Attachment Narrative

This document pretains to SES-STA-20150326-00183 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2015032600183_1081365

                                                                    Lockheed Martin Corporation
                                                                                    March 2015
                                                                                    Attachment
                                                                                     Page 1 of 2



                                 Request for Additional 30-day STA

        Lockheed Martin Corporation (“Lockheed Martin”) hereby requests special temporary
authority (“STA”) for an additional thirty-day period to operate its Carpentersville, New Jersey
C/Ku-band fixed earth station (FCC Call Sign E7541) as previously authorized in FCC File No.
SES-STA-20150304-00110 (granted 3/06/2015). This authority was granted, effective March 7,
2015, to provide telemetry, tracking and control (“TT&C”) functions during the post-launch and
early orbit phases (“LEOP”) of operation for the ABS-3A satellite. The current authorization
expires on April 6, 2015.

         Contemporaneously with the original request for a 30-day STA, Lockheed Martin also
filed a request to conduct these same LEOP operations for an extended 180-day period. See FCC
File No. SES-STA-20150304-00111.1 That application appeared on FCC Public Notice on
March 11, 2015, with the result that the Commission may not grant it until the statutory period
allowed for public comment has elapsed on Friday, April 10, 2015, and the application becomes
eligible for grant on the following business day, Monday, April 13, 2015.2 That date is one week
after the expiration date of the current short-term STA.

        Accordingly, Lockheed Martin requires an additional STA to cover the period between
the expiration of its current short-term STA, on April 6, 2015, and the date upon which the FCC
would be able to grant the company longer term authority. Although the application will
officially “come off” Public Notice on April 10, and therefore be eligible for grant on April 13, it
cannot be predicted at this time when the FCC actually will be able to complete processing of
this pending request. In addition, as the ABS-3A LEOP operations may extend beyond the 180-
day period requested, it would serve the public interest to grant Lockheed Martin a full 30-day
STA in response to this application, and defer the effective date of the requested 180-day STA, if
granted, until the day following the anticipated expiration date of the new 30-day STA that
Lockheed Martin is seeking herein.

        Assuming grant of the authority requested commencing upon the expiration of the current
STA, the resulting 30-day STA would expire at the end of the day on May 7, 2015. A grant of a
further 180-day STA effective as of the following day, May 8, 2015, would allow the long-term
STA to extend until November 4, 2015, increasing the likelihood that all LEOP operations for
ABS-3A will have been successfully concluded by the expiration date, and removing the need to
seek further authority for these operations beyond the expiration of the 180-day authority. In
order to reduce the potential need for additional STA requests, and preserve the FCC staff

1
  As explained in both STA requests, ABS-3A is a Boeing Model 702SP satellite using an all-electric
propulsion system, a design which extends the typical LEOP period from a few weeks (easily covered by
a 30-day STA) to six months or more, requiring longer term STA operation, which requires more lengthy
Commission procedures.
2
    See 47 U.S.C. § 309(b) & (c)(2)(G); 47 C.F.R. § 25.120(b)(2).


                                                                  Lockheed Martin Corporation
                                                                                  March 2015
                                                                                  Attachment
                                                                                   Page 2 of 2


resources that are required to process such requests, Lockheed Martin respectfully requests that
the authority requested here be handled as described above in order to extend the terminal date of
the long-term STA to the latest possible date. To facilitate this approach, Lockheed Martin will
also update the record in connection with the long-term STA, File No. SES-STA-20150304-
00111, upon final action on this application.

         Lockheed Martin’s Carpentersville earth station is part of a global network of control
facilities that are critical to the safe and orderly deployment of the ABS-3A satellite, and its
continued operation for this purpose will protect the hundreds of satellites licensed by the U.S.
and other countries that are currently in operation. Accordingly, the grant of this request will
serve the public interest.



Document Created: 2015-03-26 17:54:08
Document Modified: 2015-03-26 17:54:08

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