Attachment SES-STA-20190325-004

SES-STA-20190325-004

DECISION submitted by FCC

Grant

0000-00-00

This document pretains to SES-STA-20190325-00400 for Special Temporal Authority on a Satellite Earth Station filing.


                                         KA288      SES-STA-20190325-00400   1B20 19000835
                                         SES Americom, Inc.




                                                                                                                   Approved by 0MB
                                                                                                                          3060—0678

                               APPLICATION FOR EARTH STATION SPECIAL TEMPORARY AUTHORITY



APPLICANT INfORMATIONEnter a description of this application to identify it on the main menu:
I $0—Day STA for KA2$$ to provide TT&C for NSS—6 Move to and Operations at 86.8 W.L.
    1. Applicant

              Name:        SES Americorn, Inc.               Phone Number:                   202—478—7143
              DBA Name:                                      Fax Number:                     202—478—7101
              Street:      1129 20th Street NW               f—Mail:                         petra.vorwigses.com
                           Suite 1000
              City:        Washington                        State:                          DC
              Country:     USA                               Zipcode:                        20036      —




              Attention:   Petra A. Vorwig




                                                                                                        —
                                                                               3j    H
                                                     /?O d
                                                                File #       57DtS% ‘‘O

                                                                 Call SinK/1 2S Grant Date______
                                                                 (or other identifier)
                                                                                Teim Datc
                                                                 from:_______ t To:________

                                                                 Approved:

I


    2. Contact

                 Name:         Karis Hastings                         Phone Number:                         202—599—0975
                 Company:      SatCom Law LLC                         Fax Number:
                 Street:       1317 F Street, N.W.                    E—Mail:                               karis@satcomlaw.com
                               Suite 400
                 City:         Washington                             State:                                DC
                 Country:      USA                                    Zipcode:                              20004       —




                 Attention:                                           Relationship:                         Legal Counsel


    (If your application is related to an application filed with the Commission, enter either the file number or the lB Submission ID of the related
    application. Please enter only one.)
     3. Reference File Number or Submission ID
        4a. Is a fee submitted with this application?
         IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
    •
         Governmental Entity            Noncommercial educational licensee
    0
    o Other(please explain):
    4b. Fee Classification    CGX   —   fixed Satellite Transmit/Receive Earth Station
    5. Type Request


         Use Prior to Grant                                  Change Station Location                          Other
    0                                                    0

    6. Requested Use Prior Date


    7. CitySomis                                                                 8. Latitude
                                                                                 (dd mm ss.s h)   34   19    31.0   N



2


    9. State   CA                                                               10. Longitude
                                                                                (dd mm ss.s h)    118   59    44.4   W
    11. Please supply any need attachments.
    Attachment 1: STA Narrative                       Attachment 2:                                      Attachment 3:


    12. Description.   (If the complete description does not appear in this box, please go to the end of the form to view it in its entirety.)
         SES Americom,        Inc.
                             requests special temporary authority for a period of up to 180 days to
         permit earth station KA288 to communicate with the Dutch—licensed NSS—6 spacecraft in
         order to provide telemetry, tracking and control during and after drift of the satellite
         to 86.8 W.L. SES is not seeking U.S. market access for the satellite.   Please see attached




    13. By checking Yes, the undersigned certifies that neither applicant nor any other patty to the application is               Yes            No
    subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act
    of 198$, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance.
    See 47 CfR 1.2002(b) for the meaning of "party to the application" for these purposes.


    14. Name of Person Signing                                                  15. Title of Person Signing
       Petra A. Vorwig                                                            Senior Legal & Regulatory Counsel
               WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 1$, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                       (U.S. Code, Title 47, Section 312(a)(l)), AND/OR FORFEITURE (U.S. Code, Title 47. Section 503).




3


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4


12. Description

SES Americom, Inc. requests special temporary authority for a period of up to 180 days to permit
earth station KA288 to communicate with the Dutch—licensed NSS—6 spacecraft in order to provide
telemetry, tracking and control during and after drift of the satellite to 86.8 W.L.   SES is not
seeking U.S. market access for the satellite.  Please see attached narrative.




5


Applicant: SES Americom, Inc.
Call Sign: KA288
File No.: SES-STA-20190325-00400
Special Temporary Authority (“STA”)

SES Americom, Inc. (“SES Americom”) is granted STA for 180 days to operate on frequencies
14496.0 MHz and 14499.0 MHz (V,H polarization) (Earth-to-space), 11198.0 MHz and 11199.5
MHz (H,V polarization) (space-to-Earth) at fixed satellite earth station at geographic coordinates
340
    19’ 31”N, 118° 59’ 44.4”W in Somis, CA to provide telemetry, tracking, and command
(“TT&C”) services for the Dutch-licensed NSS-6 satellite to drift from 95°E to 86.8°W.
Operations will be under the following conditions:

    1. Emission designator YMOOF9D, maximum eirp of 73.0 dBW, maximum eirp density of
       49.1 dBW/4kHz.

   2. All operations shall be on an unprotected and non-harmful interference basis, KA288,
      shall not cause harmful interference to, and shall not claim protection from, interference
      caused to it by any other lawfully operating station and it shall cease transmission(s)
      immediately upon notice of such interference and must inform the Commission, in
      writing, immediately of such an event.

   3. All operators of satellites in that path will be provided with an emergency phone number
      where the licensee can be reached when harmful interference occurs.

   4. Currently the 24x7 contact information for the NSS-6 mission is SES Payload
      management Operations Centre (PMOC), Woodbine, MD, phone +1 410 970 7580, e
      mail PMOC@ses.com

   5. Grant of this STA is without prejudice to any determination that the Commission may
      make regarding pending or future SES Americom, Inc. applications.

   6. This authorization is not for a U.S. Market Access operation.

   7. Any action taken or expense incurred as a result of operations pursuant to this STA is
      solely at SES Americom, Inc’s risk.

This action is issued pursuant to Section 0.261 of the Commission’s rules on delegated authority,
47 C.F.R. §0.261, and is effective upon release.
                                                                                  •   F,




                                              dlls2n1cAGramDateO/od2D(?




                            GRANTED              from:   O
                          International Bureau
                                       •.•_
                                                 Approved:


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


In the Matter of Application by                      )
                                                     )
SES AMERICOM, iNC.                                   )       Call Signs KA288 and E050287
                                                     )
For Special Temporary Authority to                   )
Communicate with NSS-6 to Perform                    )
TT&C During and After Relocation to 86.8° W.L.       )
                  REQUEST FOR SPECIAL TEMPORARY AUTHORITY

               By this application, SF5 Americom, Inc. (“SES Americom” or “SES”)

respectfully requests earth station special temporary authority (“STA”) for a period of 180 days

to permit SES to use its KA288 and E050287 earth stations to communicate with the NSS-6

spacecraft using extended and conventional Ku-band frequencies to provide Tracking, Telemetry

and Command (“TT&C”): (1) during the planned relocation of the spacecraft from its current

position at 95° E.L. to 86.8° W.L.; and (2) to maintain the satellite at 86.8° Wi. +1- 0.100

east/west station keeping.

               SES Americom’s affiliate, New Skies Satellites B.V. (“NSS By”), holds an

authorization from Radiocommunications Agency Netherlands’ for the NSS-6 Ku-band

spacecraft. NSS BV has requested that SES Americom assist with providing TT&C to support

the planned relocation of NSS-6 to 86.8° W.L. NSS-6 will operate at the 86.8° W.L. orbital

location.

               SES is not requesting U.S. market access or any other authorization from the

Commission in relation to the non-U.S.-licensed NSS-6 spacecraft operations at 86.8° W.L., and




 Agentschap Telecom.


therefore is not providing full technical information about the NSS-6 satellite as part of this

application.2 Details regarding the NSS-6 TT&C operations, including the certifications required

under Section 25.140 of the Commission’s rules, are provided in the attachments to this request.

A basic technical description of the satellite’s proposed operations and an updated orbital debris

mitigation statement for NSS-6 are provided in Attachments 2 and 3 for the Commission’s

information.3 As discussed below, communications with NSS-6 will not adversely affect the

operation of other satellites.

                Grant of this request is in the public interest as the requested TT&C authority will

facilitate the safe operation of NSS-6 as it drifts to and is located at 86.8° W.L.

                No Harmful Interference to Other Spacecraft. TT&C transmissions during

drift of NSS-6 will be on a non-harmful interference basis. The drift of the spacecraft will be

coordinated with other satellite operators consistent with industry practice.4

                The only satellites capable of overlapping Ku-band operations within two degrees

of 86.8° W.L. are AMC-2, AMC-16 and SES-2, all of which are operated by SES Americom.

SES will coordinate the operation of these satellites with NSS-6 to ensure there is no

interference.



2
    See Waiver Requests, infra.
      The information for NSS-6 specified under Section 25.1 14(d)(l4) of the Commission’s rules
is already on file with the Commission, and SES incorporates that information by reference
herein. See PanasonicAvionics Corp., Call Sign E100089, File No. SES-MfS-20150609-00349,
Technical Appendix, Annex A-6, Part D; Letters from Carlos M. Nalda, Counsel to Panasonic
Avionics Corp., to Marlene H. Dortch, Secretary, Federal Communications Commission, File
No. SES-MFS-20150609-00349 et at., dated Jan. 7,2016 and Feb. 10, 2016.

   The 24/7 point of contact for the proposed NSS-6 operations is the SES Payload
Management Operations Centre (PMOC) in Woodbine, MD, 1 410 970 7580; e-mail:
PMOC(ses.com.

                                                  2


               Waiver Requests. SES requests limited waivers of the Commission’s

requirements in connection with the instant 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

               Sections 25.137 and 25.114. SES requests a waiver of Section 25.137 and the

other Commission rules cross-referenced therein. SES seeks authority in connection with

providing TT&C for NSS-6, a foreign-licensed spacecraft. Section 25.137 requires that

applicants proposing to use U.S.-licensed earth stations to communicate with foreign-licensed

spacecraft demonstrate that the Commission’s policies for U.S. market access are satisfied.

Section 25.137 also incorporates by reference other requirements for Commission-licensed space

stations, including the obligation to file detailed technical information as specified in

Section 25.114.

               Waiving Section 25.137 is consistent with the purpose of the rule, which was

intended to address sithations in which a non-U.S.-licensed satellite is to be used to serve the

United States. Here, the KA288 and E050287 earth stations will be used solely for TT&C, not

for commercial operations. Thus, SES is not seeking authority to communicate with NSS-6 for

purposes of providing U.S. service from 86.8° W.L. within the meaning of Section 25.137.




    PanAmSat Licensee Corp., 17 fCC Rcd 10483, 10492 (Sat. Div. 2002) (footnotes omitted).

                                                  3


                 To the extent the Commission disagrees, SES requests a waiver of the market

access and other requirements imposed in Section 25.137. Grant of a waiver will not undermine

the objectives of these requirements. The market access test described in the rule is intended to

ensure that U.S.-licensed systems have “effective competitive opportunities.”6 Because SES

Americom is not seeking authority to provide commercial services in the United States, the

requested modification does not raise any concems about competitive equality.7

                 Strict adherence with Section 25.114’s requirements for detailed technical

information is also unnecessary and would be unduly burdensome. SES Americom is proposing

to use the KA288 and E050287 earth stations only for the limited purpose of performing TT&C

for the satellite as it drifts to and is temporarily located at 86.8° W.L., and the relevant technical

characteristics of those transmissions are provided below. The transmissions to the spacecraft

will be conducted on a non-harmful interference basis. In these circumstances, no valid purpose

would be served by requiring a complete description of the NSS-6 spacecraft.

                 SES Americom’s request is consistent with Commission precedent, and the

Commission granted a similar request for both antennas to support relocation of ASTRA 3A.8 In

similar cases in which limited communications by U.S. earth stations with a foreign-licensed

satellite were proposed, the Commission has granted operational authority without requiring a




6
        C.F.R.   § 25.137(a).
    In any event, the NSS-6 spacecraft at 86.8° W.L. will be operating under the authority of
The Netherlands, a WTO member country, and therefore is exempt from the requirement to
make a showing of effective competitive opportunities. 47 C.F.R. § 25.137(a)(2).
8
     SES Americom, Inc., (Call Sign E050287) File No. SES-STA-20161110-00884, granted
Nov. 30, 2016; SES Americom, Inc., (Call Sign KA288) file No. SES-STA-20160527-00465,
granted June 14, 2016.

                                                   4


market access showing under Section 25.137 or full technical data as required by

Section 25.1 l4.

                 Section 2.106 footnote NG52. To the extent that reception of telemetry at

11198 MHz and 11199.5 MHz constitutes a domestic (i.e., non-international) service, SES

Americom respectfully requests a limited waiver of the international-service-only restriction.’0

Such a waiver is warranted in the circumstances for the limited purpose of performing TT&C.

As the Commission has recognized, TT&C operations generally require uplink and downlink

capability from the same earth station. For this reason, the Commission has previously granted

waivers of the international service restriction to enable TT&C to be performed in the U.S. using

the extended Ku-band frequencies.11

                 Grant of the requested waiver would not undermine the purpose of the restriction,

which is to ensure that earth station deployments in the extended Ku-band do not negatively

impact the deployment of fixed service (“FS”) in the same band or cause interference to such

operations. The telemetry downlink signals from NSS-6 in the extended Ku-band are narrow in

bandwidth and will comply with the power flux density limits in the Commission’s rules and,




     See, e.g., Hawaii Pacific Teleport, L.P., file No. SES-STA-20131030-00914 (Call Sign
E030115), granted Nov. 18, 2013 (authorizing earth station to provide TT&C services to ASTRA
3A operating at 176.85° W.L).; PanAmSat Licensee Corp., file Nos. SES-STA-20090922-0121 1
(Call Sign E4132) & SES-STA-20090922-01212 (Call Sign E040125), both grant-stamped
Oct. 16, 2009 (authorizing earth stations to communicate with foreign-licensed NSS-12
spacecraft for purposes of providing launch and early operations services).
10
     47 U.S.C.   §   2.106 Footnote NG52.
     See, e.g., EchoStar KuX Corporation, 20 FCC Rcd 919 (Int’l Bur. 2004) (“EchoStar 83W
Order”); EchoStar Satellite LLC, 20 FCC Rcd 930 (Int’l Bur. 2004) (“EchoStarlO9 W Order”);
EchoStar KuX Corporation, 20 FCC Red 942 (2004) (“EchoStar 121 W Order”). These
decisions granted waivers of the international only restriction in Footnote NG 104, which has
been replaced by Footnote NG52.

                                                 5


thus, will not interfere with fS station operations. Moreover, only two U.S. earth stations will be

used to perform TT&C in the extended Ku-band.’2 As a result, there will be no significant

restrictions placed on the deployment of fS in this band.

                Section 25.210(V). The NSS-6 satellite is authorized by Radiocommunications

Agency Netherlands to operate at 86.8° Wi. within a +1- 0.100 east/west station keeping box.

To the extent necessary, SES respectfully requests a waiver of Section 25.210(j) of the

Commission’s rules, which requires geostationary space stations to be operated within a +1-

0.050   east/west station keeping box. The Commission has previously waived this rule based on a

finding that allowing an increased station keeping volume would “not adversely affect the

operations of other spacecraft and would conserve fuel for future operations.”13

                The facts here fit squarely within this precedent. Allowing NSS-6 to be

maintained within an increased station keeping volume will not harm other operators. NSS-6’s

station keeping volume will not overlap with that of any other satellites. The closest satellite

operating near the 86.8° W.L. orbital location is Tupac Katari 1 located at 87.2° W.L., which is

0.3 degrees away from the outside of the proposed NSS-6 orbital box. In addition, allowing

NSS-6 to be flown at 86.8° W.L. in an expanded east-west station keeping volume of +1-0.1

degrees will result in fuel savings for the spacecraft. This will prolong the time during which

NSS-6 will be available to provide service. Under these circumstances, grant of any necessary

waiver of Section 25.210(j) will serve the public interest.




12
    See EchoStar 83W Order, at ¶ 16 (“The Commission has waived this [international only]
requirement where the number of potential earth stations in a particular service is inherently
small.”); EchoStar 109W Order, at ¶ 16 (same); EchoStar 121 W Order, at ¶ 17 (same).
‘
    See, e.g., SESAmericom, Inc., File Nos. SAT-MOD-20080124-00030 & SAT-AMD
20080311-00070, grant-stamped May 19, 2008, Attachment at ¶ 1.

                                                  6


               SES hereby certifies that no party to this application is subject to a denial of

federal 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 communicate with NSS-6 for a period of up to 180 days to provide TT&C during relocation of

the satellite and once it is on station, as described herein. Grant of the requested authority will

promote safe operation of the satellite during and after its relocation.

                                               Respectfully submitted,

                                               SES AMERICOM, iNC.

                                               By: /s/Fetra 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 NW, Suite 1000
Washington, D.C. 20004                         Washington, DC 20036
Tel: (202) 599-0975                            Tel: (202) 478-7143

Dated: March 25, 2019




                                                  7


                         Attachment 1: TT&C Emission Characteristics

1.               Earth Station Transmission Characteristics

KA288 andE050287
Emission Designator: 1MOOF9D
Max EIRP: 73.00 dBW
Max EIRP Density: 49.10 dBW/4kHz

2.               TT&C Frequencies1


     Telecommand     14496.0 MHz     Vertical polarization via global horn; horizontal
                                     polarization via omni in case of emergency
                     14499.0 MHz     Vertical polarization via global horn; horizontal
                                     polarization via omni in case of emergency
     Telemetry       11198.0 MHz     Horizontal polarization via global horn; vertical
                                     polarization via omm in case of emergency
                     11199.5 MHz     Horizontal polarization via global horn; vertical
                                     polarization via omni in case of emergency




1
        In compliance with Section 25.202(g)(l) of the Commission’s rules, the proposed TT&C
operations will cause no greater interference and require no greater protection from harmful
interference than communications traffic in these bands.

                                                 1


                              Attachment 2: NSS-6 at 86.8° W.L.


1.             Orbital Location

86.8° W.L. +1- 0.1° east-west station keeping and +/-0.1° north-south station keeping

2.             Section 25.140 Certifications

Section 25.140(a)(3)(ii). SES Americom certifies that the downlink EIRP density for its
operations in the conventional and extended Ku-bands will not exceed 17 dBW/4kHz for analog
transmissions and that the associated uplink operation will not exceed applicable EIRP density
envelopes in Section 25.218 unless the non-routine uplink andlor downlink operation is
coordinated with operators of authorized co-frequency space stations at assigned locations within
six degrees of the orbital location of the proposed space station.

3.             Compliance with PfD limits in 11.45-11.7 GHz

The allowable PFD levels in the 10.95-11.2 GHz bands (per 4 kHz) are defined in
Section 25.208(b)(1) of the Commission’s rules for all conditions, including clear sky, and for all
methods of modulation as follows:

For angles of arrival between 0 and 5 degrees above the horizontal plane:
               -150 dBW/m2 in any 4kHz band;
For angles of arrival 6 (in degrees) between 5 and 25 degrees above the horizontal plane:
               -150 + (6-5)12 dBW/m2 in any 4 kHz band; and
For angles of arrival between 25 and 90 degrees above the horizontal plane:
               -140 dBW/m2 in any 4 kHz band.




                                                 1


In order to demonstrate such compliance, the PfD levels for the telemetry carriers are calculated
below. It can be seen from the results that compliance with the PFD levels has been achieved.

                                               TM Beam
    Elevation angle, deg                     5       10             15       20       25       90
    Max. EIRP, dBW                           11.5    11.5           11.5     11.5     11.5     11.5
    Gain roll-off at elevation angle, dBi    0      0               0        0        0        0
    Carrier bandwidth, MHz                   0.2    0.2             0.2      0.2      0.2      0.2
    EIRP density at elevation angle,         -5.5   -5.5            -5.5     -5.5     -5.5     -5.5
    dBW/4kHz
    Minimum spreading loss, dB/m2            -163.3        -163.2   -163.1   -162.9   -162.8   -162.1
    25.208(a) pfd limit (10.95-11.2 and      -150          -147.5   -145     -142.5   -140     -140
    11.45-11.7 MHz), dBW/m2/4kHz

    pfd, dBWIm2I4KHz                          -168.8       -168.6   -168.5   -168.4   -168.3   -167.5
    Margin, dB, relative to 25.208             18.8         21.1     23.5     25.9     28.3     27.5


4                TT&C Contour Maps

The antenna gain contours for the TT&C omni beam operations are not included because the
contours at 8 dB below peak fall entirely beyond the edge of the visible Earth.1




         See 47 C.F.R.   § 25.1 14(c)(4)(vi)(A).
                                                       2


                     Attachment 3: Orbital Debris Mitigation Statement

The information for NSS-6 specified under Section 25.1 14(d)(14) of the Commission’s rules is
already on file with the Commission,’ and SES incorporates that information by reference herein.
SES hereby submits the following supplemental information regarding orbital debris mitigation:

Spacecraft Hardware Design: SES has assessed and limited the amount of debris released in a
planned manner during normal operations of NSS-6 at 86.8° W.L. No debris is generated during
normal on-station operations, and the spacecraft will be in a stable configuration. The satellite
will maintain an E-W stationkeeping tolerance within +1- 0.1 degrees.

Safe Flight Profiles: SES seeks authority to provide TT&C service for NSS-6 at the 86.8° W.L.
orbital location and on-station operations require station-keeping within the +/- 0.1 degree N-S
and +1- 0.1 degree E-W control box, thereby ensuring adequate collision avoidance distance from
other satellites in geosynchronous orbit. The closest satellite operating near the 86.8° W.L.
orbital location is Tupac Katari 1 located at 87.2° W.L., which is 0.3 degrees away from the
outside of the proposed NSS-6 orbital box. SES is not aware of any other FCC- or non-FCC
licensed spacecraft that are operational or planned to be deployed at 86.8° W.L. or to nearby
orbital locations such that there would be an overlap with the requested stationkeeping volume of
NSS-6. Furthermore, SES is not aware of any other system with an overlapping station-keeping
volume with NSS-6 that is either in orbit or progressing towards launch. Based on the preceding,
it is concluded that physical coordination of the NSS-6 satellite with another party is not required
at the present time. SES is seeking the necessary waivers to operate the satellite with a relaxed
stationkeeping volume.




       See Panasonic Avionics Corp., Call Sign E100089, File No. SES-MFS-20150609-00349,
Technical Appendix, Annex A-6, Part D; Letters from Carlos M. Nalda, Counsel to Panasonic
Avionics Corp., to Marlene H. Dortch, Secretary, federal Communications Commission, File
No. SES-MFS-20l50609-00349 et at., dated Jan. 7, 2016 and Feb. 10, 2016.

                                                 1



Document Created: 2019-06-12 23:00:45
Document Modified: 2019-06-12 23:00:45

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