Attachment STA Narrative SAT-STA-20170623-00096

Attachment STA Narrative

This document pretains to SAT-STA-20170623-00096 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2017062300096_1240849

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 the AMC-6 Fixed-Satellite Space )
Station to 83° W.L. )

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 June 29, 2017, to permit

relocation of the AMC-6 C/Ku-band fixed-satellite space station to 83° W.L.1 Specifically, SES

seeks authority to: (1) drift AMC-6 from its current position at 85.0° W.L. to 83.0º W.L. and

maintain it at that location using certain C-band and conventional Ku-band frequencies for

Telemetry, Tracking and Command (“TT&C”);2 and (2) operate AMC-6 in the conventional C-

band, conventional Ku-band and extended Ku-band3 frequencies at 83.0º W.L. SES seeks STA

pending submission of and action on an application to modify the AMC-6 license that will be

1
SES is requesting STA for a period of 60 days; however, if the Commission determines it is
not able to grant STA for that period, SES will accept an authorization for 30 days.
2
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).
3
Operations in the extended Ku-band (specifically 11.45-11.7 and 13.75-14 GHz) will be
conducted under an ITU network filing LUX-G8-44 held by the Luxembourg Administration.

filed shortly to reflect these changes. Grant of the requested authority will serve the public

interest by allowing SES to offer a long-term solution for customers whose service at 83° W.L.

was interrupted by the recent AMC-9 anomaly. AMC-6 will also add capacity in the extended

Ku-band.

As SES previously notified the Commission, on June 17, 2017, the AMC-9

satellite assigned to 83° W.L. experienced an anomaly of unknown origin. Due to this anomaly,

the satellite is not responding to commands, and SES is unable to maintain the satellite in its

assigned stationkeeping volume. SES received STA for 30 days to continue communications

with the satellite for TT&C purposes only.4 A significant portion of the traffic that had been

carried by AMC-9 has been transitioned to AMC-6, which was recently relocated to 85° W.L.

pursuant to Commission authority.5

In response to the anomaly, SES has developed a plan to restore long-term service

to the customers previously using AMC-9 at 83° W.L. and seeks the necessary authority to

implement the solution as quickly as possible. Initially, SES’s AMC-4 satellite, which is

currently authorized to drift to 134.9° W.L.,6 will stop temporarily at 85° W.L. on or around

June 29, 2017.7 SES will transfer active traffic on AMC-6 at 85° W.L. to AMC-4. Once the

traffic has been transferred, which is expected to be completed by early on June 30, AMC-6 can

be relocated to 83° W.L. After AMC-6 arrives at 83° W.L. on or around July 3, SES will

4
See SES Americom, Inc., File No. SAT-STA-20170619-00091, granted June 17, 2017.
5
See SES Americom, Inc., File No. SAT-MOD-20170316-00051 (the “AMC-6
Modification”), granted June 14, 2017.
6
SES Americom, Inc., File No. SAT-STA-20170503-00070, granted June 7, 2017.
7
SES is simultaneously filing a separate STA request for the proposed temporary operation
of AMC-4 at 85° W.L.

2

transfer all of the traffic from AMC-4 back to AMC-6. Following completion of that traffic

transfer on or before July 7, AMC-4 will resume its drift to the nominal 135° W.L. orbital

location.

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.,8 to operate AMC-4 temporarily at 85° W.L. in order to facilitate

the relocation of AMC-6 to 83° W.L. and to restore customers affected by the AMC-9 anomaly.

Reassignment of AMC-6 to 83° W.L. will also allow new extended Ku-band service to be

offered at that location.

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.9 Here, the requested authority is necessary to

provide a quick and long-term solution to restore service for customers, including the U.S.

Department of Defense, that were affected by the AMC-9 anomaly. The two-degree shift in the

AMC-6 location will not change the vast majority of the technical information that was included

in the AMC-6 Modification. Pending submission of the full reassignment application, SES is

attaching here updated contour maps reflecting the modest shift in the AMC-6 coverage

associated with the satellite’s move from 85° W.L. to 83° W.L.

8
See File No. SAT-ASG-20141020-00111.
9
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).

3

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

permit relocation of AMC-6 to 83° W.L pending submission of and action on the modification

application to be filed shortly.

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: June 23, 2017

4

Document Created: 2017-06-23 14:13:11
Document Modified: 2017-06-23 14:13:11

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