Attachment STA Request

This document pretains to SAT-STA-20111017-00205 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2011101700205_921464

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


In the Matter of Application of                        )
                                                       )
SES AMERICOM, INC.                                     )    File No. SAT-STA-____________
                                                       )    Call Sign S2134
For Special Temporary Authority to                     )
Relocate AMC-2 to 4.98° E.L.                           )


                                        APPLICATION

               SES Americom, Inc. (“SES Americom,” doing business as “SES”) hereby

respectfully requests special temporary authority (“STA”) for a period of sixty days beginning on

or about October 21 to relocate the AMC-2 C/Ku-band hybrid satellite from 78.95º W.L. to

4.98º E.L. Specifically, SES seeks authority to perform Telemetry, Tracking and Control

(“TT&C”) in order to relocate AMC-2 from 78.95º W.L. to 4.98° E.L. SES will not activate the

communications payloads of AMC-2 during the drift. Grant of the requested authority will serve

the public interest by allowing SES to redeploy AMC-2 to a location where it can introduce new

service in the C-band and additional Ku-band frequencies ahead of the launch of the SES-5

satellite,1 which has been delayed.

               SES has separately filed today a request for STA to operate AMC-2 upon arrival

at 4.98º E.L.2 In addition, SES is preparing to file a modification application to reassign AMC-2

to 4.98º E.L. for operations in accordance with the International Telecommunication Union




1
        The SES-5 satellite is also known as ASTRA-4B and was originally named SIRIUS 5.
See Press Release, SES Orders New SIRIUS 5 Satellite from Loral (Oct. 10, 2008),
http://www.ses-astra.com/business/en/news-events/press-archive/2008/08-10-09/index.php.
2
        See File No. SAT-STA-20111017-00204 (the “Operations STA”).


(“ITU”) filings of the Swedish Administration.3 Pending submission of and action on the

modification and action on the Operations STA, SES seeks authority to allow it to commence

relocation of AMC-2 to 4.98º E.L. If authorized to redeploy AMC-2, SES will do so at its own

risk and understands that such authority would be without prejudice to any action the

Commission ultimately may make regarding the application to reassign AMC-2 to 4.98° E.L. As

discussed herein, grant of the requested authority is consistent with Commission precedent4 and

will serve the public interest.

                AMC-2 is a hybrid C/Ku-band satellite that was launched in 1997 and currently

operates pursuant to FCC authority at the nominal 79° W.L. location,5 where it is collocated with

AMC-5, a Ku-band only satellite.6 SES Americom’s commonly-owned affiliate SES ASTRA

AB7 (“ASTRA AB”) operates satellites at the nominal 5° E.L. position pursuant to Swedish

authority8 and had planned to augment existing services with the new SES-5 satellite at the end



3
         The modification will supersede the request filed earlier this year to transfer AMC-2 from
U.S. licensing authority to Swedish licensing authority for operations at the nominal 5º E.L.
orbital location, File No. SAT-T/C-20110527-00100. SES has withdrawn the AMC-2 transfer of
control application and associated submissions. See WTH2011101790738380 (withdrawal of
AMC-2 transfer of control application); WTH2011101791252966 (withdrawal of STA request
for drift of AMC-2 to 4.98º E.L. pending action on transfer of control application).
4
         The Commission has routinely authorized operators to commence relocation of a satellite
pending a request to reassign the satellite. See, e.g., SES Americom, Inc., Call Sign S2135, File
No. SAT-STA-20100525-00108 (grant-stamped July 12, 2010) (authorizing SES to drift AMC-4
from 101° W.L. to 67° W.L. pending action on the related modification application to reassign
the satellite).
5
         See File Nos. SAT-MOD-20100324-00056 (grant-stamped June 21, 2010) & SAT-MOD-
20101215-00261 (grant-stamped March 8, 2011).
6
        See File No. SAT-MOD-20100706-00154, call sign S2156 (grant-stamped Jan. 20, 2011).
SES recently requested authority to relocate AMC-5 to 80.9° W.L. for operations pursuant to
Argentine ITU filings. See File No. SAT-MOD-20110929-00192.
7
         SES ASTRA AB was formerly known as SES SIRIUS AB. See Press Release, SES
SIRIUS Becomes SES ASTRA (Jun. 23, 2010), http://www.ses-astra.com/business/en/news-
events/news-latest/index.php?pressRelease=/pressReleases/pressReleaseList/10-06-22/index.php.
8
         For example, ASTRA 4A is at the nominal 4.8° E.L. orbital location, and ASTRA 1E is
at the nominal 5.0° E.L. orbital location. ASTRA 1E will be relocated prior to the arrival of


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of 2011. Due to delays in manufacturing and launch manifests, however, the launch of SES-5 is

likely to be delayed beyond its planned commencement of service date. The proposed relocation

of AMC-2 to the nominal 5° E.L. orbital location will allow expansion of service from that

orbital location pending the successful launch of SES-5. No customers of AMC-2 will be

adversely affected, as they have been transferred to other satellites in anticipation of the planned

relocation.

                Grant of the requested authority to relocate AMC-2 will serve the public interest

and is consistent with Commission precedent. The Commission has repeatedly observed that its

policy is to allow “satellite operators to rearrange satellites in their fleet to reflect business and

customer considerations where no public interest factors are adversely affected.”9 As the

International Bureau has explained:

                        the Commission attempts, when possible, to leave
                        spacecraft design decisions to the space station licensee
                        because the licensee is in a better position to determine how
                        to tailor its system to meet the particular needs of its
                        customers. Consequently the Commission will generally
                        grant a licensee’s request to modify its system, provided
                        there are no compelling countervailing public interest
                        considerations.10



AMC-2, so there will be no overlap of the two satellites’ stationkeeping volume. ASTRA 4A
operates in the 11.7-12.75 GHz, 14.0-14.25 GHz, 17.3-18.1 GHz, 18.8-19.3 GHz, 19.7-19.95
GHz, 21.5-21.75 GHz, 29.15-29.4 GHz and 29.5-30.0 GHz bands, and ASTRA 1E operates in
the 10.7-11.2 GHz and 11.45-12.1 GHz, 12.75-13.25 GHz, 14.0-14.25 GHz and 17.3-17.7 GHz
bands. Both ASTRA 4A and ASTRA 1E operate pursuant to ITU filings submitted by Sweden.
9
        SES Americom, Inc., Order and Authorization, DA 06-757 (IB rel. Apr. 7, 2006) at 4, ¶ 8,
citing Amendment of the Commission’s Space Station Licensing Rules and Policies, Second
Report and Order, 18 FCC Rcd 12507, 12509, ¶ 7 (2003).
10
        AMSC Subsidiary Corp., Order and Authorization, DA 98-493, 13 FCC Rcd 12316 (IB
1998) (“AMSC Modification Order”) at 12318, ¶ 8 (footnote omitted). Although AMSC never
implemented the relocation authorized in this case, the Commission has repeatedly reaffirmed its
policy of allowing licensees to change their fleet configurations to accommodate customer
requirements. See, e.g., Space Station Licensing Rules and Policies, First Reconsideration Order
and Fifth Report and Order, FCC 04-147, 19 FCC Rcd 12637, 12653, ¶ 39 (“we generally permit


                                                   3


               Pursuant to this policy, the Commission has routinely authorized satellite

operators to configure or reconfigure their fleets in order to satisfy customer demand, including

demand for capacity outside the U.S. For example, the Commission has authorized U.S.

licensees to relocate satellites from orbital positions over the U.S. to locations without U.S.

coverage in order to respond to existing or potential demand for capacity. 11 Similarly, the

Commission has granted U.S. licenses to operators for satellites at locations from which no U.S.

coverage is planned or possible.12

               Here, the proposed change will allow SES to make efficient use of AMC-2 in

order to expand the available capacity at the nominal 5° E.L. orbital location. Because SES has

already transferred customers that had been using AMC-2 at the nominal 79º W.L. orbital

location, the relocation of AMC-2 will not have any impact on existing services.

               Relocation of AMC-2 to 4.98º E.L. will not adversely affect other operators. The

proposed stationkeeping volume will not overlap with that of any other spacecraft. SES will

operate only the TT&C frequencies of AMC-2 during the drift.13 SES will follow standard



licensees to modify their systems to adapt to changing business and customer needs,” citing
AMSC Modification Order and other cases).
11
        See, e.g., Intelsat North America LLC, Call Sign S2159, File No. SAT-T/C-20100112-
00009, grant-stamped July 30, 2010 (authorizing Intelsat to relocate Galaxy 27 from 129° W.L.
to 45.10° E.L.); PanAmSat Licensee Corp., Call Sign S2253, File No. SAT-MOD-20080225-
00051, grant-stamped July 22, 2008 (authorizing relocation of Galaxy 11 from 91° W.L. to
32.80° E.L. in order to supplement service provided there by Intelsat 802, which had suffered an
anomaly that reduced its available power); AMSC Modification Order (authorizing AMSC to
relocate its satellite away from 101° W.L. in order to provide service to southern Africa).
12
        See, e.g., Afrispace, Inc., Order and Authorization, DA 06-4, 21 FCC Rcd 7 (IB 2006)
(authorizing launch and operation of AfriStar-2 satellite for service to Africa and Europe from
21° E.L.); Assignment of Orbital Locations to Space Stations in the Ka-Band, Order, DA 96-708
(IB 1996) (assigning 33 orbital locations between 62° W.L. and 175.25° E.L. to 13 Ka-band
applicants, finding that the public interest would be served by authorizing international
operations pending the development of policies for Ka-band satellite service within the U.S.).
13
        The AMC-2 TT&C frequencies are as follows:
        Command: 6423.5 MHz (horizontal polarization; uplink)


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industry practices for coordination of TT&C transmissions during the relocation process. Once

AMC-2 arrives at 4.98º E.L., SES will operate the satellite pursuant to Swedish ITU filings and

in conformance with Sweden’s coordination agreements regarding that location.

               SES 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.

SES 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 respectfully requests STA to relocate AMC-2

from 78.95º W.L. to 4.98º E.L. beginning on or about October 21, 2011.

                                                      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 Street, N.W., Suite 400                        Four Research Way
Washington, D.C. 20004                                Princeton, NJ 08540

Dated: October 17, 2011




        Telemetry: 3700.5 MHz (horizontal polarization; downlink), 4199.5 MHz (vertical
polarization; downlink), and 12198.0 MHz (horizontal polarization; downlink).


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Document Created: 2011-10-17 20:49:29
Document Modified: 2011-10-17 20:49:29

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