Letter re E000696 DL

LETTER submitted by SES Americom, Inc.

Letter on Proposed Operations in 4500-4800 MHz

2015-11-02

This document pretains to SES-MFS-20130604-00470 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2013060400470_1113430

                                                                              SatCom Law LLC
                                                                       1317 F St. NW, Suite 400
                                                                       Washington, D.C. 20004
                                                                               T 202.599.0975
                                                                           www.satcomlaw.com

November 2, 2015

By Electronic Filing

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

Re:    SES Americom, Inc. Application for Modification of E000696 Earth Station
       File No. SES-MFS-20130604-00470

Dear Ms. Dortch:

SES Americom, Inc. (“SES”), by its attorney and pursuant to Section 1.65 of the Commission’s
rules, 47 C.F.R. § 1.65, hereby updates the record with respect to the above-captioned earth
station application to advise the Commission that SES is willing to operate on an unprotected,
non-interfering basis for purposes of receiving signals in the 4500-4800 MHz band from the
SES-6 satellite.

The Netherlands-licensed SES-6 satellite has been granted U.S. market access at the
40.5° W.L. orbital location, 1 and the E000696 earth station in Bristow, VA is authorized to
communicate with that spacecraft in specified bands. 2 However, in both the SES-6 Market
Access Grant and the E000696 License, the Commission deferred action on SES’s request for
                                                                          3
authority to use the Appendix 30B C-band spectrum at 4500-4800 MHz. SES was granted
special temporary authority to use E000696 to receive signals in the 4500-4800 MHz band on
an unprotected basis for a limited period during 2014 in order to permit SES to monitor the




1
 See New Skies Satellites B.V., Call Sign S2870, File No. SAT-PPL-20120717-00117, grant-
stamped Aug. 1, 2013 (the “SES-6 Market Access Grant”).
2
 See SES Americom, Inc., Call Sign E000696, File No. SES-MFS-20130604-00470, granted
March 14, 2014 (the “E000696 License”), Section D.
3
  SES-6 Market Access Grant, Attachment to Grant at 1 n.1 (request to access the U.S. market
in the 4500-4800 MHz band will be addressed as part of an earth station application to add
SES-6 as a point of communication); E000696 License, Special and General Provisions,
Condition 90120 (deferring action on the request to use the 4500-4800 MHz band).


Ms. Marlene H. Dortch                          -2-                              November 2, 2015

                                             4
quality of services provided outside the U.S. The SES request for regular authority for
E000696 to receive in this spectrum remains pending.

SES recognizes that reception of downlink signals in the 4500-4800 MHz band in the U.S. is
subject to coordination with the National Telecommunication and Information Administration
(“NTIA”) in light of federal operations in this spectrum. To facilitate such coordination, SES
confirms that it seeks authority in the 4500-4800 MHz band on a wholly unprotected basis and
explicitly accepts the risk that interference from federal operations may disrupt reception of
signals from SES-6 to the E000696 antenna. SES does not propose to use E000696 to provide
customer services in the 4500-4800 MHz band. Instead, as with the E000696 STA, SES seeks
to use E000696 for monitoring purposes only, in order to ensure the service quality of customer
carriers that are all intended to be received outside the U.S. SES would not object to an
express licensing condition that prohibits the use of E000696 to provide customer services in
the 4500-4800 MHz band.

SES emphasizes that it does not propose any alteration in the operations of SES-6 in the 4500-
4800 MHz band. As noted above, that satellite is currently being used to serve customers
outside the U.S., and its downlink footprint covers portions of the U.S. Accordingly, grant of the
requested earth station authority would not result in harmful interference to federal operations in
the 4500-4800 MHz band. Nevertheless, SES agrees to operate on a non-interference basis
and to cease use of the 4500-4800 MHz band in the U.S. if interference is reported. In addition,
consistent with the terms of E000696 STA, SES will provide notification to the Mid-Atlantic
Frequency Coordinator prior to commencing operations.

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:    Jose Albuquerque
       Kathyrn Medley
       Paul Blais




4
 See SES Americom, Inc., Call Sign E000696, File No. SES-STA-20140507-00339, granted
May 21, 2014 (the “E000696 STA”).



Document Created: 2015-11-02 12:22:52
Document Modified: 2015-11-02 12:22:52

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