Letter Requesting Co

LETTER submitted by SES Americom, Inc.

Letter Requesting Correction of E110104 License

2012-09-11

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

IBFS_SESMFS2012052500476_965663

                                                                                  SatCom Law LLC
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                                                                           Washington, D.C. 20004
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September 11, 2012

By Electronic Filing

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

Re:    SES Americom, Inc. Request for Correction of Earth Station License
       Call Sign E110104, File No. SES-MFS-20120525-00476

Dear Ms. Dortch:

SES Americom, Inc. (“SES Americom,” doing business as “SES”), by its attorney, hereby
requests that the Commission correct the license issued in response to the above-referenced
modification application (the “E110104 Modification”) to refer to both the U.S.-licensed and
Netherlands-licensed payloads of the NSS-7 spacecraft.

In the E110104 Modification, SES sought to update the earth station’s license to reflect the fact
that NSS-7, one of the satellites with which the station was authorized to communicate, was
being relocated from 22° W.L. to 20° W.L. At 22° W.L., NSS-7 had been operated by New
Skies Satellites B.V. (“New Skies”), an affiliate of SES Americom, pursuant to Netherlands
license. However, SES explained in the E110104 Modification narrative that following relocation
of NSS-7, New Skies would continue to operate the satellite’s C-band payload, certain extended
Ku-band telemetry, tracking and control (“TT&C”) frequencies, and a portion of the conventional
Ku-band payload pursuant to Netherlands authorization and that Intelsat was seeking a
                                                                                                  1
Commission license for the remaining NSS-7 conventional and extended Ku-band frequencies.
SES sought authority for E110104 to communicate with NSS-7 in the extended Ku-band both
for TT&C and to provide customer services, requiring the earth station to access both
Netherlands-licensed and U.S.-licensed frequencies.

The license issued in response to the E110104 Modification specifies NSS-7 as a point of
communications at 20° W.L. but does not clearly reference the two separately-licensed
payloads of the spacecraft.2 Instead, the entry for NSS-7 on the E110104 license is internally
inconsistent, indicating that the satellite is Netherlands-licensed but citing call sign S2854, which
1
 See E110104 Modification, Narrative at 1 & nn. 2 & 3, citing New Skies Satellites N.V., File No.
SAT-MPL-20120215-00017, call sign S2463, and Intelsat License LLC, File No. SAT-RPL-
20120216-00018, call sign S2854.
2
 See Call Sign E110104, File No. SES-MFS-20120525-00476 (grant date 09/06/2012) at 3,
Section D.


Ms. Marlene H. Dortch                          -2-                            September 11, 2012


is the call sign associated with the U.S.-licensed frequencies on the satellite. SES requests that
the Commission correct the E110104 license by including separate entries under Section D for
the two payloads of NSS-7 as follows:

       2) 1 to NSS-7 @ 20 W.L. S2463 (Netherlands-licensed)

       3) 1 to NSS-7 @ 20 W.L. S2854 (U.S.-licensed)

Correction of the license will serve the public interest by making clear that SES is authorized to
use E110104 both to perform TT&C functions for NSS-7 and to provide service continuity to
customers.

Please address any questions regarding this matter to the undersigned.

Respectfully submitted,

/s/ Karis A. Hastings

Karis A. Hastings

Counsel for SES Americom, Inc.
karis@satcomlaw.com

cc:    Paul Blais



Document Created: 2012-09-11 08:55:18
Document Modified: 2012-09-11 08:55:18

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