Attachment supplement

supplement

SUPPLEMENT submitted by Boeing

supplement

2005-03-31

This document pretains to SAT-STA-20050325-00076 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2005032500076_426414

Ex parte on Late Filep STEPTOE&JOHNSON« arroaneys at caw 1110 Comectiw Aenve, N¥ mnasoms ORIGINAL MemmrsroC omm cnldaturepmccon T1 2022203000 facaors 2002 sepsecom RECEIVED March 31, 2005 mar 3 1 2005 via nanp peuivery C Mnlmmunmfim‘m\’fl 7 Marlene H. Dortch oteetsumay ECeived Secretary Federal Communications Commission APR 0 7 2005 445 12th Street,NW. Washington, D.C. 20554 'm:nfauiiifi?flau Re:— WRITTEN EX PARTE PRESENTATION File No. SAT—STA—20050325—00076 Application of SES Americom,Inc. for Special Temporary Authority To Repoint Satcom SN—4 Dear Ms. Dontch: ‘The Bosing Company ("Bosing") hereby filesthisleter to further supplement the record in the above—captioned application proceeding. On March 25, 2005, SES Americom, Inc. filed an application for Special Temporary Authority (‘STA") equesting authority to repoint the Satcom SN~4 satelite and provide Ku—band service over water areas of International Telecommunication Union ("TTU®) Region 1. On March 29, 2005, Bocing filed an ex partelettrin support of SES Americom‘s STA application and related modification application." This letter provides additional information regarding the extrmordinary circumstances justifying grantof SES Americom‘s STA application. ‘ See Application of SES Americom,Inc. for Special Temporary Authority to Repoint Satcom SN—A, File No. SAT—STA—20050325—00076 (filed March 25, 2005). SES Americom also filed an aecompanying modification application seeking, among other things, permanent authority for operationalchanges requested in the STA application. See Application of SES Americom,Inc. for Modification of Satcom SN—4 Fixed Satelite Space Station License, File No. SAT—MOD—20050325— 00075 (filed March 25, 2005). * See Letter to Marlene H. Dortch from Carlos M. Nalda, File Nos. SAT—$TA—20050325—00076 and SAT—MOD—20050325—00075 (dated March 29, 2005). No. o Copiee reed List a800E o vasnmerow + wew york + rmotwix +. tos anoruts +. toxbon + srussus

Marlene H. Dortch March 31, 2005 Page 2 As the Commission is aware, grant of the STA application will enable SES Americom to provide Bocing with Ku—band satellite capacity for the Connexion by Bocingsystem to provide iterim Pacific Ocean region ("L—POR") coverage pending launch of the AMC—23 satellitelater this year. In addition to Satcom SN—4, I—POR coverage will be implemented using the Intelsat —605, Superbird C and NSS—3 satelltes, However, only the Satcom SN—4 satellite requires repointing to provide optimal coverage for —POR service. Thus, it is the only satelfte for which additionalregulatory authorityis required for use in connection with I—POR coverage. ‘The Satcom SN—1 satelite is an essential element of Bocing‘s I—POR coverage. As indicated in the attached Microsoft PowerPoint slide, Satcom SN—4 will provide the largest Pacific Ocean area coverage of any —POR satellite, and it will be the only satellte serving the critical Northem Pacific commercialair routes linking Asia and North America. Without access o Satcom SN—4, Bocing cannot provide seamless Pacific Ocean region coverage to is arline customers, including All Nippon Airways (CANA"), Japan Airlines (JAL")and Singapore Airlines ("SIA"),which are presently equipped and operating with the Connexion by Bocing®" system. As highlighted in SES Americom‘s STA application, Bosing‘s 1—POR coverage is scheduled to commence on April 15, 2005, and satellitetesting prior to commencement of service needs to occur beginning April 1, 205. Inthis connection, Bocing currently has technical personnel on the ground at its gateway facilty on Vancouver Island, Canada standing by to commence testing with Satcom SN—# upon grant ofthe requested STA.. In adition, the Bocing‘s Connexion 1 testbed and demonstration airerafis scheduled to make a Pacific Ocean region flight on April 7, 2005 to test LPOR coverage, including system performance with the Satcom SN—1 satelite. Bocing‘s imminent program of esting, which will continue through early May 2005, is critical to ensure that I—POR coverage can commence commerciallyater testing has been completed. Bocing would also note the SES Americom and Bocing met with representatives ofthe Intermational Bureau staff on January 18, 2005 to discuss issues associated with repointing Satcom SN—# in the context of Bosing‘s I—POR coverage. Given the need to modify Satcom SN—1‘s operating authorityin relatively shorttime frame, a space station modification application accompanied by an STA application (in the event thatthe modification application could not be granted in time) was considered an appropriate procedural approach. Although certain technical complexitiesassociated with application development in the contextof Sstcom SN—4 repointing delayed submission ofthe applications, grant of an STA during the pendency of the underiying modification application remains uppropriate

Mariene H. Dortch March 31, 2005 Page3 In particular, the Satcom SN—4 satelite will provide interim service only pending launch of the AMC—23 satellte, which includes a payload designed to provide full Pacific Ocean region coverage for Bocing. Furthermore, as described above, there are extraordinary factual circumstances supporting the pressing need for expedited grant of an STA in this case. Finally, SES Americom seeks an STA to operate for a brief 60—day period on a non—harmfulinerference basis only, and recognizes that the STA is subject to change or cancellation at any time upon reasonable notice and that any action taken pursuant to the STA is atits own risk and without prejudice to any action the Commission might take on the related Satcom SN—4 space station modification application. For all of the foregoing reasons, Boeing respectfully requests that the Commission accord SES Americom‘s STA application expedited treatment and grant the requested STA atthe carliet possible time, Please feelfree to contact the undersigned with any questions regarding this submission. Respectfully submitted. /ILHHie Carios M. Nalda Counselfor The Boeing Company Artachment ce (watt): Nancy J.Eskenazi Vice President and Associate General Counse! SES Americom, Ic. Four Research Way Princeton, NJ 08540 Peter A. Rohrbach Karis A. Hastings Hogan & Hartson LL P 555 Thirteenth St., NW Washington, DC 20004—1109 Counsel for SES Americom, Inc.

Interim Pacific Ocean Region Coverage w sn s s 160 s s &A .. *iso sse icomm # «o is u w o w is y C |__Coverage to Asian Commercial Airlines (ANA, JAL, KAL, SIA,CHI) Tohnesion ar31/2005 1


Document Created: 2005-04-07 16:45:48
Document Modified: 2005-04-07 16:45:48
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