Attachment Narrative

This document pretains to SAT-MOD-20170823-00121 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2017082300121_1265556

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SAT-MOD-___________ ) Call Sign S2134 Application for Modification of AMC-2 ) Fixed-Satellite Space Station License ) APPLICATION OF SES AMERICOM, INC. SES Americom, Inc. (“SES”) respectfully requests a modification of its license for the AMC-2 fixed-satellite space station to extend the satellite’s license term to December 31, 2020. The requested extension will serve the public interest by enabling SES to continue to offer service using AMC-2 at the nominal 85° W.L. orbital location, promoting efficient use of spectrum and orbital resources. A completed FCC Form 312 is attached, and SES incorporates by reference the technical information previously provided in support of AMC-2.1 MODIFICATION AMC-2 is a hybrid C/Ku-band satellite that is licensed to operate pursuant to Commission authority at 84.85° W.L. +/- 0.1 degrees with a license term that expires on December 31, 2017.2 SES requests an extension of the AMC-2 license term to December 31, 2020. SES has calculated that there is sufficient fuel onboard the AMC-2 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 mitigation plan the Commission has 1 The most recent technical data regarding AMC-2 was submitted in File Nos. SAT-MOD- 20170202-00011 and SAT-MOD-20160329-00029. 2 See File No. SAT-MOD-20160329-00029, Attachment to Grant at 1, granted June 23, 2016; see also File No. SAT-MOD-20170202-00011, Attachment to Grant at 2, ¶ 7, granted March 30, 2017.

previously approved for the satellite.3 In making these calculations, SES has assumed that standard stationkeeping maneuvers will be performed to maintain AMC-2 within its existing east-west stationkeeping tolerance.4 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-2 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. For the foregoing reasons, SES seeks a modification of the AMC-2 license to extend the satellite’s license term through December 31, 2020. Respectfully submitted, SES AMERICOM, INC. By: /s/ Petra A. Vorwig Of Counsel Karis A. Hastings Petra A. Vorwig SatCom Law LLC Senior Legal & Regulatory Counsel 1317 F Street, N.W., Suite 400 SES Americom, Inc. Washington, D.C. 20004 1129 20th Street, N.W., Suite 1000 Tel: (202) 599-0975 Washington, D.C. 20036 Tel: (202) 599-0975 Dated: August 23, 2017 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 AMC-2 operates at 84.85° W.L. +/- 0.1 degrees in inclined orbit. See File No. SAT-MOD- 20160329-00029, Technical Appendix at 7-8. 2


Document Created: 2017-08-23 16:35:44
Document Modified: 2017-08-23 16:35:44
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