Attachment Intelsat - Grant Feb

Intelsat - Grant Feb

DECISION submitted by IB,FCC

Grant

2016-02-24

This document pretains to SAT-AMD-20151120-00077 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2015112000077_1130438

                                                                                  Ganmene uce                 #« See also
$2404        SAT—AMD—20151120—00077      182015002256
                                                                           Fils# 6Bt— BNMPD— 2015 1120—00077.    set—miop—2oisi020—coon2?
Intelsat License LLC
INTELSAT 805                                                                Call Sign    324        Grant Date Q?.&Li[i(a
                                                                            oz other identifier)
                                                                                                             cs See€ s        Approved by OMB
                                                                            From_ 02 /24/1G                     conditions          3060—0678

  Date & Time Filed: Nov 20 2015 11:28:07:063AM
  File Number: SAT—AMD—20151120—00077                   €with conchtions                           Sfegigh J: Duall
                                                                                                   Chief, Satellite Policy Branch
        FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM                               FCC Use Only

                           FCC 312 MAIN FORM FOR OFFICIAL USE ONLY


  APPLICANT INFORMATION
  Enter a description of this application to identify it on the main menu:
  Application to Amend Modification Application for Intelsat 805 (Call Sign $2404)
  1—8. Legal Name ofApplicant

              Name:        Intelsat License LLC             Phone Number:                           703—559—7848
              DBA                                           Fax Number:                             703—559—8539
              Name:

              Street:      c/o Intelsat Corporation         E—Mail:                                 susan.crandall@intelsat.com
                           7900 Tysons One Place
              City:        McLean                           State:                                  VA
              Country:      USA                             Zipcode:                                22102       —8972
              Attention:   Susan H. Crandall


                                      Intelsat License LLC
              IBFS File Nos. SAT—MOD—20151020—00072; SAT—AMD—20151120—00077
                                         Call Sign $2404

The application of Intelsat License LLC (Intelsat) to modify the authorization for its Intelsat 805 space
station, IBFS File No. SAT—MOD—20151020—00072, as amended by IBFS File No.
SAT—AMD—20151120—00077, is GRANTED.‘ Intelsat is authorized to provide Fixed—Satellite Service
(FSS) via Intelsat 805 (Call Sign $2404) at the 169.0° E.L. orbital location, instead ofits currently
authorized orbital location of 55.5° W.L., in the 3400—4200 MHz (space—to—Earth), 5850—6650 MHz
(Earth—to—space), 12.5—12.75 GHz (space—to—Earth), and 14.0—14.25 GHz (Earth—to—space) frequency
bands. Intelsat is also authorized to conduct Telemetry, Tracking, and Command (TT&C) operations
necessary to maintain the Intelsat 805 space station at the 169.0° E.L. orbital location using the following
center frequencies: 3947.5 MHz, 3948.0 MHz, 3950 MHz, 3952.0 MHz, 3952.5 MHz, and 12.501 GHz
(space—to—Earth), and 6173.7 MHz, and 6176.3 MHz (Earth—to—space). Finally, the license term for
Intelsat 805, which expires on July 18, 2016, is extended through December 31, 2019. Operations under
this authorization must be in accordance with the terms and conditions contained in Intelsat‘s application
and the Federal Communications Commission‘s rules and are subject to the following conditions:
         #:       For operation in the frequency bands 3400—3700 MHz, 5850—5925 MHz, and 6425—6650
MHz at the nominal orbital location of 169° E.L, Intelsat must prepare the necessary information, as may
be required, for submission to the International Telecommunication Union (ITU) to initiate and complete
the advance publication, international coordination, due diligence, and notification process of this space
station, in accordance with the ITU Radio Regulations. Intelsat shall be held responsible for all cost—
recovery fees associated with ITU filings. We also note that no protection from interference caused by
radio stations authorized by other administrations is guaranteed unless coordination and notification
procedures are timely completed or, with respect to individual administrations, by successfully
completing coordination agreements. Any radio station authorization for which coordination has not been
completed may be subject to additional terms and conditions as required to effect coordination ofthe
frequency assignments of other administrations. See 47 C.F.R. § 25.111(b).
         2,      While at the 169.0° E.L. orbital location, Intelsat must maintain the Intelsat 805 space
station with an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.
         3.       Intelsat must coordinate the operations of Intelsat 805 with existing geostationary space
stations to ensure that no unacceptable interference results fromits operations at the 169.0° E.L. orbital
location.
       4.      In connection with the provision of service in any particular country, Intelsat is obliged to
comply with the applicable laws, regulations, rules, and licensingprocedures of that country. —
         §        Intelsat must operate Intelsat 805 at the 169.0° E.L. orbital location in compliance with
all existing or future coordination agreements for this location.
        6.      Use ofthe 3400—3600 MHz (space—to—Earth) frequency band is not permitted for non—
Federal FSS in the United States Table of Frequency Allocations, 47 C.F.R. § 2.106. Intelsat must not
permit any earth station in the United States or its possessions to operate with the Intelsat 805 space
station in the 3400—3600 MHz (space—to—Earth) frequency band.
        T       Intelsat must inform its customers and operators using the 3400—3600 MHz (space—to—
Earth) frequency band of the potential for interference from U.S. government operations worldwide.


‘ The application was placed on Public Notice as accepted for filing on December 11, 2015, See Policy Branch
Information, Satellite Space Applications Acceptedfor Filing, Public Notice, Report No. SAT—01112, (IBFS File
No. SAT—MOD—20151020—00072).
2 Intelsat states that the 3400—3600 MHz band will not be used in the United States. Legal Narrative, IBFS File No.
SAT—LOA— SAT—MOD—20151020—00072, at 9.


                                       Intelsat License LLC
               IBFS File Nos. SAT—MOD—20151020—00072; SAT—AMD—20151120—00077
                                          Call Sign $2404

        8.       Intelsat‘s use of the 3600—3650 MHz (space—to—Earth) band is subject to GN Docket No.
12—354, which limits FSS communications within the United States in the 3600—3650 MHz band on a
primary basis to existing earth stations or to new earth stations within 10 miles of existing earth stations."
All other FSS earth station operations in the band 3600—3650 MHz must be on a secondary basis.
         9.      Intelsat‘s use of the 3600—3650 MHz (space—to—Earth) band is subject to footnote US245
of the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US245, which states that the
3600—3650 MHz use of the non—Federal FSS is limited to international inter—continental systems and is
subject to case—by—case electromagnetic compatibility analysis.
         10.     Intelsat‘s use of the 3650—3700 MHz (space—to—Earth) band is subject to footnote NG185
of the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, NG185, which states that the
3650—3700 MHz use of the non—Federal FSS is limited to international inter—continental systems.
         11;      Intelsat‘s use of the 3650—3700 MHz (space—to—Earth) band is subject to footnote NG169
of the United States Table of Frequency Allocations, which states that after December 1, 2000, operations
on a primary basis by the FSS (space—to—Earth) in the band 3650—3700 MHz must be limited to
grandfathered earth stations. All other FSS earth station operations in the band 3650—3700 MHz must be
on a secondary basis.
       12.     Use of the 5850—5925 MHz frequency band shall comply with the terms of Footnote
US245 to the U.S. Table of Frequency Allocations, 47 C.F.R. § 2.106, US245, and Section 2.108 ofthe
Commission‘s rules, 47 C.F.R. § 2.108, which states that the 5850—5925 MHz use of the non—Federal
fixed—satellite service is limited to international, intercontinental satellite systems and is subject to case—
by—case electromagnetic compatibility analysis. Intelsat shall not claim protection from radiolocation
transmitting stations operating in accordance with footnote G2."
         13.      Intelsat is directed to bear in mind the needs of the passive services when operating the
Intelsat 805 space station in the 6425—6650 MHz frequency band pursuant to Footnote 5.458 to the United
States Table of Frequency Allocations, 47 C.F.R. §2.106, Footnote 5.458.
        14.     Intelsat‘s request that the prior waivers granted to Intelsat 805 for Sections 25.202(a)(1)‘,
25.202(g), 25.210(a)(3), 25.210(i)(1), and 25.210(f) of the Commission‘s rules be extended to the
operation of Intelsat 805 at 169.0° E.L.; is GRANTED, subject to the conditions in the original grant.‘
         15.      Intelsat‘s request for waivers of Sections 25.202(a)(1) and 2.106 ofthe Commission‘s
rules, 47 C.F.R. §§ 25.202(a)(1) and 2.106, which allocate 12.5—12.7 GHz to Fixed Service (FS) and
Broadcast Satellite Service (BSS), and 12.7—12.75 GHz to FS, Mobile Service, and FSS (Earth—to—space)
in International Telecommunication Union (ITU) Region 2, is GRANTED. Intelsat‘s operations in these


 Amendment ofthe Commission‘s Rules with Regard to Commercial Operations in the 3550—3650 MHz Band, GN
Docket No. 12—354, Notice of Proposed Rulemaking and Order, 27 FCC Red 15594, 15646, { 168 (2012).

 For technical information of these radiolocation systems, see NTIA Report 83—115, Spectrum Resource
Assessment in the 5650—5925 MHz Band, and NTIA Report 00—373, Measured Occupancy of 5850—5925 MHz and
Adjacent 5—GHz Spectrum in the United States at http:/www.its.bldrdoc.gov/pub/pubs.php.

* The existing waiver of Section 25.202(a)(1) applies only to C—band frequencies on Intelsat 805.

5 See Applications ofIntelsat LLC For Authority to Operate, and to Further Construct, Launch and Operate C—Band
and Ku—Band Global Satellites That Form a Global Communications System in Geostationary Orbit, Memorandum
Opinion and Order and Authorization , 15 FCC Red 15460, at Appendix C (2000) , recon. denied, 15 FCC Red
25234. We note that one ofthe original waived rules, Section 25.210(g)(1), 47 C.F.R. § Section 25.210(g)(1), which
required full frequency reuse, is now included in Section 25.210(f), 47 C.F.R. § Section 25.210(f).


                                            Intelsat License LLC
              IBFS File Nos. SAT—MOD—20151020—00072; SAT—AMD—20151120—00077
                                        Call Sign $2404

bands at the 169.0° E.L. orbital location will be solely in Region 3, in which the 12.5—12.75 GHz band is
allocated to FSS in the space—to—Earth direction, and thus conforms to the International Table of
Frequency Allocations. Further, under the ITU Region 2 BSS Plan, there is at least 15.8 degrees of
orbital separation between Intelsat 805 at 169.0° E.L. and the nearest possible BSS network that could
provide service to any portion of the ITU Region 2, so it is unlikely that operations of Intelsat 805 will
interfere with any BSS networks in Region 2.
        16.     The operations of Intelsat 805 and associated earth stations must comport with the
applicable uplink limits in 47 C.F.R, §§ 25.211, 25.212, 25.218, 25.222, 25.226, and/or 25.227, and the
downlink limit in 47 C.F.R. § 25.212(c)(2), unless Intelsat coordinates any non—conforming operation
with the operations of U.S.—licensed GSO space stations within 6 degrees of 169.0° E.L. Non—conforming
operation must also be coordinated with respect to those operations of non—U.S.—licensed spacestations
within 6 degrees of 169.0° E.L. involving approved communications with U.S.—licensed earth stations
pursuant to Section 25.137 of the Commission‘s rules, 47 C.F.R. § 25.137.
       17.     Intelsat‘s request for waivers of Sections 25.114(d)(14)(ii) and 25.283(c) of the
Commission‘s rules, 47 C.F.R. §§ 25.114(d)(14)(ii), 25.283(c), is granted. Sections 25.114(d)(14)(ii) and
25.283(c) specify that space stations must discharge all stored energy sources at end—of—life of the space
station. Intelsat 805 does not completely discharge all stored energy at end of life. Intelsat states that
residual oxidizer will not be vented at the spacecraft‘s end oflife because the two tanks containing this
oxidizer were sealed shortly after the satellite‘s launch. Intelsat further states that Intelsat 805 has two
helium tanks with a volume of 68.63 liters each, and the estimated mass and pressure of residual helium
in each tank will be 414.0 grams and 527.9 psia at 17.3 degrees C, respectively, at end oflife." The
information submitted by Intelsat is not sufficient to support a finding that the underlying purpose of
Section 25.283(c) is served by sealing the oxidizer tanks without completely venting them. Nevertheless,
we grant Intelsat a partial waiver of Sections 25.114(d)(14)(ii) and 25.283(c). Intelsat 805 was launched
and the tanks sealed before Section 25.283(c) was adopted. Furthermore, compliance with Section
25.283(c) would require direct retrieval of the spacecraft or launching a servicing mission to the
spacecraft, which is not practicable at this time. This action is without prejudice to future licensing
decisions in connection with other spacecraft of the same manufacturing series.
        18.      Intelsat requests waiver ofthe requirement to meet milestones or post a bond for
operations at 169.0° E.L., pursuant to Sections 25.164(a) and 25.165 of the Commission‘s rules, 47 C.F.R.
§§ 25.164(a) and 25.165. Because Intelsat 805 is already in—orbit and operating at 169.0° E.L. pursuant to
grants of special temporary authority, grant of authority to operate Intelsat 805 at 169.0° E.L. is not
subject to milestone conditions and Intelsat is not required to post a bond. As such, waiver of Sections
25.164(a) and 25.165 of the Commission‘s rules is not necessary.
         19.    Intelsat is afforded thirty days from the date ofthis action to decline this authorization as
conditioned. Failure to respond within this period will constitute formal acceptanceof the authorization
as conditioned.




? See Engineering Statement in Intelsat‘s application, IBFS File No. SAT—MOD—20151020—00072, at 7.


                                           Intelsat License LLC
              IBFS File Nos. SAT—MOD—20151020—00072; SAT—AMD—20151120—00077
                                        Call Sign $2404



        20.     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 immediately. Petitions for reconsideration under Section
1.106 or applications for review under Section 1.115 of the Commission‘s rules, 47 C.F.R. §§ 1.106,
1.115, may be filed within 30 days of the date of the public notice indicating that this action was taken.




                                                            SPrMOP—20151020— 672.
                                                    File # SDT— PMPD~ 2015 |12G — 60077 _

                                                    Call Sign $2404          Grant Date    OZ{L“{AQ
                                                    (or other Identifier)
                                                                             Term Dates gee
                                                    l-vwan_Z. 24      /lto         To:    C'.Otd\‘h\OY\S_


9—16. Name of Contact Representative

            Name:          Susan H. Crandall                     Phone Number:                        703—559—7848
            Company:       Intelsat Corporation                  Fax Number:                          703—55%—8539
            Street:        7900 Tysons One Place                 E—Mail:                              susan.crandall@intelsat.com


            City:          McLean                                State:                               VA
            Country:        USA                                  Zipcode:                             22102—5972
            Attention:                                           Relationship:                        Legal Counsel


CLASSIFICATION OF FILING
17. Choose the button next to the
classification that applies to this filing for    (N/A) b1. Application for License of NewStation
both questions a. and b. Choose only one          (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 175.                     & b3. Amendment to a Pending Application
                                                  £3 b4. Modification of License or Registration
   C al. Earth Station
                                                 b5. Assignment of License or Registration
   & a2. Space Station                           b6. Transfer of Control of License or Registration
                                                 e b7. Notification of Minor Modification
                                                  (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                 Satellite
                                                  (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                 States
                                                  (N/A) b10. Other (Please specify)
                                                    (N/A) bl1. Applicationfor Earth Stationto Access a Non—U.S .satellite Not Currently Authorized
                                                 to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                    (N/A) b12. Application for Database Entry
                                                  {3 b13. Amendment to a Pending Database Entry Application
                                                  «3 b14. Modification of Database Entry


 17c¢. Is a fee submitted with this application?                                       .
@ IfYes, complete andattach FCC Form 159.          If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C Governmental Entity         {} Noncommercial educational licensee
g4 Other(please explain}:

17d.

Fee Classification CWY — Space Station Amendment(Geostationary)




18. If this filing is in reference to an     19. If this filing is an amendment to a pending application enter both fields, if this filing is a
existing station, enter:                     modification please enter only the file number:
(a) Call sign of station:                    (a) Date pending application was filed:              (b) File number:
     $2404
                                             10/20/2015                                           SATMOD2015102000072


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

E a. Fixed Satellite
D b. Mobile Satellite
D c. Radiodetermination Satellite
D d. Earth Exploration Satellite
D e. Direct to Home Fixed Satellite
D £. Digital Audio Radio Service
D g. Other (please specify)


21. STATUS: Choose the button next to the applicable status. Choose      122. If earth station applicant, check all that apply.
only one.                                                                D Using U.S. licensed satellites
{G Common Carrier       € Non—Common Carrier                             D Using Non—U.S. licensed satellites


23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding See. 214 filings. Choose one. Are these
factilities:
C Connected to a Public Switched Network         3 Not connected to a Public Switched Network           G N/A

 24. FREQUENCY BAND(S): Place an °X" in the box(es) next to all applicable frequency band(s}.
E a. C—Band (4/6 GHz) E b. Ku—Band (12/14 GHz)
D c.Other (Please specify upper and lower frequencies in MHz.)
        Frequency Lower:      Frequency Upper: (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
3 a Fixed Earth Station
3 b. Temporary—Fixed Earth Station
3 c 12/14 GHz VSAT Network
y 4. Mobile Earth Station
%, e. Geostationary Space Station
{ £. Non—Geostationary Space Station
«4 g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
&3 Transmit/Receive g3 Transmit—Only            g3 Receive—Only    G N/A
"For Space Station applications, select N/A."


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an °X" in the box{es} next to all that apply.)


    D a —— authorization to add new emission designator and related service
    D b — authorization to change emission designator and related service
    D c —— authorization to increase EIRP and EIRP density
    D d —— authorization to replace antenna
    D e —— authorization to add antenna
    D f —authorization to relocate fixed station
    D g —— authorizationto change frequency(ies)
     D h —— authorization to add frequency
    D i — authorization to add Points of Communication (satellites & countries)
    D j —— authorization to change Points of Communication (satellites & countries)
    D k —— authorization for facilities for which environmental assessment and
radiation hazard reporting is required
     I:] 1 —— authorization to change orbit location
    D m — aguthorizationto perform fleet management
    D n — authorizationto extend milestones
    D o — Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental         {3 Yes @ No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.E.R. 1.1308 and 1.1311, as an exthibit to this application.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
acronautical fixed radio station services are not required to respond to Items 30—34.


29. Is the applicant a foreign government or the representative of any foreign government?                             3 Yes @ No




30. Is the applicant an alien or the representative of an alien?                                                       3 Yes @ No 3 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                 {} Yes € No 3 N/A




32. Is the applicant a corporation of which more than one—fifth of the capitalstock is owned of record or voted by     {»; Yes @ No g, N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlledby any other corporation of which more than           & Yes q3 No 4 N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?




34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, andthe percentage of stock they own or vote.



BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                                  @ Yes      «34 No
IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.

                                                                                                                          EngineeringStatement




36. Has the applicant or any party to this applicationor amendment had any FCC station authorization orlicense                @ Yes      4 No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction perimit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances.


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    «4 Yes   & No
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,        3 Yes    G No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition?IfYes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   «3 Yes   & No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of
beneficiaries. Also list the names and addresses ofthe officers and directors of the Filer.


41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is           @ Yes        &4 No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
 1988, 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.




42a. Does the applicant intendto use a non—U.S. licensed satellite to provideservice in the United States? IfYes,          &4 Yes       & No
answer 42b and attach an exhibit providing the information specified in 47 C.ER. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process oflicensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?




43. Description. (Summarize the nature of the application and the services to be provided).   {If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
     Intelsat License LLC, pursuant to Section 25.116 of the rules of the Federal
     Commurications Commission,              47 C.F.R.       section 25.116,         hereby amends its pending application
     to modify the authorization for Intelsat 805                        (Call Sign $2404)          to allow the satellite to
     relocate to,       and operate at,         169.0 E.L.,        to extend the license term,               and to extend all

Amendment




10


 43a. Geographic Service Rule Certification                                                                                    @ A
 By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25.
                                                                                                                               £4 B
 By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.
                                                                                                                              3 C
 By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
 coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
 feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
 compromises in satellite design and operation as to make it economically unreasonable. A narrative description
 and technical analysis demonstrating this claim are attached.




CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether bylicense or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated hereinas if set out in full in this application.
The undersigned, individually and for the applicant, herebycertifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.




11


44. Applicant is a (an}: (Choose the button next to applicable response.)


 be: Individual
 g4 Unincorporated Association
 34 Partnership
 ¢y Corporation
 C3 Governmental Entity
 & Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Susan H. Crandall                                                      Assoc. General Counsel, Intelsat Corporation
       ——>



             WILLFUL FALSE STATEMENTS MADE ON THIS FORMARE PUNISHABLE BY FINE AND / ORIMPRISONMENT
                      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                    (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW104—13, OCTOBER
1, 1995, 44 U.S.C. SECTIQON 3507.




13


43. Description. (Summarize the nature of the application and the services to be provided).

Intelsat License LLC,          pursuant to Section 25.116 of the rules of the Federal Communications
Commission,      47 C.F.R.     section 25.116,        hereby amends its pending application to modify the
authorization for Intelsat 805              (Call Sign §$2404)       to allow the satellite to relocate to,   and
operate at,      169.0 E.L.,      to extend the license term,            and to extend all previously granted waivers,
through December 31,         2019.                                                                                  '




14



Document Created: 2016-03-18 15:55:13
Document Modified: 2016-03-18 15:55:13

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