Attachment Attachment

This document pretains to SAT-STA-20100430-00086 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010043000086_813465

                                    Before the
                     FEDERAL COMMUNICATIONS COMMISSION
                              Washington, D.C. 20554


In the Matter of Application of                        )
                                                       )
SES AMERICOM, INC.                                     )    File No. SAT-STA-___________
                                                       )    Call Sign S2433
For Special Temporary Authority to                     )
Drift and Operate AMC-11                               )

EXPEDITED ACTION REQUESTED

                        APPLICATION OF SES AMERICOM, INC.

               SES Americom, Inc. (“SES Americom,” doing business as “SES WORLD

SKIES”1) hereby respectfully requests special temporary authority for a period of thirty days,

starting on May 20, 2010, to perform Tracking, Telemetry, Command, and Monitoring

(“TTC&M”) in order to drift the AMC-11 C-band satellite up to 0.5 degrees to the east and west

of its assigned orbital location of 131º W.L., i.e. between 130.5° and 131.5° W.L., and to operate

the satellite’s communications payload throughout this period.2 The purpose of the requested

flexibility is to enable SES WORLD SKIES to maneuver AMC-11, as necessary, to mitigate

potential interference from the PanAmSat Licensee Corp. (“PanAmSat”) Galaxy 15 satellite (call

sign S2387), which recently suffered an anomaly and which is drifting in an uncontrolled manner

in the direction of AMC-11. Grant of the requested authority and any necessary waiver will


1
     On September 7, 2009, SES S.A. announced that the newly integrated operations of its two
indirect subsidiaries, New Skies Satellites B.V. and SES Americom would be conducted under a
single brand name, SES WORLD SKIES. The new brand name does not affect the underlying
legal entities that hold Commission authorizations or U.S. market access rights.
2
    To the extent required, SES WORLD SKIES requests a waiver of the requirement to
maintain a Commission-licensed spacecraft within +/- 0.05 degrees of its assigned station-
keeping position. See 47 C.F.R. §§ 1.3 (waiver for good cause), 25.210(j) (east/west station-
keeping).


serve the public interest by allowing SES WORLD SKIES to take certain steps, as necessary, to

minimize service disruptions for customers on AMC-11 as Galaxy 15 approaches and passes

through the 131° W.L. orbital location.

               As the Commission is aware, because of an anomaly that occurred on or about

April 5, the Galaxy 15 satellite is currently drifting eastward in an uncontrolled manner from its

assigned orbital location of 133° W.L. at a very slow but accelerating rate of 0.04-0.1 degrees per

day. SES WORLD SKIES understands that PanAmSat is currently undertaking efforts to regain

control of Galaxy 15 and, if that fails, will begin taking more aggressive efforts to disable the

payload on the satellite starting on May 3.3 If those efforts are unsuccessful, Galaxy 15 is

expected to come within 0.8 degrees of the AMC-11 satellite at 131° W.L. on or about May 18

with its payload active, and to pass through AMC-11’s station-keeping box on or about May 31.

Because Galaxy 15 operates on the same C-band frequencies as AMC-11, the potential for

harmful interference into AMC-11 operations is significant as Galaxy 15 approaches. There will

also be an increased risk of an in-orbit collision as Galaxy 15 passes through AMC-11’s station-

keeping box.

               SES WORLD SKIES is exploring a number of different options to address these

matters in conjunction with its customers and Intelsat. One such method is to ensure a 0.3 to 0.5

degree orbital separation between AMC-11 and the active Galaxy 15 as it approaches and passes

through 131° W.L. Specifically, AMC-11 would first drift to the east as Galaxy 15 approaches

from west, and then be maneuvered to the west of 131° W.L. as Galaxy 15 continues on its

passage east. PanAmSat managed a successful transition of traffic from Galaxy 15 to Galaxy 12




3
     See File Nos. SES-STA-20100423-00473, SAT-STA-20100426-00084.

                                                  2


by operating Galaxy 12 outside of the 133° W.L. box (with Commission authority)4 for a period

of time to maintain a minimum separation between the satellites. SES WORLD SKIES hereby

requests Commission authority to permit use of the same approach. This option also has the

virtue of facilitating the avoidance of in-orbit collision between the satellites.

                Grant of the requested authority and any requisite waiver will serve the public

interest by enabling SES WORLD SKIES to take these steps, as necessary, to minimize service

disruptions for customers on the AMC-11 satellite resulting from interference caused by

Galaxy 15. It will also enable SES to perform any maneuvers needed to avoid in-orbit collision

with the Galaxy 15 satellite. Grant of the requested authority will not adversely affect other

authorized operations. AMC-11 will not be located at the same orbital location as another

satellite or at an orbital location that has an overlapping stationkeeping volume with another

satellite. There are no C-band satellites assigned to operate within +/- 0.5 degrees of 131º W.L.

The closest C-band spacecraft to the east of AMC-11 is Galaxy 13 at 127º W.L., and to the west

is Galaxy 12, which has been deployed to 133º W.L. to carry the traffic previously carried by

Galaxy 15.5 SES WORLD SKIES does not expect that its proposed operations outside of its

assigned station-keeping box will cause harmful interference to either adjacent satellites and will

coordinate the proposed relocation and operation of AMC-11 with PanAmSat’s adjacent

operations.

                SES WORLD SKIES hereby certifies that no party to this application is subject to

a denial of federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21

U.S.C. § 862.


4
     See File No. SAT-STA-20100408-00070 (Call Sign S2422), grant-stamped Apr. 9, 2010.
5
     See id.

                                                   3


               SES WORLD SKIES 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.

               For the foregoing reasons, SES WORLD SKIES seeks temporary authority for a

period of up to 30 days beginning on May 20, 2010, to drift and operate AMC-11 between

130.5º W.L. and 131.5º W.L., using both the TTC&M and communications payloads on AMC-

11 throughout this process. At the end of this period, AMC-11 will be returned to its assigned

orbital location of 131° W.L.

                                             Respectfully submitted,

                                             SES AMERICOM, INC.

                                             By: /s/ Daniel C.H. Mah

Of Counsel                                       Daniel C. H. Mah
Karis A. Hastings                                Regulatory Counsel
Hogan & Hartson L.L.P.                           SES Americom, Inc.
555 13th Street, N.W.                            Four Research Way
Washington, D.C. 20004-1109                      Princeton, NJ 08540
Tel: (202) 637-5600

Dated: April 30, 2010




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Document Created: 2010-04-30 10:56:55
Document Modified: 2010-04-30 10:56:55

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