Attachment Narr and Annexes

This document pretains to SES-MFS-20170725-00793 for Modification w/ Foreign Satellite (earth station) on a Satellite Earth Station filing.

IBFS_SESMFS2017072500793_1251571

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) AC BidCo LLC ) File No. SES-MOD-___________ ) Call Sign E120106 Modification to Blanket License for ) Operation of Ku-Band Transmit/Receive ) Earth Stations Aboard Aircraft ) MODIFICATION AC BidCo LLC (“AC BidCo”) hereby requests a modification of its blanket license to operate Ku-band transmit/receive earth stations aboard aircraft (“ESAAs”) on domestic and international flights. 1 AC BidCo requests that the Commission modify the AC BidCo ESAA License to include additional spacecraft as authorized points of communication, including a replacement satellite. Specifically, AC BidCo requests that the Commission permit ESAA operations with: (1) the U.S.-licensed AMC-4 satellite at 134.9° W.L.; (2) the U.S.-licensed AMC-6 satellite at 83° W.L.; (3) the Colombian-licensed SES-10 replacement satellite at 66.9° W.L.; and (4) the Australian-licensed Optus D2 satellite at 152° E.L. A narrative description of the relevant changes is provided here, and AC BidCo is attaching an FCC Form 312 that identifies the new points of communication. Supplemental technical information and copies of relevant coordination letters are attached as well. Pursuant to Section 25.117(c) of the Commission’s rules, AC BidCo is providing herein information that 1 See Call Sign E120106, File No. SES-MFS-20170109-00015, granted July 21, 2017 (the “AC BidCo ESAA License”).

is changing as a result of the modification. AC BidCo certifies that the remaining information provided in support of the AC BidCo ESAA License has not changed. 2 I. SATELLITES USED BY THE AC BIDCO ESAA NETWORK AC BidCo requests modification of its license to specify the satellites described below as points of communication for the AC BidCo ESAA network pursuant to the provisions of Section 25.227(a)(2) and (b)(2). Each of the requested satellites is eligible for authority for use with the AC BidCo ESAA network. Updated tables listing the satellites to be used and the associated ground stations are provided in Annex 2 hereto. As noted in Annex 2, AC BidCo seeks authority for each of the satellites except for AMC-4 to communicate with both the AeroSat model HR6400 antennas designated as AES1 on the AC BidCo ESAA License and the ThinKom model 2Ku antennas designated as AES2 on the license. AC BidCo proposes to use only the ThinKom model 2Ku AES2 terminals with AMC-4. AMC-4: AMC-4 is U.S.-licensed, and a request to reassign the satellite from 67° W.L. to 134.9° W.L. is currently pending before the Commission. 3 AC BidCo seeks authority to use AMC-4 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 11.45-11.7 GHz downlink spectrum, consistent with the satellite’s license as modified pursuant 2 For the Commission’s convenience, AC BidCo has attached as Annex 1 hereto a table listing the information required pursuant to Section 25.227 of the Commission’s rules and providing a cross-reference to the necessary information. 3 SES Americom, Inc., Call Sign S2135, File No. SAT-MOD-20170518-00073, (“AMC-4 Relocation Application”). Pending action on the AMC-4 Relocation Application, the Commission has authorized the drift of AMC-4 to 134.9° W.L., see SES Americom, Inc., Call Sign S2135, File No. SAT-STA-20170503-00070, granted June 7, 2017, and SES has requested special temporary authority for AMC-4 operations upon the satellite’s arrival, see SES Americom, Inc., Call Sign S2135, File No. SAT-STA-20170725-00108. 2

to the AMC-4 Relocation Application and with the Commission’s orders in the ESAA proceeding. 4 AMC-4 will provide coverage of North America and the Pacific Ocean. A letter confirming that operation of the AC BidCo ThinKom model 2Ku AES2 terminals is consistent with coordination agreements with satellites operated within six degrees of AMC-4 at its planned location of 134.9° W.L. is included in Annex 3. AMC-6: AMC-6 is U.S.-licensed, and a request to reassign the satellite from 85° W.L. to 83° W.L. is currently pending before the Commission.5 AC BidCo has already commenced ESAA operations with AMC-6 at 83° W.L. pursuant to a grant of Special Temporary Authority. 6 AC BidCo seeks authority to use AMC-6 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 11.45-11.7 GHz downlink spectrum, consistent with the satellite’s license as modified pursuant to the AMC-6 Relocation Application and with the ESAA Orders. 4 Revisions to Parts 2 and 25 of the Commission’s Rules to Govern the Use of Earth Stations Aboard Aircraft Communicating with Fixed-Satellite Service Geostationary-Orbit Space Stations Operating in the 10.95-11.2 GHz, 11.45-11.7 GHz, 11.7-12.2 GHz and 14-14.5 GHz Frequency Bands, Notice of Proposed Rulemaking and Report and Order, IB Docket Nos. 12-376 & 05-20, 27 FCC Rcd 16510 (2012); Second Report and Order and Order on Reconsideration, IB Docket No. 12-376, 29 FCC Rcd 4226 (2014) (collectively, the “ESAA Orders”). 5 SES Americom, Inc., Call Sign S2347, File No. SAT-MOD-20170628-00102 (“AMC-6 Relocation Application”). Pending action on the AMC-6 Relocation Application, the Commission has authorized the relocation of AMC-6 to 83° W.L. and operations of the satellite at its new orbital location. See SES Americom, Inc., Call Sign S2347, File No. SAT-STA- 20170623-00096, granted June 29, 2017. 6 See AC BidCo LLC, File No. SES-STA-20170629-00724, granted June 30, 2017. 3

AMC-6 will provide coverage of North America. A letter confirming that operation of the AC BidCo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of AMC-6 at 83° W.L. is included in Annex 3. SES-10: SES-10 is a Colombian-licensed satellite positioned at 66.9° W.L., replacing the capacity previously provided at that location by AMC-4 and AMC-6. The Commission placed SES-10 on the Permitted Space Station List for operations at 66.9° W.L.in the conventional and extended Ku-band, 7 and complete technical information regarding the satellite is therefore already on file with the Commission.8 AC BidCo seeks authority to use SES-10 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum and on an unprotected basis in the 10.95-11.2 GHz and 11.45-11.7 GHz downlink spectrum, consistent with the SES-10 Market Access Grant and with the ESAA Orders. SES-10 provides coverage of North and Central America, the Gulf of Mexico, and the Caribbean. A letter confirming that operation of the AC BidCo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of SES-10 is included in Annex 3. Optus D2: Optus D2 is licensed by Australia and is positioned at 152° E.L. Optus D2 is not on the Permitted Space Station List, but its licensing administration, Australia, is a member of the World Trade Organization (“WTO”). Accordingly, under the Commission’s 7 See New Skies Satellites B.V., Call Sign S2950, File No. SAT-MPL-20170108-00002, reissued Mar. 22, 2017 (“SES-10 Market Access Grant”). 8 AC BidCo has already commenced ESAA operations with SES-10 in the conventional Ku- band spectrum pursuant to grants of Special Temporary Authority. See AC BidCo LLC, File Nos. SES-STA-20170428-00486, granted May 11, 2017, & SES-STA-20170706-00738, granted July 11, 2017. 4

DISCO II market access framework, there is a presumption that allowing the satellite to communicate with U.S.-licensed earth stations for services covered by the WTO Basic Telecommunications Agreement will serve the public interest. 9 AC BidCo seeks authority to use Optus D2 capacity for ESAA operations on a primary basis in the 14-14.5 GHz uplink spectrum, consistent with the Commission’s ESAA Orders. AC BidCo seeks authority to use Optus D2 capacity for ESAA operations on a nonconforming basis in the 12.25-12.75 GHz downlink spectrum. Optus D2 will provide coverage of Australia. A letter confirming that operation of the AC BidCo ESAA terminals is consistent with coordination agreements with satellites operated within six degrees of Optus D2 is included in Annex 3. In addition, Annex 4 contains technical materials regarding the proposed AC BidCo operations with Optus D2, including a coverage map, link budgets, and an orbital debris mitigation statement. II. COORDINATION AND SPECTRUM SHARING MATTERS Attached as Annex 3 pursuant to Section 25.227(b)(2) of the Commission’s rules are copies of letters confirming that AC BidCo’s proposed ESAA operations are consistent with the coordination agreements between the satellites discussed above and operators of adjacent spacecraft. Furthermore, AC BidCo’s operations with the additional satellites will conform to the terms of the agreements between AC BidCo and the National Aeronautics and Space Administration and the National Science Foundation. 9 See Amendment of the Commission’s Policies to Allow Non-U.S. Licensed Space Stations providing Domestic and International Service in the United States, Report & Order, 12 FCC Rcd 24094, 24112, ¶ 39 (1997) (“DISCO II”). 5

III. WAIVER REQUEST AC BidCo seeks a limited waiver of the Commission’s rules in connection with its request to add satellites as authorized points of communication for the AC BidCo ESAA network. Specifically, AC BidCo requests a waiver of the U.S. Table of Allocations in Section 2.106 to permit ESAA operations with the Optus D2 satellite in the 12.25-12.75 GHz spectrum. Grant of this waiver is consistent with Commission precedent. The Commission has expressly recognized that “terminals on U.S.-registered aircraft may need to access foreign satellites while traveling outside of the United States (e.g., over international waters), and therefore may need to downlink in the extended Ku-band in certain circumstances.” 10 To meet this need, AC BidCo and other ESAA providers have requested and received Commission authority to receive signals in the 12.2-12.75 GHz band. 11 The same rationale supports grant of a waiver to permit AC BidCo to receive transmissions from the Optus D2 spacecraft in the 12.25-12.75 GHz band. This spectrum will not be used in U.S. airspace, and the proposed operations with Optus D2 are consistent with coordination agreements with operators of adjacent satellites within six degrees. Authorizing AC BidCo to receive signals from Optus D2 will not alter the technical characteristics of the satellite’s operations in any way, and therefore will not create harmful interference to other authorized users of the spectrum. Furthermore, AC BidCo will not claim interference protection 10 Service Rules and Procedures to Govern the Use of Aeronautical Mobile Satellite Service Earth Stations in Frequency Bands Allocated to the Fixed Satellite Service, IB Docket No. 05- 20, Notice of Proposed Rulemaking, 20 FCC Rcd 2906 (2005) at ¶ 18 (footnote omitted). 11 See, e.g., AC BidCo ESAA License, Section B and conditions 900387 and 900389 (authorizing reception of transmissions in the 12.2-12.75 GHz band on a non-interference, non- protected basis); Panasonic Avionics Corporation, File No. SES-MFS-20160819-00730, Call Sign E100089, granted Oct. 19, 2016, Section B and condition 90312 (same). 6

from such authorized users. Under these circumstances, grant of a Section 2.106 waiver is justified to permit use of the 12.25-12.75 GHz band for downlinks from Optus D2 as part of the AC BidCo ESAA network. IV. CONCLUSION AC BidCo respectfully requests that the Commission modify the AC BidCo ESAA License to reflect the changes described herein. Respectfully submitted, AC BIDCO LLC By: /s/ Marguerite Elias Of Counsel Marguerite Elias Karis A. Hastings Executive Vice President & General Counsel SatCom Law LLC AC BidCo LLC 1317 F Street, N.W., Suite 400 111 North Canal Street Washington, D.C. 20004 Chicago, IL 60606 (202) 599-0975 (202) 870-7220 Dated: July 25, 2017 7

ANNEX 1: Table of Information Required by Section 25.227 Section 25.227 Requirement Citation to Information Provided 25.227(a)(4) & N/A: no use of a contention protocol is proposed. 25.227(b)(5) 25.227(a)(5) & The 24/7 point of contact information remains the same. The phone 25.227(b)(6) number is +1 866-943-4662 and the e-mail address is noc@gogoair.com. The street address is: AC BidCo Network Operations Center, 111 North Canal Street, Chicago, IL, 60606, as specified in Form 312 Schedule B, Items E2-E9. 25.227(a)(15) AC BidCo certifications are in Annex 5 attached. 25.227(b)(2)(i) Off-axis EIRP density information regarding the AeroSat and ThinKom terminals licensed for use by AC BidCo was previously provided to the Commission. Operations with the additional satellites included in this application will not involve any increase in the maximum off-axis EIRP density levels previously described to the Commission for the AeroSat and ThinKom terminals and authorized in the AC BidCo ESAA license. 25.227(b)(2)(ii) Target satellite operator certifications are in Annex 3 attached. 25.227(b)(2)(iii) AC BidCo has previously demonstrated that its system will comply with & (iv) coordination agreements and requirements to cease emissions. 25.227(b)(4) The ESAA network will operate in U.S. airspace, foreign airspace, and in the airspace over international waters. Coverage areas for the specific satellites to be used in the ESAA network are described in the table found in Annex 2 attached. Contours for the AMC-4, AMC-6, and SES-10 satellites are already on file with the Commission. A coverage map for Optus D2 is included in Annex 4. 25.227(b)(7) AC BidCo certifications are in Annex 5 attached. 25.227(b)(8) No change to previously filed Radiation Hazard analyses. 25.227(c) AC BidCo’s coordination agreement with NASA was filed February 1, 2013 in File Nos. SES-LIC-20120619-00574 et al. 25.227(d) AC BidCo’s coordination agreement with NSF was included as Amendment Exhibit B in File No. SES-AMD-20120731-00709. 1

ANNEX 2: Updated Spacecraft and Teleport Tables Use in US Satellite Satellite Location Beam Coverage Area Tx (GHz) Rx (GHz) airspace? Operator North America, Pacific AMC-1 129.15W 14-14.5 11.7-12.2 Yes Ocean AMC-4 1 134.9W North America, Pacific 14-14.5 11.45-11.7; Yes Ocean 11.7-12.2 AMC-6 85W North America 14-14.5 11.45-11.7 Yes 11.7-12.2 AMC-21 124.9W United States 14-14.5 11.7-12.2 Yes 11.7-12.2; ASTRA 4A 4.8E Europe 14-14.25 No 12.2-12.75 SES-1 101W North America 14-14.5 11.7–12.2 Yes SES SES-3 103W North America 14-14.5 11.7-12.2 Yes SES-4 22W Europe 14-14.5 12.5-12.75 No 10.95-11.2; East Atlantic Ocean 14-14.5 No 11.45-11.7 SES-6 40.5W 10.95-11.2; West Atlantic Ocean 14-14.5 Yes 11.45-11.7 North and Central America, 10.95-11.2; SES-10 67W the Gulf of Mexico, and the 14-14.5 11.45-11.7; Yes Caribbean 11.7-12.2 Galaxy 17 91W North America 14-14.5 11.7-12.2 Yes Galaxy 28 89W Brazil 14-14.5 11.7-12.2 No North and South America IS-14 45W 14-14.5 11.7–12.2 Yes excludes Brazil IS-18 180E South Pacific 14-14.5 12.25-12.75 No Northeast Pacific 14-14.5 12.25-12.75 Yes Northwest Pacific IS-19 166E Intelsat Australia 14-14.5 12.25-12.75 No Southwest Pacific 10.95-11.2; IS-20 68.5E Middle East 14-14.5 11.45-11.7; No 12.5-12.75 Brazil 14-14.5 11.7–12.2 No IS-21 58W South Atlantic Ocean 14-14.5 11.45–11.7 No Mobility from Mideast to IS-22 72.1E 14-14.5 12.25–12.5 No Japan and to Australia 1 This satellite is only used for communications with the ThinKom 2Ku antenna system, designated AES2. 2

Tx Rx Use in US Satellite Satellite Location Beam Coverage Area (GHz) (GHz) airspace? Operator 10.95-11.7; IS-29e 50W United States 14-14.5 Yes 11.7-12.2 10.95-11.2; 11.45-11.7; IS-33e 60E Africa, Asia, and Europe 14-14.5 No 11.7-12.2; 12.5-12.6 Intelsat 10.95–11.2; IS-904 60E Spot 1 - Western Russia 14-14.5 No 11.45-11.7 10.95–11.2; IS-907 27.5W East Pacific 14-14.5 Yes 11.45-11.7 Eutelsat 114.9W North America 14-14.5 11.7-12.2 Yes 115WB Eutelsat 116.8W Central and South America 14-14.5 11.7-12.2 Yes 117WA Eutelsat 10.95-11.2; North Pacific and E172A 1 172E 14-14.5 11.45-11.7; No Northeastern Russia 12.2-12.75 10.95-11.2; Africa 14-14.5 11.45-11.7; No T-11N 37.5W 12.5-12.75 Atlantic 14-14.5 11.45-11.7 No Telesat Telstar 12V 15W Brazil 14-14.5 11.7-12.2 No (S2933) T-18 138E Asia 14-14.5 12.2–12.75 No 11.45-11.7; JCSAT-2B 154E South Pacific 14-14.5 Yes 12.25-12.75 JSAT JCSAT-5A1 132E Japan 14-14.5 12.25-12.75 No 10.95-11.2; 183E Yamal 300K North Pacific Ocean 14-14.5 11.45-11.7; Yes (177W) 12.5-12.75 Gazprom Space 10.95-11.2; Systems Yamal 401 90E Russia 14-14.5 11.45-11.7; No 12.5-12.75 Asiasat 7 105.5E China 14-14.5 12.25-12.75 No AsiaSat Empresa ARSAT-2 Argentina de 81W North America 14-14.5 11.7-12.2 Yes Soluciones Satelitales S.A Optus D2 152E Australia 14-14.5 12.25-12.75 No Optus 1 These satellites are only used for communications with the Aerosat antenna system, designated AES1. 3

Satellite Teleport Location FCC Call Sign AMC-1 Woodbine, MD E900448 To be assigned (File No. SES- AMC-4 Woodbine, MD LIC-INTR2017-02019) AMC-6 Perris, CA E940448 AMC-21 Woodbine, MD E900448 ASTRA 4A Betzdorf, Luxembourg N/A SES-1 Woodbine, MD E920698 SES-3 Woodbine, MD E140059 Bristow, VA E020071 SES-4 Bristow, VA E000696 SES-6 Betzdorf, Luxembourg N/A SES-10 Perris, CA E940448 Galaxy 17 Atlanta, GA ATL-K26 E990214 Galaxy 28 Rio de Janeiro, Brazil N/A ATL teleport ATL-C06 E940333 IS-14 ATL teleport ATL-K15 E090093 IS-18 Napa teleport NAP-K22 E990224 Perth, Australia N/A IS-19 Napa teleport NAP-K31 E980460 Napa teleport NAP-C30 E980467 IS-20 Fuchsstadt, Germany N/A Rio de Janeiro, Brazil N/A IS-21 Mobility: MTN teleport MTN-K02 E030051 IS-22 Kumsan, Korea N/A IS-29e Hagerstown, MD E030103 Fuchsstadt, Germany N/A IS-33e Moscow, Russia N/A IS-904 Moscow, Russia N/A IS-907 Hagerstown, MD E030103 Eutelsat 115WB Brewster, WA E120043 Eutelsat 117WA Brewster, WA E060416 E172A Khabarovsk, Russia N/A T-11N Aflenz, Austria N/A T-12V Rio de Janeiro, Brazil N/A T-18 China (City TBD) N/A JCSAT-2B Kapolei, HI E010236 JCSAT-5A Yokohama, Japan N/A Yamal 300K Brewster, WA BRW-05C E120043 Yamal 401 Moscow, Russia N/A Asiasat 7 Beijing, China N/A ARSAT-2 Brewster, WA E120043 Optus D2 Belrose, Australia N/A 4

ANNEX 3: Satellite Company Letters 5

6

7

8

OPTUS 2 June 2017 Postal Address PO Box 888 North Ryde Federal Communications Commission NSW 1670 International Bureau Australia 445 12th Street, SW Washington, DC 20554 Street Address UNITED STATES OF AMERICA Level A1 N 1 Lyonpark Road, Macquarie Park NSW, 2113 Australia Reply Phone +612 8082 6883 Email lex.vipond@optus.com .au Our Ref. SC4/3M0 To whom it may concern AC BIDCO LLC APPLICATION FOR EARTH STATIONS ABOARD AIRCRAFT ("ESAA") TERMINALS This letter certifies that Singtel Optus Pty Limited (‘Optus") is aware that AC BidCo LLC (°AC BidCo") is planning to seek authorization from the Federal Communications Commission (°FCC") to operate Ku band transmitfreceive earth stations aboard aircraft ("ESAA") terminals with the OPTUS—D2 satellite at 152.0° E.L. under the current ESAA rules including Section 25.227. Based upon the information provided by AC BidCo, Optus: (1) Certifies that the power density levels that AC BidCo provided to Optus are consistent with the existing satellite frequency co—ordination agreements between Optus satellites at 152.0° E.L. and adjacent satellites within 6 degrees of orbital separation of the 152.0° E.L. orbit position; (ii) Confirms that if the FCC authorises the operations proposed by AC BidCo, Optus will include the power density levels associated with such operations in future satellite frequency co—ordination with adjacent satellite operators. Yours sincerely % /4 W J A VIPOND Manager, Spectrum Planning, Satellite Planning and Strategy Group optus.com.au SingTel Optus Pty Ltd ABN 90 052 833 208

ANNEX 4: OptusD2 Coverage Maps, Link Budgets, and Orbital Debris Mitigation Statement 10

Optus D2 Coverage Maps 11

Optus D2 Link Budget: AeroSat Antenna Forward Link Budget Return Link Budget Hub Sydney Terminal Ku Remote Required Eb/No 1.7 dB Required Eb/No 3.5 dB Modulation 4-PSK Modulation 2-PSK Info Rate 37,206 Kbps Info Rate 1250 Kbps FEC Rate 0.4134 FEC Rate ½ Carrier Rolloff 1.2 Carrier Spacing 1.20 Satellite SFD @ 2 -71.6 dBW/m2 Carrier Spreading 1.20 dB/K Satellite SFD @ 2 -87.5 dBW/m2 Transponder Atten dB dB/K Transponder ID Transponder dB Hub Transmit Atten Frequency 14.02 GHz Transponder ID Satellite G/T 6 dB/oK Aircraft Transmit Antenna Diameter 13 m Terminal Carrier EIRP 86.88 dBW Frequency 14.18 GHz Ant. Input PFD -17.43 dBW/4kHz Satellite G/T -1 dB/oK Path Loss 206.76 dB Antenna Diameter 0.4 m Atm/Point/Pol Loss 0.12 dB Carrier EIRP 44.24 dBW Aircraft Receive Ant Input PFD -12.82 dBW/4kHz Terminal Path Loss 206.61 dB Frequency 12.28 GHz Atm/Point/Pol 0.07 dB Satellite EIRP 46 dBW Loss Downlink PFD@ 10.89 dBW/4kHz Hub Receive Beam Center Frequency 12.43 GHz Receive Gain 63.8 dB Satellite EIRP 51 dBW Terminal G/T 10.97 dB/oK Downlink PFD@ -6.45 dBW/4kHz Path Loss 205.36 dB Beam Center Other Losses 0.06 dB Hub G/T 41.12 dB/oK Transponder Path Loss 205.71 dB Total OPBO 0.60 dB Other Losses 0.10 dB Carrier OPBO 0.60 dB Transponder C/No Thermal Up 114.10 dB-Hz Total OPBO 4.62 dB C/No Thermal Dn 79.46 dB-Hz Carrier OPBO 31.16 dB C/Io Total 90.77 dB-Hz C/No Thermal Up 65.07 dB-Hz C/No+Io 79.15 dB-Hz C/No Thermal Dn 83.26 dB-Hz Add’l Link Margin 1.74 dB C/Io Total 74.38 dB-Hz % BW per cxr 100 % C/No+Io 64.53 dB-Hz % Power per cxr 100 % Add”l Link 0.06 dB Xpdr BW Alloc 54 MHz Margin % BW per cxr 5.56 % % Power per cxr 0.22 % Xpdr BW Alloc 3 MHz 12

Optus D2 Link Budget: ThinKom Antenna Forward Link Budget Return Link Budget Hub Sydney Terminal 2Ku Remote Required Eb/No 3 dB Required Eb/No 3.6 dB Modulation 4-PSK Modulation 4-PSK Info Rate 62,370 Kbps Info Rate 2500 Kbps FEC Rate 0.6930 FEC Rate ½ Carrier Rolloff 1.2 Carrier Spacing 1.20 Satellite SFD @ 2 -71.6 dBW/m2 Carrier Spreading 0 dB/K Satellite SFD @ 2 -87.5 dBW/m2 Transponder Atten dB dB/K Transponder ID Transponder dB Hub Transmit Atten Frequency 14.02 GHz Transponder ID Satellite G/T 6 dB/oK Aircraft Transmit Antenna Diameter 13 m Terminal Carrier EIRP 86.88 dBW Frequency 14.18 GHz Ant. Input PFD -17.39 dBW/4kHz Satellite G/T -1 dB/oK Path Loss 206.76 dB Antenna Diameter 0.6 m Atm/Point/Pol Loss 0.12 dB Carrier EIRP 48.30 dBW Aircraft Receive Ant Input PFD -17.56 dBW/4kHz Terminal Path Loss 206.61 dB Frequency 12.28 GHz Atm/Point/Pol 0.07 dB Satellite EIRP 45 dBW Loss Downlink PFD@ 10.89 dBW/4kHz Hub Receive Beam Center Frequency 12.43 GHz Receive Gain 65 dB Satellite EIRP 51 dBW Terminal G/T 14.45 dB/oK Downlink PFD@ -2.79 dBW/4kHz Path Loss 205.36 dB Beam Center Other Losses 0.06 dB Hub G/T 41.12 dB/oK Path Loss 205.71 dB Transponder Other Losses 0.10 dB Total OPBO 0.60 dB Transponder Carrier OPBO 0.60 dB Total OPBO 4.62 dB C/No Thermal Up 114.10 dB-Hz Carrier OPBO 27.50 dB C/No Thermal Dn 81.93 dB-Hz C/No Thermal Up 68.73 dB-Hz C/Io Total 90.77 dB-Hz C/No Thermal Dn 86.92 dB-Hz C/No+Io 81.40 dB-Hz C/Io Total 74.38 dB-Hz Add’l Link Margin 0.45 dB C/No+Io 67.63 dB-Hz % BW per cxr 100 % Add”l Link 0.05 dB % Power per cxr 100 % Margin Xpdr BW Alloc 54 MHz % BW per cxr 5.56 % % Power per cxr 0.52 % Xpdr BW Alloc 3 MHz 13

OPTUS SATELLITE | OPTUS D2 | ORBITAL DEBRIS MANAGEMENT STATEMENT OPTUS D2 SATELLITE The Optus D2 Spacecraft is an Orbital STK GEOStar-2 model satellite that operates within the Fixed Satellite Service Ku frequency band (12.25-12.75 GHz downlink and 14.0-14.5 GHz uplink) at the orbital location of 152° E.L. This has been the operational location of Optus D2 since services commenced in October 2007. SPACECRAFT DESIGN Optus, and the Optus D2 spacecraft manufacturer, have assessed and limited the amount of debris released in a planned manner during normal operations of Optus D2. No debris is generated during foreseeable on-station operations. During the Optus D2 Spacecraft design, the possibility of the spacecraft itself becoming a source of debris due to loss of control preventing appropriate deorbit or disposal was considered and mitigated with redundant components and minimisation of single points of failure. In addition, critical components located within the structure of the spacecraft are shielded from external debris. MINIMISING RISK OF ACCIDENTAL EXPLOSIONS Optus and the Optus D2 spacecraft manufacturer have assessed and limited the probability of accidental explosions during operations, until and after end of mission life. The Optus D2 Spacecraft has been designed to minimise the risk of on-board hazardous materials within the Propulsion Subsystem (fuel and oxidiser) and the Electrical Power Subsystem (e.g. batteries) from causing an event that has the potential to generate orbital debris. Specifically: • The Propulsion Subsystem was designed, manufactured, and tested to ensure a very low risk of fuel and oxidiser leakage; and a very low risk of undesired mixing of fuel and oxidiser to prevent conditions that could potentially result in the release of orbital debris. • The Electrical Power Subsystem was designed and has multiple on-board safety systems to maintain the on-board batteries within their safe operating range as specified by the manufacturer to mitigate the risk of battery overcharge, undercharge, thermal runaway, or instability that could potentially result in the release of orbital debris, even in the event of an Electrical Power Subsystem component failure. Throughout the Optus D2 mission, critical subsystems such as the Propulsion Subsystem and Electrical Power Subsystem are monitored to further reduce the already very remote risk of an event that could result in the release of orbital debris. At the end of operational life, after the satellite has reached its final disposal orbit, unless prevented by technical failures beyond its control, Optus will deplete or secure all on-board sources of stored energy, by venting excess propellant, discharging batteries, relieving pressure vessels, and other appropriate measures, to minimize any explosion hazard creating debris. 14

OPTUS SATELLITE | OPTUS D2 | ORBITAL DEBRIS MANAGEMENT STATEMENT SAFE FLIGHT PROFILE AND ORBITAL COORDINATION Optus has assessed and limited the probability of the Optus D2 Spacecraft becoming a source of debris through collision with large debris or another operating spacecraft. The Optus D2 Spacecraft at 152° E.L. has 1.5 degrees of separation from the nearest operating spacecraft, and Optus is not aware of any spacecraft that are planned to be deployed near 152° E.L. such that there would be an overlap with the stationkeeping volume of Optus D2. Due to the large separation, there is no material risk of collision with a nearby operating spacecraft. Should Optus D2 co-locate with another spacecraft in the future, Optus will coordinate this operation on an as needed basis. Optus has active management processes in place to limit the probability of the spacecraft becoming a source of debris by collisions with objects that could cause loss of control and prevent post-mission disposal. This includes maintaining contact with institutions capable of advising of potential ‘close approaches’ with known orbital debris, and if advised of a ‘close approach’ Optus will execute evasive orbital manoeuvres as necessary. POST MISSION DISPOSAL At the end of mission life, the Optus D2 Spacecraft will be moved to a disposal orbit approximately 300km higher than the geostationary orbit altitude, in compliance with: (a) Recommendation ITU-R S.1003.2 12/2010 environmental protection of the geostationary satellite orbit. S Series Fixed-satellite services. Geneva, 2011; (b) IADC Space Debris Mitigation Guidelines, IADC-02-01 Rev 1, Action Item number 22.4,9/2007; and (c) Space systems - disposal of satellites operating at geosynchronous altitude, ISO 26872. Switzerland, 2010. Optus derived the disposal orbit altitude through the following calculations: Effective Area of the Satellite: 52 m2 Mass of the spacecraft: 1080kg (Note: Effective Area is the solar radiation pressure coefficient, CR, multiplied by the Area of the Satellite.) Therefore the Minimum Disposal Orbit Perigee Altitude, as calculated under the IADC formula is: 36,021 km + (1000 x CR x A/m) = 36069 km, or 283 km above the GSO arc (35,786 km) Optus intends to reserve 7 kg of fuel to account for post-mission disposal of Optus D2. Optus has assessed fuel gauging uncertainty and has provided an adequate margin of fuel reserve to address the assessed uncertainty. 15

ANNEX 5: AC BidCo Certifications AC BidCo LLC (“AC BidCo”), in support of the foregoing application to modify the AC BidCo ESAA License, hereby certifies as follows: 1. AC BidCo’s target space station operators have confirmed that AC BidCo’s proposed ESAA operations over international waters are within coordinated parameters for adjacent satellites up to 6 degrees away on the geostationary arc. 2. AC BidCo will comply with the requirements contained in paragraphs (a)(6), (a)(9), (a)(10), and (a)(11) of Section 25.227 of the Commission’s rules, 47 C.F.R. § 25.227. By: /s/ Timothy Joyce Timothy Joyce VP of RF Engineering, Gogo LLC for AC BidCo LLC July 25, 2017 16


Document Created: 2017-07-25 18:06:12
Document Modified: 2017-07-25 18:06:12
© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC