Attachment Narrative SES-MFS-20160624-00607

Attachment Narrative

This document pretains to SES-MFS-20160624-00607 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2016062400607_1140788

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of Application by )
)
SES AMERICOM, INC. ) Call Sign E050287
)
To Modify its Earth Station License to Perform )
TT&C for ASTRA 3A at 86.85º W.L. )

REQUEST FOR MODIFICATION

By this application, SES Americom, Inc. (“SES Americom” or “SES”)

respectfully seeks to modify its license for earth station E050287 to allow it to communicate with

the ASTRA 3A spacecraft in order to provide Tracking, Telemetry and Command (“TT&C”)

following relocation of the satellite from 176.85º W.L. to 86.85° W.L. (+/- 0.10° east/west

stationkeeping). The satellite is expected to arrive at 86.85° W.L. on or about August 15, 2016.

SES Americom’s affiliate, SES ASTRA S.A. (“SES ASTRA”), holds an
1
authorization from the Luxembourg Ministry of State, Office of Media and Communications for

the ASTRA 3A Ku-band spacecraft. SES ASTRA has requested that SES Americom assist with

providing TT&C to support the planned relocation of ASTRA 3A to 86.85º W.L. Upon arrival at

the nominal 87º W.L. orbital location, ASTRA 3A will join the SES-2 spacecraft and will

operate in inclined orbit.

SES is not requesting U.S. market access or any other authorization from the

Commission in relation to the non-U.S.-licensed ASTRA 3A spacecraft, and therefore is not

1
Ministère d’État, Service des Médias et des Communications of the Grand Duchy of
Luxembourg.

2
providing full technical information about the ASTRA 3A satellite as part of this application.

Details regarding the ASTRA 3A TT&C operations, including link budgets and interference

analysis, are provided in Attachment 1 to this request. A basic technical description of the

satellite’s proposed operations, and an updated orbital debris mitigation statement for ASTRA

3A, are provided in Attachment 2 for the Commission’s information. As discussed below,

communications with ASTRA 3A will not adversely affect the operation of any adjacent

satellites.

Grant of this Modification Request Will Serve the Public Interest. Grant of this

request is in the public interest. The requested TT&C authority will facilitate the safe operation

of ASTRA 3A once it relocates to 86.85° W.L.

No Harmful Interference to Other Spacecraft. Apart from SES-2, the nearest

satellites to 86.85° W.L. with Ku-band operations are Intelsat’s Galaxy 28 at 89.0° W.L. and the

Ku-band payload of AMC-16 at 85.0° W.L., which is licensed to EchoStar. Attachment 1

demonstrates that the proposed operations comply with the Commission’s two-degree spacing

requirements.

Waiver Requests. SES requests limited waivers of the Commission’s

requirements in connection with the instant request. Grant of these waivers is consistent with

Commission policy:

The Commission may waive a rule for good cause shown.
Waiver is appropriate if special circumstances warrant a
deviation from the general rule and such deviation would
better serve the public interest than would strict adherence
to the general rule. Generally, the Commission may grant a
waiver of its rules in a particular case if the relief requested
would not undermine the policy objective of the rule in

2
See Waiver Requests, infra.

2

question and would otherwise serve the public interest.3

Sections 25.137 and 25.114. SES requests a waiver of Section 25.137 and the

other Commission rules cross-referenced therein. SES seeks a modification of its authority in

connection with TT&C for ASTRA 3A, a foreign-licensed spacecraft. Section 25.137 requires

that applicants proposing to use U.S.-licensed earth stations to communicate with foreign-

licensed spacecraft demonstrate that the Commission’s policies for U.S. market access are

satisfied. Section 25.137 also incorporates by reference other requirements for Commission-

licensed space stations, including the obligation to file detailed technical information as specified

in Section 25.114.

By its terms, Section 25.137 is inapplicable to the instant request. The rule’s

requirements come into play only when a non-U.S.-licensed satellite is to be used to “serve the
4
United States.” Here, the E050287 earth station will be used solely for TT&C, not for

commercial operations. Thus, SES is not seeking authority to communicate with ASTRA 3A for

purposes of providing U.S. service within the meaning of Section 25.137.

To the extent the Commission disagrees, SES requests a waiver of the market

access and other requirements imposed in Section 25.137. Grant of a waiver will not undermine

the objectives of these requirements. The market access test described in the rule is intended to
5
ensure that U.S.-licensed systems have “effective competitive opportunities.” Because SES

3
PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted).
4
47 C.F.R. § 25.137(a).
5
Id.

3

Americom is not seeking authority to provide commercial services in the United States, the
6
requested modification does not raise any concerns about competitive equality.

Strict adherence with Section 25.114’s requirements for detailed technical

information is also unnecessary and would be unduly burdensome. SES Americom is proposing

to use E050287 only for the limited purpose of performing TT&C for the satellite once it arrives

at 86.85° W.L., and the relevant technical characteristics of those transmissions are provided

below. The transmissions to the spacecraft will be conducted on a non-harmful interference

basis. In these circumstances, no valid purpose would be served by requiring a complete

description of the ASTRA 3A spacecraft.

SES Americom’s request is consistent with Commission precedent. In similar

cases in which limited communications by U.S. earth stations with a foreign-licensed satellite

were proposed, the Commission has granted operational authority without requiring a market
7
access showing under Section 25.137 or full technical data as required by Section 25.114.

Section 2.106 Footnote NG52. To the extent that reception of telemetry at

11450.25 MHz and 11699.50 MHz constitutes a domestic (i.e., non-international) service, SES

6
In any event, the ASTRA 3A spacecraft at 86.85° W.L. will be operating under the authority
of Luxembourg, a WTO member country, and therefore is exempt from the requirement to make
a showing of effective competitive opportunities. 47 C.F.R. § 25.137(a)(2).
7
See, e.g., SES Americom, Inc., File No. SES-MFS-20131108-00951 (Call Sign KA288),
granted Mar. 19, 2014; Hawaii Pacific Teleport, L.P., File No. SES-MFS-20131030-00913 (Call
Sign E030115), granted Apr. 16, 2014 (granting authority for earth station to provide TT&C
services to ASTRA 3A operating at 176.85° W.L).; PanAmSat Licensee Corp., File Nos. SES-
STA-20090922-01211 (Call Sign E4132) & SES-STA-20090922-01212 (Call Sign E040125),
both grant-stamped Oct. 16, 2009 (granting authority for earth stations to communicate with
foreign-licensed NSS-12 spacecraft for purposes of providing launch and early operations
services).

4

8
Americom respectfully requests a limited waiver of the international-service-only restriction.

Such a waiver is warranted in the circumstances for the limited purpose of TT&C. As the

Commission has recognized, TT&C operations generally require uplink and downlink capability

from the same earth station. For this reason, the Commission has previously granted waivers of

the international service restriction to enable TT&C to be performed in the U.S. using the
9
extended Ku-band frequencies.

Grant of the requested waiver would not undermine the purpose of the restriction,

which is to ensure that earth station deployments in the extended Ku-band do not negatively

impact the deployment of fixed service (“FS”) in the same band or cause interference to such

operations. The telemetry downlink signals from ASTRA 3A in the extended Ku-band are

narrow in bandwidth, and will comply with the power flux density limits in the Commission’s

rules and, thus, will not interfere with FS station operations. Moreover, only a small number of
10
U.S. earth stations will be used to perform TT&C in the extended Ku-band. Once ASTRA 3A

is on-station at 86.85° W.L., the TT&C will be performed by two U.S. earth stations: SES

Americom’s KA288 earth station in South Mountain, California, and its E050287 earth station in

8
47 U.S.C. § 2.106 Footnote NG52.
9
See, e.g., EchoStar KuX Corporation, 20 FCC Rcd 919 (Int’l Bur. 2004) (“EchoStar 83W
Order”); EchoStar Satellite LLC, 20 FCC Rcd 930 (Int’l Bur. 2004) (“EchoStar109W Order”);
EchoStar KuX Corporation, 20 FCC Rcd 942 (2004) (“EchoStar 121W Order”). These
decisions granted waivers of the international only restriction in Footnote NG104, which has
been replaced by Footnote NG52.
10
See EchoStar 83W Order, at ¶ 16 (“The Commission has waived this [international only]
requirement where the number of potential earth stations in a particular service is inherently
small.”); EchoStar 109W Order, at ¶ 16 (same); EchoStar 121W Order, at ¶ 17 (same).

5

Woodbine, Maryland. As a result, there will be no significant restrictions placed on the

deployment of FS in this band.

Section 25.210(j). The ASTRA 3A satellite is authorized by the Luxembourg

Government to operate at 86.85° W.L. within a +/- 0.10° east/west stationkeeping box. To the

extent necessary, SES respectfully requests a waiver of Section 25.210(j) of the Commission’s

rules, which requires geostationary space stations to be operated within a +/- 0.05° east/west

stationkeeping box. The Commission has previously waived this rule based on a finding that

allowing an increased stationkeeping volume would “not adversely affect the operations of other

spacecraft, and would conserve fuel for future operations.” 11

The facts here fit squarely within this precedent. Allowing ASTRA 3A to be

maintained within an increased stationkeeping volume will not harm other operators. ASTRA

3A’s stationkeeping volume will not overlap with that of any other satellites. In addition,

allowing ASTRA 3A to be flown at 86.85° W.L. in an expanded east-west stationkeeping

volume of +/-0.1 degrees will result in fuel savings for the spacecraft. This will prolong the time

during which ASTRA 3A will be available to provide service. Under these circumstances, grant

of any necessary waiver of Section 25.210(j) will serve the public interest.

SES hereby certifies that no party to this application is subject to a denial of

federal benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 862.

11
See File Nos. SAT-MOD-20080124-00030 & SAT-AMD-20080311-00070, grant-stamped
May 19, 2008, Attachment at ¶ 1.

6

For the foregoing reasons, SES respectfully seeks to modify its E050287 earth

station license to communicate with ASTRA 3A in order to provide TT&C once it is on station,

as described herein. Grant of the requested authority will promote safe operation of the satellite

after its relocation.

Respectfully submitted,

SES AMERICOM, INC.

By: /s/ Petra Vorwig

Of Counsel Petra 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: June 24, 2016

7

Attachment 1: TT&C Emission Characteristics

1. Earth Station Transmission Characteristics

E050287 (Woodbine, MD -- on-station)
Emission Designator: 800KF9D
Max EIRP: 78.5 dBW
Max EIRP Density: 55.5 dBW/4kHz

These EIRP and EIRP density levels are the maximum EIRP and EIRP density levels authorized
in the current E050287 earth station license.

2. TT&C Frequencies

Telecommand: 14499 MHz vertical polarization
Telemetry: 11450.25 MHz horizontal polarization
11699.50 MHz horizontal polarization

3. TT&C Link Budgets

Woodbine (E050287)

Woodbine - Telecommand
Link Parameters Units 800KF9D
Uplink Frequency MHz 14499.00
Carrier Allocated Bandwidth kHz 800.0
Uplink:
Nominal E/S e.i.r.p. per carrier dBW 78.5
Earth Station Diameter m 9.2
Earth Station Gain dBi 61.0
Uplink Input Power per Carrier dBW 17.5

Uplink EIRP density dBW/4kHz 55.5
Spreading Loss dB 162.5
Other Losses dB 1.1
SFD at satellite dBW/m2 -85.1
CMD subsystem SFD Threshold dBW/m2 -92.0
Margin dB 6.9

ASTRA-3A - Telemetry
downlink EIRP (dBW) 6.3
Hypothetical satellite
Downlink EIRP (EOC) (dBW) 6.3
Receive earth station size (m) 9.2
Receive earth station gain (dBi) 58.5
Receive earth station off-axis (dBi) 21.0
Required C/I (dB) 15.0
Interference analysis
Calculated C/I (single satellite) (dB) 37.5
Calculated C/I (two satellites) (dB) 34.5
Margin (dB) 19.5

5. Compliance with PFD limits in 11.45-11.7 GHz

The allowable PFD levels in the 11.45-11.70 GHz bands (per 4 kHz) are defined in
Section 25.208(b)(1) of the Commission's rules for all conditions, including clear sky, and for all
methods of modulation as follows:

1. For angles of arrival between 0 and 5 degrees above the horizontal plane: -150 dBW/m2
in any 4 kHz band;
2. For angles of arrival δ (in degrees) between 5 and 25 degrees above the horizontal plane:
-150 + (δ-5)/2 dBW/m2 in any 4 kHz band; and
3. For angles of arrival between 25 and 90 degrees above the horizontal plane: -140
dBW/m2 in any 4 kHz band.

In order to demonstrate such compliance, the PFD levels for the telemetry carriers, based on the
link budgets set forth in Section 3 are calculated below. It can be seen from the results that
compliance with the PFD levels has been achieved.

PFD level compliance calculation
Angle of Arrival Applicable PDF limit Spreading Loss Gain Contour Worst case PFD PFD Margin
0 -150.0 -163.4 -0.2 -172.0 22.0
5 -150.0 -163.3 -0.1 -171.8 21.8
10 -147.5 -163.2 -0.1 -171.7 24.2
15 -145.0 -163.0 0.0 -171.4 26.4
20 -142.5 -162.9 0.0 -171.3 28.8
25 -140.0 -162.8 0.0 -171.2 31.2
Peak (90) -140.0 -162.1 0.0 -170.5 30.5

6. TT&C Contour Maps

SES Americom is not including antenna gain contours for the TT&C beams because the contours
1
at 8 dB below peak fall entirely beyond the edge of the visible Earth.

1
See 47 C.F.R. 25.114(c)(4)(vi)(A).

Attachment 2: Updated Orbital Debris Mitigation Statement

Information regarding the orbital debris mitigation plan for ASTRA 3A was previously
submitted to the Commission in File No. SES-STA-20130722-00653, Attachment 3. The only
changes to that plan are described below.

Safe Flight Profiles

ASTRA 3A will be positioned at 86.85° W.L., immediately adjacent to the SES-2 spacecraft, at
the 87.0° W.L. orbital location. In considering current and planned satellites that may have a
station-keeping volume that overlaps the ASTRA 3A satellite, SES has reviewed the FCC
databases for FCC licensed satellite networks and those that are currently under consideration by
the FCC. In addition, networks for which a request for coordination has been published by the
ITU within ±0.15 degrees of 86.85° W.L. have also been reviewed. Only those networks that
either operate, or are planned to operate, and have an overlapping station-keeping volume with
the ASTRA 3A satellite, have been taken into account in the analysis.

Based on these reviews, the only satellite operating near 86.85° W.L. is SES-2, which is also
controlled and operated by SES. SES is not aware of any pending applications before the
Commission requesting authorization to use an orbital location within ±0.15° of 86.85° W.L.,
and within this sub-arc, SES is not aware of any proposals by any other administration to launch
or deploy a satellite to such locations in the near term.

Based on the preceding, it is concluded that physical coordination of the ASTRA 3A satellite
with another party is not required at the present time.

On-station station-keeping operations will be within the +/- 0.10 degree E-W control box with no
inclination control, thereby ensuring adequate collision avoidance distance from other satellites
in geosynchronous orbit.

Document Created: 2016-06-24 15:27:09
Document Modified: 2016-06-24 15:27:09

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC