Attachment STA Narrative SES-STA-20170110-00025

Attachment STA Narrative

This document pretains to SES-STA-20170110-00025 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017011000025_1163896

Before the
FEDERAL COMMUNICATIONS COMMISSION
Washington, D.C. 20554

In the Matter of Application by )
)
SES AMERICOM, INC. ) SES-STA-________-_____
) Call Signs E110104 & _____
For Special Temporary Authority to Provide )
TT&C for SES-10 during IOT at 68.5° W.L. )
and During Drift to 66.9º W.L. )

REQUEST FOR SPECIAL TEMPORARY AUTHORITY

By this application, SES Americom, Inc. (“SES Americom” or “SES”)

respectfully requests earth station special temporary authority (“STA”) for a period of 30 days,

beginning 11 days following launch of SES-10, to permit SES to provide Tracking, Telemetry

and Command (“TT&C”) services to support in-orbit testing (“IOT”) of the SES-10 satellite

using two antennas – one in Manassas, Virginia (E110104) and a new antenna in Somis,

California. The satellite is currently scheduled to launch in mid-February 2017 and will
1
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 stations with SES-10 at 66.9° W.L.

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.

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

requested that SES Americom assist with testing the satellite and provide TT&C during the tests

at 68.5°W.L. and during the drift to the nominal 67° W.L. orbital location. The earth stations

will operate as described in Attachments 1 and 2.

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 provide TT&C services while SES-10 is tested at

68.5° W.L. and drifts to its final orbital location will facilitate the safe operation of SES-10.

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. Furthermore, TT&C

transmissions during drift of SES-10 will be on a non-harmful interference basis. The drift of the
3
spacecraft will be coordinated with other satellite operators consistent with industry practice.

2
Id. SES Americom incorporates by reference the technical information submitted in the SES-
10 Petition.
3
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.

2

4
Furthermore, as demonstrated in the analysis provided in Attachments 3 and 4,

operations in 13.75-14.0 GHz from either location will not cause harmful interference to U.S.

Navy radar stations or NASA TDRSS stations.

For the foregoing reasons, SES Americom respectfully requests special temporary

authority for its earth stations to communicate with SES-10 to provide TT&C for a period of up

to 30 days to test and drift of the satellite, 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 10, 2017

4
For its antenna in Manassas, Virginia (call sign E110104), SES is submitting the analysis
previously conducted in support of operations with the NSS 7 spacecraft operating at 20° W.L.
See File No. SES-LIC-20110715-00830 (filed July 15, 2011). This STA application requests
authority to operate with SES-10 at 68.5° W.L., which will result in operations at a higher
elevation angle reducing the potential for interference into terrestrial systems; therefore, the
attached analysis remains valid.

3

Attachment 1

Call Sign: E110104
Site Details
Contact Information: Address:
Gary Cruickshank 8000 Gainsford Ct.
703-367-7311 Bristow, VA
20136
Geographic Coordinates:
Latitude: 38° 47’ 0.6" N Longitude: 77° 34’ 25.4" W

Site Elevation:
86.0 meters

Antenna Details
Antenna ID: NMW-13
Manufacture/Model: Viasat 8016A
Antenna Size: 11.3 meters
Antenna Gain Transmit: 62.8 dBi at 14 GHz
Antenna Gain Receive: 61.7 dBi at 12 GHz
Height Above Ground Level: 13.27 meters
Height Above Sea Level: 99.27 meters
Total Input Power at the Flange: 1859.0 watts
Total EIRP for all Carriers: 95.49 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 500KG7W 69.8 48.8
and Vertical
13750-14000 T Horizontal 1M0G7W 71.0 47
and Vertical
13750-14000 T Horizontal 54M0G7W 80.6 39.3
and Vertical
14000-14500 T Horizontal 100KG7W 62.78 48.8
and Vertical
13750-14000 T Horizontal 665KG7W 71.0 48.8
and Vertical
13750-14000 T Horizontal 54M0G7W 84.99 43.69
and Vertical
14000-14500 T Horizontal 100KG7W 62.78 48.8
and Vertical
14000-14500 T Horizontal 54M0G7W 89.79 48.49
and Vertical

14000-14500 T Horizontal N0N 48.8 48.8
and Vertical
10950-11200 R Horizontal 100KG7W
and Vertical
10950-11200 R Horizontal 54KG7W
and Vertical
11450-11700 R Horizontal 100KG7W
and Vertical
11450-11700 R Horizontal 54KG7W
and Vertical
11700-12200 R Horizontal 100KG7W
and Vertical
11700-12200 R Horizontal 54M0G7W
and Vertical

Attachment 2

Call Sign: New earth station

Site Details

Contact Information: Address:
David Coyle 5990 Solano Verde Dr.
805-386-2712 Somis, California
93066
Geographic Coordinates:
Latitude: 34° 19’ 31.2" N Longitude: 118° 59’ 43.6"W

Site Elevation:
308.0 meters

Antenna Details
Antenna ID: SMK-5
Manufacture/Model: GD Satcom/Vertex
Antenna Size: 9m
Antenna Gain Transmit: 60.1 dBi at 14.125 GHz
Antenna Gain Receive: 58.5 dBi at 11.725 GHz
Height Above Ground Level: 9.7 meters
Height Above Sea Level: 317.7 meters
Total Input Power at the Flange: 750 watts
Total EIRP for all Carriers: 88.85 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 2M83G7W 68 39.5
and Vertical
13750-14000 T Horizontal 54M0G7W 80.8 39.5
and Vertical
14000-14500 T Horizontal 100KG7W 60.08 46.1
and Vertical
14000-14500 T Horizontal 54M0G7W 87.1 45.8
and Vertical
14000-14500 T Horizontal N0N 46.1 46.1
and Vertical
10950-11200 R Horizontal 100KG7W
and Vertical
10950-11200 R Horizontal 54KG7W

and Vertical
11450-11700 R Horizontal 100KG7W
and Vertical
11450-11700 R Horizontal 54KG7W
and Vertical
11700-12200 R Horizontal 100KG7W
and Vertical
11700-12200 R Horizontal 54M0G7W
and Vertical

Attachment 3
Compliance with FCC Report & Order (FCC 96-377) for the 13.75-14.0 GHz Band
Analysis and Calculations for E110104

Exhibit For
SES Americom, LLC
Bristow, Virginia
ViaSat 11.3 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 Bristow, Virginia 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): 38° 47’ 0.6” N, 77° 34’ 25.4” W

• Satellite Location for Earth Station: NSS 7 (20.0° W)

• Frequency Band: 13.75-14.0 GHz for uplink

• Polarizations: Linear

• Emissions: 500KG7W, 1M00G7W, 36M0G7W, and
77M0G7W

• Modulation: Digital

• Maximum Aggregate Uplink EIRP: 69.8 dBW for the 500 kHz Carriers
70.99 dBW for the 1 MHz Carriers
78.77 dBW for the 36 MHz Carriers
82.07 dBW for the 77 MHz Carriers

• Transmit Antenna Characteristics
Antenna Size: 11.3 meters in Diameter
Antenna Type/Model: ViaSat
Gain: 62.8 dBi

• RF power into Antenna Flange: 500 kHz
7.0 dBW
or -14.0 dBW/4 kHz (Maximum)

• RF power into Antenna Flange 1.0 MHz
(Continued) 8.2 dBW or 0.0 dBW/ MHz
or -15.8 dBW/4 kHz (Maximum)

36 MHz
16.0 dBW or 15.5 dBW/ MHz
or -23.5 dBW/4 kHz (Maximum

77 MHz
19.3 dBW or 18.8 dBW/ MHz
or -23.5 dBW/4 kHz (Maximum

• Minimum Elevation Angle:
Bristow. 16.4° @ 111.7° Az. (NSS 7) at 20.0° 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.

$77 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -23.5 dBw/4 kHz + 1.3 dBi – 10*log[4Π*(97500m)2] = -133.0 dBW/m2/4 kHz + Additional Path Losses (~64.3 dB) = -197.3 dBW/m2/4 kHz Our calculations show additional path loss of approximately 64.3 dB including absorption loss and earth diffraction loss for the actual path profiles from the proposed earth station to the nearest shoreline. The worst case calculated PFD including additional path losses to the closest shoreline location is –187.8 dBW/m2/4 kHz. This is 20.8 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 Bristow 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 Bristow, Virginia 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 Bristow, Virginia. The TDRSS space-to-space link in the 13.770 to 13.780 GHz band is assumed to be protected if an earth station produces an EIRP less than 71 dBW/6 MHz in this band. The 11.3 meter earth station antenna will have an EIRP less than 71 dBW/6 MHz for the 500 kHz carriers in this band. In addition, the total EIRP for the 1 MHz, 36 MHz, and 77 MHz carriers is 70.99 dBW, 78.99 dBW and 82.07 dBW, respectively. The equivalent EIRP per 6 MHz segment will remain at 69.8 dBW/6 MHz and 70.99 dBW/6 MHz for the 500 kHz and 1 MHz carriers. For the 36 MHz and 77 MHz carriers the calculated dBW/6 MHz are 70.99 dBW/6 MHz for both sets of carriers. Therefore, there should not be interference to the TDRSS space-to-space link for the 500 kHz or 1 MHz, 36 MHz, or 77 MHz carriers. At the above power levels, transmit operations from 13750 to 14000 MHz will be permitted.$

Further, SES Americom also plans to operate the 1.0 MHz, 36 MHz, and 77 MHz carriers, with
total EIRPs of 72.8 dBW (1 MHz), 88.3 dBW (36 MHz) and 89.8 dBW (77 MHz). These total
EIRPs will equate to an EIRP per 6 MHz level of 72.8 dBW/6 MHz, 80.5 dBW/6 MHz, and 78.7
dBW/6 MHz, respectively. Since these levels are above the 71.0 dBW/6 MHz threshold, and
there will be interference to the TDRSS space-to-space link, SES Americom will avoid
operations between 13770 - 13780 MHz and limit their operations in this spectrum from 13780
to 14000 MHz.

For these higher power levels, transmit operations will not be permitted between 13770 and
13780 MHz. Operations at these levels for the 1 MHz, 36 MHz, and 77 MHz carriers will be
limited to that portion of the spectrum from 13780 to 14000 MHz.

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 Bristow facility and the US Navy and NASA systems
space-to-earth link are possible for the 500 kHz, 1 MHz, 36 MHz, and 77 MHz carriers.
Operations in NASA systems space-to-space link (13772.0 to 13778.0 MHz) will also be
permitted, at the lower EIRP levels noted on Page 1 of this report (Table 1).

When SES Americom utilizes higher EIRP levels noted above for the 1 MHz, 36 MHz, and 77
MHz carriers, the results of the analysis and calculations performed in this exhibit indicate that
compatible operation between the earth station at the Bristow facility and the US Navy and
NASA systems space-to-earth link are possible. However, operations in NASA systems space-
to-space link (13770.0 to 13780.0 MHz) will not be permitted. In this instance, operations in the
spectrum will be restricted to frequencies 13780 to 14000 MHz for the 1 MHz, 36 MHz, and 77
MHz carriers.

Attachment 4
Compliance with FCC Report & Order (FCC 96-377) for the 13.75-14.0 GHz Band
Analysis and Calculations for 9 Meter Antenna at Somis, CA

Exhibit For
SES Americom, LLC
South Mountain (Somis), California
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 South Mountain (Somis), California 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): 34° 19’ 31.77” N, 118° 59’ 43.8” 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: No Modulation and Digital

• Maximum Aggregate Uplink EIRP: 39.5 dBW for the N0N Carrier
53.5 dBW for the 100 kHz Carriers
63.5 dBW for the 1 MHz Carriers
79.0 dBW for the 36 MHz Carriers
80.8 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)
-20.6 dBW
or -20.6 dBW/4 kHz (Maximum)

• RF power into Antenna Flange 100 kHz
(Continued) -6.6 dBW
or -20.6 dBW/4 kHz

1 MHz
3.4 dBW
or -20.6 dBW/4 kHz (Maximum)

36 MHz
18.9 dBW
or –20.6 dBW/4 kHz (Maximum)

54 MHz
20.7 dBW
or –20.6 dBW/4 kHz (Maximum)

• Minimum Elevation Angle:
Somis, CA 23.7° @ 114.9° 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 – 14.0 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.

$36 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -20.6 dBw/4 kHz + (-4.8) dBi – 10*log[4Π*(28770m)2] = -125.6 dBW/m2/4 kHz + Additional Path Losses (~41.8 dB) = -167.4 dBW/m2/4 kHz 54 MHz Carriers PFD = Antenna Feed Power density (dBW/4 kHz) + Antenna Off-Axis Gain (dBi) – Spread Loss (dBw-m2). = -20.6 dBw/4 kHz + (-4.8) dBi – 10*log[4Π*(28770m)2] = -125.6 dBW/m2/4 kHz + Additional Path Losses (~41.8 dB) = -167.4 dBW/m2/4 kHz Our calculations identified additional path losses of approximately 41.8 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 –167.4 dBW/m2/4 kHz for the CW Carriers, 100 kHz, 1 MHz, 36 MHz and 54 MHz carriers. This is 0.4 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 South Mountain 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 South Mountain (Somis), California 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 South Mountain, California. 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 39.5 dBW and the equivalent EIRP per 6 MHz segment will remain at 39.5 dBW/6 MHz. The total EIRP for the 100 kHz, carriers is 53.5 dBW. The equivalent EIRP per 6 MHz segment will remain at 53.5 dBW/6 MHz. The total EIRP for the 1 MHz, carriers is 63.5 dBW. The equivalent EIRP per 6 MHz segment will remain at 63.5 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 79.0 dBW (36 MHz), and 80.8 dBW (54 MHz)$

equate to an EIRP per 6 MHz of 73.0 dBW/6 MHz and 74.8 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 South Mountain (Somis) 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.

Document Created: 2017-01-10 13:48:24
Document Modified: 2017-01-10 13:48:24