers (bandwidth: 800KHz, 1.2 MHz capture range) C-band 6423.5 H Beacons/Telemetry (bandwidth: 300 KHz) 3700.5 V C-band pair 4199.5 V Table 2: TT&C Carrier Frequencies and Polarizations through the Global Horn Antenna 4.0 Certification with respect to two degree spacing levels (§25.140(a)) SES certifies that the AMC-1 downlink EIRP density will not exceed 3 dBW/4kHz for digital transmissions or 8 dBW/4kHz for analog transmissions in the C-band, nor will the downlink EIRP density exceed 14 dBW/4kHz in the Ku-band unless higher levels are coordinated with the operators of authorized co-frequency space stations at assigned locations within six degrees of 130.9° W.L. and except as provided in §25.140(d). SES also certifies that the associated uplink EIRP density levels in the C-band and in the Ku-band will not exceed the applicable envelopes in §25.218, §25.221(a)(1), §25.222(a)(1), §25.226(a)(1), or §25.227(a)(1) unless appropriately coordinated with operators of authorized co-frequency space stations at assigned locations within six degrees of 130.9° W.L. and except as provided in §25.140(d). 5.0 Maximum Theoretical Operation Levels AMC-1 will be operated consistent with coordination agreements with adjacent satellites. In any case, in the 11.7-12.2 GHz band, the downlink EIRP density of the AMC-1 digital carriers will not exceed -18 dBW/Hz; and in the 14-14.5 GHz band, the input power density of the uplink digital carriers of earth stations operating with AMC-1 will not exceed -45 dBW/Hz. In the 4

3700-4200 MHz band, the downlink EIRP density of the AMC-1 digital carriers will not exceed -30.0 dBW/Hz; and in the 5925-6425 MHz band, the input power density of the uplink digital carriers of earth stations operating with AMC-1 will not exceed -38.7 dBW/Hz. 6.0 Mitigation of Orbital Debris (§25.114(d)(14)) The information required under §25.114(d)(14) of the Commission’s Rules is already on file with the Commission and is incorporated by reference herein.3 The only change to that information is that SES proposes to move AMC-1 to the 130.9° W.L orbital location. At 130.9° W.L., AMC-1 will be in inclined orbit.4 SES is not aware of any other FCC- or non-FCC licensed spacecraft that are operational or planned to be deployed at 130.9° W.L. or to nearby orbital locations such that there would be an overlap with the requested stationkeeping volume of AMC-1. SES’s AMC-11 spacecraft operates at 131.0° W.L. with an east/west stationkeeping tolerance of ±0.05 degrees. 3 See File No. SAT-MOD-20110718-00130, Technical Appendix, Section 3. 4 AMC-1 began inclined orbit operation at 129.15°W.L and will continue operating at an inclined orbit at 130.9°W.L. The initial inclination will be 1.73 degrees, and the rate of change in inclination per year will be 0.8 degrees. The expected end-of-life of the satellite accounting for inclined orbit operation and the maneuvers specified under §25.283 of the Commission's rules is June 2021. Note that the Inclination Excursion or North/South Station-Keeping Tolerance is actually a range that will vary from 1.73 to 4.8 degrees. In the Schedule S database SES has put in 1.73 degrees since the field does not allow for a range. 5

DECLARATION I, Pascale Dumit, 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/_Pascale Dumit______ Pascale Dumit Manager, Spectrum Management and Development SES Americom, Inc. Dated: August 10, 2017 6


Document Created: 2017-08-10 11:24:58
Document Modified: 2017-08-10 11:24:58
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC