Attachment STA Narrative-VSAT

This document pretains to SES-STA-20171117-01260 for Special Temporal Authority on a Satellite Earth Station filing.

IBFS_SESSTA2017111701260_1304704

                                                                                    Exhibit A
                                                                                     Page 1

                 REQUEST FOR SPECIAL TEMPORARY AUTHORITY

              SES Americom, Inc. (“SES”) respectfully requests special temporary
authority (“STA”) for a period of 30 days beginning December 1, 2017, to permit SES to
operate VSAT-type terminals with specified SES satellites. The temporary VSAT
network operations will permit evaluation of the Ku-band spot beams of the SES-15
satellite (call sign S2951) at 129.15° W.L. prior to the scheduled commencement of
commercial operations with the satellite in January 2018. Specifically, SES requests
authority for thirteen 1.2 meter terminals positioned at a variety of locations in the
contiguous United States and Hawaii to communicate with SES-1 at 101° W.L., SES-3
at 103° W.L., and SES-15 at 129.15° W.L.
              SES Satellites (Gibraltar) Limited received market access for the Ku/Ka-
band SES-15 satellite to serve the United States from 129.15° W.L.1 SES-15 was
launched on May 18, 2017 and following the completion of in-orbit testing, is expected
to arrive at its assigned orbital location by December 22, 2017. After SES-15 arrives,
there will be only a brief period before the satellite is scheduled to begin commercial
operations during which testing of the Ku-band antennas can occur. In order to prepare
for that testing process, SES plans to conduct initial operation of the VSAT terminals
with the U.S.-licensed SES-1 and SES-3 satellites.
              A full description of the antennas and the proposed operations, including a
list of the locations at which the VSAT terminals will be positioned, is provided in
Attachment 1. The terminals to be used are 1.2 meter Skyware Global model antennas
                                                             2
that have previously been authorized by the Commission. The VSAT terminals will
transmit in the conventional Ku-band Earth-to-space frequencies, 14.0-14.5 GHz.
During the operation with SES-1 and SES-3, the terminals will receive in the
conventional Ku-band space-to-Earth frequencies, 11.7-12.2 GHz. When the terminals


1
 SES Satellites (Gibraltar) Limited, (Call Sign S2951), File No. SAT-MPL-20160718-
00063, granted Dec. 14, 2016; modifying File No. SAT-PPL-20160126-00007, granted
July 12, 2016 (“SES-15 Grant”).
2
 See, e.g., X2nSat, (Call Sign E140069), File No. SES-LIC-20140715-00602, granted
Sept. 15, 2014.


                                                                                  Exhibit A
                                                                                   Page 2

are operating with SES-15, they will also receive in the following extended Ku-band and
Appendix 30B band space-to-Earth frequencies: 10.7-10.95 GHz, 10.95-11.2 GHz,
11.2-11.45 GHz, and 11.45-11.7 GHz.
              Operation of the VSAT terminals will be controlled remotely by SES
gateway facilities that are authorized to communicate with the satellites being used, and
these operations will be within the scope of the gateway facilities’ existing
authorizations. During the initial operations of the VSAT terminals with SES-1 and SES-
3, the gateway earth stations used will be in Woodbine, MD (Call Signs E920698 &
E140059).
              During testing with SES-15, the gateway earth stations used will be in
Brewster, WA (Call Sign E160015); Woodbine, MD (Call Sign E160021); and Somis, CA
(Call Sign E160022). These gateways are authorized to communicate with the satellite
in Ka-band frequencies in support of the Ku-band spot beams on SES-15.
              The transmissions associated with the proposed tests will not cause
harmful interference to the operations of any other spacecraft or terrestrial operators.
The VSAT-type antennas will communicate with the U.S.-licensed SES-1 and SES-3
satellites and with SES-15, which has been authorized to serve the U.S. in Ku-band
frequencies. In addition, and in any event, SES will conduct all test operations on a
non-harmful interference basis, and will cease transmissions promptly in the event any
harmful interference is caused by such operations.
              SES seeks a waiver of footnote NG52 of the Table of Allocations in
Section 2.106 to permit the reception of U.S. domestic services from SES-15 in the
10.7-11.7 GHz frequencies on an unprotected, non-interference basis. 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
                     would not undermine the policy objective of the rule in


                                                                                  Exhibit A
                                                                                   Page 3

                      question and would otherwise serve the public
                      interest.3

               The Commission has granted a waiver for SES-15 to provide domestic
service in the 10.7-11.7 GHz frequencies.4 Footnote NG52 was intended to preserve
access to the 10.7-11.7 GHz spectrum for terrestrial fixed service (“FS”) stations by
limiting FSS use of the band to international operations only.5 SES-15 will meet the
power flux density limits on the ground to protect FS operations, and the number of
antennas that will be used to communicate in these bands will be limited, thereby
ensuring protection of FS services. Moreover, because SES seeks authority to receive
in this spectrum on an unprotected basis, FS use of the band will not be constrained.
Therefore, grant of the requested waiver will not undermine the purpose of the rule.
               Authorizing tests of the performance of SES-15 with these antennas is in
the public interest. Such testing is necessary to prepare for commencement of
commercial operations with the satellite to facilitate the transition of customer operations
to SES-15.
               For the foregoing reasons, SES respectfully requests special temporary
authority for VSAT-type antennas to communicate with SES-1, SES-3, and SES-15 in
order to evaluate the performance of the SES-15 spacecraft.




3
 PanAmSat Licensee Corp., 17 FCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes
omitted).
4
    SES-15 Grant, Attachment at 2, Condition 3.
5
 See 47 C.F.R § 2.106, Footnote NG52. This policy was previously codified in footnote
NG104.


                                                                             Exhibit A
                                                                              Page 4

                                       Attachment 1

Site Details

Contact Information:                          Address:
Ramiro Reinoso, Senior Manager                4 Research Way
Tel: 1 609 987 4169                           Princeton, NJ

Geographic Coordinates:                       Site Elevation:
Various-CONUS, HI & AK, see below             Various

Antenna Details

Antenna ID:                         1.2m
Manufacture/Model:                  Skyware Global
Antenna Size:                       1.2 meters
Antenna Gain Transmit:              43.3 dBi at 14.3 GHz
Antenna Gain Receive:               41.8 dBi at 12.0 GHz
Height Above Ground Level:          Various
Height Above Sea Level:             Various
Total Input Power at the Flange:    4 watts
Total EIRP for the test Carriers:   49.3 dBW

Operational Details
Frequency     Transmit/       Polarization    Emission      Max EIRP      Max EIRP
(GHz)         Receive                         Designator    per Carrier   Density per
                                                            (dBW)         Carrier
                                                                          (dBw/4kHz)
10.7-10.95      R             H and V         N0N           0.0           0.0
10.7-10.95      R             H and V         150MG7W       0.0           0.0
10.95-11.2      R             H and V         N0N           0.0           0.0
10.95-11.2      R             H and V         150MG7W       0.0           0.0
11.2-11.45      R             H and V         N0N           0.0           0.0
11.2-11.45      R             H and V         150MG7W       0.0           0.0
11.45-11.7      R             H and V         N0N           0.0           0.0
11.45-11.7      R             H and V         150MG7W       0.0           0.0
11.7-12.2       R             H and V         N0N           0.0           0.0
11.7-12.2       R             H and V         150MG7W       0.0           0.0
14.0-14.5       T             H and V         N0N           49.3          49.3
14.0-14.5       T             H and V         400KG7W       49.3          29.3
14.0-14.5       T             H and V         1M50G7W       49.3          23.56
14.0-14.5       T             H and V         3M00G7W       49.3          20.55
14.0-14.5       T             H and V         6M00G7W       49.3          17.55


                                                                      Exhibit A
                                                                       Page 5

VSAT network/ Site and Hub locations:
                                           Hub for Dry Run     Hub for SES-15
                       Lat.     Long
        Site                            with SES-1 and SES-3    Tests (Ka/Ku)
                    (Deg. N.) (Deg. W.)
                                         (Ku/Ku)(Hub/VSAT)       (Hub/VSAT)
                                            Woodbine, MD       Woodbine, MD
    Montrose, MI      43.13     83.81
                                        (E920698 & E140059)       (E160021)
                                            Woodbine, MD       Woodbine, MD
      Ulm, MT         47.41    111.48
                                        (E920698 & E140059)       (E160021)
                                            Woodbine, MD       Woodbine, MD
   Wilmington, NC     34.23     78.02
                                        (E920698 & E140059)       (E160021)
                                            Woodbine, MD          Somis, CA
Colorado Springs, CO 38.89     104.75
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD        Brewster, WA
  Port St Lucie, FL   28.10     80.70
                                        (E920698 & E140059)       (E160015)
                                            Woodbine, MD        Brewster, WA
 Panama Beach, FL     30.16     85.66
                                        (E920698 & E140059)       (E160015)
                                            Woodbine, MD          Somis, CA
 Coon Rapids, MN      45.18     93.28
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD        Brewster, WA
   Windemere, TX      30.46     97.65
                                        (E920698 & E140059)       (E160015)
                                            Woodbine, MD          Somis, CA
    Phoenix, AZ       33.50    112.03
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD          Somis, CA
     Somis, CA        34.32    118.99
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD       Woodbine, MD
   Woodbine, MD       39.37     77.08
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD          Somis, CA
  Sunset Beach, HI    21.67    158.03
                                        (E920698 & E140059)       (E160022)
                                            Woodbine, MD        Brewster, WA
    Brewster, WA      48.09    119.78
                                        (E920698 & E140059)       (E160015)



Document Created: 2017-11-17 09:27:33
Document Modified: 2017-11-17 09:27:33

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