Attachment STA Request

This document pretains to SAT-STA-20130225-00025 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013022500025_987195

                                    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 80.85° W.L. +/- 0.15 degrees          )


                        APPLICATION OF SES AMERICOM, INC.

               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 April 1, 2013, to relocate the AMC-2 fixed-satellite space station from 19.0° E.L. to

80.85° W.L. with an east-west stationkeeping tolerance of +/- 0.15 degrees, where it will be co-

located with SES’s AMC-5 satellite. Specifically, SES requests authority to perform Telemetry,

Tracking and Command (“TT&C”) using certain C-band and Ku-band frequencies 1 in order to

relocate AMC-2 from 19.2º E.L. to 80.85° W.L., and authority to operate both the TT&C and

communications payloads on AMC-2 after it has arrived. SES will operate AMC-2 at 80.85°

W.L. in accordance with the International Telecommunication Union (“ITU”) filings and

coordination agreements of the Argentine Administration. Grant of the requested authority will

serve the public interest by allowing SES to use AMC-2 to meet the requirements of its customer,

Empresa Argentina de Soluciones Satelitales S.A. (“AR-SAT”), and expand the services

available from the nominal 81° W.L. orbital location.


1
     The AMC-2 TT&C frequencies and nominal polarizations are as follows:
        Command: 6423.5 MHz (vertical polarization; uplink)
        Telemetry: 3700.5 MHz (vertical polarization; downlink), 4199.5 MHz (vertical
polarization; downlink), and 12198.0 MHz (horizontal polarization; downlink).


                SES has separately filed today a modification application to reassign AMC-2 to

80.85° W.L. +/- 0.15 degrees for operations in accordance with the Argentine ITU filings. 2

Pending action on the modification, SES seeks authority to allow it to commence relocation of

AMC-2 to 80.85º W.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 80.85º W.L. As discussed

herein, grant of the requested authority is consistent with Commission precedent 3 and will serve

the public interest.

                AMC-2 is a hybrid C/Ku-band satellite that is currently licensed by the FCC to

operate at 19.0° E.L. with an east-west stationkeeping tolerance of +/- 0.1 degrees under the ITU

satellite network filings of the Luxembourg Administration. 4 SES proposes to relocate AMC-2

to the nominal 81° W.L. orbital location (at 80.85° W.L. to be precise), where it will operate

under the ITU satellite network filings of the Argentine Administration. The redeployment of

AMC-2 will not impact continuity of operations at the nominal 19.2° E.L. location as any traffic

on that satellite will be transferred to other spacecraft in the SES fleet prior to relocation.

                Grant of the requested authority to relocate and operate AMC-2 will serve the

public interest and is consistent with Commission precedent. The Commission has repeatedly


2
    See File No. SAT-MOD-20130225-00024. SES incorporates by reference the supporting
materials that were filed with the modification application.
3
     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).
4
     See File No. SAT-MOD-20120524-00087, grant-stamped July 25, 2012 (the “AMC-2
19.2° E.L. Grant”).



                                                   2


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.” 5 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. 6

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

order to expand the available capacity at the nominal 81° W.L. orbital location. At that location,

AMC-2 will supplement the service being provided by the Ku-band only AMC-5 spacecraft by

adding South American C-band and Ku-band coverage to AMC-5’s North American Ku-band

coverage. 7 SES will coordinate internally to ensure compatibility of Ku-band operations

between AMC-2 and AMC-5.

                Reassignment of AMC-2 to 81.2º W.L. will not adversely affect other operators.

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

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

Once AMC-2 arrives at 80.85º W.L., SES will operate the satellite pursuant to Argentine ITU

filings and in conformance with Argentina’s coordination agreements regarding that location.


5
     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).
6
    AMSC Subsidiary Corp., Order and Authorization, DA 98-493, 13 FCC Rcd 12316 (IB
1998) at 12318, ¶ 8 (footnote omitted).
7
     See File No. SAT-MOD-20110929-00192, grant-stamped Mar. 2, 2012.



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               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 19.0° E.L. to 80.85° W.L. +/- 0.15 degrees beginning on or about April 1, 2013.

                                              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: February 25, 2013




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Document Created: 2013-02-25 22:22:28
Document Modified: 2013-02-25 22:22:28

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