Attachment Narrative SAT-PPL-20160304-00024

Attachment Narrative

This document pretains to SAT-PPL-20160304-00024 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2016030400024_1129152

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, DC 20554

In the Matter of )
)
Empresa Argentina de Soluciones )
Satelitales S.A. Petition for Declaratory Ruling ) File No.
To Add ARSAT-2 to the ) Call Sign
Permitted Space Station List )
)
)

PETITION FOR DECLARATORY RULING

Empresa Argentina de Soluciones Satelitales S.A. (“ARSAT”), an Argentine corporation,

respectfully files this Petition for a Declaratory Ruling pursuant to Section 25.137(c) of the

Federal Communications Commission (“Commission”) Rules to add the ARSAT-2 satellite at

81ºW to the Permitted Space Station List (“Permitted List”).1 ARSAT-2 will serve the United

States in the C- and Ku- band.

The Commission allows non-U.S.-licensed satellites to be included on the Permitted List

upon demonstrating compliance with Sections 25.114 and 25.137 of the Commission’s Rules,

assuming there are no other public interest concerns. This Petition and its associated

attachments, including FCC Form 312 and Schedule S, provide the information required for the

1
ARSAT-2 will be permanently located 81º W. However, the satellite is temporarily
positioned at 81.1º W because satellite AMC-2 is currently located at 80.85º W. In order to
ensure safe stationkeeping volume, ARSAT-2 will be maintained at 81.1º W until AMC-2 is
repositioned in June 2016. ARSAT has coordinated stationkeeping and power levels with SES to
ensure there is no possibility of collision or harmful interference during this period.

Commission to determine that the ARSAT-2 satellite meets the requirements of Sections 25.114

and 25.137 and is thus eligible to be on the Permitted List.

I. REQUIREMENT OF SECTION 25.114 AND 25.137 OF THE COMMISSION’S
RULES

ARSAT-2 is licensed by Argentina and will be located at the 81º W orbital location.

The 81º W orbital location is assigned to Argentina. Therefore, the Commission cannot license

U.S. satellites in these frequency bands at this orbital location. Argentina is a member country

of the WTO. In addition, Argentina and the United States have reached a bilateral agreement

that allows Argentine satellites to offer FSS service in the United States, after those satellites

have been coordinated with the United States.2

ARSAT is requesting to provide Fixed-Satellite Services (“FSS”) covered by the WTO

Telecom Agreement and “other FSS services” covered by the US-Argentina Bilateral Agreement.

Given Argentina’s membership in the WTO and the existing Bilateral Agreement with the

United States, Argentina is not required to make the effective competitive opportunities showing
3
pursuant to Section 25.137 of the Commission’s Rules. The relevant International

2
Protocol Concerning the Transmission and Reception of Signals From Satellites for the
Provision of Direct-to-Home Satellite Services and Fixed-Satellite Services in the United States
of American and the Argentine Republic (June 5, 1998) (available at
http://www.state.gov/documents/organization/112469.pdf) (“US-Argentina Bilateral
Agreement”).
3
See 47 C.F.R. § 25.137(a)(2); see also Amendment of the Commission’s Regulatory Policies to
Allow Non-U.S. Licensed satellites Providing Domestic and International Service in the United
States, Report and Order, IB Docket No. 96-111, 12 FCC Rcd 24094, ¶ 39 (1997) (“We adopt
our proposal to apply a presumption in favor of entry in considering applications to access non-
U.S. satellites licensed by WTO members to provide services covered by the U.S. commitments
under the WTO Basic Telecom Agreement.”); Id., ¶ 64 (“[W]e will not evaluate the effective
competitive opportunities in the route market for non-U.S. satellites licensed by a WTO Member
providing WTO covered services. Thus, we will not perform an ECO-Sat test on any route,
whether a WTO route market or a non-WTO route market.”).

2

Telecommunications Union (“ITU”) network for the ARSAT-2 satellite has been notified under

Article 11 of the ITU Radio Regulations and is recorded in the ITU Master Register.

ARSAT-2 is already on orbit and operating, and is the second geostationary satellite

launched and operated by ARSAT. Therefore, it is not necessary for ARSAT to provide

financial information for the Commission to determine that ARSAT is financially capable of

building, launching, and operating its satellite.4

II. REQUEST FOR WAIVER OF SECTION 25.210(A)(3) OF THE COMMISSION’S
RULES

ARSAT requests a waiver of Section 25.210(a)(3) of the Commission’s Rules, which

requires that the C-band payload on the space station providing service to the U.S. be capable of

switching polarity upon ground command. The ARSAT-2 C-band transmission polarization

sense is not switchable from the ground. The Commission has previously waived this rule in

several cases for good cause for other non-U.S. licensed FSS operators requesting to add space

stations to the Permitted Space Station List.

Section 1.3 of the Commission’s Rules provides that the Commission may waive any of

its rules if the petitioner shows “good cause,” for example, circumstances in which waiver would

better serve the public interest than would application of the rule. 5 In this case, the

Commission’s satellite policies are well served by the omission of payload polarization

4
Amendment of the Commission’s Regulatory Policies To Allow Non-U.S.-Licensed Space
Stations To Provide Domestic and International Satellite Service in the United States, Report and
Order, IB Docket No. 96-111, 12 FCC Rcd 24094, ¶ 191 (1997) (“DISCO II Order”) (explaining
that the presence of in-orbit satellites satisfies concerns about an operator’s capabilities of
building and operating a satellite).
5
47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153 (D.C. Cir. 1969); appeal after remand,
459 F.2d 1203 (D.C. Cir. 1972), cert. denied, 409 U.S. 1027 (1972); Northeast Cellular Tel. Co.
v. FCC, 897 F.2d 1164 (D.C. Cir. 1990).

3

switching capabilities. First, this design decision reduces the technical risk by avoiding a single

point of failure in each transponder’s polarization. It also reduces the mass and cost of the

satellite, as well as reducing input and output losses resulting in better performance.

Furthermore, such capability is unnecessary because ARSAT-2 has completed coordination with

operators of adjacent satellites and will operate in accordance with those agreements, which take

into account the fixed polarization of its C-band transmissions. The Commission has granted

this same waiver to several other non-U.S. satellite operators who have applied to be on the

Permitted Space Station List under similar circumstances.6

In these Orders, the Commission concluded that waiving Section 25.210(a)(3) will not

undercut the policies underlying the Commission’s adoption of the rule and the Commission

placed appropriate conditions on the waiver.7 Consistent with relevant precedent, granting this

waiver under Section 1.3 of the Commission’s Rules is appropriate and would serve the public

interest.

III. ADDING ARSAT-2 TO THE PERMITTED SPACE STATION LIST IS IN THE
PUBLIC INTEREST

The Commission has found on several previous occasions that adding Central and South

American satellites to the Permitted Space Station List was in the public interest.8 For these

6
See Telesat Canada, Petition for Declaratory Ruling, Order, DA 00-2835, 15 FCC Rcd 24828,
¶¶ 16-17 (2000) (“Telesat Canada Order”); see also SAT-PPL-20060329-00030 and SAT-
AMD-20060724-00080 (2006).
7
Telesat Canada Order, ¶ 17.
8
See, e.g., Satélites Mexicanos, S.A. de C.V. Petition for Rulemaking, Order, DA 00-1793, 15
FCC Rcd 19311 (2000) (adding Solidaridad 2 and Satmex 5 to the Permitted Space Station List
at 113˚W and 116.8˚W, respectively); SAT-PPL-20060329-00030 and SAT-AMD-20060724-
00080 (2006) (adding Satmex 6 to the Permitted Space Station List at 113º W); SAT-PDR-
19991214-00131 and SAT-MOD-20060821-00090 (2006) (modifying orbital location of
Solidaridad 2 to 114.9ºW on the Permitted Space Station List).

4

Attachment A

Regulatory Compliance Index

FCC Rule Rule Summary (This column will be deleted Application/Exhibit Section No.
prior to filing)
25.114(c)(4)(i) For each transmitting and receiving antenna Schedule S
beam, provide center frequencies, bandwidth,
and polarization.
25.114(c)(4)(vi) Map of the proposed coverage area and Gain Attachment B § 5
or (vii) contours (numbers and maps)
25.114(c)(8) Calculated maximum power flux density levels Attachment B - Annex 1 § 2 (supplemental
within each coverage area and energy dispersal information to Schedule S)
bandwidths, if any, needed for compliance
with §25.208, for the angles of arrival
specified in the applicable paragraph(s) of
§25.208;
25.114(d)(1) Overall description of system facilities, Narrative Statement; Attachment B, § 2
operations and services and explanation of
how uplink frequency bands would be
connected to downlink frequency bands
25.224(d)(6) Public interest considerations in support of Narrative Statement at III.
grant
25.114(d)(7) (Refers to §25.140(a)) Provide interference Attachment B - Annex 1§ 1
analysis showing compatibility with satellites
within 2 degrees.
25.114(d)(14)(i- Orbital Debris Mitigation plan Attachment B – Annex 2
iv)
25.137(a)(1) Demonstrate that that U.S.-licensed satellite Narrative at I
systems have effective competitive
opportunities to provide analogous services in
Argentina
25.137(b) Provide legal and technical information Form 312; Narrative Statement;
consistent with §25.114 Attachment B
25.202(e) Demonstrate frequency tolerance of 0.002 or Attachment B, § 7
better
25.202(f)(1-3) Out of band emissions limits Attachment B, § 7
25.208 Power Flux Density limits Attachment B, Annex 1, § 2.0
25.210(a)(3) Polarization requirements Narrative Statement at II (Waiver
Requested)
25.283 End of life disposal Attachment B - Annex 2

6

ATTACHMENT B

Technical Information to Supplement Schedule S

1 SCOPE

This Attachment contains additional information required by §25.114(c) and other sections of the

FCC §25 rules that cannot be entered into the Schedule S submission.

2 GENERAL DESCRIPTION (§25.114(d)(1))

The ARSAT-2 satellite will operate at 81° W orbital location (with a temporary location of 81.1°

W until June 2016). The ARSAT-2 will provide FSS services to the United States using the

conventional C- and Ku-band frequencies. The satellite employs 6 C-band transponders and 10

Ku-band transponders using both linear polarizations thereby providing dual frequency re-use.

The satellite has one C-band beam which provides coverage of most of the Americas, and two

Ku-band beams: a North American beam and a South America beam. There is inter-connectivity

between the two Ku beams.

7

6 SERVICES TO BE PROVIDED (§25.114(d)(4))

The ARSAT-2 satellite will provide digital FSS services. Representative link budgets, which

include details of the transmission characteristics, performance objectives and earth station

characteristics, are provided in the associated Schedule S submission.

7 TT&C CHARACTERISTICS (§25.114(c)(4)(i) & §25.114(c)(9))

The ARSAT-2 TT&C sub-system provides for communications during pre-launch, transfer orbit

and on-station operations, as well as during spacecraft emergencies. Ku-band telecommand

transmissions are received by the spacecraft through a near omni-directional antenna during both

transfer orbit and emergency operations. When on-station, TC is conducted via the Ku-band

South America beam while TM is conducted via a global horn.

TT&C operations will be conducted from Argentine territory. ARSAT does not seek

Commission authorization for TT&C transmissions. Contact details for the control stations are

provided below:

Nominal station
Av. Juan Domingo Peron 7934
Benavidez, Buenos Aires
Argentina B1621BGZ
+54 11 58112600

Backup station
Ruta Provincial E96 Km10
Departamento de Punilla, Bosque Alegre
Coordinates: -31.606319, -64.568644
Cordoba, Argentina 5187
+54 11 58112600

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8 SATELLITE TRANSPONDER FREQUENCY RESPONSES (§25.114(c)(4)(vii))

The transponder frequency responses specified over the various channel bandwidths are shown

in Tables 7-1 through 7-3. In addition, the frequency tolerances of §25.202(e) and the out-of-

band emission limits of §25.202(f)(1), (2) and (3) will be met.

Table 7-1. 72 MHz C-Band Transponder Frequency Response

Maximum Amplitude Variation relative to maximum
Frequency Offset from
gain (dBpp) Comments
channel center
Receive Transmit
CF +/‐ 20 MHz 0.3 0.39
CF +/‐ 28 MHz 0.3 0.51
In Band
CF +/‐ 32 MHz 0.5 0.57
CF +/‐ 36 MHz 0.7 0.63

Frequency Offset from IMUX Rejection (dB) OMUX Rejection (dB)
Comments
channel center
Receive Transmit
CF +/‐ 44 MHz 19.1 19.6
CF +/‐ 45 MHz 25.0 21.1 Out of Band
CF +/‐ 80 MHz 49.4 33.3

Table 7-2. 88 MHz C-Band Transponder Frequency Response

Maximum Amplitude Variation relative to maximum
Frequency Offset from
gain (dBpp) Comments
channel center
Receive Transmit
CF +/‐ 24.4 MHz 0.3 0.42
CF +/‐ 34.2 MHz 0.3 0.55
In Band
CF +/‐ 39.1 MHz 0.4 0.62
CF +/‐ 44 MHz 0.7 0.69

Frequency Offset from IMUX Rejection (dB) OMUX Rejection (dB)
Comments
channel center
Receive Transmit
CF +/‐ 54 MHz 22.7 20.0
CF +/‐ 55 MHz 30.7 23.1 Out of Band
CF +/‐ 90 MHz 51.1 33.1

14

Table 7-3. 72 MHz Ku-Band Transponder Frequency Response

Maximum Amplitude Variation relative to maximum
Frequency Offset from
gain (dBpp) Comments
channel center
Receive Transmit
CF +/‐ 24 MHz 0.4 0.45
CF +/‐ 28 MHz 0.5 0.48
In Band
CF +/‐ 32 MHz 0.9 0.51
CF +/‐ 36 MHz 1.3 0.64

Frequency Offset from IMUX Rejection (dB) OMUX Rejection (dB)
Comments
channel center
Receive Transmit
CF +/‐ 44 MHz 21.4 22.6
CF +/‐ 45 MHz 27.4 19.5 Out of Band
CF +/‐ 80 MHz 51.4 28.7

9 INTERFERENCE AND PFD ANALYSES (§25.140(b)(2) & (§25.114(c)(8))

The interference and PFD analyses are contained in Annex 1 to this Attachment.

10 ORBITAL DEBRIS MITIGATION PLAN (§ 25.114(d)(5))

The Orbital Debris Mitigation Plan is contained in Annex 2 to this Attachment.

11 ESTIMATED OPERATIONAL LIFETIME AND RELIABILITY

The satellite is designed for a lifetime of 15 years. The probability of the entire satellite

successfully operating to that date is estimated at 0.7 based upon a bus reliability of better than

0.78 and a payload reliability better than 0.9. These numbers are based on a detailed reliability

analysis performed by the spacecraft manufacturer of all critical components in the satellite bus

and payload.

15

11 ITU FILING

The ARSAT-2 has been notified and recorded in the ITU’s Master Register as P-P-SAT-1.9

9
ITU SNL Part B Query Result for P-P-SAT-1 (available at http://www.itu.int/net/ITU-
R/space/snl/bresult/radvance.asp?sel_satname=P-P-SAT-1).

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ANNEX 1

INTERFERENCE AND PFD ANALYSES

1.0 Interference Analyses (§§ 25.114(d)(7), 25.140(a))

There are 3 C-/Ku-band operational satellites within two degrees away from the 81° W orbital

location to be occupied by ARSAT-2. As previously mentioned, AMC-2 currently operates at

the 80.85° W, but will be relocated in June 2016. Table 1-1 below summarizes the nearby

satellites. The purpose of this section is to demonstrate compatibility between the operations of

networks within two degrees.

Table 1. Satellites within Two Degrees of ARSAT-2

Loc. Status Name Operator 24 Ku-band transponders
83 W active AMC 9 SES S.A. 32 Ku-band transponders
82 W active Nimiq 4 Telesat Canada Ltd. 24 Ku-band and 24 C-band transponders.
80.85 26 Ku-band (2 beams) and 10 C-band (hemi
active AMC 2 (GE 2) SES S.A.
W beam) equivalent transponders
81.1
active ARSAT 2 ARSAT
W
81 W planned ARSAT 3 ARSAT 24 active Ku-band transponders
79 W active Sky-Mexico 1 DirecTV, Inc. 24 Ku-band transponders

Tables 2 through 3 provide a summary of the C-band and Ku-band transmission parameters,

respectively, derived from the ARSAT-2 link budgets that are embedded in the Schedule S form.

Table 4 provides a summary of the C-band and Ku-band transmission parameters (antenna

envelope, power densities, etc.) coordinated with adjacent satellites in the frame of generic

agreements.

17

Table 2. ARSAT-2 Typical C-Band Transmission Parameters

Assigned
Emission Tx E/S Gain Uplink EIRP Downlink Rx E/S Gain C/I Criterion
Carrier ID Bandwidth
Designator (dBi) (dBW) EIRP (dBW) (dBi) (dB)
(MHz)
1 60K0G7W 0.06 45.3 9.08 7.7 38 18.5
2 4M50G7W 4.5 45.3 27.83 26.8 38.0 19.2
3 9M00G7W 9.0 45.3 30.83 29.8 38.0 19.2
4 18M0G7W 18.0 45.3 33.83 32.8 38.0 19.2
7 36M0G7W 36.0 45.3 36.83 35.8 38.0 19.2
8 72M0G7W 72.0 51.4 39.84 41.9 38.0 21.9
9 88M0G7W 88.0 51.4 40.74 41.9 40.0 21.9

Table 3. ARSAT-2 Typical Ku-Band Transmission Parameters

Assigned
Emission Tx E/S Gain Uplink EIRP Downlink Rx E/S Gain C/I Criterion
Carrier ID Bandwidth
Designator (dBi) (dBW) EIRP (dBW) (dBi) (dB)
(MHz)
1 60K0G7W 0.06 49.5 ‐2.22 18.1 41.3 18.5
2 4M50G7W 4.5 49.5 16.48 36.8 41.3 19.2
3 9M00G7W 9.0 49.5 19.48 39.8 41.3 19.2
4 18M0G7W 18.0 49.5 22.48 42.8 41.3 19.2
7 36M0G7W 36.0 49.5 25.48 45.8 41.3 20.9
8 72M0G7W 72.0 56.9 27.17 51.9 41.3 23.2

Table 4. Transmission Parameters agreed with adjacent slots for generic coordination

Ground station antenna envelope: 29 – 25 log

C band EIRP downlink density: -33 dBW/Hz

C band uplink power density (at antenna flange): -38.7 dBW/Hz

Ku band EIRP downlink density: -22.6 dBW/Hz

Ku band uplink power density (at antenna flange): -50 dBW/Hz

2.0 C-Band PFD Analyses (§ 25.114(d)(5))

ARSAT will operate the ARSAT-2 satellite such that all C-band downlink transmissions will

comply with the PFD limits of §25.208(a). The maximum C-band downlink EIRP density that

18

will be transmitted is -36.6 dBW/Hz. Table Z shows the maximum PFD levels that will occur at

various angles of arrival using a downlink EIRP density of -32 dBW/Hz and demonstrates

compliance with §25.208.

Table Z. Maximum C-Band PFD Levels on ground of ARSAT-2

Applicable PFD Limit for Spreading Gain Worst Case PFD Level at
Angle of PFD Margin
Angle of Arrival Loss Contour Angle of Arrival
Arrival (dB)
(dBW/m2/4 KHz) (dBW/m2) (dB) (dBW/m2/4 KHz)
0° ‐152.0 ‐163.4 ‐2.5 ‐159.9 7.9
5° ‐152.0 ‐163.3 ‐2.4 ‐159.8 7.8
10° ‐149.5 ‐163.2 ‐2.3 ‐159.5 10.0
15° ‐147.0 ‐163.0 ‐2.0 ‐159.1 12.1
20° ‐144.5 ‐162.9 ‐1.7 ‐158.7 14.2
25° ‐142.0 ‐162.8 ‐1.3 ‐158.2 16.2
72° (Peak) ‐142.0 ‐162.1 ‐0.2 ‐156.4 14.4

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Document Created: 2016-03-04 16:35:01
Document Modified: 2016-03-04 16:35:01

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