Attachment STA Request

This document pretains to SAT-STA-20121224-00222 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012122400222_979204

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


In the Matter of                                         )
                                                         )
SES AMERICOM, INC.                                       )    File No. SAT-STA-___________
                                                         )    Call Sign S2181
Request for Special Temporary Authority to               )
Alter the Ka-band Coverage of AMC-16                     )


                            REQUEST OF SES AMERICOM, INC.

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

special temporary authority (“STA”) for a period of 60 days beginning on or before January 25,

2013, to permit reorientation of the AMC-16 fixed-satellite space station’s Ka-band beams. SES

seeks STA pending action on its concurrently-filed application to modify the AMC-16 license to

permit adjustment of the satellite’s Ka-band footprint. 1 Grant of the requested authority will

enable SES to tailor the Ka-band coverage of AMC-16 to better accommodate customer service

requirements.

                As discussed in the AMC-16 Modification, SES has a customer request to

perform a slight reorientation of the AMC-16 Ka-band beams. The modification application

includes a public interest analysis in support of the request as well as technical materials

demonstrating that adjusting the AMC-16 Ka-band coverage as proposed will not adversely

affect any other satellite operators. The Commission has generally permitted satellite operators

the flexibility to design and modify their networks in response to customer requirements, absent




1
      SES Americom, Inc., Call Sign S2181, File No. SAT-MOD-20121224-00221 (the “AMC-
16 Modification”).


compelling countervailing public interest considerations. 2 Here, grant of the requested STA will

permit SES to accommodate customer requirements and facilitate efficient use of AMC-16 to

provide service to customers.

               For the foregoing reasons, SES respectfully requests expeditious grant of STA to

permit reorientation of AMC-16 in order to adjust the Ka-band footprint pending action on the

AMC-16 Modification.

                                             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
Tel: (202) 599-0975

Dated: December 24, 2012




2
         See, e.g. AMSC Subsidiary Corporation, 13 FCC Rcd 12316 at ¶ 8 (IB 1998) (the
Commission generally leaves space station design decisions to the licensee “because the licensee
is in a better position to determine how to tailor its system to meet the particular needs of its
customers”) (footnote omitted).



                                               2



Document Created: 2012-12-24 11:52:24
Document Modified: 2012-12-24 11:52:24

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