Attachment STA Request

This document pretains to SAT-STA-20101117-00238 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010111700238_852847

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SAT-STA-___________ ) Call Sign S2134 Request for Special Temporary Authority to ) Operate AMC-2 C-Band Payload ) REQUEST OF SES AMERICOM, INC. SES Americom, Inc. (“SES Americom,” doing business as “SES WORLD SKIES”1), hereby respectfully requests special temporary authority (“STA”) for a period of up to 30 days to operate the C-band frequencies (including the C-band TT&C frequencies) on the AMC-2 hybrid satellite with polarizations that are the opposite of what is specified in the current AMC-2 license. Grant of the requested STA will serve the public interest by facilitating possible use of the AMC-2 C-band payload in efforts to mitigate interference to the AMC-18 satellite as Galaxy 15 approaches and passes through the AMC-18 stationkeeping volume. Earlier this year, the Commission granted SES WORLD SKIES’ application for modification of the AMC-2 license to reassign the spacecraft from the nominal 101º W.L. orbital location to 78.95º W.L.2 In the AMC-2 Modification, SES WORLD SKIES specified that the polarizations of the C-band transponders and TT&C frequencies at 78.95º W.L. would be 1 SES WORLD SKIES is the commercial brand name for the integrated operations of two indirect subsidiaries of SES S.A.: SES Americom and New Skies Satellites B.V. (effective January 1, 2009). The brand name does not affect the underlying legal entities that hold Commission authorizations or U.S. market access rights. 2 File No. SAT-MOD-20100324-00056, Call Sign S2134 (the “AMC-2 Modification”), grant- stamped June 21, 2010.

reversed from the polarizations used at 101º W.L.3 Similarly, in the Schedule S supplied with the AMC-2 Modification, SES WORLD SKIES provided specific polarization information that likewise indicated that the C-band polarizations at 78.95º W.L. would be the opposite of those used at 101º W.L.4 The AMC-2 satellite is equipped with polarization switches that would permit SES WORLD SKIES to conform the C-band transponder and TT&C polarizations to those described in the AMC-2 Modification. However, SES WORLD SKIES is concerned that switching the polarization could disrupt the operations of the spacecraft. The polarization switches are potential single points of failure. If a switch were to fail in an “in-between” configuration, it could jeopardize the ability to use either polarization of C-band frequencies on the satellite. As the Commission is aware, Galaxy 15 (licensed to PanAmSat Licensee Corp., call sign S2387) suffered an anomaly on or about April 5 and is drifting eastward in an uncontrolled manner with its payload active. Galaxy 15 is nearing AMC-18 (call sign S2713), a C-band satellite licensed to SES Satellites (Gibraltar) Limited (“SES Gibraltar”), a wholly- owned subsidiary of SES Americom. AMC-18 is Gibraltar-licensed and on the Commission’s Permitted Space Station List, authorized to serve the U.S. from 104.95º W.L. Galaxy 15 is expected to pass through AMC-18’s station-keeping box on or about November 24. Because Galaxy 15 operates on the same C-band frequencies as AMC-18, the potential for harmful interference into AMC-18 operations is significant as Galaxy 15 approaches. 3 See AMC-2 Modification, Technical Appendix at 2. 4 AMC-2 Modification, Schedule S, Item S9. 2

To mitigate the interference risk, SES Gibraltar plans to maneuver AMC-18 within a larger stationkeeping volume to maintain a minimum distance between AMC-18 and Galaxy 15. During the time these maneuvers are taking place, AMC-18 customers may need to re-direct their transmissions to another spacecraft so that they can be relayed to AMC-18 using a ground antenna with a large diameter and advanced tracking capability. This double-hop approach will reduce the risk of interference, while avoiding the need for repointing the hundreds of antennas that receive signals from AMC-18. SES WORLD SKIES anticipates that the AMC-2 C-band payload may be needed as a relay satellite for AMC-18 C-band traffic, as part of the interference mitigation measures relating to Galaxy 15’s uncontrolled drift. In order to ensure that AMC-2 is available for this purpose and to mitigate the technical risk of a polarization switch failure, SES WORLD SKIES seeks temporary authority to operate the AMC-2 C-band payload and TT&C frequencies without switching the polarization from the configuration used on the satellite at 101º W.L. In all other respects, operation of the satellite will conform to the terms of the current AMC-2 license. Grant of the requested authority will serve the public interest by allowing use of AMC-2 to facilitate service continuity for customers of the AMC-18 spacecraft. Operation of AMC-2 at 78.95° W.L. as proposed herein will not harm other operators. SES WORLD SKIES submitted an interference analysis with the AMC-2 Modification showing that its planned operations were compatible with adjacent satellites. The analysis did not rely on polarization diversity to reach this conclusion.5 As a result, the proposed 5 AMC-2 Modification, Technical Appendix, Annex 3 at 33. As described in the interference analysis, polarization is primarily relevant only with respect to analog video channels, which are typically coordinated on a case-by-case basis. SES WORLD SKIES does not seek authority to use AMC-2 for analog video – the traffic being relayed to AMC-18 will consist solely of digital video and data. 3

operation during the period of the STA will be consistent with the assumptions underlying the interference analysis in the AMC-2 Modification and the conclusions of that analysis remain valid. In addition, AMC-2 operations under this STA will conform to the terms of existing and future coordination agreements applicable to its operations at the nominal 79° W.L. orbital location.6 For the foregoing reasons, SES WORLD SKIES seeks STA to permit temporary operation of the AMC-2 C-band payload and TT&C frequencies with polarizations that do not conform to the terms of its current license. Respectfully submitted, SES AMERICOM, INC. By: /s/ Daniel C.H. Mah Of Counsel Daniel C. H. Mah Karis A. Hastings Regulatory Counsel Hogan Lovells US LLP SES Americom, Inc. 555 13th Street, N.W. Four Research Way Washington, D.C. 20004-1109 Princeton, NJ 08540 Tel: (202) 637-5600 Dated: November 17, 2010 6 SES WORLD SKIES notes that the Venesat-1 satellite operates at 78° W.L. under a Uruguayan ITU network filing that is lower in priority than the U.S. ITU filing at the nominal 79° W.L. location. 4


Document Created: 2010-11-17 18:01:01
Document Modified: 2010-11-17 18:01:01
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