Attachment STA Narrative

This document pretains to SES-STA-20170109-00019 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017010900019_1163316

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of Application by ) ) SES AMERICOM, INC. ) SES-STA-________-_____ ) Call Sign _____ For Special Temporary Authority to ) Perform In-Orbit Testing for SES-10 at 68.5° W.L. ) REQUEST FOR SPECIAL TEMPORARY AUTHORITY By this application, SES Americom, Inc. (“SES Americom” or “SES”) respectfully requests special temporary authority (“STA”) for a period of 30 days, beginning 11 days following launch of SES-10, to permit SES to perform in-orbit testing of the SES-10 satellite at 68.5° W.L. using its new antenna in Woodbine, MD. The satellite is currently 1 scheduled to launch mid-February 2017 and will ultimately operate at 66.9° W.L. Following the completion of in-orbit testing at 68.5° W.L., SES-10 will drift to its final orbital location at 66.9° W.L. SES Americom will separately seek authority to allow ongoing operation of the earth station with SES-10 at 66.9° W.L. SES Americom’s affiliate, New Skies Satellites B.V. (“NSS”), received authority 2 to provide service into the United States using SES-10 at 67° W.L. on June 23, 2016. NSS has 1 See New Skies Satellites B.V. Market Access Application, File No. SAT-PPL-20160117-00005 (“SES-10 Petition”), granted on June 23, 2016 (“SES-10 Grant”). The grant was based on SES- 10 operating at 67.0° W.L., but NSS has filed a modification of its authority to operate the satellite at 66.9° W.L. pursuant to the Commission’s expedited process set out in Section 25.117(h)(1). New Skies Satellites B.V. Modification, File No. SAT-MPL-20170108-00002, (Call Sign S2950), filed Jan. 8, 2017. 2 Id. SES Americom incorporates by reference the technical information submitted in the SES- 10 Petition.

requested that SES Americom assist with testing the satellite at 68.5°W.L. SES Americom, therefore, requests STA to use its earth station to test the SES-10 communications payloads using the following frequencies: Uplink 13.75-14.0 GHz Uplink 14.0-14.5 GHz Uplink 17.3-17.55 GHz Downlink 10.95-11.2 GHz Downlink 11.45-11.7 GHz Downlink 11.7-12.2 GHz The proposed operations will be coordinated with all satellite operators that use the same frequency bands within six degrees of 68.5° W.L. and those within the drift path. All operators of potentially affected satellites will be provided with an emergency phone number where the licensee can be reached in the event harmful interference occurs. Grant of STA Will Serve the Public Interest. Grant of this STA request is in the public interest. The requested authority to test SES-10 will ensure it is capable of providing valuable services once it begins full operation. No Harmful Interference to Other Spacecraft. All operations with SES-10 while it is located at 68.5° W.L. will be on a non-harmful interference basis. SES has commenced coordinating the proposed IOT operations in the C- and Ku-band satellites positioned near 68.5° W.L., including Nimiq 5 (72.7° W.L.), Arsat 1 (71.8° W.L.), Star One C2 (70° W.L.), Star One C4 (70° W.L.), Star One C1 (65° W.L.), Eutelsat 65 West A (65.2° W.L.), and Telstar 14R (63° W.L.). The maximum EIRP density identified in Attachment 1 will also not be exceeded, except 3 in the case of certain tests involving high-powered continuous wave (“CW”) carriers. The drift 3 47 C.F.R. § 25.275(e). 2

of the spacecraft will be coordinated with other satellite operators consistent with industry 4 practice. As demonstrated in the assessment provided in Attachment 2, operations in 13.75- 14.0 GHz will not cause harmful interference to U.S. Navy radar stations of NASA TDRSS stations. Waiver Requests. SES requests limited waivers of the Commission’s requirements in connection with the instant STA request. 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 and Footnote US271. The SES-10 Grant included a waiver of Section 2.106 and footnote US271 permitting NSS to provide service into the United States at 67° W.L. using the 17.3-17.55 GHz band, which is allocated for the fixed-satellite service but 6 limited to use by broadcasting-satellite service (“BSS”) feeder links. The only other BSS satellite within the coordination arc is Nimiq 5, which is more than four degrees away at 72.7° W.L. A similar waiver is justified to support in-orbit testing. As described in the SES-10 4 The 24/7 point of contact for the proposed SES-10 operations is the SES Payload Management Operations Centre (PMOC) in Woodbine, MD, 1 800 772 2363 or 1 410 970 7570; e-mail: PMOC@ses.com. 5 PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted). 6 See SES Petition. 3

Petition, BSS feeder links are similar to other FSS operations using large earth station antennas that can share on a roughly two degree spacing basis. Furthermore, operations in the 17.3-17.55 GHz band will be on an unprotected, non-interference basis. Thus, granting a waiver will not undermine Commission policy because BSS operations will be fully protected. Section 2.106 Footnote NG52. SES Americom also seeks a waiver of footnote NG52 to permit the reception of U.S. domestic services in the 10.95-11.2 GHz and 11.45- 11.7 GHz bands on an unprotected, non-interference basis for purposes of testing the SES-10 payload. The Commission has granted a waiver for SES-10 to provide domestic service in these bands, and SES Americom needs to ensure the payload is operating properly. Footnote NG52 was intended to preserve access to the 10.7-11.7 GHZ spectrum for terrestrial fixed service 7 (“FS”) stations by limiting FSS use of the band to international operations only. SES-10 will 8 meet the power flux density limits on the ground to protect FS operations and the requested tests will be for a limited duration of time. Therefore, grant of the requested waiver will not undermine the purpose of the rule. 7 See 47 C.F.R § 2.106, Footnote NG52. This policy was previously codified in footnote NG104. 8 See SES Petition. 4

For the foregoing reasons, SES Americom respectfully requests special temporary authority for its earth station to communicate with SES-10 for a period of up to 30 days to test the communications payload at 68.5° W.L. as described herein. Grant of the requested authority will promote safe operation of the satellite during and after it is tested. Respectfully submitted, SES AMERICOM, INC. By: /s/ Petra Vorwig Of Counsel Petra Vorwig Karis A. Hastings Senior Legal & Regulatory Counsel SatCom Law LLC SES Americom, Inc. 1317 F Street, N.W., Suite 400 1129 20th Street NW, Suite 1000 Washington, D.C. 20004 Washington, DC 20036 Tel: (202) 599-0975 Tel: (202) 478-7143 Dated: January 9, 2017 5

ATTACHMENT 1 Call Sign: New earth station (WBK11) Site Details Contact Information: Address: Mark Rathert 2323 Grimville Rd 410-970-7501 Mt. Airy, MD 21771 Geographic Coordinates: Latitude: 39° 22’ 38.8" N Longitude: 77° 04’ 52.97" W Site Elevation: 194.0 meters Antenna Details Antenna ID: WBK11 Manufacture/Model: GD Satcom/Vertex Antenna Size: 9m Antenna Gain Transmit: 60.1 dBi at 14.125 GHz 61.96 dBi at 17.5 GHz Antenna Gain Receive: 58.5 dBi at 11.725 GHz Height Above Ground Level: 9.7 meters Height Above Sea Level: 203.7 meters Total Input Power at the Flange: 3000 watts Total EIRP for all Carriers: 94.87 dBW Operational Details Frequency Transmit/ Polarization Emissions Max EIRP Max EIRP (MHz) Receive Designator per Carrier Density per (dBW) Carrier (dBw/4kHz) 13750-14000 T Horizontal 1M24G7W 71.0 46.1 and Vertical 13750-14000 T Horizontal 54M0G7W 84.99 43.69 and Vertical 14000-14500 T Horizontal 100KG7W 60.08 46.1 and Vertical 14000-14500 T Horizontal 54M0G7W 87.09 45.79 and Vertical 14000-14500 T Horizontal N0N 46.1 46.1 and Vertical

17300-17550 T Horizontal 100KG7W 63.93 49.96 and Vertical 17300-17550 T Horizontal 36M0G7W 89.5 49.96 and Vertical 17300-17550 T Horizontal N0N 71 71 and Vertical 10950-11200 R Horizontal 100KG7W and Vertical 10950-11200 R Horizontal 54M0G7W and Vertical 11450-11700 R Horizontal 100KG7W and Vertical 11450-11700 R Horizontal 54M0G7W and Vertical 11700-12200 R Horizontal 100KG7W and Vertical 11700-12200 R Horizontal 54M0G7W and Vertical 2

Attachment 2 Compliance with FCC Report & Order (FCC 96-377) for the 13.75-14.0 GHz Band Analysis and Calculations for 9 Meter Antenna at Woodbine, MD

Exhibit For SES Americom, LLC Woodbine, Maryland Vertex Corporation 9 Meter Earth Station Compliance with FCC Report & Order (FCC96-377) for the 13.75 - 14.0 GHz Band Analysis and Calculations 1. Background This Exhibit is presented to demonstrate the extent to which the SES Americom, LLC satellite earth station in Woodbine, Maryland is in compliance with FCC REPORT & ORDER 96-377. The potential interference from the earth station to US Navy shipboard radiolocation operations (RADAR) and the NASA space research activities in the 13.75 - 14.0 GHz Band is addressed in this exhibit. The parameters for the earth station are: Table 1. Earth Station Characteristics • Coordinates (NAD83): 39° 22’ 38.8” N, 77° 04’ 52.9” W • Satellite Location for Earth Station: SES-10 (68.5° W) • Frequency Band: 13.75-14.0 GHz for uplink • Polarizations: Linear • Emissions: N0N, 100KG7W, 1M00G7W, 36M0G7W and 54M0G7W • Modulation: Digital • Maximum Aggregate Uplink EIRP: 46.1 dBW for the N0N Carrier 60.0 dBW for the 100 kHz Carriers 70.0 dBW for the 1 MHz Carriers 85.0 dBW for the 36 MHz Carriers 85.0 dBW for the 54 MHz Carriers • Transmit Antenna Characteristics Antenna Size: 9.0 meters in Diameter Antenna Type/Model: Vertex Corporation Gain: 60.1 dBi • RF power into Antenna Flange: No Modulation (N0N) -14.0 dBW or -14.0 dBW/4 kHz (Maximum)

• RF power into Antenna Flange 100 kHz (Continued) -0.1 dBW or -14.0 dBW/4 kHz 1 MHz 9.9 dBW or -14.0 dBW/4 kHz (Maximum) 36 MHz 24.9 dBW or –14.6 dBW/4 kHz (Maximum) 54 MHz 24.9 dBW or –16.4 dBW/4 kHz (Maximum) • Minimum Elevation Angle: Woodbine, Md 43.6° @ 166.6° Az. (SES 10) at 68.5° W • Side Lobe Antenna Gain: 32 - 25*log(θ) Because the above uplink spectrum is shared with the Federal Government, coordination in this band requires resolution data pertaining to potential interference between the earth station and both Navy Department and NASA systems. Potential interference from the earth station could impact with the Navy and/or NASA systems in two areas. These areas are noted in FCC Report and Order 96-377 dated September 1996, and consist of (1) Radiolocation and radio navigation, (2) Data Relay Satellites. Summary of Coordination Issues: 1) Potential Impact to Government Radiolocation (Shipboard Radar) 2) Potential Impact to NASA Data Relay Satellite Systems (TDRSS) 2. Potential Impact to Government Radiolocation (Shipboard Radar) Radiolocation operations (RADAR) may occur anywhere in the 13.4 - 14 GHz frequency band aboard ocean going United States Navy ships. The Federal Communication Commission (FCC) order 96-377 allocates the top 250 MHz of this 600 MHz band to the Fixed Satellite Service (FSS) on a co-primary basis with the radiolocation operations and provides for an interference protection level of -167 dBW/m2/4 kHz.

The closest distance to the shoreline from the Woodbine earth station is approximately 65.9 km Southeast toward the Chesapeake Bay. The calculation of the power spectral density at this distance is given by: N0N 100 kHz 1.0 MHz 36.0 MHz 54 MHz 1. Clear Sky EIRP (dBW): 46.1 60.0 70.0 85.0 85.0 2. Carrier Bandwidth: CW Signal 100 kHz 1 MHz 36 MHz 54 MHz 3. PD at antenna Input: -14.0 -14.0 -14.0 -14.6 -16.4 (dBW/4 kHz) 4. Transmit Antenna Gain: 60.1 dBi 5. Antenna Gain Horizon: FCC Reference Pattern 6. Antenna Elevation Angle: 43.6° The proposed earth station will radiate interference toward the Chesapeake Bay according to its off-axis side-lobe performance. A conservative analysis, using FCC standard reference pattern, results in off-axis antenna gains of -10.0 dBi toward the Chesapeake Bay. The signal density at the shoreline, through free space is: N0N Carriers (CW Carrier) PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2] = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB) = -194.4 dBW/m2/4 kHz 100 kHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2] = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB) = -194.4 dBW/m2/4 kHz 1 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -14.0 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2] = -131.4 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB) = -194.4 dBW/m2/4 kHz

36 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -14.6 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2] = -131.9 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB) = -194.9 dBW/m2/4 kHz 54 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -16.4 dBw/4 kHz + (-10.0) dBi – 10*log[4Π*(65900m)2] = -133.8 dBW/m2/4 kHz + Additional Path Losses (~63.0 dB) = -196.8 dBW/m2/4 kHz Our calculations identified additional path losses of approximately 63.0 dB including absorption loss and earth diffraction loss for the actual path profiles from the earth station to the nearest shoreline. The worst case calculated PFD including additional path losses to the closest shoreline location is –194.4 dBW/m2/4 kHz for the CW, 100 kHz and 1 MHz carriers and -194.9 dBW/m2/4 kHz for the 36 MHz carriers and -196.8 dBW/m2/4 kHz for the 54 MHz. All carriers are a minimum of 27.4 dB below the –167 dBW/ m2/4 kHz interference criteria of R&O 96-377. Therefore, there should be no interference to the US Navy RADAR from the Woodbine earth station due to the distance and the terrain blockage between the site and the shore. 3. Potential Impact to NASA’s Data Relay Satellite System (TDRSS) The geographic location of the SES Americom earth station in Woodbine, Maryland is outside the 390 km radius coordination contour surrounding NASA’s White Sands, New Mexico ground station complex. Therefore, the TDRSS space-to-earth link will not be impacted by the SES Americom earth station in Woodbine, Maryland. The TDRSS space-to-space link in the 13.772 to 13.778 GHz band is assumed to be protected if an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 9 meter earth station antenna will have an EIRP less than 71 dBW/6 MHz for both the CW carrier, 100 kHz and 1 MHz carriers in this band. The total EIRP for the CW Carrier is 46.1 dBW and the equivalent EIRP per 6 MHz segment will remain at 46.1 dBW/6 MHz. The total EIRP for the 100 kHz, carriers is 60.0 dBW. The equivalent EIRP per 6 MHz segment will remain at 60.0 dBW/6 MHz. The total EIRP for the 1 MHz, carriers is 70.0 dBW. The equivalent EIRP per 6 MHz segment will remain at 70.0 dBW/6 MHz. Therefore, there should not be interference to the TDRSS space- to-space link for the CW carriers or the 100 kHz and 1 MHz carriers. For the 36 MHz and 54 MHz carriers, the total EIRP of 85.0 dBW (36 MHz), and 85.0 dBW (54 MHz) equate to an EIRP per 6 MHz of 79.0 dBW/6 MHz and 76.0 dBW/6 MHz, respectively. To avoid interference to the TDRSS space-to-space link the 36 MHz and 54 MHz carriers will not be used for the transmit spectrum of 13.772 to 13.778 GHz by this earth station.

4. Coordination Issue Result Summary and Conclusions The results of the analysis and calculations performed in this exhibit indicate that compatible operation between the earth station at the Woodbine facility and the US Navy and NASA systems space-to-earth link are possible for all of the proposed carriers. Operations in NASA systems space-to-space link (13772.0 to 13778.0 MHz) will also be permitted for all of the carriers with the exception of the 36 MHz and 54 MHz emissions.


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Document Modified: 2017-01-09 14:09:50
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