Attachment New Skies - Correcte

New Skies - Correcte

DECISION submitted by IB, FCC

Grant permitted list

2013-07-12

This document pretains to SAT-PPL-20120717-00117 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2012071700117_1006688

                                                                    . GPpwtenp w/REsPET m PeemiTTED2012
                                                                                                    LsT07ONOfL; ofiEe REeauegs DEFERPED»®*+~
                                                                                                          17— 801 17
                                                                             mrnmmninatencommssmeetomne   Hile # SBT—PPL—
$2870       StAl'Il'-tPPLé28/120717-001 17       1B2012001693
New Skies Satellites    B.V.
                                                                         [
SES—6
                                                                         |                                Call Sign S$2870_ Grant Date o7 /2/13
                                                                         |                                (or other identifier)
                                                                         [

                                                                         !
                                                                                                     :                             Term Dates See              Approved by OMB
                                                                                                     _                  2 /1                . _condition             3060—0678
                                                                         |        crantep«                FoneHMeFIs_                    Ts codtion
            Date & Time Filed: Jul 17 2012 10:37:48:453AM                .|_lMicinational
                                                                                   Bureau_|               Approved:            §                s          f
           File Number: SAT—PPL—20120717—00117                        ¥with conditions                                           "r”p Yo ,.P‘v’)“ ea B ‘h
           Callsign/Satellite ID: $2870                              (@orsectea| O8/08/13)                                     Chief, Satellite Folgy Brane
                                     APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                                                    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:
           Market access for SES—6 at 40.5W
              1—8. Legal Name ofApplicant
                          Name:              New Skies Satellites B.V.                       Phone Number:                          202—478—7137

                          DBA Name:                                                         Fax Number:                             202—478—7101

                          Street:            1129 20th St. NW                               E—Mail:                                 daniel.mah@ses.com
                                             Suite 1000

                          City:              Washington                                      State:                                 DC
                          Country:           USA                                            Zipcode:                                20036           >
                          Attention:         Mr. Daniel Mah


                                            Attachment to Grant
                                   Application of New Skies Satellites B.V.
                                 IBFS File No. SAT—PPL—20120717—00117
                                               Call Sign $2870




        Addition of SES—6 to the C— and Ku—Band Permitted Space Station List at 40.5° W.L.

The petition of New Skies Satellites, B.V. (New Skies), IBFS File No. SAT—PPL—20120717—00117, to add
SES—6 (Call Sign $2870) at the 40.5° W.L. orbital location to the Commuission‘s C— and Ku—band
Permitted Space Station List (Permitted List) is GRANTED.‘ The operations of SES—6 addressed by this
grant are licensed by the Administration of the Netherlands. Accordingly, each U.S.—licensed earth
station with "ALSAT" or "Permitted List" designated as a point of communication is authorized to access
the SES—6 space station at 40.5° W.L. to provide Fixed—Satellite Service (FSS) 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, to, from, or within the United States, subject to the parameters set forth
in the earth station license. In addition, New Skies‘ request is granted to use SES—6 to provide direct—to—
home FSS in these conventional C— and Ku—bands (1) within the United States, and (2) between the
United States and the Netherlands, current European Union member states," Mexico, Brazil, the
Netherlands Antilles, Guatemala, Honduras, Nicaragua, Bermuda, the British Virgin Islands, and the
Cayman Islands." Communications between U.S.—licensed earth stations and the SES—6 space station
must be in accordance with the terms, conditions, and technical specifications contained in New Skies‘
petition, the Federal Communications Commission‘s rules not waived herein, and the following
conditions:

       1.       Communications between U.S.—licensed earth stations and the SES—6 space station at the
40.5° W.L. orbital location must comply with all existing and future space station coordination
agreements reached between the Netherlands and other Administrations.
        2.       Communications between U.S.—licensed earth stations and the SES—6 space station at the
40.5° W.L. orbital location are conditioned on New Skies maintaining the SES—6 space station with an
east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.

        3.      New Skies‘ request for a waiver of Section 25.202 (g) of the Commission‘s rules, 47
C.F.R. § 25.202(g), to permit U.S. earth stations to receive a beacon signal of 3947.5 MHz from SES—6 at




‘ The Petition was placed on Public Notice on August 31, 2012. Report No. SAT—00893, Public Notice (Int‘l Bur.,
rel. Aug. 31, 2012). No comments were filed. On June 13, 2013, New Skies notified the Commission that the SES—
6 space station had been successfully launched on June 3, 2013. Letter from Daniel C.H. Mah, Regulatory Counsel
for New Skies Satellites B.V., to Marlene H. Dortch, Secretary, FCC, dated June 13, 2013.

> The current E.U. member states are: Austria, Belgium, Bulgaria, Cyprus, Czech Republic, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands,
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the United Kingdom.

* As part of its petition, New Skies also requested that U.S. earth stations be permitted to conduct telemetry,
tracking, and command (TT&C) operations for SES—6 at 40.5° W.L. using the following center frequencies in the
conventional C— and Ku—bands: 11.7005 GHz, 11.701 GHz (space—to—Earth); 3947.5 MHz ,12.1995 GHz, 14.00
GHz, and 14.499 GHz (Earth—to—space). This request will be addressed in modifications of earth station licenses that
seek to add the SES—6 space station at 40.5° W.L. as a point of communication. See IBFS File Nos. SES—MFS—
20130603—00461 (EO0O0102) and SES— MFS—20130604—00470 (EQOO0696).


                                           Attachment to Grant
                                  Application of New Skies Satellites B.V.
                                IBFS File No. SAT—PPL—20120717—00117
                                             Call Sign $2870


40.5° W.L. is granted, as conditioned.* Section 25.202(g) requires that TT&C operations be conducted at
the edges of the allocated bands. SES—6 is intended as a replacement for New Skies‘ NSS—806 space
station currently located at 40.5° W.L.," which has both telemetry and beacon frequencies allocated in the
middle of the C—band and which have been coordinated with adjacent operators, including U.S.—licensed
satellites, for many years.© New Skies argues that the use of a beacon in the middle of the C—band for
SES—6 simplifies pointing and tracking for those earth stations that currently track NSS—806 and that will
be transitioned to SES—6. We grant the requested waiver of Section 25.202(g) subject to the following
conditions:
                 a.      The use of a beacon signal at 3947.5 MHz by SES—6 at 40.5° W.L. must be
                 pursuant to any existing or future coordination agreements with adjacent satellite
                 operators operating in the C—band,;
                 b.      The use of a beacon signal at 3947.5 MHz by SES—6 at 40.5° W.L.is solely on an
                 unprotected and non—harmful interference basis; and
                 c.      New Skies must accommodate future space station networks that are compliant
                 with Section 25.202 (g).
        4.      New Skies‘ request for a waiver of Section 25.210(a)(1) of the Commission‘s rules, 47
C.F.R. § 25.210(a)(1), is granted, as conditioned. Section 25.210(a)(1) requires that C—band operations
use orthogonal linear polarization. Like NSS—806, SES—6 uses circular polarization for its C—band
communications payload; additionally, one of SES—6‘s conventional C—band tracking beacons uses linear
polarization, but the planes are rotated 45 degrees relative to the equatorial plane. This waiver is granted
based upon a finding that there is currently no potential for harmful interference from operations at this
location with circular polarization and that there would be an undue hardship to customers if they
were required to reconfigure existing circularly—polarized antennas to operate with linear
polarization. As a condition of this waiver, New Skies must accommodate future space station networks
that comply with Section 25.210(a)(1). Further, New Skies must operate SES—6 pursuant to any existing
or future coordination agreements for this location.
         5.       Section 25.210 (a) (3) of the Commission‘s rules, 47 C.F.R. §25.210(a)(3), is granted, as
conditioned. Section 25.210(a)(3) requires FSS space stations using the C—band to be capable of
switching polarization sense upon ground command. The Commission requires polarity—switching
capability for two reasons: (1) to provide U.S.—licensed space stations with the flexibility to operate at
different orbital locations, and (2) to mitigate potential interference between adjacent fixed space station
systems transmitting analog television signals. See Telesat Canada, Order, 22 FCC Red 588, 592, {10
(Int‘l Bur. 2007). This waiver is based upon a finding that the ability to switch polarization is not
currently necessary to protect other space stations at adjacent orbital locations from harmful interference
because the SES—6 space station‘s operations will be in compliance with existing coordination
agreements. As a condition of this waiver, New Skies must accommodate future space station networks
that comply with Section 25.210(a)(3). Further, New Skies must operate SES—6 pursuant to any existing
or future coordination agreements for this location.

* We do not address in this grant of market access New Skies‘ request concerning use of a second beacon signal at
4500.1 MHz. See New Skies Petition at 12 n.35.
° New Skies Satellites, N.V., Memorandum Opinion and Order, 16 FCC Red 7482 (Sat. Div. 2001). See also New
Skies Satellites, N.V., IBFS File No. SAT—MPL—20110923—00187, granted June 28, 2012.

° New Skies Satellites, N.V., 16 FCC Red at [ 70—71.


                                         Attachment to Grant
                                Application of New Skies Satellites B.V.
                              IBFS File No. SAT—PPL—20120717—00117
                                            Call Sign $2870


        6.      New Skies‘ request for a waiver of Section 25.210(i)(1), of the Commission‘s rules, 47
C.ER. § 25.210(i)(1), for the SES—6 space station is granted, as conditioned. Section 25.210(i)(1)
requires FSS space station antennas to be designed to meet a cross—polarization isolation of 30 dB within
the primary coverage area of the antenna. The minimum cross—polarization isolation of SES—6‘s
communications beams is 25.4 dB; and the minimum for the omnidirectional TT&C beams is 16 dB.
This waiver is based upon a finding that these shortfalls will not produce a significant increase in
interference, except to the space station itself, and will not adversely affect any other operator. As a
condition of the waiver, New Skies must accommodate future satellite networks serving the United States
that are two—degree compliant and other licensed radiocommunication systems operating in accordance
with the Commission‘s rules.

        7.       New Skies‘ request for a waiver of Section 25.211(a) of the Commission‘s rules, 47
C.F.R. 25.211(a), is dismissed as moot. Section 25.211(a) provides that downlink analog video
transmissions in the C—band shall be transmitted only on a center frequency of 3700+20N MHz, where
N=1 to 24, with corresponding uplink frequencies 2225 MHz higher. Because New Skies states that there
are no plans to use SES—6 for C—band analog video transmissions, there is no need to address its request
for waiver of 25.211(a). Should those plans change, however, New Skies must request, and be granted, a
modification of its grant of U.S. market access for SES—6 prior to providing downlink analog video
transmissions and any such transmission must be coordinated with adjacent satellites.
        8.       New Skies‘ request for a waiver of Section 25.114(d) (3) of the Commission‘s rules, 47
C.FR. § 25.114(d) (3), is granted. Section 25.114(d) (3) requires predicted space station antenna gain
contour(s) for each transmit and each receive antenna beam and nominal orbital location requested. New
Skies indicates that because certain beams on SES—6 do not intersect with the Earth‘s surface, it has not
provided gain contours for these beams. See Attachment A, Annex B, Figures 26—35. We find, however,
that Attachment A, Annex B, together with the descriptive characterization provided in figures 26—35 of
the Engineering Statement, fulfill the requirements of Section 25.114(d)(3).

        9.       New Skies‘ request for waiver of Sections 25.114 (d)(14)(ii) and 25.283(c) of the
Commission‘s rules, 47 C.EF.R. §§ 25.114(d)(14)(ii) and 25.283, is GRANTED. Sections
25.114(d)(14)(ii) and 25.283(c) specify that space stations must discharge all stored energy sources at
end—of—life of the space station. SES—6 is an EADS Astrium E3000 series satellite, which does not
completely discharge all stored energy at end of life. At the completion of mission, upon disposal of the
spacecraft, the chemical propulsion tanks will be depleted. A helium pressurant tank, however, will retain
a total mass of 1.25 kg of helium with a volume of 182.79 liters at end of life. SES—6 was launched on
June 3, 2013. Compliance with Section 25.283(c) is not achievable except through direct retrieval of the
spacecraft. The information submitted is not sufficient to support a finding that the underlying purpose of
Section 25.283(c) would be served by sealing the helium tank without completely venting it. However,
we grant a partial waiver of the rule because undue hardship would result from requiring modification of
the space station at this time. This action is without prejudice to possible future licensing decisions in
connection with other spacecraft of the same manufacturing series.
        10.      Operations using SES—6 to or from the United States must comply with the power levels
specified in Section 25.212 of the Commission‘s rules, 47 C.F.R. § 25.212, unless New Skies coordinates
any operations using power levels exceeding the levels in Section 25.212 with all potentially affected
adjacent satellites within 6 degrees orbital separation of the 40.5° W.L. orbital location. New Skies must
inform the Commission of any coordinated power levels to be used within the United States that are
higher than the limits in Section 25.212. In addition, New Skies must inform all affected U.S.—licensed
earth station operators that Section 25.220 of the Commission‘s rules, 47 C.F.R. § 25.220, applies to


                                              Attachment to Grant
                                 Applicati on of New Skies Satellites B.V.
                               IBFS File No. SAT—PPL—20120717—00117
                                                Call Sign $2870


operations that exceed the power levels specified in Section 25.212. In the Ku—band, the downlink EIRP
density level of the SES—6 digital carriers must not exceed —20 dBW/Hz, and the input power density level
of the uplink digital carriers of U.S.—licensed earth stations operating with SES—6 must not exceed —47
dBW/Hz. In the C—band frequencies, the downlink EIRP density level of the SES—6 digital carriers must
not exceed —30 dBW/Hz, and the input power density level of the uplink digital carriers of U.S.—licensed
earth stations operating with SES—6 must not exceed —38.7 dBW/Hz.

         11.    This grant of market access will terminate in the event that the SES—6 space station is
relocated from the 40.5° W.L. orbital location or ceases to operate. In either case, SES—6 will be removed
from the Permitted List. If New Skies wishes to provide service to the U.S. using another space station, it
must file a new application to have that space station placed on the Permitted List.

        12.     New Skies is afforded 30 days from the date of release of this action to decline this grant
of market access as conditioned. Failure t o respond within this period will constitute formal acceptance
of the grant as conditioned.
        13.      This action is téken pursu ant to Section 0.261 of the Commission‘s rules, 47 C.F.R. §§
0.261, and is effective immediately. Petitions for reconsideration under Section 1.106 of the
Commission‘s rules 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 public notice indicating that this action was taken.


           +4 GEAMTED w/RESPECT 710 PeEEMTTEDQ List oncty; omick Reaugests pEeFerrEDr*r
                                               Tile # SM)— PPL— 20120717— OO 7


                                               Call Sign 82870 GrantDate_O7/2/3
                                               (or other identifier)
                                                                       Term Dates S¢¢ 3
                                               From O7/2/2                  To    conditions

                       International Bureau    Approved:          Sligeg )Qull
                     fors                                         éw‘eéheM_ D vall
                   (¢orreced o%/c¢/B}                             Chief, Satellite poll(:) Branch


  9—16. Name of Contact Representative
            Name:           Karis A. Hastings                     Phone Number:                       202—599—0975
            Company:        SatCom Law LLC                        Fax Number:
            Street:          1317 F Street, N.W., Suite 400       E—Mail:                             karis@satcomlaw.com


            City:           Washington                            State:                               DC
            Country:         USA                                  Zipcode:                            20004      —
            Attention:                                            Relationship:                       Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                  b.
classification that applies to thisfiling for   «3 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.                   (N/A) b3. Amendment to a Pending Application
                                                (N/A) b4. Modification of License or Registration
  a.                                            (N/A) b5. Assignment of License or Registration
(N/A) al . Earth Station                        (N/A) b6. Transfer of Control of License or Registration
  @ a2. Space Station                           (N/A) b7. Notification of Minor Modification
                                                (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite

                                                { b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                «4 b10. Replacement Satellite Application — no new frequency bands
                                                £3 b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                «; b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


  17¢. Is a fee submitted with this application?
C IfYes, complete and attach FCC Form 159.
  If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
  C Governmental Entity g*3 Noncommercial educational licensee
) Other(please explain):       Permitted Space Station List and Market Access Petition


17¢. Fee Classification


18. If this filing is in reference to an existing station, enter:
(a) Call sign of station:
    Not Applicable




19. If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                     (b) File number of pending application:

Not Applicable                                                              Not Applicable


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:

E a. Fixed Satellite
D b. Mobile Satellite
D c. Radiodetermination Satellite
D d. Earth Exploration Satellite
E e. Direct to Home Fixed Satellite
D £. Digital Audio Radio Service
D g. Other (please specify)


21. STATUS: Choose thebutton next to the applicable status. Choose       22. If earth station applicant, check all that apply.
only one.                                                                Not Applicable
   C Common Carrier @ Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
      C Connected to a Public Switched Network       C 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)
   E 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.

 (N/A) a. Fixed Earth Station
 (N/A) b. Temporary—Fixed Earth Station
 (N/A) c. 12/14 GHz VSAT Network
 (N/A) d. Mobile Earth Station
 @ & Geostationary Space Station.
 { £f. Non—Geostationary Space Station
 ) & Other (please specify)




26. TYPE OF EARTH STATION                FACILITY: Not Applicable
PURPOSE OF MODIFICATION


 27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
 apply.)

 ENVIRONMENTAL POLICY


 28. Would a Commussion grant of any proposal in this application or amendment have a significant environmental     y Yes @ 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 or the representative of any foreign government?                                3 Yes @No




30. Is the applicant an alien or the representative of an alien?                                                          3 Yes No 3 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                    @ Yes C 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       @Yes No 4 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 (yNo 3 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 under the 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
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 C 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 or license         C 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    O 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,        ba 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   0 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   Exhibit A
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           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,     @ Yes y 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? The Netherlands


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.)
     Petitioner seeks U.S. market access for the Netherlands—licensed SES—6 spacecraft to be
     located at 40.5 deg. W.L.




  Narr and Tech App


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 specifiedin 47 C.F.R. Part 25.
                                                                                                                              o 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.
                                                                                                                              «y 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.


44.   Applicant is a (an): (Choose the button next to applicable response.)


 (e Individual
 ¢4 Unincorporated Association
 {£4 Partnership
 C Corporation
 «34 Governmental Entity
 @ Other (please specify)      Dutch BV



45. Name of Person Signing                                               46. Title of Person Signing
Daniel C.H. Mah                                                          Regulatory Counsel
47. Please supply any need attachments.
 1:




           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).



Completed Schedule S




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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
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11



Document Created: 2013-08-08 16:34:52
Document Modified: 2013-08-08 16:34:52

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