Attachment Response letter

Response letter

REPLY submitted by SES Americom

Response letter

2007-01-19

This document pretains to SES-STA-20061020-01880 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2006102001880_546485

An SES GLOBAL Company January 19, 2007 Mr. Robert G. Nelson Chief, Satellite Division Federal Communications Commission. 445 12"" St, N.W. Washington, D.C. 20554 File Nos. SES—STA—20061020—01876 through —01880, SES—STA—20061211—02123 through —02128 SES—STA—20070109—00043 through —00047 Dear Mr. Nelson: This is in response to your letter to James Barker dated January 18, 2007, referencing the applications listed above. SES Americom addresses the questions you raise, and can answer any additional questions you may have concerning this matter. 1. When did AMC—18 leave the 80° W.L. location, and when did it arrive at the 81° W.L. location? Was the communications payload of the spacecraft, i.e., other than TT&C functions, operated after the spacecraft left 80° W.L.? Ifyes, please explain the nature and scope ofsuch operations. AMC—18 left the 80° W.L. location on January 9, 2007, and arrived at the 81° W.L. location on January 11, 2007. The communications payload of the spacecraft was not operated during the drift but was operated after the satellite arrived at 81° W.L. Specifically, from January 12 to January 16 multiple carriers were transmitted from a non—U.S. facility to transponders on both polarizations of the satellite. 2. Did SES Americom transmit signals to or receive signals from AMC—18, using a U.S. earth station, during the drift ofAMC—18 from 80° W.L. to 81° W.L.? Was a U.S. earth station utilized to effect the placement of the satellite at the 81° W.L. orbital position? Did SES Americom transmit signals to or receive signals from AMC—18 at 81 ° W.L. using a U.S. earth station? \WDC — 090844/000007 — 2421584 v4 SES AMERICOM, Inc. Four Research Way Princeton NJ 08540 USA tel 1 (609) 987 4000 www.ses—americom.com

SES Americom has not used a U.S. earth station to control the satellite during the drift from 80° W.L. to 81° W.L., to place the satellite at 81° W.L., or to transmit and receive service from the satellite over the satellite payload. As a precautionary redundancy measure, in addition to primary receipt of the satellite telemetry beacons at the non—U.S. earth station, two U.S. earth stations have passively monitored the telemetry beacons of the satellite during the drift and while the satellite has been at 81° W.L. 3. When did SES Americom, SES Global, and/or SES Gibraltarfirst begin planning for a possible stop ofAMC—18 at 81° W.L.? When were those plans finalized? When did SES Gibraltarfirst discuss those plans with Gibraltar regulators? When did SES Americom become aware ofthose discussions? SES Americom has over time considered possible operation of satellites at 81° W.L., including possible transactions involving AMC—18, subject to appropriate regulatory approval. However, none of these matters has matured. In late November—early December 2006 SES Americom began seriously considering the possibility of using AMC—18 for a demonstration service at 81° W.L. in order to evaluate the ability to use a multi—feed dish for IPTV service from satellites at two degree spacing. This evaluation is relevant to SES Americom‘s work with local exchange carriers to develop IPTV services, especially for rural customers. The 81° W.L. orbital location is not currently in use, and is adjacent to operations that SES Americom has underway for IPTV at 79° W.L. However, SES Americom recognized that the opportunity for such a service evaluation was limited given that AMC—18 was to be launched on December 8, and needed to be in place to meet important customer requirements at 104.95° W.L. by the end of January 2007. I am a Vice President and officer of SES Americom and an officer of SES Satellites (Gibraltar) Ltd. I first discussed this matter with Gibraltar regulators on December 8, 2006, when I was with them at the launch of AMC—18 in Kourou. Plans for the service evaluation were finalized after the successful launch of the satellite and these discussions. An application to the Commuission was filed on December 11. Pursuant to the rules of the Gibraltar Regulatory Authority ("GRA"), SES Satellites (Gibraltar) Ltd. made a formal notification of its plans on December 12, (see Attachment A), and the GRA provided a non—objection confirmation by letter of December 19 (see Attachment B). As recognized in your letter, on January 18 SES Americom withdrew its applications for special temporary authority to operate the AMC—18 satellite at 81° W.L. The company will not be able to conduct the IPTV service evaluation as planned given the customer requirements for use of AMC—18 at 104.95° WL by the end of the month. The satellite must begin moving to that orbital location immediately to meet that deadline. iN\DC — 090844/000007 — 2421584 v4

Pursuant to Section 1.16 of the Commuission‘s rules, I declare under penalty of perjury that the following is true and correct, and that I am executing this statement on the above—referenced date. Respectfully submitted, John A. Nelsen VP Spectrum Development co: Scott Kotler Andrea Kelly Cassandra Thomas Gardner Foster Karl Kensinger Frank Peace Sergio Scarabino, Comision National de Communicaciones de Republica Argentina (All by e—mail) \\\DC — 090844/000007 — 2421584 v4

ATTACHMENT A John A. Nelsen Vice President Business Operations CONFIDENTIAL & PROPRIETARY Mr. Paul Canessa December 12, 2006 Chief Executive Gibraltar Regulatory Authority Suite 811 Europort Gibraltar RE: AMC-18 Notification #2 Dear Paul, In accordance with the Outer Space Act Licence for AMC18, SES Satellites (Gibraltar) Limited (“SES-G”) hereby notifies the Gibraltar Regulatory Authority that on completion of In Orbit Testing (“IOT”) of AMC-18 at the 80°W orbital position on January 1 ,2007, the satellite will be repositioned to 81°W for a period not to exceed twenty days in order to facilitate technical demonstrations for customers. Operation will be on a non-interference basis relative to adjacent operating satellite systems: SES AMERICOM (AMC2 at 85°W AMC9 at 83°W, and C3 at 79°W) and Intelsat (Galaxy 4R at 77°W). There is no other satellite operating at 81°W. When operation at 81°W is completed, the satellite will be repositioned to 105°W (Actual operation will be 104.95°W ± .05°W to facilitate co-location with SES AMERICOM’s AMC15 Ka/Ku satellite which will operate 105.05°W ± .05°W. ) SES-G will notify the GRA of commencement of the drift to and arrival at 105°W. If you have any questions please contact Norbert Schroeder at (+44) 7796 178 536, or myself at the address/telephone numbers below. Regards, SES Satellites (Gibraltar (Limited) Four Research Way Princeton NJ 08540 USA tel (1) 609 987 4088 fax (1) 609 987 4312 john.nelsen@ses-americom.com Registered in Gibraltar under Number 57393. Registered Office at 28 Irish Town P.O. .Box 15, Gibraltar

l Fra Glratar Regulatery Autorty Sute at1, Eucpor Gbater Torsssomiese Fac «asoraice Your ret: enaineggng Our ret: 1621 ut Moimugag Date: 19 December 2006 Mr John A Nelsen Vice President Business Operations SESatelites (Gibraktr) Limited Four Research Way Princeton No oss40 usa Dear John AMC—18 Notification #2 We note the contents of AMC—18 Notifcation #2 and raise no requlatory objections. Please notify us once the operation at BI°W is complete and the drif is commenced to repostion the satelite to 105°W. Yours sincerely Paul J Canessa Chief Executive


Document Created: 2007-01-19 14:18:17
Document Modified: 2007-01-19 14:18:17
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