Attachment Narr and Exhibits

This document pretains to SES-STA-20160729-00699 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2016072900699_1145138

                                                                                        Gogo LLC
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                 REQUEST FOR SPECIAL TEMPORARY AUTHORITY

        Gogo LLC (“Gogo”), which holds a license to operate an earth station aboard aircraft
(“ESAA”) network, 1 hereby requests special temporary authority (“STA”) for a period of
60 days commencing no later than August 29, 2016, to permit up to 200 ESAA terminals 2 to
communicate with the Luxembourg-licensed ASTRA 4A satellite located at 4.8° E.L. Grant of
the requested STA will serve the public interest by allowing Gogo to initiate service to a new
fleet customer. Gogo is preparing an application to modify its ESAA license to add ASTRA 4A
and other satellites as authorized points of communications, and seeks STA pending submission
of and action on that modification application.

                                           Background

         Gogo is currently authorized to operate two types of Ku-band terminals with specified
satellites for ESAA service in U.S. airspace, foreign airspace, and the airspace over international
waters. Gogo’s license was issued based on its demonstration that its proposed network would
enhance competition in the provision of in-flight broadband service to air travelers and airline
crew members. Gogo also showed that its planned operations were fully consistent with
technical standards designed to ensure protection of other authorized communications networks.
In order to enhance and expand its ESAA operations, Gogo is preparing an application to modify
the Gogo ESAA License to add new satellites as points of communication for the Gogo network.

                                          STA Request

         Gogo seeks STA to commence communications with ASTRA 4A in the near term while
it is completing preparation of the upcoming modification application. ASTRA 4A does not
have coverage of the United States and is not on the Commission’s Permitted Space Station List,
but its licensing administration, Luxembourg, is a member of the World Trade Organization
(“WTO”). Accordingly, under the Commission’s 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. 3

1
      See Call Sign E120106, File No. SES-MFS-20151022-00735, granted June 30, 2016 (the
“Gogo ESAA License”).
2
        Gogo is licensed for two ESAA terminals, the 0.24 meter AeroSat model HR6400 and the
0.74 meter ThinKom model 2Ku, and requests authority for both models, up to a combined total
of 200 terminals.
3
    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”).


                                                                                     Gogo LLC
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        Gogo seeks authority to use ASTRA 4A capacity for ESAA operations on a primary basis
in the 14-14.25 GHz uplink spectrum and in the 11.7-12.2 GHz downlink spectrum, consistent
with the Commission’s orders in the ESAA proceeding. 4 Gogo also seeks authority to use
ASTRA 4A capacity for ESAA operations on a nonconforming basis in the 12.2-12.75 GHz
downlink spectrum. Communications with the satellite will be supported by an SES teleport in
Betzdorf, Luxembourg.

        ASTRA 4A will provide coverage of Europe. In support of this STA request, Gogo is
attaching the following information:

     •   A letter confirming that operation of the Gogo ESAA terminals is consistent with
         coordination agreements with satellites operated within six degrees of ASTRA 4A;

     •   A coverage map showing the ASTRA 4A beam that will be used by Gogo;

     •   Link budgets for the two Gogo ESAA terminals’ operations with ASTRA 4A; and

     •   An orbital debris mitigation statement for ASTRA 4A.

The technical parameters of the proposed operations with ASTRA 4A are provided in the
following table:

Antenna       Maximum EIRP Density                 EIRP (dBW)            Emission Designator
              Per Carrier (dBW/4 kHz)
    AES 1               15.56                          42.67                  2M05G7W
    AES 2               14.58                           41.7                  2M05G7W

        Gogo proposes to use ASTRA 4A for coverage of Europe. Gogo requires the ability to
use additional capacity in Europe on an urgent basis to accommodate the scheduled initiation of
service to a new airline customer. Gogo’s existing European capacity is heavily used, and Gogo
needs access to supplemental capacity in order to ensure a high quality of service for its new
customer and to allow Gogo to continue to compete effectively in the ESAA market. Gogo does
not propose to use the satellite in U.S. airspace.


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) (“ESAA Order”); Second Report and Order and Order on
Reconsideration, IB Docket No. 12-376, 29 FCC Rcd 4226 (2014) (“ESAA Second Order,” and
with the ESAA Order, the “ESAA Decisions”).


                                                                                            Gogo LLC
                                                                                         Attachment A
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        Gogo emphasizes that the scope of this STA request is limited. Gogo is only seeking
authority to add ASTRA 4A as an authorized point of communication for a limited number of
ESAA terminals. Gogo is otherwise prepared to operate consistently with the terms and
conditions set forth in the existing Gogo ESAA License. In addition, Gogo is willing to operate
pursuant to the STA on an unprotected, non-harmful interference basis.

                                        Waiver Requests

        Gogo seeks limited waivers of the Commission’s rules in connection with its request for
an STA to add ASTRA 4A as an authorized point of communication for the Gogo ESAA
network. Specifically, Gogo seeks a waiver of the Table of Allocations for its proposed
operations in the 12.2-12.75 GHz spectrum and a waiver of orbital debris mitigation
requirements because ASTRA 4A cannot fully vent propellants and relieve pressure vessels at
end of life. Grant of these waivers is consistent with Commission policy:

                      The Commission may waive a rule for good cause shown.
                      Waiver is appropriate if special circumstances warrant a
                      deviation from the general rule and such deviation would
                      better serve the public interest than would strict adherence
                      to the general rule. Generally, the Commission may grant a
                      waiver of its rules in a particular case if the relief requested
                      would not undermine the policy objective of the rule in
                      question and would otherwise serve the public interest. 5

        Section 2.106: Gogo requests waiver of the Table of Allocations in Section 2.106 of the
Commission’s rules to permit use of downlink spectrum in the 12.2-12.75 GHz band for ESAA
operations. Prior to adoption of the ESAA decisions, the Commission granted waivers for
downlink operations in the 11.7-12.2 GHz conventional Ku-band downlink spectrum “based
upon either a showing that the proposed AMSS downlink transmissions will not exceed the
10 dBW/4 kHz limit for routine processing in Section 25.134(g)(2) of the Commission’s rules or
proof that adjacent satellite operators have consented to the operations.” 6 ESAA operators were
also permitted to use extended Ku-band frequencies for ESAA downlinks pursuant to the same
rationale. 7 The Commission has recognized that “terminals on U.S.-registered aircraft may need


5
    PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted).
6
     See, e.g., Panasonic Avionics Corporation, Application for Authority to Operate Up to 50
Technically Identical Aeronautical Mobile-Satellite Service Aircraft Earth Stations in the 14.0-
14.4 GHz and 11.7-12.2 GHz Frequency Bands, Order and Authorization, 26 FCC Rcd 12557
(IB and OET 2011) at ¶ 11.
7
     See Row 44 Inc., File No. SES-MFS-20100715-00903, Call Sign E080100, Attachment at 3
(requesting expansion of the waiver of Section 2.106 that Row 44 was granted for conventional


                                                                                         Gogo LLC
                                                                                      Attachment A
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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.” 8

         The Commission’s ESAA Decisions modified the Table of Allocations to permit ESAA
operations in the conventional Ku-band, as well as in the 10.95-11.2 GHz and 11.45-11.7 GHz
segments of the extended Ku-band. The Commission acknowledged that ESAA operators may
also wish to use other downlink spectrum, particularly for reception of transmissions from space
stations with little or no U.S. coverage. 9 Although the Commission had not requested comment
on changing the allocation status of this downlink spectrum, it specifically contemplated that
access to such spectrum could be granted “on a case-by-case basis under Part 25 licensing
rules.” 10 For example, the Commission has authorized Gogo and other ESAA providers to
receive signals in the 12.2-12.75 GHz band. 11

         Consistent with these past rulings, Gogo requests a waiver of the Table of Allocations to
permit its terminals to receive transmissions from ASTRA 4A in the 12.2-12.75 GHz band. As
noted above, Gogo does not propose to use ASTRA 4A in U.S. airspace, and SES has confirmed
that Gogo’s proposed ESAA operations are consistent with SES’s coordination agreements with
satellites within six degrees. Authorizing Gogo to receive signals from ASTRA 4A 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, Gogo will not
claim interference protection from such authorized users. Under these circumstances, grant of a
Section 2.106 waiver is justified to permit use of the 12.2-12.75 GHz band for downlinks from
ASTRA 4A.

       Section 25.283(c): Section 25.283(c) specifies requirements relating to venting stored
energy sources at the spacecraft’s end of life. Specifically, the rule provides that upon
completion of a satellite’s mission, “a space station licensee shall ensure, unless prevented by
technical failures beyond its control, that all stored energy sources on board the satellite are


Ku-band downlinks to cover the proposed use of the 11.45-11.7 GHz band), granted Dec. 23,
2010.
8
     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).
9
     See ESAA Order at n.43.
10
     Id.
11
    See, e.g., Gogo Blanket License, Section B (authorizing use of the 12.2-12.75 GHz band);
Panasonic Avionics Corporation, File No. SES-MFS-20130930-00845, Call Sign E100089,
granted Sept. 24, 2014 (the “Panasonic ESAA Grant”), Section B (authorizing use of the 10.7-
12.75 GHz band).


                                                                                         Gogo LLC
                                                                                      Attachment A
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discharged, by venting excess propellant, discharging batteries, relieving pressure vessels, and
other appropriate measures.” 12 Gogo requests any necessary waiver of this requirement in
connection with its request to communicate with ASTRA 4A, an in-orbit spacecraft that was not
designed to allow complete venting at end of life.

        ASTRA 4A is a Lockheed Martin A2100 model spacecraft. As described in more detail
in the attached Orbital Debris Mitigation Statement, the oxidizer tanks on the ASTRA 4A
spacecraft were sealed following completion of the launch phase and will therefore retain
residual pressure when the spacecraft is retired. Given the spacecraft design, it is physically
impossible to vent the oxidizer tanks in order to comply with Section 25.283(c).

        Under Commission precedent, grant of a waiver is warranted. In a number of cases
involving various spacecraft models with similar limitations, the Commission has waived
Section 25.283(c) to permit launch and operation of spacecraft that do not allow for full venting
of pressure vessels at end of life, based on a finding that modifying the space station design at a
late stage of construction would pose an undue hardship. 13 In the case of ASTRA 4A, which is
currently in-orbit, there is no question of bringing the satellite into compliance with the rule. The
Commission has expressly recognized this, finding a waiver of Section 25.283(c) to be justified
for in-orbit spacecraft that cannot satisfy the rule’s requirements. For example, in a decision
involving the AMC-2 satellite, which is a Lockheed Martin A2100 design like ASTRA 4A, the
Commission waived Section 25.283(c) on its own motion, observing that venting the spacecraft’s
sealed oxidizer tanks “would require direct retrieval of the satellite, which is not currently
possible.” 14


12
     47 C.F.R. § 25.283(c).
13
     See, e.g., EchoStar Satellite Operating Corp., File No. SAT-LOA-20071221-00183, Call
Sign S2746, grant-stamped Mar. 12, 2008, Attachment at ¶ 4 (granting a partial waiver of
Section 25.283(c) for AMC-14, a Lockheed Martin A2100 model spacecraft, on grounds that
requiring modification of satellite would present an undue hardship); DIRECTV Enterprises
LLC, File No. SAT-LOA-20090807-00086, Call Sign S2797, grant-stamped Dec. 15, 2009,
Attachment at ¶ 4 (same for DIRECTV 12, a Boeing 702 model spacecraft); PanAmSat Licensee
Corp., File Nos. SAT-MOD-20070207-00027, SAT-AMD-20070716-00102, Call Sign S2237,
grant-stamped Oct. 4, 2007, Attachment at ¶ 7 (same for Intelsat 11, an Orbital Sciences Star
model spacecraft).
14
    File No. SAT-MOD-20101215-00261, Call Sign S2134, grant-stamped Mar. 8, 2011,
Attachment at ¶ 4. See also XM Radio Inc., File No. SAT-MOD-20100722-00165, Call Sign
S2616, grant-stamped Oct. 14, 2010, Attachment at ¶ 2 (waiving Section 25.283(c) for XM-4, a
Boeing 702 model spacecraft, because “modification of the spacecraft would present an undue
hardship, since XM-4 is an in-orbit space station and venting XM-4’s helium and xenon tanks
would require direct retrieval of the satellite, which is not currently possible”).


                                                                                       Gogo LLC
                                                                                    Attachment A
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        The same practical obstacle is present here. Because ASTRA 4A is already in orbit, it
cannot be modified to enable full venting of residual pressure. Given this reality, a waiver is
clearly warranted.

                                     Public Interest Showing

        Grant of the requested STA is consistent with Commission policy and will not adversely
affect other authorized operations. Gogo’s proposed operations with ASTRA 4A are consistent
with SES’s coordination agreements with adjacent satellite operators and will also conform to
the terms of Gogo’s agreements with the National Science Foundation and the National
Aeronautics and Space Administration, as required by the Gogo ESAA License. 15 In addition,
Gogo will comply with power flux density limits to protect terrestrial services outside the U.S.

       Grant of the proposed STA will allow Gogo to initiate high-quality, reliable service to a
new airline customer, promoting competition in the provision of aeronautical services and
expanding the availability of in-flight broadband to air travelers and crew members.

       Gogo understands that any Commission grant of this STA will be without prejudice to the
ultimate determination the Commission will make regarding Gogo’s future modification
application. In addition, Gogo acknowledges that any action taken pursuant to a grant of the
requested STA will be at Gogo’s own risk.




15
       Gogo ESAA License at 7, condition 90057.


      Patrick van Niftrik
      Vice President Spectrum Management & Development, EMEA




      Federal Communications Commission
      International Bureau
             th
      445 12 Street, S.W.
      Washington, D.C. 20554
      United States



      29 July 2016

      Subject: Engineering Certification of SES for the ASTRA-4A satellite



      To whom it may concern,

      This letter confirms that SES is aware that Gogo LLC (“Gogo”), licensed by the Federal
      Communications Commission (“FCC”) as Gogo LLC, is planning to file an application seeking a
      modification to its blanket authorization (the “Modification Application”) to operate two types of Ku-
      band Earth Stations Aboard Aircraft (“ESAA”) transmit/receive terminals (Call Sign E120106) pursuant
      to ITU RR 5.504A and Section 25.227 of the Commission’s rules, on domestic and international
      flights. Among other changes, the Modification Application will seek authority for Gogo’s ESAA
      terminals to communicate with the ASTRA-4A satellite at 4.8°E.L., under the current ESAA rules,
      including Section 25.227.

      Based upon the representations made to SES by Gogo concerning how it will operate on ASTRA-4A
      according to its letters dated 28 July 2016:

              SES acknowledges that the proposed operation of the Gogo ESAA terminals has the
               potential to create harmful interference to satellite networks adjacent to ASTRA-4A that may
               be unacceptable.
              SES certifies that it has completed coordination as required under the FCC’s rules and that
               the power density levels specified by Gogo are consistent with existing coordination
               agreements to which SES is a party with all adjacent satellite operators within +/- 6 degrees
               of orbital separation from ASTRA-4A.
              If the FCC authorizes the operations proposed by Gogo, SES will include the power density
               levels specified by Gogo in all future satellite network coordination with other operators of
               satellites adjacent to ASTRA-4A.

      Yours Sincerely,




      Patrick van Niftrik



      SES ASTRA S.A.                    Tel. +352 710 725 1               Company Register No. B 22 589
      Château de Betzdorf               Fax +352 710 725 227              Identification No. LU12859882
      L-6815 Betzdorf                   Enter sender e-mail
1/1   Luxembourg                        www.ses.com


Ku band: ECEE (EU) beam EIRP                                  SES*
                                           Contours Shown
                                                sire reavg
                                             527. Beampeak
                                                    s
                                                    5
                                                    s
                                                    «o
                                                    as
                                                    ar
                                                    4
                                                    as
                                                    as




                                     Notes
                                     ‘Te adjacent plot shous the
                               ~]|   measured pertormance ofa tpicat
                                     satelitetransponder. Perfomance
                                     iferences should be expected
                                     between indivual ransponders
                                     Elevation Angles are shown at 0,5
                                     and 10 Degrees


                             ASTRA 4A Link Budgets


AeroSat Antenna
            Forward Link Budget                        Return Link Budget
Hub                          Betzdorf,     Terminal                        Ku
                          Luxembourg       Required Eb/No              3.5 dB
Required Eb/No               .9 dB         Modulation             2-PSK
Modulation              4-PSK              Info Rate                  1.03 KMps
Info Rate                22.74 Mbps        FEC Rate                     .5
FEC Rate                  0.41             Carrier Spacing             1.3
Carrier Rolloff             1.2            Carrier Spreading           0.0
Satellite SFD @ 0        -91.7 dBW/m2      Satellite SFD @ 0           -79 dBW/m2
dB/K                                       dB/K
Transponder Atten         11.0 dB          Transponder Atten            13 dB
Transponder ID        4.224/4.224          Transponder ID        4.306/4.306
Hub Transmit                               Aircraft Transmit
Frequency                17.77 GHz         Terminal
Satellite G/T               6.1 dB/oK      Frequency                  14.2 GHz
Antenna Diameter            9.0 m          Satellite G/T               2.3 dB/oK
Carrier EIRP             75.33 dBW         Antenna Diameter           0.74 m
Ant. Input PFD          -25.67 dBW/4kHz    Carrier EIRP               42.7 dBW
Path Loss                  209 dB          Ant Input PFD            -13.3 dBW/4kHz
Atm/Point/Pol Loss          0.5 dB         Path Loss                207.0 dB
Aircraft Receive                           Atm/Point/Pol Loss          0.7 dB
Terminal                                   Hub Receive
Frequency                12.52 GHz         Frequency                  12.7 GHz
Satellite EIRP            52.8 dBW         Satellite EIRP               50 dBW
Downlink PFD@            13.41 dBW/4kHz    Downlink PFD@            -12.7 dBW/4kHz
Beam Center                                Beam Center
Receive Gain                29 dBi         Hub G/T                    38.4 dB/oK
Terminal G/T              11.7 dB/oK       Path Loss                206.2 dB
Path Loss                  206 dB          Other Losses                0.8 dB
Other Losses                0.7 dB
                                           Transponder
Transponder
                                           Total OPBO                  4.4 dB
Total OPBO                    1 dB         Carrier OPBO               38.8 dB
Carrier OPBO                  1 dB         C/No Thermal Up            66.0 dB-Hz
C/No Thermal Up          100.5 dB-Hz       C/No Thermal Dn            71.3 dB-Hz
C/No Thermal Dn             77 dB-Hz       C/Io Total                 83.3 dB-Hz
C/Io Total                86.3 dB-Hz       C/No+Io                   64..8 dB-Hz
C/No+Io                   76.6 dB-Hz       Add”l Link Margin           1.2 dB
Add’l Link Margin           1.0 dB         % BW per cxr                3.7 %
% BW per cxr               100 %           % Power per cxr            0.04 %
% Power per cxr            100 %           Xpdr BW Alloc              2.67 MHz
Xpdr BW Alloc               33 MHz


                             ASTRA 4A Link Budgets


ThinKom Antenna
            Forward Link Budget                        Return Link Budget
Hub                          Betzdorf,     Terminal                        2Ku
                          Luxembourg       Required Eb/No              3.5 dB
Required Eb/No              1.7 dB         Modulation             2-PSK
Modulation              4-PSK              Info Rate                  1.03 KMps
Info Rate                22.74 Mbps        FEC Rate                     .5
FEC Rate                  0.41             Carrier Spacing             1.3
Carrier Rolloff             1.2            Carrier Spreading           2.0
Satellite SFD @ 0        -91.7 dBW/m2      Satellite SFD @ 0        -80.8 dBW/m2
dB/K                                       dB/K
Transponder Atten         11.0 dB          Transponder Atten           4.0 dB
Transponder ID        4.224/4.224          Transponder ID        4.306/4.306
Hub Transmit                               Aircraft Transmit
Frequency                17.76 GHz         Terminal
Satellite G/T               6.1 dB/oK      Frequency                  14.2 GHz
Antenna Diameter            9.0 m          Satellite G/T               4.1 dB/oK
Carrier EIRP             75.33 dBW         Antenna Diameter           0.74 m
Ant. Input PFD          -25.67 dBW/4kHz    Carrier EIRP               41.7 dBW
Path Loss                  209 dB          Ant Input PFD            -13.3 dBW/4kHz
Atm/Point/Pol Loss          0.2 dB         Path Loss                207.6 dB
Aircraft Receive                           Atm/Point/Pol Loss          0.4 dB
Terminal                                   Hub Receive
Frequency                12.52 GHz         Frequency                  12.7 GHz
Satellite EIRP              51 dBW         Satellite EIRP               50 dBW
Downlink PFD@            13.41 dBW/4kHz    Downlink PFD@            -12.7 dBW/4kHz
Beam Center                                Beam Center
Receive Gain                33 dBi         Hub G/T                    38.4 dB/oK
Terminal G/T                6.1 dB/oK      Path Loss                206.2 dB
Path Loss                  206 dB          Other Losses                0.8 dB
Other Losses                0.7 dB         Transponder
Transponder                                Total OPBO                  4.4 dB
Total OPBO                    1 dB         Carrier OPBO               38.8 dB
Carrier OPBO                  1 dB         C/No Thermal Up              66 dB-Hz
C/No Thermal Up          100.5 dB-Hz       C/No Thermal Dn            71.3 dB-Hz
C/No Thermal Dn             77 dB-Hz       C/Io Total                 85.6 dB-Hz
C/Io Total                86.3 dB-Hz       C/No+Io                   64..8 dB-Hz
C/No+Io                   76.9 dB-Hz       Add”l Link Margin           1.2 dB
Add’l Link Margin            .6 dB         % BW per cxr                3.7 %
% BW per cxr               100 %           % Power per cxr            0.04 %
% Power per cxr            100 %           Xpdr BW Alloc              2.67 MHz
Xpdr BW Alloc               33 MHz


This document contains the information required under Section 25.114(d)(14) of the Federal
Communications Commission’s Rules for the ASTRA 4A satellite operating at 4.8° E.L.

Spacecraft Hardware Design: SES has assessed and limited the amount of debris released in a
planned manner during normal operations of ASTRA 4A. No debris is generated during normal
on-station operations, and the spacecraft will be in a stable configuration. On-station operations
require station keeping within the +/- 0.05 degree E-W and N-S control box, thereby ensuring
adequate collision avoidance distance from other satellites in geosynchronous orbit. In the event
that co-location within the same stationkeeping volume of this and another satellite is required,
use of the proven Inclination-Eccentricity (I-E) separation method can be employed. This
strategy is presently in use by SES to ensure proper operation and safety of multiple satellites
within one orbital box.

SES has also assessed and limited the probability of the space station becoming a source of
orbital debris by collisions with small debris or meteoroids that could cause loss of control and
prevent post-mission disposal. SES requires that spacecraft manufacturers assess the probability
of micrometeorite damage that can cause any loss of functionality. This probability is then
factored into the ultimate spacecraft probability of success. Any significant probability of
damage would need to be mitigated in order for the spacecraft design to meet the required
probability of success of the mission. The design of the spacecraft locates all sources of stored
energy within the body of the structure, which provides protection from small orbital debris.
Steps have been taken to limit the effects of any collisions through shielding, the placement of
components, and the use of redundant systems.

Minimizing Accidental Explosions: SES has assessed and limited the probability of accidental
explosions during and after completion of mission operations. As part of the Safety Data
Package, an extensive analysis is completed by the spacecraft manufacturer, reviewing each
potential hazard relating to accidental explosions. A matrix is generated indicating the worst-
case effect, the hazard cause, and the hazard controls available to minimize the severity and the
probability of occurrence. Each subsystem is analyzed for potential hazards, and the Safety
Design Package is provided for each phase of the program running from design phase,
qualification, manufacturing and operational phase of the spacecraft. Also, the spacecraft
manufacturer generates a Failure Mode Effects and Criticality Analysis for the spacecraft to
identify all potential mission failures. The risk of accidental explosion is included as part of this
analysis. This analysis indicates failure modes, possible causes, methods of detection, and
compensating features of the spacecraft design.

The design of the ASTRA 4A spacecraft is such that the risk of explosion is minimized both
during and after mission operations. In designing and building the spacecraft, the manufacturer
took steps to ensure that debris generation will not result from the conversion of energy sources
on board the satellite into energy that fragments the satellite. All propulsion subsystem pressure


vessels, which have high margins of safety at launch, have even higher margins in orbit, since
use of propellants and pressurants during launch decreases the propulsion system pressure. Burst
tests are performed on all pressure vessels during qualification testing to demonstrate a margin of
safety against burst. Bipropellant mixing is prevented by the use of valves that prevent
backwards flow in propellant and pressurization lines. All pressures, including those of the
batteries, are monitored by telemetry.

At the end of operational life, after the satellite has reached its final disposal orbit, on-board
sources of stored energy will be depleted or secured, and the batteries will be discharged.
However, at the end of ASTRA 4A’s operational life, there will be oxidizer remaining in the
tanks that cannot be vented. Following insertion of the spacecraft into orbit, the spacecraft
manufacturer permanently sealed the oxidizer tanks by firing pyrotechnic valves. This is a
design feature of the Lockheed A2100 series spacecraft that cannot now be changed or remedied.
Information regarding the residual oxidizer in the tanks is as follows:

           Item                Total        Pressure [bar]    Temp. [deg C]      Total Mass [kg]
                             Volume [l]
  Oxidizer (in two              657               19               21.5                 12
  interconnected tanks)

The oxidizer tanks are well shielded, and the residual pressure in the tanks will be well below
their maximum rating. The oxidizer in the tanks is MON-3 (N2O4 with 3% NO2). In addition
to the oxidizer, the tanks include helium pressurant, which has a residual mass of approximately
1.9 kg. Given the tank temperature, the majority of the residual oxidizer (over 8 liters) is in a
liquid form. Accordingly, the pressure results above reflect the combined pressure of the helium
gas and the vapor pressure from the oxidizer that is in gas form, using a tank volume of
approximately 649 liters (657 liters less the 8 liters occupied by the liquid oxidizer).

Safe Flight Profiles: SES has assessed and limited the probability of the space station becoming
a source of debris by collisions with large debris or other operational space stations.
Specifically, SES has assessed the possibility of collision with satellites located at, or reasonably
expected to be located at, 4.8° E.L. or assigned in the vicinity of that location.

Regarding avoidance of collisions with controlled objects, in general, if a geosynchronous
satellite is controlled within its specified longitude and latitude stationkeeping limits, collision
with another controlled object (excluding where the satellite is collocated with another object) is
the direct result of that object entering the allocated space.

At 4.8° E.L., ASTRA 4A operates at an offset from SES’s SES-5 satellite operating at the
nominal 5.0° E.L. During regular operation there are no other satellites assigned to or reasonably


expected to be located at 4.8° E.L. or to nearby orbital locations such that there would be an
overlap with the stationkeeping volume of ASTRA 4A at 4.8° E.L.

SES uses the Space Data Center (“SDC”) system from the Space Data Association to monitor the
risk of close approach of its satellites with other objects. Any close encounters (separation of
less than 10 km) are flagged and investigated in more detail. If required, avoidance maneuvers
are performed to eliminate the possibility of collisions.

During any relocation, the moving spacecraft is maneuvered such that it is at least 30 km away
from the synchronous radius at all times. In most cases, much larger deviation from the
synchronous radius is used. In addition, the SDC system is used to ensure no close encounter
occurs during the move. When de-orbit of a spacecraft is required, the initial phase is treated as
a satellite move, and the same precautions are used to ensure collision avoidance.

Post-Mission Disposal: Post-mission disposal of the satellite from operational orbit will be
accomplished by carrying out maneuvers to a higher orbit. The upper stage engine remains part
of the satellite, and there is no re-entry phase for either component.

Post-mission disposal of the satellite from operational orbit will be accomplished by carrying out
maneuvers to a higher orbit. The fuel budget for this operation is included in the satellite design.
SES plans to maneuver ASTRA 4A to a disposal orbit with a minimum perigee of 258 km above
the normal operational altitude. This proposed disposal orbit altitude is based on the following
calculation pursuant to § 25.283 of the Commission’s Rules.

       Area of the satellite (average aspect area): 54 m2
       Mass of the spacecraft: 2261.4 kg
       CR (solar radiation pressure coefficient): 0.98

Therefore the Minimum Disposal Orbit Perigee Altitude, as calculated under the IADC formula
is:

36,021 km + (1000 x CR x A/m) = 36,044 km, or 258 km above the GSO arc (35,786 km)

SES intends to reserve 5.3 kg of fuel in order to account for post-mission disposal of
ASTRA 4A. SES has assessed fuel gauging uncertainty and has provided an adequate margin of
fuel reserve to address the assessed uncertainty.



Document Created: 2016-07-29 18:53:24
Document Modified: 2016-07-29 18:53:24

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