Attachment Narrative

This document pretains to SES-LIC-20170417-00390 for License on a Satellite Earth Station filing.

IBFS_SESLIC2017041700390_1205552

                                     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 1.6 meter 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.

                 SES seeks a waiver of footnote NG52 in the Table of Allocations to permit the

reception of U.S. domestic services in the 10.95-11.2 GHz and 11.45-11.7 GHz bands 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

1
     See 47 C.F.R § 2.106, Footnote NG52. This policy was previously codified in footnote
NG104.


                       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 10.95-11.2 GHz and 11.45-11.7 GHz bands 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.

               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: April 14, 2017




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



Document Created: 2017-04-14 11:08:29
Document Modified: 2017-04-14 11:08:29

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