SES Americom, Inc. C-Band Transition Quarterly Report - Corrected (Filed December 31, 2020)

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

SES Americom, Inc. C-band Transition Quarterly Report

December 31, 2020

This report describes the transition activities undertaken by SES between March 1, 2020 and December 17, 2020, to achieve the accelerated clearing deadlines set out in the FCC’s C- band Report and Order.1 The activities described in this report reflect the day-to-day work required to carry out the Final Transition Plan we have filed with the FCC. SES engaged in numerous discussions with the FCC in advance of filing our Final Transition Plan on August 14, 2020,2 which reflected the comments we received from the FCC. As part of the revisions we made to our revised Final Transition Plan,3 we removed the incumbent earth stations (“IESs”) that are subject to a successful lump sum election and updated our estimated costs as a result of those elections, but made no other material changes.

While we previously reported some of the actions SES had completed in our August 14, 2020, and October 28, 2020 filings, this report provides a comprehensive summary of the actions taken with respect to the Relocation Coordinator, customer services, electing and non-electing SES-associated IES operators, and vendors. The format of this report includes topics that we expect to report on and update over the course of the transition; therefore, it contains items for which there is no updated information at this time. We will provide any available updates in future reports.

I. Overview

A. Successes

During this period, we remain on track and in some cases are ahead of the schedule set out in our revised Final Transition Plan.4 We have brought on board nearly all of the vendors we need to complete our Phase I and Phase II clearing obligations on time. These include the satellite manufacturers, launch providers, earth station antenna manufacturers, filter manufacturers, compression equipment manufacturer, and equipment installers.

1 Expanding Flexible Use of the 3.7 to 4.2 GHz Band, Report and Order and Order of Proposed Modification, 35 FCC Rcd 2343, ¶ 316 (2020) (“C-Band R&O”); 47 C.F.R. § 27.1412(f).

2 Letter from Brian D. Weimer, Counsel, SES Americom, Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket Nos. 18-122 & 20-173 (filed Aug. 14, 2020) (“Final Transition Plan”).

3 Letter from Brian D. Weimer, Counsel, SES Americom, Inc., to Marlene H. Dortch, Secretary, FCC, GN Docket Nos. 18-122 & 20-173 (filed Oct. 28, 2020) (“revised Final Transition Plan”).

4 Id., Appendix E.

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

We also conducted substantial outreach to IES operators beyond what was previously described in the revised Final Transition Plan to further refine our list of claimed IESs and prepare for installation of equipment such as antennas and passband filters at the sites where the claimed IESs are operating. We have ordered nearly all filters estimated to be needed in Phase I, including 3820-4200 MHz passband filters for Phase I IESs that will be receiving services from SES satellites above 3820 MHz after December 5, 2021 and 4000-4200 MHz passband filters for Phase I IESs that will be receiving services exclusively above 4000 MHz after December 5, 2021.

The technology upgrades needed for transitioning services, including compression/modulation upgrades, have commenced and are well underway for completion according to plan. A large proportion of the required Phase I satellite service transitions have been completed. We have also continued and expanded upon our partnerships with various stakeholders including customers, individually and through trade associations, as well as with IES operator associations to communicate our transition plans, address questions and concerns, and reiterate near-term transition plans. Specifically, we have been working with numerous radio, cable, and broadcasting associations to communicate the latest moves regarding the C- band transition. A number of associations have agreed to post information on their websites and newsletters, including NCTC, ACA Connects (America’s Communications Association), NAB (National Association of Broadcasters), and NRB (National Religious Broadcasters). ACA Connects has conducted two educational webinars for members with the spotlight on SES and our Final Transition Plan. We have a 24/7 helpdesk and email address to address questions and concerns.

SES and the other satellite operators engaged in accelerated clearing have also contracted with RSM US LLP to act as the Relocation Coordinator pursuant to the Commission’s Report and Order.5 We have been interacting multiple times each week with the Relocation Coordinator to further communicate transition plans and coordinate activities among each of the satellite operators.

B. Risk/Challenges

COVID-19 Related Risks: At this time, we remain on schedule to meet our Phase I and Phase II clearing obligations. However, we have learned that COVID-19 is impacting our satellite manufacturing programs, our satellite service transitions, our equipment suppliers, and our installation activities at IES sites. With respect to our satellite programs, a few component suppliers have informed two of our satellite manufacturers that the component delivery will likely be delayed due to COVID-19 infections in their facility or further down their supply chain. We are working with these satellite manufacturers to mitigate the effects of such component delays and maintain margin in the manufacturing schedule.

5 C-Band R&O ¶ 308; 47 C.F.R. § 27.1413(a).

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

Two customers have also informed us of slight delays in the transitioning of satellite services at their uplinks due to COVID-19 restrictions or infections at their facilities or the associated IES downlink locations. One filter supplier has informed us of decreased manufacturing volumes due to COVID-19 restrictions but still believes it can fulfill all of our Phase I filter requirements. In a few cases, COVID-19 restrictions and IES operator or equipment installer infections have prevented access to IES sites. At this point, however, these delays have not impacted our overall transition timeline. In all cases, we have worked with the impacted parties to develop workarounds, including rearranging schedules, to mitigate the effects of these impacts to our overall transition schedule.

Other Risks: In addition to the risks described in our Final Transition Plan, such as the risk of launch failure or other operational issues with our first four satellites, we note that there also are a number of IES operators who have not responded to contacts from us or our designated installers. As discussed further below, the current lack of response from some IES operators has not caused a delay in the clearing schedule, but we will not be able to clear the related IESs in a timely manner without a response from the operator.

C. Requests for FCC Assistance/Intervention

At this time, we are not requesting any assistance or intervention from the Commission.

D. Other Observations

At this time, we have no further observations on the clearing process.

II. Satellite Manufacture and Launch Procurement

Over the course of June and August 2020, SES contracted with Boeing and Northrop Grumman to manufacture three satellites that will be launched to 103° W.L., 131° W.L., and 135° W.L. to carry services that must transition to clear the lower 300 MHz of C-band spectrum as well as an in-orbit spare satellite that will be located at 103° W.L. and used only in the event we experience an in-orbit satellite failure at 103° W.L. or other SES satellite delivering C-band service to the United States. SES also contracted with Thales Alenia Space to manufacture two ground spares. As described in our Final Transition Plan, these ground spares are necessary to ensure we can meet our clearing obligations in the event one or more of the first four satellites experience a launch or technical issue that makes them inoperable.

The satellite procurement programs are progressing as planned with all three satellite manufacturers. Boeing has successfully completed Critical Design Review (“CDR”) for the SES- 20 and SES-21 satellites. Northrop Grumman has scheduled CDR for the SES-18 and SES-19 satellites for Q1 2021, having successfully completed the Equipment Qualification Status Reviews (“EQSR”) and Preliminary Design Reviews (“PDR”). Thales Alenia Space has also successfully completed the EQSR and System PDR for SES-22 and has confirmed the CDR for Q1 2021.

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

SES has also signed contracts with ULA and SpaceX to launch the satellites in 2022. Kick-off meetings took place among SES, the launch vehicle providers and the satellite manufacturers, and no major issues regarding the missions were identified.

Notwithstanding the impact of the COVID-19 pandemic described in more detail above in Section I.B, the forecasted delivery dates for the satellites remain on track. Critical paths for each spacecraft are well identified and the satellite manufacturers are required to enforce heightened focus on their supply chains to ensure the critical deliveries will come on-time and will not drive the overall delivery schedules.

III. Satellite Service Migrations

SES provided a detailed list of services subject to the transition in Appendix B of our revised Final Transition Plan. We are attaching an updated version of Appendix B, which reflects the status of each service: Transition Completed, In Transition, Pending Transition, Deleted, or Added – indicated by a “C”, “I”, “P”, “D” or “A”, respectively. Changes to transition timelines of individual services from our revised Final Transition Plan are also indicated by red font. We also provide a new note field, which details further information associated with the changes. Below is a summary of the information provided in the updated Appendix B.

Deletions Since Last Report: As of December 17, 2020, 19 services were removed from the revised Final Transition Plan because the service was terminated, the service contract expired, the service is no longer required to transition or we have been informed that the service will expire without renewal prior to the transition dates. These deleted services will not be included in future updates.

Additions Since Last Report: We have added 29 service migrations since filing our revised Final Transition Plan. Of these, 6 were erroneously omitted from our revised Final Transition Plan and all but one of these omitted services have completed transition. The other additions reflect refinements to the overall Final Transition Plan and have been fully confirmed by the affected customers. Importantly, many of these additions have resulted in fewer infrastructure upgrades needed to effectuate the transition of international services to the Hawley TT&C/Gateway site. All of the additional service transitions will occur within the previously established timeline for our clearing activities.

Migrated/Remaining: During the period covered by this report, we have completed 41% of our Phase I and 2% of our Phase II service transitions on our satellites. The completion of these transitions allows us to move to filtering IESs in our Final Transition Plan that are now receiving services exclusively above 3820 MHz. We anticipate completing all Phase I service transitions on time and in accordance with our overall timelines as reflected in our revised Final Transition Plan.

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

IV. Compression Technology

Uplink Completed/Remaining: All uplink compression equipment has been shipped to and installed at the earth station locations associated with the services requiring compression technology. The equipment is currently being configured and tested to allow for the commencement of the service transitions to the new technology at the end of the first quarter or the beginning of the second quarter of 2021.

Downlink Completed/Remaining: Over 50% of the downlink equipment, including demodulators, decoders, transcoders and related equipment, have been shipped to IES operators receiving the satellite services requiring compression technology and are ready for installation and configuration. The remaining downlink equipment will be shipped in January 2021.

V. Incumbent Earth Station Migration

Our primary IES equipment installation vendor, USSI, has been contacting IES operators that will require filters and other equipment within the next one to two quarters based on our Final Transition Plan. This “virtual site survey” process identifies the individual needs of each IES site, the quantity and configuration of antennas accessing SES satellites, and any other relevant information needed in order for us to prepare the sites for satellite service transitions and the eventual installation of passband filters. Additionally, in cases where the performance of an antenna (primarily antennas with multiple feeds) must be assessed to determine if that antenna can support a higher adjacent satellite interference environment associated with the repacked satellite spectrum, we have conducted individualized on-site testing at IES sites.

A detailed list of SES-associated IES records6 were included in Appendix C to the revised Final Transition Plan. Since that revised plan was filed, the Commission has issued updates to the final list of IESs that are subject to a successful lump sum election and therefore should be excluded from each satellite operator’s transition plan.7 We are attaching an updated version of Appendix C that reflects the current list of IES records that are not subject to a lump sum election and that we believe receive at least one service from an SES satellite. We will continue outreach activities on the most current list of IES records provided by the FCC and will update the list of SES-associated IESs in subsequent quarterly reports. We also include an

6 The FCC has published a number of updated lists reflecting valid IES registrations. The list includes individual records, each of which represents a single registration in the International Bureau’s Filing System (“IES record”). Many records include multiple antennas which qualify as IESs, but only a few may be receiving services from an SES satellite. Appendix C provides one line item for each IES record that includes at least one antenna that is receiving a service from an SES satellite (“SES-associated IES”) but does not indicate that all of those antennas are receiving a service from an SES satellite.

7 Erratum to International Bureau Releases Updated List of Incumbent Earth Stations in the 3.7-4.2 GHz Band in the Contiguous United States, Public Notice, DA 20-1448, IB Docket No. 20-205 (rel. Dec. 3, 2020) (“December 3 List”).

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

indexing of each IES record that was developed by the Relocation Coordinator. Below is a summary of the information reflected in the updated Appendix C.

IESs Removed Since Last Report: In addition to removing IES records from Appendix C that are subject to a successful lump sum election, we also removed IES records that were determined as (1) not having an antenna accessing an SES satellite based on our various methods of outreach, (2) no longer in operation based on correspondence with the IES operators, or (3) not having an antenna at the address or geo-coordinates as shown on the December 3 List. These removed IES records are indicated in a tab titled “Unclaimed IES 4Q2020” in the updated Appendix C. We have informed the Relocation Coordinator of these changes for their further investigation and disposition of these IESs records.

There have also been a number of IES operators who have not responded to contacts from us or our designated installers. As noted above, we have engaged in substantial individual outreach and joint activities with a number of industry associations. While the current lack of response from some IES operators has not caused a delay in the clearing schedule, we note that we will not be able to clear these IESs in a timely manner without a response from the operator. To the extent we identify IESs that are at risk of missing their clearing deadline, we will inform the Relocation Coordinator, and if those IESs are not favorably dispositioned within 30 days of our informing the Relocation Coordinator, we will deem this a transition delay “beyond the control” of SES, inform the FCC, and remove the relevant IES records from our Appendix C.8

IES Transition Status: With the aforementioned changes, we now expect to transition one or more IESs within 3978 IES records during the three-year clearing period. Of those, it is estimated that approximately 100 IES sites will require one or more antennas to be installed for the Phase I clearing. To date, we have installed 10% of the estimated number. Additionally, all of the SES-associated IESs located at an IES site will require at least one, but possibly two or more, filters, depending upon the antenna configuration, for an estimated total of 3400 filters to be installed over the course of Phase I. During the reporting period, we installed only a small number of filters as most of the satellite service transitions must be completed prior to the installation of filters.

Self-Installations: As noted in the revised Final Transition Plan, we expect that some IES operators will wish to install equipment themselves, and we asked operators to notify us by October 14, 2020, if they intend to do so. To date, seven IES operators (based on location) will be subject to self-installation; the associated IES records for the specific antennas are designated as such in the updated Appendix C. In future quarterly reports, we will inform the FCC whether the operators conducting the installation themselves have provided the requisite certification of completion or if any of them have missed a certification deadline.

8 C-Band R&O ¶ 294.

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

VI. TT&C/Gateway Construction/Service Transition

Construction of our TT&C/Gateway facilities in Brewster, WA, and Hawley, PA, remain on target to support the Phase I and Phase II clearing deadlines. At SES’s Hawley facility, all foundations have been poured to support four new gateway antennas, along with two associated equipment shelter foundations and two propane tank foundations required to support the antenna deicing systems.

The first two antenna systems have been received at the Hawley facility and we have commenced installation with efforts on schedule to meet the planned April 2021 operational dates. The remaining two antenna systems are scheduled to be received at the Hawley facility by the end of 2020, which is earlier than originally expected. Engineering work associated with the installation of a new full motion TT&C antenna at the Hawley facility is well underway with plenty of margin to support the required operational date.

The initial communications equipment shelter has been received at the Hawley facility and the second shelter is expected to be delivered by the end of 2020. Electrical work is well underway at Hawley to support the overall new data center and its associated power room.

Similarly, we have successfully established contractual arrangements with USEI at Brewster, WA, to host a full motion TT&C antenna to support SES’s TT&C needs. The antenna foundation, shelter foundation, and propane tank foundations have been poured at the Brewster facility. Antenna delivery at the Brewster facility is scheduled before the planned January delivery date. All associated electrical work at the Brewster facility is progressing in accordance with the schedule.

The planning for the migration of existing platforms to the Hawley facility has concluded and equipment procurement is underway, with scheduled delivery and integration in the second quarter of 2021. This migration to the Hawley facility will allow for the reception of services from international satellites that could not be relocated to frequencies above 4000 MHz.

VII. Costs

A. Costs Submitted for Reimbursement/Paid to Date

During the period covered by this report, we did not submit any costs for reimbursements.

B. Updates to Estimates

At this time, there are no changes to the cost estimates provided in SES’s revised Final Transition Plan.

SES Americom, Inc. C-band Transition Quarterly Report - corrected (filed December 31, 2020)

VIII. Updates to Transition Timeline

At this time, there are no changes to the transition timeline provided in SES’s revised Final Transition Plan.