Attachment Narrative

This document pretains to SES-LIC-20170213-00151 for License on a Satellite Earth Station filing.

IBFS_SESLIC2017021300151_1185078

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) SES-LIC-________-_____ ) Call Sign _____ Application for Ten Temporary Fixed Earth ) Stations Operating in the Ku-Band ) SES Americom, Inc. (“SES Americom” or “SES”) respectfully requests a license to operate ten temporary fixed earth stations in the conventional and extended Ku-bands. The antennas will be used to demonstrate SES’s capabilities around the continental United States. As described in more detail in the Form 312 submitted with this application, the antennas are 1.0 meter antennas manufactured by AVL. Each will be installed on a truck, which will be moved to each demonstration location where the antenna will be deployed on top of the truck and operated in a fixed position. Because the antenna will always operate on the top of the truck, we have listed the antenna height above ground level in the Form 312 as 4.3 meters, which includes the height of the truck. Each antenna on its own will measure 1.2 meters. SES also seeks a waiver of footnote NG52 in the Table of Allocations to permit the reception of U.S. domestic services in the 10.95-11.7 GHz band on an unprotected, non- interference basis. Footnote NG52 was intended to preserve access to the 10.7-11.7 GHz spectrum for terrestrial fixed service (“FS”) stations by limiting FSS use of the band to

1 international operations only. As the Commission explained in a prior case granting an EchoStar entity a waiver of footnote NG104: waiver of footnote NG 104 would not undermine the rule’s purpose because it involves only passive receive-only earth stations that are not capable of causing interference into FS stations operating in this band. Further, because, EchoStar has agreed to accept any level of interference from FS stations into its receive-only earth stations’ operations in the extended Ku-bands, FS operators will not be required to coordinate their station operations with the EchoStar receive-only earth stations’ operations. Under these circumstances, we determine that additional coordination burden would not be placed upon FS operators and that their ability to expand service in the future would not in 2 any manner be restricted. The SES request for authority to receive domestic signals from satellites authorized to transmit in the 10.95-11.7 GHz band on an unprotected basis fits squarely within this line of precedent. Accordingly, the Commission should conclude that grant of the requested waiver will serve the public interest. 1 See 47 C.F.R § 2.106, Footnote NG52. This policy was previously codified in footnote NG104. 2 EchoStar KuX Corp., 20 FCC Rcd 919, 923 (Sat. Div. 2004). See also Intelsat North America LLC, Call Sign S2817, File No. SAT-LOA-20101014-00219, grant-stamped July. 26, 2011, Attachment to Grant at 23, ¶¶ 7-9 (granting waiver of footnote NG104 to allow Intelsat 18 to provide domestic service in the 10.95-11.2 GHz and 11.45-11.7 GHz bands); PanAmSat Licensee Corp., Call Sign S2381, File No. SAT-MOD-20060303-00019, grant-stamped Oct. 26, 2006, Attachment to Grant at 1-2, ¶¶ 1-4 (granting waiver of footnote NG104 to allow Galaxy 3C to provide domestic service in the 11.45-11.7 GHz band). 2

For the foregoing reasons, SES requests approval of the above application. 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 NW, Suite 1000 Washington, D.C. 20004 Washington, DC 20036 Tel: (202) 599-0975 Tel: (202) 478-7143 Dated: February 13, 2017 3


Document Created: 2017-02-13 09:47:25
Document Modified: 2017-02-13 09:47:25
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