Attachment Narrative

This document pretains to SES-MFS-20141030-00828 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2014103000828_1066532

FCC Form 312                                                                                     Exhibit 1


                       ADDITION OF POINT OF COMMUNICATION


       Tokyo Broadcasting System Television, Inc. (“TBS”), licensee of two temporary-
fixed satellite antennas under FCC Call Sign E080226, hereby seeks modification of its
authorization in order to add the Japanese-licensed Superbird C2 satellite as a point of
communication to its Rockwell Collins CCT-90 antenna (identified as TBS03). The
Superbird C2 satellite is operated by Sky Perfect JSAT Corporation.

        A.      Superbird C2 Satellite as a Point of Communication

        The Commission has adopted two alternative procedures for authorizing non-
U.S. licensed space stations to serve the United States. Under one procedure, a full
showing as to the space stations is made in an earth station application. 1 Under the
other procedure, a full showing as to the space stations is made in a Petition for
Declaratory Ruling or letter of intent filing. 2

       Panasonic Avionics Corporation (“Panasonic”) recently followed the first
procedure by making a full showing as to the Superbird C2 satellite in its modification
application filed under Call Sign E100089. 3 By granting Panasonic’s modification
application that specified the Superbird C2 satellite as a point of communication, the
Commission has determined that the Superbird C2 satellite operations satisfy the FCC’s
technical and legal requirements for non-U.S. licensed space stations that are authorized
to serve the United States.

       TBS is hereby incorporating by reference the relevant materials of the Panasonic
application to support its use of the Superbird C2 satellite as a point of communication.

        B.      Regarding Two-Degree Spacing Requirement

       TBS previously submitted a modification application to add the Rockwell Collins
CCT90 antenna to its authorization.4 In the modification application submitted at that
time, TBS supplied antenna patterns relating to the operational characteristics of the
antenna. TBS is incorporating those antenna patterns by reference as they relate to its
proposed use of the CCT90 with the Superbird C2 satellite, as nothing in the patterns
varies by way of different points of communication.

1 See 47 C.F.R. § 25.137(b), (d). See In the Matter of Amendment of the Commission’s Space Station Licensing

Rules and Policies; Mitigation of Orbital Debris, First Report and Further Notice of Proposed Rulemaking, IB
Docket No. 02-34, and First Report and Order, IB Docket No. 02-54, 18 FCC Rcd 10760, ¶ 288 (2003)
(“Space Station Licensing Reform Order”), ¶¶286-288.
2 See 47 C.F.R. § 25.137(c)-(d). See also Space Station Licensing Reform Order, ¶¶286-288.
3 FCC File No. SES-MFS-20130930-00845 (granted Sep. 24, 2014).
4 FCC File No. SES-MFS-20130201-00143, amended by SES-AFS-20130702-00563 (granted Oct. 23, 2013).


FCC Form 312                                                                  Exhibit 1



      In addition, TBS is furnishing the Commission again with written documentation
from Sky Perfect JSAT Corporation, over whose satellites TBS’ signals will be
communicated, acknowledging the use of the antennas and certifying to their
compliance with two-degree spacing regulations.

     In addition to the documentation associated herewith, TBS makes the following
commitments:

   •   The antenna patterns associated with the application exceed the sidelobe
       specification established in Section 25.209.
   •   TBS certifies that it will limit its pointing error to 0.5°.
   •   TBS acknowledges that its antenna will be protected from radio interference
       caused by other space stations only to the degree to which harmful interference
       would not be expected to be caused to an earth station employing
       an antenna conforming to the referenced patterns defined in Section 25.209.



Document Created: 2014-10-30 15:39:04
Document Modified: 2014-10-30 15:39:04

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