Attachment STA Narrative

This document pretains to SAT-STA-20170316-00052 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2017031600052_1201219

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SAT-STA-___________ ) Call Sign S2347 Request for Special Temporary Authority to ) Relocate AMC-6 Fixed-Satellite Space Station ) Expedited Action Requested REQUEST OF SES AMERICOM, INC. SES Americom, Inc. (“SES”) hereby respectfully requests special temporary authority (“STA”) for a period of 60 days beginning on or before May 14, 2017, to permit relocation of the AMC-6 C/Ku-band fixed-satellite space station. Specifically, SES seeks authority to: (1) drift AMC-6 from its current position at 67.0° W.L. to 85.0º W.L. and maintain it at that location in inclined orbit using certain C-band and conventional Ku-band frequencies for Telemetry, Tracking and Command (“TT&C”);1 and (2) operate AMC-6 in the conventional Ku-band and extended Ku-band2 frequencies at 85.0º W.L. SES seeks STA pending action on its application to modify the AMC-6 license to reflect these changes.3 Grant of the requested 1 The AMC-6 TT&C frequencies and nominal polarizations are as follows: Command: 6423.5 MHz (horizontal polarization; uplink) Telemetry: 3700.5 MHz (horizontal polarization; downlink), 4199.5 MHz (vertical polarization; downlink), and 11702.0 MHz (horizontal polarization; downlink) 12198.0 MHz (vertical polarization; downlink). 2 Operations in the extended Ku-band will be conducted under an ITU network filing held by the Netherlands Administration. 3 SES Americom, Inc., Call Sign S2347, File No. SAT-MOD-20170316-00051 (the “AMC-6 Modification”). SES incorporates the supporting materials submitted with the AMC-6 Modification by reference herein.

authority will serve the public interest by allowing SES to use AMC-6 to supplement Ku-band service provided by the AMC-2 and AMC-16 satellites to serve customers in the northern latitudes of North America. AMC-6 will also add capacity in the extended Ku-band. As discussed in the AMC-6 Modification, SES has entered into an agreement with EchoStar Satellite Operating Corporation (“EchoStar”), which holds the license for the Ku-band payload of the AMC-16 Ku/Ka-band spacecraft located at 85° W.L.,4 to reposition AMC-6 in order to supplement the Ku-band capacity of AMC-16 and AMC-2. Reassignment of AMC-6 to 85° W.L. will also allow extended Ku-band service from that location. The modification application includes a public interest analysis in support of the request as well as technical materials demonstrating that relocating AMC-6 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 compelling countervailing public interest considerations.5 Here, grant of the requested STA will permit SES to accommodate customer requirements and facilitate efficient use of AMC-6 to provide service to customers. 4 See File No. SAT-ASG-20141020-00111. 5 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

For the foregoing reasons, SES respectfully requests expeditious grant of STA to permit relocation of AMC-6 pending action on the AMC-6 Modification. Respectfully submitted, SES AMERICOM, INC. By: /s/ Petra A. Vorwig Of Counsel Petra A. Vorwig Karis A. Hastings Senior Legal & Regulatory Counsel SatCom Law LLC SES Americom, Inc. 1317 F Street, N.W., Suite 400 1129 20th Street, N.W., Suite 1000 Washington, D.C. 20004 Washington, D.C. 20036 Tel: (202) 599-0975 Dated: March 16, 2017 3


Document Created: 2017-03-16 15:28:55
Document Modified: 2017-03-16 15:28:55
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