Attachment AMC-5 STA Request

This document pretains to SAT-STA-20110913-00178 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011091300178_916466

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


In the Matter of Application of                         )
                                                        )
SES AMERICOM, INC.                                      )    File No. SAT-STA-___________
                                                        )    Call Sign S2156
For Special Temporary Authority to                      )
Operate AMC-5 at 79.10° W.L.                            )


                         APPLICATION OF SES AMERICOM, INC.

               SES Americom, Inc. (“SES Americom”) hereby respectfully requests special

temporary authority (“STA”) for a period of 30 days commencing on September 30, 2011, to

provide service using the AMC-5 Ku-band fixed-satellite space station. Grant of the requested

authority will serve the public interest by permitting SES Americom to respond to the

requirements of a prospective U.S. government customer.

               AMC-5 is a conventional Ku-band1 only spacecraft launched in 1998. The terms

of the satellite’s current license specify operation at 79.05º W.L. with an east-west

stationkeeping tolerance of +/- 0.05 degrees.2 SES Americom has requested modification of the

AMC-5 license to reassign the spacecraft to 79.10º W.L. and permit operations with a

+/- 0.1 degree east-west stationkeeping tolerance.3 SES Americom has implemented this change



1
      AMC-5 has uplink frequencies at 14.0-14.5 GHz and downlink frequencies at 11.7-
12.2 GHz.
2
       See File No. SAT-MOD-20100706-00154, Call Sign S2156, grant-stamped Jan. 20, 2011,
Attachment to Grant at ¶ 3. The AMC-5 satellite is currently in inclined orbit. See Letter of
Karis A. Hastings, Counsel for SES Americom, Inc., to Marlene H. Dortch, Secretary, FCC,
regarding AMC-5 (Call Sign S2156) dated June 16, 2010.
3
     File No. SAT-MOD-20110714-00126 (“AMC-5 Modification”), Narrative at 1. The
AMC-5 Modification was placed on public notice as accepted for filing on August 5, 2011, see


pursuant to STA, but under the terms of the STA, only telemetry, tracking and command

(“TT&C”) operations are authorized.4

               SES Americom also operates the AMC-2 C/Ku-band hybrid spacecraft at the

nominal 79º W.L. orbital location.5 SES Americom has proposed to relocate AMC-2 later this

year to the nominal 5º E.L. orbital location and to operate it there pursuant to Swedish licensing

authority. 6 In preparation for the proposed relocation, SES Americom is in the process of

transitioning all customer traffic off of AMC-2.7

               SES Americom now has an opportunity to use AMC-5 to provide service at

79.10º W.L. Specifically, a U.S. government customer has expressed interest in wide-band, low-

cost, inclined Ku-band capacity. The customer would use a tracking antenna for

communications with AMC-5 to accommodate the satellite’s inclined orbit operations and

expanded east-west stationkeeping tolerance.

               In order to be able to supply this capacity, SES Americom seeks STA to activate

the AMC-5 Ku-band communications payload. Grant of the requested authority will serve the



Report No. SAT-00798, Public Notice: Policy Branch Information (rel. Aug. 5, 2011), and no
comments were filed on the application.
4
        See File Nos. SAT-STA-20110614-00108, grant-stamped June 29, 2011;
SAT−STA−20110715−00128, grant-stamped July 29, 2011 (authorizing SES Americom to
perform TT&C to position AMC-5 at 79.1º W.L. +/- 0.1 degrees for periods of 30 and 60 days,
respectively).
5
       See File No. SAT-MOD-20100324-00056, grant-stamped June 21, 2010.
6
       See File No. SAT-T/C-20110527-00100 (“AMC-2 5º E.L. Application”).
7
       See id., Narrative at 3. Subject to the receipt of Commission authority, SES Americom
proposes to return AMC-2 to the nominal 79º W.L. orbital location following the successful
launch and commencement of operations of the SES-5 satellite at 5º E.L. See Letter of Karis A.
Hastings, Counsel for SES Americom, Inc., to Marlene H. Dortch, Secretary, Federal
Communications Commission, File No. SAT-T/C-20110527-00100, dated Aug. 19, 2011 at 4-5.

                                                 2


public interest and is consistent with Commission precedent. The proposed STA will allow SES

Americom to make efficient use of AMC-5, a spacecraft which is not currently providing service,

in order to satisfy demand for capacity from a prospective customer.

               Activating the AMC-5 communications payload will not adversely affect other

operations. As noted above, traffic is being transitioned off of AMC-2 in preparation for its

proposed relocation. If AMC-5 is selected for use by the government customer, the service will

occupy a transponder on the spacecraft that will have no frequency overlap with transponders

occupied by customers on AMC-2.

               Furthermore, there will be no harm to adjacent satellite networks. SES Americom

has previously demonstrated that operation of AMC-5 at the nominal 79º W.L. orbital location

conforms to the Commission’s requirements for compatibility with a co-coverage, co-frequency

satellite at two degree spacing. 8 Here, SES Americom proposes to operate AMC-5 slightly to the

west of 79.0º W.L., closer to the adjacent 81º W.L. position. Because there is no Ku-band

satellite operating at 81º W.L.,9 this small decrease in orbital spacing will have no effect. SES

Americom will operate AMC-5 consistent with existing and future international coordination

agreements applicable to the 79º W.L. orbital location, including the agreement with Argentina.

               SES Americom incorporates by reference herein the request in the AMC-5

Modification for waiver of Section 25.210(j) of the Commission’s rules. 10 That provision

8
      See File No. SAT-MOD-19980113-00002, Attachment C, Interference Analysis for GE-5
Ku-Band Transponders.
9
        The satellite previously positioned at 81° W.L., Intelsat 3R, has been deorbited. See
Letter of Susan H. Crandall, Assistant General Counsel, Intelsat Corporation, to Marlene H.
Dortch, Secretary, Federal Communications Commission, dated August 24, 2011 (notifying the
Commission that pursuant to authority granted in File No. SAT-STA-20110503-00083, Intelsat
completed end-of-life maneuvers for Intelsat 3R on August 17, 2011).
10
       AMC-5 Modification, Narrative at 4-5.

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specifies that geostationary space stations “must be maintained within 0.05º of their assigned

orbital longitude in the east/west direction, unless specifically authorized by the Commission to

operate with a different longitudinal tolerance.”11 As discussed in the AMC-5 Modification,

grant of a waiver to permit an expanded stationkeeping tolerance will result in fuel saving that

will prolong the spacecraft’s life and there will be no adverse effect on other operators.

               For the foregoing reasons, SES Americom requests grant of special temporary

authority to activate the AMC-5 Ku-band payload at 79.1º W.L.

                                              Respectfully submitted,

                                              SES AMERICOM, INC.

                                              By: /s/ Daniel C.H. Mah

Of Counsel                                        Daniel C. H. Mah
Karis A. Hastings                                 Regulatory Counsel
SatCom Law LLC                                    SES Americom, Inc.
1317 F St. NW, Suite 400                          Four Research Way
Washington, D.C. 20004                            Princeton, NJ 08540
Tel: (202) 599-0975

Dated: September 13, 2011




11
       47 C.F.R. § 25.210(j).

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Document Created: 2011-09-13 11:40:24
Document Modified: 2011-09-13 11:40:24

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