Attachment Legal Narrative

This document pretains to SES-MFS-20120525-00476 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2012052500476_953110

SES Americom, Inc. Page 1 of 2 APPLICATION FOR MODIFICATION OF LICENSE Earth Station E110104 SES Americom, Inc. (doing business as “SES”) hereby requests modification of its license for earth station E110104. Specifically, SES seeks to change the points of communications to reflect the relocation of the NSS-7 satellite from 22° W.L. to 20° W.L. Grant of the requested modification will serve the public interest by enabling SES to use this earth station for NSS-7 telemetry, tracking and control (“TT&C”) and to provide service continuity. The E110104 earth station is licensed to operate in the conventional Ku-band with all authorized U.S. satellites and all foreign-licensed satellites on the Commission’s Permitted Space Station List. In addition, the earth station is licensed to use extended Ku-band frequencies, including the 10.95-11.2 GHz, 11.45-11.7 GHz, and 13.75-14.0 GHz bands. Operation in the extended bands is limited to spacecraft specifically identified in the station license.1 The E110104 earth station license currently authorizes communications with the Netherlands-licensed NSS-7 satellite at 22° W.L. However, following replacement of NSS-7 at that location by the SES-4 spacecraft, NSS-7 is being relocated to 20° W.L. At the satellite’s new location, New Skies Satellites N.V. (“New Skies”) will continue to operate the NSS-7 C- band payload, certain TT&C frequencies, and a portion of the conventional Ku-band payload pursuant to Netherlands authorization.2 Intelsat has requested a U.S. license for the remaining NSS-7 Ku-band frequencies pursuant an agreement between SES and Intelsat.3 Full technical information regarding the operations of NSS-7 at 20° W.L. was included with the New Skies and Intelsat applications. SES has requested and received special temporary authority to use E110104 to communicate with NSS-7 during and after the satellite’s relocation in order to provide TT&C and carry customer traffic.4 SES now seeks modification of the E110104 license to update the specified orbital position for NSS-7 to reflect that relocation. The new orbital location for NSS-7 is within the arc for which E110104 has already been coordinated, and no change in the other technical details of the earth station’s operations is proposed. Accordingly, no Schedule B is being submitted with this modification, because the information contained in the schedule would be duplicative of the technical information already on file with respect to this facility. 1 See SES Americom, Inc., File No. SES-LIC-20110715-00830, call sign E110104 (“E110104 Application”), granted March 27, 2012 (“E110104 Grant”) at 3 (ALSAT authority limited to communications in the conventional Ku-band). 2 See New Skies Satellites N.V., File No. SAT-MPL-20120215-00017, call sign S2463. 3 See Intelsat License LLC, File No. SAT-RPL-20120216-00018, call sign S2854. 4 See SES Americom, Inc., File No. SES-STA-20120426-00400, call sign E110104, grant- stamped May 17, 2012.

SES Americom, Inc. Page 2 of 2 Grant of the requested modification will allow SES to use E110104 to continue providing TT&C5 and service to customers on NSS-7, and is therefore in the public interest. 5 As SES previously explained in the original application for E110104, certain telemetry and tracking frequencies on NSS-7 are in the extended Ku-band. See E110104 Application, Legal Narrative at 3-4. Use of this spectrum in the U.S. is subject to a restriction limiting operations to international service only. See id., citing 47 C.F.R. § 2.106, Footnote NG104; 47 C.F.R. § 25.202(a)(1), Note 2. To the extent use of extended Ku-band frequencies for telemetry and tracking could be considered a domestic service, the E110104 Application sought any necessary waiver of the international-service-only restriction to permit use of E110104 for TT&C operations with NSS-7. E110104 Application, Legal Narrative at 3-4. For the reasons set forth in the E110104 Application, SES requests the same waiver here to allow continued use of E110104 for NSS-7 TT&C following relocation of the satellite.


Document Created: 2012-05-25 13:36:33
Document Modified: 2012-05-25 13:36:33
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