Attachment Narrative

This document pretains to SES-MOD-20170920-01041 for Modification on a Satellite Earth Station filing.

IBFS_SESMOD2017092001041_1279222

                                                                                   Exhibit A
                                                                                 Page 1 of 2

                                       APPLICATION

               SES Government Solutions, Inc. (“SES-GS,” formerly Americom
Government Services, Inc.) requests modification of its license for earth station call sign
E050252 in Suitland, Maryland. Specifically, SES-GS requests that the Commission
update the license to reflect the use of two 6.3 meter C-band antennas rather than the
single 6.1 meter antenna listed on the license. SES-GS previously completed
coordination for the 6.3 meter antennas, and the site has subsequently been protected
based on the correct antenna size. Accordingly, grant of the requested modification is
consistent with the record and will not adversely affect any other authorized spectrum
users.
               The change sought here to the E050252 license was requested and
granted pursuant to a prior submission, IBFS File No. SES-MOD-20090504-00547 (the
“2009 C-band Modification”). That application sought revision of the E050252 license to
specify two 6.3 meter C-band antennas in lieu of a 6.1 meter antenna and also
corrected the site location data. In support of that application, SES-GS submitted a
Comsearch report confirming the successful coordination of the 6.3 meter equipment
with terrestrial users 1 as well as a radiation hazard analysis for the 6.3 meter antennas. 2
               The 2009 C-band Modification was accepted for filing and subsequently
granted on April 13, 2010. However, the current license for E050252 does not reflect
the antenna size changes described in the 2009 C-band Modification. It appears this
disconnect occurred because at the same time SES-GS submitted the 2009 C-band
Modification, it also separately requested authority to add a Ku-band antenna to the
E050252 license. See IBFS File No. SES-MOD-20090504-00548 (the “2009 Ku-band
Modification”). The two applications were processed in parallel, and the 2009 Ku-band
Modification was also granted on April 13, 2010.
               The grant of the 2009 Ku-band Modification, which is designated as the
“Current Authorization” in IBFS, appears to have been issued just after the grant of the


1See File No. SES-MOD-20090504-00547, Frequency Coordination and Interference
Analysis Report performed by Comsearch dated May 3, 2009.
2   See id., Radiation Hazard Study.


                                                                                  Exhibit A
                                                                                Page 2 of 2

2009 C-band Modification, and it does not incorporate the update regarding the C-band
antenna sizes that was requested and authorized in response to the 2009 C-band
Modification. Unfortunately, this omission was not recognized at the time, and SES-GS
only recently became aware that the current E050252 license is incorrect.
              Through this modification application SES-GS seeks an update of the
license to incorporate the antenna size changes from the 2009 C-band Modification.
Grant of a corrected license will serve the public interest and will not adversely affect
other authorized C-band operators. As discussed above, Comsearch completed
coordination of the 6.3 meter C-band equipment prior to submission of the 2009 C-band
Modification. SES-GS relies on Comsearch to provide ongoing protection of the SES-
GS earth stations. Comsearch has confirmed to SES-GS that the Comsearch database
reflects the use of 6.3 meter C-band antennas at the E050252 location and that
Comsearch has been providing protection of the site consistent with that information.
Because the 6.3 meter antennas have been subject to continuous protection since
Comsearch performed the coordination analysis for the 2009 C-band Modification, no
new coordination report should be required.
              Accordingly, SES-GS requests that the Commission update the E050252
license to delete the 6.1 meter antenna listed as Antenna 1 on the license and instead
reflect the use of two 6.3 meter antennas, consistent with the information provided in the
attached Form 312 Schedule B. As discussed above, the earth station site also has a
Ku-band antenna, and no changes to the information relating to that antenna are
needed.



Document Created: 2017-09-20 15:35:41
Document Modified: 2017-09-20 15:35:41

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