Attachment STA Narrative

This document pretains to SES-STA-20170821-00935 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017082100935_1264551

Before the FEDERAL COMMUNICATIONS COMMISSION Washington, D.C. 20554 In the Matter of ) ) SES AMERICOM, INC. ) File No. SES-STA-___________ ) Call Sign KB27 Request for Special Temporary Authority to ) Perform Testing with SES-11 at 142.5° W.L. ) REQUEST OF SES AMERICOM, INC. SES Americom, Inc. (“SES”) respectfully requests special temporary authority (“STA”) for its KB27 earth station to communicate with the SES-11 spacecraft at 142.5° W.L. in order to perform in-orbit testing (“IOT”) of the satellite. Authority is sought for a period of up to 30 days, commencing eleven days following launch of SES-11, which could occur as early as the end of September 2017. Specifically, SES requests authority for the earth station to communicate with the Gibraltar-licensed SES-11 C-band payload in order to: (1) test the transmission capability of the payload, and (2) perform Tracking, Telemetry and Command (“TT&C”) in the C-band while the satellite is at 142.5° W.L.1 SES-11 is a dual-licensed spacecraft that will operate at the nominal 105° W.L. orbital location. The Commission has issued a license for the satellite’s Ku-band payload, which 1 The Commission has granted a space station STA to permit SES-11, which also has a U.S.- licensed Ku-band payload, to be positioned at 142.5° W.L. during IOT. SES Americom, Inc., (Call Sign S2964), File No. SAT-STA-20170526-00080, granted July 7, 2017 (“SES-11 Space Station STA”).

will replace the Ku-band capacity of AMC-15, and has granted U.S. market access for the satellite’s Gibraltar-licensed C-band payload, which will replace the AMC-18 satellite.2 Following launch of SES-11, SES proposes to position the satellite at 142.5° W.L. for IOT. SES-11 will be located at 142.5° W.L. +/-0.1 degrees during IOT. The proposed stationkeeping volume will not overlap with any other satellite. SES seeks earth station STA to perform testing of the SES-11 C-band payload and associated TT&C. As discussed below, performing IOT at 142.5° W.L. rather than at 105° W.L. will permit testing to occur without disruption to existing customers at 105° W.L. and will not adversely affect the operation of any adjacent satellites. SES seeks STA to support tests in the following bands. 3700-4200 MHz Downlink 5925-6425 MHz Uplink Grant of STA Will Serve the Public Interest. Grant of SES’s request to test SES- 11 at 142.5° W.L. is in the public interest. By testing SES-11 at this location, SES will minimize the risk of interference to its other satellites operating at the nominal 105° W.L. orbital location. Testing will allow SES to ensure that the satellite’s C-band communications payload is fully operational at the time it arrives at its final orbital location, thereby avoiding any interruption in service that otherwise might be associated with spacecraft testing. No Harmful Interference to Other Spacecraft. Positioning and testing SES-11 at 142.5° W.L. will not cause harmful interference to the operations of any other spacecraft due to 2 See SES Americom, Inc., File No. SAT-LOA-20160512-00047 and SES Satellites (Gibraltar) Ltd, File No. SAT-PPL-20160512-0048 (together, the “SES-11 Applications”). These applications were combined under a single call sign, S2964, and granted on December 7, 2016. 2

orbital angular separation, frequency diversity and/or geographically diverse beam coverage. SES has coordinated the proposed TT&C and IOT operations with other C-band satellites positioned near 142.5° W.L. There are no other operators nearby with frequency overlap in the C- band. The nearest satellites operating in the C-band are operated by SES. In order to facilitate coordination with nearby C-band spacecraft, SES intends to use only Ku-band frequencies for TT&C while drifting the satellite from 142.5° W.L. to 104.95° W.L. No Harmful Interference to Terrestrial Services. Transmissions associated with IOT of SES-11 will not cause harmful interference to any co-primary terrestrial services in the conventional C-band. The C-band earth station to be used for in-orbit testing of the satellite has been coordinated to communicate with satellites in an arc that includes 142.5° W.L. The earth station will not exceed the maximum output EIRP density specified in its license, except in the case of certain tests involving high-powered continuous wave (“CW”) for a short duration of time lasting from 30 minutes to several hours. SES will conduct all IOT operations on a non- harmful interference basis and will cease transmissions promptly in the event SES receives a complaint of harmful interference regarding its operations. Waiver Request. SES seeks a limited waiver of Section 25.210(j) of the Commission’s rules in order to operate SES-11 at 142.5° W.L. with an east-west stationkeeping tolerance of +/- 0.1 degree during the IOT operations. Grant of this waiver 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 3

would not undermine the policy objective of the rule in question and would otherwise serve the public interest.3 Section 25.210(j) specifies that geostationary space stations “must be maintained within 0.05° of their assigned orbital location in the east/west direction, unless specifically authorized by the Commission to operate with a different longitudinal tolerance.”4 Here, SES is seeking authority to operate SES-11 with a relaxed stationkeeping tolerance of +/- 0.1 degree during the limited period of IOT operations. The Commission has already granted a similar waiver request when it authorized SES to operate the Ku-band payload of SES-11 at 142.5° W.L. with +/-0.1 degree stationkeeping.5 SES requests a waiver because the relaxed stationkeeping tolerance will minimize interruptions to the payload testing operations due to stationkeeping maneuvers, which would delay the satellite’s on-station start of operations. It will also conserve fuel for future satellite operations. Furthermore, the proposed operations will not result in any overlap with other satellites near 142.5° W.L. and therefore will not adversely affect the operations of other spacecraft. Protective Conditions. SES seeks authority for KB27 to communicate with SES- 11 in the C-band frequencies in order to position and test SES-11 at 142.5° W.L. with +/-0.1 degree stationkeeping tolerance. SES will coordinate its drift and test operations with all potentially affected operating satellite networks and will operate only the Ku-band TT&C payload of the SES-11 spacecraft during satellite drift. All testing will be conducted on an 3 PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted). 4 47 C.F.R. § 25.210(j). 5 SES-11 Space Station STA, condition 6, at 2. 4

unprotected, non-harmful interference basis, and SES operations will cease immediately upon notification of harmful interference.6 SES hereby certifies that no party to this application is subject to a denial of benefits pursuant to Section 5301 of the Anti-Drug Abuse Act of 1988, 21 U.S.C. § 862. For the foregoing reasons, SES respectfully requests special temporary authority to operate its KB27 earth station to test the C-band payload on SES-11 at 142.5° W.L. for a period of up to 30 days, commencing eleven days following the launch of SES-11 and to perform TT&C in the C-band while the satellite is operating at 142.5° W.L. Grant of the requested authority will permit testing of the spacecraft without affecting services to customers and will permit a seamless transition of services. As noted above, SES is preparing to launch SES-11 in September 2017 and requests action on this application to accommodate that schedule. Respectfully submitted, SES AMERICOM, INC. By: /s/ Petra A. Vorwig Of Counsel Petra A. Vorwig Karis A. Hastings Senior Legal & Regulatory Counsel SatCom Law LLC SES Americom, Inc. 1317 F Street, N.W., Suite 400 1129 20th Street, N.W., Suite 1000 Washington, D.C. 20004 Washington, D.C. 20036 Tel: (202) 599-0975 Tel: (202) 478-7143 Dated: August 21, 2017 6 The 24/7 point of contact for SES during IOT and drift is Dave Coyle, Manager, South Mountain Earth Station, (805) 386-2710, dave.coyle@ses.com. 5


Document Created: 2017-08-21 13:39:50
Document Modified: 2017-08-21 13:39:50
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