Attachment E070181 STA Request

This document pretains to SES-STA-20110218-00182 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2011021800182_870437

               REQUEST FOR SPECIAL TEMPORARY AUTHORITY

         SES Americom, Inc. (“SES Americom”) respectfully requests a Special
Temporary Authority (“STA”), starting on or about March 4, 2011, to use the earth
station license with call sign E070181 to perform telemetry, tracking and command
(“TT&C”) functions with the NSS-703 spacecraft once it arrives at the 47.05° W.L.
orbital location. All on-station TT&C operations will be performed in the following C-
band frequencies:

        Telecommand:              6173.7 MHz, 6176.3 MHz
        Telemetry:                3947.5 MHz, 3948.0 MHz, 3952.5 MHz, 3952.0 MHz
        Tracking Beacon:          3950.0 MHz

         As the Commission is aware, SES Satellites (Gibraltar) Ltd (“SES Gibraltar”), an
indirect wholly-owned subsidiary of SES Americom, has filed a petition for declaratory
ruling to add the NSS-703 satellite to the FCC’s Permitted Space Station List to provide
C- and Ku-band service to the United States from the 47.05° W.L. orbital location. See
File Nos. SAT-PPL-20101103-00230, SAT-APL-20110120-00015 (Call Sign S2818;
Public Notice, Report No. SAT-00753, rel. Feb. 1, 2011). SES Gibraltar has been
authorized by the Gibraltar Regulatory Authority to utilize the C- and Ku-band
frequencies at the nominal 47° W.L. orbital location to serve various countries within the
satellite’s footprint. A full description of the licensing and technical specifications of the
satellite (including its TT&C subsystem) is contained in SES Gibraltar’s filing with the
Commission.

        SES Gibraltar has arranged with its affiliate SES Americom to use earth station
E070181 to perform TT&C functions for the NSS-703 satellite once the satellite arrives
on-station at 47.05° W.L. Once SES Gibraltar’s Permitted List petition is granted, all
U.S. earth stations with an “ALSAT” or “Permitted List” designation will be authorized
to communicate with NSS-703 at 47.05° W.L. Pending the grant of that petition,
however, SES Americom is requesting an STA to allow earth station E070181 to
communicate with the spacecraft.

         SES Americom acknowledges that the TT&C frequencies for the NSS-703
satellite are located at the center of the allocated C-band frequencies, and not at the band
edges as required by 47 C.F.R. § 25.202(g). SES Americom respectfully requests a
waiver of § 25.202(g) to the extent one is required for the grant of this STA. As
explained in SES Gibraltar’s petition for declaratory ruling, NSS-703’s use of center-of-
band TT&C frequencies is simply the product of the historical, international origins of
the NSS-703 satellite as a former INTELSAT satellite. The FCC has previously waived
§ 25.202(g) for former INTELSAT satellites that are now serving the United States as
U.S.- or foreign-licensed spacecraft,1 and should do so again here on the same basis. See
also SES-STA-20101208-01518 (granted Dec. 10, 2010) (granting STA to use earth


1
 See Petition of Declaratory Ruling at 6-8 notes 16, 18 & 23, in File No. SAT-PPL-20101103-00230 (filed
Nov. 3, 2010) (pending).


station WB81 to perform TT&C on center-of-band frequencies with NSS-703 during drift
to 47.05° W.L.).

        Grant of the requested STA and any necessary waiver will serve the public
interest as it will assure safe operation of the NSS-703 satellite once it arrives on-station
at 47.05° W.L. Grant of the STA will also not cause any harmful interference. The use
of the C-band frequencies on earth station E070181 has been coordinated with terrestrial
services for orbital locations as far east as 15° W.L. See File No. SES-MOD-20100930-
01226 (granted Nov. 8, 2010).

       For all of these reasons, SES Americom respectfully requests expeditious grant of
a 30-day STA to use earth station E070181 to perform on-station TT&C with the NSS-
703 satellite at 47.05° W.L. by no later than March 4, 2011.



Document Created: 2011-02-18 11:06:23
Document Modified: 2011-02-18 11:06:23

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