Attachment STA Request

This document pretains to SAT-STA-20130322-00051 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2013032200051_991149

                                       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                      )
Relocate AMC-5 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 5, 2013, to change slightly the station-keeping box for the satellite from

80.9° W.L. (+/- 0.1° east-west tolerance) to 80.85° W.L. (+/- 0.15° east-west tolerance). SES

will continue to operate AMC-5 at the nominal 81° W.L. orbital location in accordance with the

International Telecommunication Union (“ITU”) filings and coordination agreements of the

Argentine Administration. Grant of the requested authority will enable SES to safely operate a

second satellite (AMC-2) at the nominal 81° W.L. orbital location while conserving fuel for the

provision of service.

               SES is preparing a modification application to reflect this proposed small shift in

the AMC-5 orbital assignment. Pending submission of and action on the modification, SES

seeks authority to allow the change to take effect in order to accommodate the expected arrival of

AMC-2. SES will make any authorized change in the AMC-5 orbital position 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-5 to 80.85º W.L. As discussed


herein, grant of the requested authority is consistent with Commission precedent 1 and will serve

the public interest.

                SES is currently authorized by the Commission to operate the AMC-5 satellite at

the nominal 81º W.L. orbital location (at 80.9° W.L. to be precise) pursuant to the ITU satellite

network filings of Argentina and under an agreement with SES’s customer, Empresa Argentina

de Soluciones Satelitales S.A. (“AR-SAT”). 2 SES recently applied for authority to relocate its

hybrid AMC-2 spacecraft from 19.0° E.L. to the nominal 81º W.L. orbital location under a

similar arrangement with AR-SAT. 3 SES intends to operate both AMC-5 and AMC-2 within the

same east-west stationkeeping box of 80.85° W.L. +/- 0.15°.

                Grant of the requested authority will serve the public interest by enabling SES to

safely co-locate a second satellite at the nominal 81° W.L. orbital location in order to expand

service to its customer AR-SAT while conserving fuel for future operations. Moreover, the

modification will not adversely affect any other operators. The proposed stationkeeping volume

for AMC-2 and AMC-5 will not overlap with the stationkeeping volume of any other spacecraft.

In addition, the small proposed shift in AMC-5’s orbital location and stationkeeping box will

have a minimal effect on the interference environment in which adjacent satellites operate. SES


1
     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).
2
    See Stamp Grant, Call Sign S2156, File No. SAT-MOD-20110929-00192 (granted Feb. 24,
2012).
3
     See Call Sign S2134, File No. SAT-MOD-20130225-00024 (the “AMC-2 Modification”);
Letter of N. Pablo Tognetti, AR-SAT, to Suzanne Malloy, SES, dated Feb. 25, 2013, attached to
AMC-2 Modification narrative as Annex 1. The letter contemplates operation of both AMC-5
and AMC-2 at the nominal 81° W.L. location.



                                                 2


will coordinate internally to ensure compatibility of Ku-band operations between AMC-5 and

AMC-2. AMC-5 will also be operated consistent with existing and future coordination

agreements of the Argentine Administration relating to its ITU filings at 81° W.L.

               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-5 to

80.85° W.L. +/- 0.15 degrees beginning on or about April 5, 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: March 22, 2013




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Document Created: 2013-03-22 08:27:36
Document Modified: 2013-03-22 08:27:36

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