AMC-2.pdf

LETTER submitted by SES Americom, Inc.

AMC-2 Update and Response to Commission Letter

2011-08-19

This document pretains to SAT-T/C-20110527-00100 for Transfer of Control on a Satellite Space Stations filing.

IBFS_SATTC2011052700100_913080

                                                                                                             Hogan Lovells US LLP
                                                                                                             Columbia Square
                                                                                                             555 Thirteenth Street, NW
                                                                                                             Washington, DC 20004
                                                                                                             T +1 202 637 5600
                                                                                                             F +1 202 637 5910
                                                                                                             www.hoganlovells.com




August 19, 2011


By Electronic Filing

Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
445 12th Street, S.W.
Washington, D.C. 20554

Re:              AMC-2 (Call Sign S2134), File No. SAT-T/C-20110527-00100
                 Update Pursuant to Section 1.65 and Response to Commission Letter

Dear Ms. Dortch:

SES Americom, Inc. (“SES Americom”) and SES ASTRA AB (“ASTRA AB,” and with SES
Americom, the “Applicants”), by their attorneys and pursuant to Section 1.65 of the Commission’s
rules,1 hereby update their above-referenced application to transfer the AMC-2 space station from
operations under U.S. licensing authority to operations under Swedish licensing authority at the
nominal 5° E.L. orbital location (the “AMC-2 Transfer Application”). In addition, the Applicants
respond below to the Commission’s letter requesting additional information concerning the AMC-2
Transfer Application.2 SES Americom and ASTRA AB respectfully request that the Commission
incorporate the supplemental information provided here into the record relating to the AMC-2
Transfer Application.

                                                                     Section 1.65 Update

AMC-2 Orbital Position: The AMC-2 Transfer Application stated that at the nominal 5° E.L. orbital
location ASTRA AB would operate AMC-2 pursuant to International Telecommunication Union
(“ITU”) filings made by the Swedish Administration for the benefit of ASTRA AB.3 The application
went on to explain that ASTRA AB currently operates other satellites under Swedish authority and
ITU filings at the nominal 5° E.L. orbital location, including ASTRA 4A and ASTRA 1E.4 In order to

1
    47 C.F.R. § 1.65.
2
    See Letter of Robert G. Nelson, Chief, Satellite Division to Karis A. Hastings dated July 19, 2011
    (the “AMC-2 Letter”).
3
    AMC-2 Transfer Application, Narrative at 1-2.
4
    Id. at 2 & n.7.
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Ms. Marlene H. Dortch                               -2-                                   August 19, 2011


avoid stationkeeping overlaps with these satellites, SES Americom and ASTRA AB initially proposed
to position AMC-2 at 5.16° E.L.5

The Applicants hereby advise the Commission of a change to this deployment plan. Specifically, the
Applicants now propose to position AMC-2 at 4.98° E.L., rather than at 5.16° E.L. This change will
not result in an overlap of the proposed stationkeeping volume of AMC-2 with the other ASTRA AB
satellites at the nominal 5° E.L. location.6

Updated officers and directors: Exhibit E of the AMC-2 Transfer Application contained lists of the
officers and directors of SES Americom and ASTRA AB, but there have been subsequent changes
to both Applicants’ management. An updated copy of Exhibit E that reflects the current director and
officer information for each of the Applicants is attached hereto.

                                        Response to AMC-2 Letter

Responses to the information requests in the AMC-2 Letter are provided below.

      1. A copy of any licensing document to operate the AMC-2 space station using C- and Ku-band
         frequencies at the 5.16° E.L. orbital location from the Swedish Post and Telecommunications
         Agency, and an English translation of that authorization, if necessary.

The Swedish Post and Telecommunications Agency (“PTS”) has not issued a license for the
operations of AMC-2 at the nominal 5° E.L. orbital location, and no such PTS license is required.
The Applicants filed with the AMC-2 Transfer Application a letter from the PTS describing the current
ITU filings that have been submitted at this nominal location and indicating that the filings were made
for the benefit of ASTRA AB.7

A supplemental letter from the PTS is attached hereto.8 The August PTS Letter makes clear that the
PTS is aware that ASTRA AB plans to operate AMC-2 at 4.98° E.L.,9 and that “PTS supports the
operation of AMC-2 at 4.98°E under Swedish ITU filings” that were submitted on behalf of ASTRA
AB.10




5
     Id. at 2, n.4.
6
     Specifically, ASTRA 1E will be relocated prior to the arrival of AMC-2 to avoid any overlap, and ASTRA
     4A will remain positioned at the nominal 4.8° E.L. orbital location.
7
     Letter from Helena Åkerlund, Head of the Fixed Radio and Satellite Unit, Swedish Post and Telecom
     Agency, to SES ASTRA AB dated May 25, 2011, attached as Annex 1 to the AMC-2 Transfer
     Application.
8
     Letter from Helena Åkerlund, Head of the Fixed Radio and Satellite Unit, Swedish Post and Telecom
     Agency, to SES ASTRA AB dated Aug. 15, 2011 (the “August PTS Letter”).
9
     As discussed above, the Applicants now propose to position AMC-2 at 4.98° E.L., rather than
     5.16° E.L.
10
     August PTS Letter at 1.


Ms. Marlene H. Dortch                           -3-                                 August 19, 2011


   2. Please state whether ASTRA AB’s operations of AMC-2 at 5.16° E.L. require authority under
      the Swedish Space Act. If so, please indicate whether such authority has been requested or
      granted. If it is SES Americom’s view that no such authorization is needed, please provide
      an explanation of that view.

The planned operations of AMC-2 at 4.98° E.L. do not require authority under the Swedish Space
Act. The Applicants’ view that no authority under the Swedish Space Act is required is based on
discussions between ASTRA AB personnel and staff of the Swedish National Board for Space
Activities (the “National Board”). During those discussions, the National Board staff have indicated
that authority under the Swedish Space Act is required only with respect to a satellite that is being
commanded and controlled from Swedish territory. The Applicants do not propose to control AMC-2
from Sweden while it is positioned at 4.98° E.L.

As a point of comparison, ASTRA AB currently operates ASTRA 1E at the nominal 5° E.L. orbital
location pursuant to Swedish ITU filings but without a license under the Swedish Space Act because
the satellite is not controlled from Sweden. In contrast, ASTRA AB sought and obtained a license
under the Swedish Space Act for SES-5 (also known as ASTRA-4B), because that satellite will be
controlled from ground station facilities located in Sweden.

   3. Points of contact with the Swedish Post and Telecommunications Agency and the National
      Board for Space Activities.

PTS Contact:
       Adviser Marie Broström
       Phone: +46 8 678 57 12
       Mobile: +46 73 066 57 12
       e-mail: marie.brostrom@pts.se

       PTS
       Box 5398
       SE-102 49 Stockholm
       Sweden
National Board contact:
       Ms. Maria Nilsson
       Phone: +46 8 627 64 94
       Fax: +46 8 627 50 14
       e-mail: maria.nilsson@snsb.se

       Swedish National Space Board
       Box 4006
       SE-171 04 Solna
       Sweden

   4. The anticipated length of time AMC-2 will operate at the 5.16° E.L. orbital location. In
      addition, because AMC-2 will operate at 5.16° E.L. until the launch of the SES-5 space
      station to that location, please provide the status of the construction and launch of SES-5.

The Applicants anticipate that AMC-2 will operate at 4.98° E.L. for approximately four to seven
months, depending on a variety of factors. Subject to receipt of the required Commission authority,


Ms. Marlene H. Dortch                              -4-                                    August 19, 2011


SES Americom proposes to commence relocation of AMC-2 in mid-October, and anticipates that the
drift from 78.95° W.L. to 4.98° E.L. would take roughly two and a half months, so that the satellite
would arrive in January 2012. The Applicants propose to maintain AMC-2 at 4.98° E.L. pending the
successful launch of the SES-5 satellite to the nominal 5° E.L. orbital location. The Applicants
anticipate that the AMC-2 satellite will be released from its duties at 5° E.L. by May 2012, unless the
launch of SES-5 is significantly delayed.

This estimated time frame is based on the current schedule for SES-5. While ASTRA AB remains
hopeful that SES-5 can still be launched by the end of 2011 (as planned), the delays experienced to
date indicate that the construction of the satellite will more likely be completed by the end of this
year, and that launch will more likely take place in March 2012.

     5. SES Americom states that no customers of AMC-2 at 78.95° W.L. will be adversely affected
        by this request. Please provide information regarding the specific space station(s) to which
        AMC-2 customers will be transferred.

Prior to the proposed departure of AMC-2 from 78.95° W.L., the customers currently on AMC-2 will
have been transferred to the SES-1 and AMC-3 satellites.

     6. Specify SES Americom’s actions with respect to its current authorization at 78.95° W.L. in
        light of the requirements of Section 25.161(c) of the Commission’s rules.

SES Americom plans to return AMC-2 to the nominal 79° W.L. orbital location following its period of
service at 4.98° E.L.11 SES Americom therefore requests any necessary authority under
Section 25.161(c) to permit AMC-2 to return to the nominal 79° W.L. orbital location after completion
of its interim operations at 4.98° E.L. Grant of such authority is in the public interest because the
temporary relocation of AMC-2 will allow the initiation of new services and will not result in the
interruption of services to any AMC-2 customers. Moreover, AMC-2 will be available to return to
79° W.L. to serve U.S. consumers from that slot well before a new spacecraft could be deployed
there.

Section 25.161(c) provides that a license will automatically terminate upon “removal or modification
of the facilities which renders the station not operational for more than 90 days, unless specific
authority is requested.”12 SES Americom hereby requests such authority to permit AMC-2 to resume
operations in the C-band and Ku-band at the nominal 79° W.L. orbital location no later than
December 15, 2012. This requested return deadline will allow time for SES-5 to commence service
and for AMC-2 to be drifted back to its currently assigned position. The proposed return date would
also accommodate modest further delays in the launch of SES-5, and would permit AMC-2 to be
away from the nominal 79° W.L. orbital location for a maximum period of 14 months.

Authority under Section 25.161(c) is justified to achieve the public interest benefits identified in the
AMC-2 Transfer Application and further described below. These benefits, moreover, will be

11
   At the time the Applicants filed the AMC-2 Transfer Application, they indicated that a decision had not
   yet been made regarding deployment of AMC-2 following completion of its proposed operations at the
   nominal 5° E.L. location. See AMC-2 Transfer Application, Narrative at 3 n.8. Subsequently, a
   determination was made that, subject to the receipt of required Commission authority, the satellite
   would be returned to the nominal 79° W.L. orbital location following the successful launch of SES-5 to
   5° E.L.
12
   47 C.F.R. § 25.161(c).


Ms. Marlene H. Dortch                               -5-                                   August 19, 2011


achieved without any adverse impact on other users. As discussed above, SES Americom has
committed to ensuring that all current customers of AMC-2 at 78.95° W.L. will be transferred to other
satellites before relocation of AMC-2 begins.

Under these circumstances, authority under Section 25.161(c) is consistent with Commission
precedent and is in the public interest. The Commission has indicated that Section 25.161(c) is
intended to prevent unacceptable lapses in service that could result if a satellite is moved out of its
assigned orbit location for an extended period.13 Where these interests are not implicated, the
Commission has granted relief under the rule. For example, the International Bureau granted a
waiver of Section 25.161(c) to permit relocation of SES Americom’s AMC-16 satellite to
118.75° W.L. pending launch and commencement of operations of the Canadian-licensed Anik F3
spacecraft at that location.14 The Bureau later extended the deadline for AMC-16’s return because
of further delays in the Anik F3 launch schedule.15 The Commission found that waiver of
Section 25.161(c) was warranted because there would be no interruption in service at the satellite’s
original location and the relocation was for a limited duration with a definite end date.16

The same facts justify relief under Section 25.161(c) here. The Applicants have proposed to return
AMC-2 to the nominal 79° W.L. orbital location after a limited period. The relocation of AMC-2 will
allow new service to be established at the nominal 5° E.L. orbital location pending launch and
commencement of operations of the delayed SES-5 spacecraft. Finally, no customers will be
adversely affected. In these circumstances, the public interest will be served by grant of the
requested waiver.17

     7. Provide additional information regarding how grant of the transfer will serve the public
        interest, including any effect the transfer may have on the U.S. Administration’s International
        Telecommunication Union filing for the 79° W.L. orbital location.

Grant of the proposed transfer is consistent with Commission precedent and will serve the public
interest by allowing SES Americom to make efficient use of the AMC-2 satellite to initiate new
service at the nominal 5° E.L. location notwithstanding the delay in launch of SES-5.

The Commission has repeatedly stated 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.”18 Pursuant to this policy, the Commission has routinely authorized
satellite operators to configure or reconfigure their fleets in order to satisfy customer demand,


13
   See, e.g., VisionStar Incorporated, 19 FCC Rcd 14820 (IB 2004).
14
   SES Americom, Inc., Order and Authorization, DA 06-757 (IB rel. Apr. 7, 2006) (“AMC-16 Relocation
   Order”).
15
   SES Americom, Inc., Memorandum Opinion and Order, DA 06-2591 (IB rel. Dec. 22, 2006). With the
   extension, the total authorized period for AMC-16’s absence from its assigned orbital location was
   roughly fifteen months.
16
   AMC-16 Relocation Order at 5, ¶ 9.
17
   See, e.g., PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (“Generally, the
   Commission may grant a waiver of its rules in a particular case if the relief requested would not
   undermine the policy objective of the rule in question and would otherwise serve the public interest.”)
   (footnotes omitted).
18
   AMC-16 Relocation Order 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).


Ms. Marlene H. Dortch                               -6-                                     August 19, 2011


including demand for capacity outside the U.S. For example, the Commission has authorized U.S.
licensees to relocate satellites from orbital positions over the U.S. to locations without U.S. coverage
in order to respond to existing or potential demand for capacity.19 Similarly, the Commission has
granted U.S. licenses to operators for satellites at locations from which no U.S. coverage is planned
or possible.20

As the Bureau explained in the AMSC Modification Order:

                         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.21

The facts here are similar to those before the Commission in support of Intelsat’s application to
transfer Galaxy 27 for operations at 45.1° E.L. under German licensing authority. Intelsat did not
propose to serve the U.S. from the new location, which is not capable of “seeing” the U.S. Instead,
Intelsat explained that relocation would “help satisfy high customer demand for capacity over the
Middle East” and would allow Intelsat to operate Galaxy 27 “with the coordination benefits
associated with Germany’s ITU filings for the 45.10° E.L. location.”22 Intelsat noted that no
customers would be adversely affected by the proposed move because “they will have been
relocated to other satellites prior to Galaxy 27’s drift to 45.10° E.L.”23

As with Galaxy 27, relocation of AMC-2 will allow the Applicants to respond to demand for capacity
outside the U.S. Customers at the nominal 5° E.L. orbital location will benefit from the coordination

19
   See, e.g., Intelsat North America LLC, Call Sign S2159, File No. SAT-T/C-20100112-00009 (“Galaxy
   27 Relicensing Application”) (grant-stamped July 30, 2010) (authorizing Intelsat to relocate Galaxy 27
   from 129° W.L. to 45.10° E.L.); PanAmSat Licensee Corp., Call Sign S2253, File No. SAT-MOD-
   20080225-00051 (grant-stamped July 22, 2008) (authorizing relocation of Galaxy 11 from 91° W.L. to
   32.80° E.L. in order to supplement service provided there by Intelsat 802, which had suffered an
   anomaly that reduced its available power); AMSC Subsidiary Corp., Order and Authorization, DA 98-
   493, 13 FCC Rcd 12316 (IB 1998) (“AMSC Modification Order”) (authorizing AMSC to relocate its
   satellite away from 101° W.L. in order to provide service to southern Africa).
20
   See, e.g., Afrispace, Inc., Order and Authorization, DA 06-4, 21 FCC Rcd 7 (IB 2006) (authorizing
   launch and operation of AfriStar-2 satellite for service to Africa and Europe from 21° E.L.); Assignment
   of Orbital Locations to Space Stations in the Ka-Band, Order, DA 96-708 (IB 1996) (assigning 33 orbital
   locations between 62° W.L. and 175.25° E.L. to 13 Ka-band applicants, finding that the public interest
   would be served by authorizing international operations pending the development of policies for Ka-
   band satellite service within the U.S.).
21
   AMSC Modification Order, 13 FCC Rcd at 12318, ¶ 8 (footnote omitted). Although the relocation
   authorized in this case was never implemented, the Commission has repeatedly reaffirmed its policy of
   allowing licensees to change their fleet configurations to accommodate customer requirements. See,
   e.g., Space Station Licensing Rules and Policies, First Reconsideration Order and Fifth Report and
   Order, FCC 04-147, 19 FCC Rcd 12637, 12653, ¶ 39 (“we generally permit licensees to modify their
   systems to adapt to changing business and customer needs,” citing the AMSC Modification Order and
   other cases).
22
   Galaxy 27 Relicensing Application, Narrative at 1.
23
   Id. Intelsat indicated that it intended to relocate another satellite in its fleet to the 129° W.L. orbital
   location to provide service in lieu of Galaxy 27. See id. at 2 n.1.


Ms. Marlene H. Dortch                           -7-                                  August 19, 2011


status of the Swedish ITU filings at that position. There will be no adverse effect on existing
customers because AMC-2 traffic will have been transferred to other satellites before the planned
relocation commences. Thus, the facts here are squarely within the precedent established in the
Galaxy 27 relocation proceeding, and grant of similar authority is warranted.

The proposed transfer of AMC-2 will have no effect on the U.S. Administration’s ITU filing for the
79° W.L. orbital location. As discussed above, subject to the grant of required Commission
authority, SES Americom intends to return AMC-2 to the nominal 79° W.L. orbital location following
the successful launch of SES-5 to the nominal 5° E.L. orbital location. If the Commission grants the
requested relief under Section 25.161(c), SES Americom would have to resume C- and Ku-band
service using AMC-2 at 79° W.L. within 14 months or risk the cancellation of its license at that
location. Because the ITU rules permit Administrations to suspend the use of a recorded frequency
assignment for a period of up to two years,24 the planned return of AMC-2 to the nominal 79° W.L.
orbital location will allow the existing rights pursuant to the U.S. ITU filing at this location to be
retained.

Please address any further questions regarding this matter to the undersigned.

Respectfully submitted,

/s/ Karis A. Hastings

Karis A. Hastings

Counsel for SES Americom, Inc.
karis.hastings@hoganlovells.com
D +1.202.637.5767

cc:       Robert Nelson
          Stephen Duall
          Karl Kensinger
          Alyssa Roberts




24
     ITU Radio Regulations No. 11.49.


                                                                                     FCC Form 312, Exhibit E
                                                                                                 Page 1 of 2

                               Exhibit E: Response to Items 34, 40 and A20

                           OWNERSHIP AND CONTROL OF SES ASTRA AB

          In this application, SES Americom, Inc. (“SES Americom”) and its commonly-owned affiliate SES
ASTRA AB (“ASTRA AB”) seek FCC consent to the transfer of control of the AMC-2 satellite from U.S.
licensing authority to Swedish licensing authority upon relocation of the spacecraft to the nominal 5° E.L.
orbital location. Although ASTRA AB will not become an FCC licensee as a result of the proposed transfer,
information regarding the ownership and control of ASTRA AB is provided herein in response to items 34, 40
and A20.

          Like SES Americom, ASTRA AB is an indirect wholly-owned subsidiary of SES S.A. (“SES,”
formerly known as SES Global S.A.). SES ASTRA S.A. (“SES ASTRA”), a direct wholly-owned subsidiary
of SES, holds 67.66% of the capital stock of ASTRA AB. The remaining 32.34% of the capital stock of
ASTRA AB is held by SES Global Americas Holdings GP, a Delaware general partnership that is owned
99.94% by SES and 0.06% by SES ASTRA. SES Global Americas Holdings GP also holds 100% of the
capital stock of SES Global-Americas, Inc., which in turn holds 100% of the capital stock of SES Americom.
SES and SES ASTRA are both Luxembourg companies, and ASTRA AB is a Swedish company. The other
entities are U.S. corporations or partnerships.

        SES wholly owns SES Americom, SES ASTRA, and New Skies Satellites B.V. Through its
subsidiaries and affiliates, SES engages in the provision of satellite services throughout the world.

         The offices of ASTRA AB are at Kista Science Tower, Färögatan 33, SE-164 51 Kista, Sweden. The
offices of SES and SES ASTRA are at L-6815 Château de Betzdorf, Luxembourg. The address of SES
Americom, SES Global-Americas, Inc., and SES Global Americas Holdings GP is 4 Research Way, Princeton,
NJ 08540.

        The names, addresses, and citizenship of stockholders owning of record and/or voting 10 percent or
more of SES voting stock are:

    1. The Etat du Grand Duché de Luxembourg (the “State of Luxembourg”) – and Banque et Caisse
       d’Epargne de l’Etat (“BCEE”) and Société Nationale de Crédit et d’Investisement (“SNCI”), each of
       which is an institution created by act of the Luxembourg Parliament and 100% owned by the State of
       Luxembourg – hold Class B shares of SES representing a combined effective economic interest of
       16.67% and effective voting power of 33.33%. In addition, in 2007 and 2008 these entities received
       SES Fiduciary Deposit Receipts (“FDRs”), which each represent one Class A share of SES. The
       FDRs distributed to these entities represent a combined 5.43% economic interest and effective voting
       power of 4.35%. SES Americom has no information regarding whether the Class B shareholders
       continue to hold these FDRs. The principal business of both BCEE and SNCI is financial services.
       The addresses of BCEE and SNCI are as follows:

                         Banque et Caisse d’Epargne de l’Etat
                         1, place de Metz
                         L-2954 Luxembourg

                         Société Nationale de Crédit et d’Investisement
                         7, place du St. Esprit
                         L-1475 Luxembourg

The address for the State of Luxembourg is Ministry of State, 4 rue de la Congrégation, L-2910, Luxembourg.


                                                                                   FCC Form 312, Exhibit E
                                                                                               Page 2 of 2


Directors and Officers

        The directors and officers of ASTRA AB are:

        Ferdinand Kayser
        Norbert Hölzle
        Padraig McCarthy
        Håkan Sjödin
        Ranjani Srinivasan

Mr. Kayser is a Luxembourg national, Mr. Hölzle is a German national, and Mr. McCarthy is an Irish national,
and their address is: L-6815 Château de Betzdorf, Luxembourg. Mr. Sjödin and Ms. Srinivasan are Swedish
nationals, and their address is: SES ASTRA AB, Kista Science Tower, Färögatan 33, SE-164 51 Kista,
Sweden.

        The directors of SES Americom are:

                Robert Bednarek
                Robert J. Kisilywicz
                David J. Lidstone
                Sergy Mummert
                Mike J. Noon

The address of Messrs. Bednarek, Kisilywicz, Lidstone, Mummert and Noon is SES Americom, Inc., 4
Research Way, Princeton, NJ 08540. All of the directors are U.S. citizens.

The officers of SES Americom are:

           NAME                                              TITLE
Robert Bednarek                 President & CEO
Robert J. Kisilywicz            Senior Vice President & CFO
Steve Bunke                     Vice President
Carl Capista                    Vice President
Christopher Coogan              Vice President
Steve Corda                     Vice President
Peter Gustafson                 Vice President
Robert Jones                    Vice President/Controller
Richard A. Langhans             Vice President
David J. Lidstone               Vice President/Assistant Secretary
Sergy Mummert                   Vice President
John A. Nelsen                  Vice President
Maureen Offord                  Vice President
Steven Osman                    Vice President
Aaron Shourie                   Vice President/Assistant Secretary
Daniel Mah                      Assistant Secretary
Suzanne Malloy                  Assistant Secretary
Hanaa Nasr                      Assistant Treasurer - Taxes

The address of all the officers is SES Americom, Inc., 4 Research Way, Princeton, NJ 08540. With the
exception of Mr. Mah, who is an Australian national, all of the officers are U.S. nationals.


           d                                          Date             Page

PTS                                                   2011—08—15       1(1)
                                                      Your date        Your reference




Kiamal Akperov                                        SES ASTRA AB
Frequency Management Department                       Attn. Mrs. Ranjani Srinivasan
Swedish Post and Telecom Agency                       Firogatan 33
                                                      SE—164 51 Kista
                                                      Sweden

                                                      Fax: +1 202 418 1208




Subject:        Operation of AMC—2 at 4.98°E



Dear Sir or Madam,


The Swedish Post and Telecom Agency, PTS would like to refer to our
previous letter (subject: "SIRIUS—5E filings at 5° East Longitude"), dated 25
May, 2011.


SES ASTRA AB has informed PTS that AMC—2 will be operating at 4.98°E,
and PTS supports the operation of AMC—2 at 4.98°E under Swedish ITU
filings, which have been submitted to ITU on behalf of SES ASTRA AB.


Best Regards,




SPatoud...
Helena Akerlund
Head of the Fixed Radio and Satellite Unit




Swedish Post and Telecom Agency



Box 5398                      Visiting address:               Switchboard: +46 8 678 55 00

SE—102 49 Stockholm           Birger Jarlsgatan 117           Telefax: +46 8 678 55 05

Sweden                        www.pts.se                      pts@pts.se



Document Created: 2011-08-19 15:52:31
Document Modified: 2011-08-19 15:52:31

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