Attachment Narrative & Exhibits

This document pretains to SAT-LOA-20121025-00187 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2012102500187_973007

                                             Before the
                                 Federal Communications Commission
                                        Washington, DC 20554


        In the Matter of

        Intelsat License LLC                                File No. SAT-LOA- _____________

        Application for Authority to Launch and
        Operate Intelsat 30 at 95.1º W.L.



               APPLICATION FOR AUTHORITY TO LAUNCH AND OPERATE
                             INTELSAT 30 AT 95.1º W.L.

          Intelsat License LLC (“Intelsat”), pursuant to Section 25.114 of the Federal

Communications Commission’s (“FCC” or “Commission”) rules,1 hereby applies to launch and

operate a C/Ku-band satellite, to be known as Intelsat 30, at the 95.1º W.L. orbital location.

Intelsat 30 is scheduled for launch on an Ariane 5 vehicle in the third quarter of 2014 and will be

collocated with the Galaxy 3C satellite (call sign S2381), which is currently operating at 95.05º

W.L.2 and a new satellite, to be known as Intelsat 31, which will operate at 95.1° W.L.3 Intelsat

30 will operate on a non-common carrier basis.4



1
    47 C.F.R. § 25.114.
2
 See Policy Branch Information; Actions Taken, Report No. SAT-00222, File No. SAT-MOD-
20040405-00079 (June 18, 2004) (Public Notice). Intelsat will file an application to relocate
Galaxy 3C to 95.1° W.L.
3
    Intelsat will file shortly an application for Intelsat 31.
4
  Section 310(b) is not applicable to this license because Intelsat 30, like all other satellites
licensed to Intelsat, will operate on a non-common carrier basis. See Applications of The News
Corp. Ltd. and The DIRECTV Group, Inc. (Transferors) and Constellation, LLC, Carlyle
PanAmSat I, LLC, Carlyle PanAmSat II, LLC, PEP PAS, LLC and PEOP PAS, LLC
(Transferees) for Authority to Transfer Control of PanAmSat Licensee Corp., Public Notice, 19
FCC Rcd 15,424, 15,425 (n.5) (Int’l Bur. 2004).


         As demonstrated below, Intelsat is legally and technically qualified to launch and operate

its proposed satellite. Moreover, grant of this application will serve the public interest by

providing additional capacity to a large Intelsat customer for services to Latin America. In

accordance with the Commission’s requirements,5 this application has been filed electronically

as an attachment to FCC Form 312 and Schedule S.

    I.   INTELSAT IS QUALIFIED TO HOLD THE SATELLITE AUTHORIZATION
         REQUESTED HEREIN

             A. Legal Qualifications

         Intelsat is legally qualified to hold the space station authorization requested in this

application. The information provided in the attached Form 312 demonstrates Intelsat’s

compliance with the Commission’s basic legal qualifications. In addition, Intelsat already holds

multiple Commission satellite licenses, and its “legal qualifications are a matter of record” before

the Commission.6

             B. Technical Qualifications

         In the attached Form 312, Schedule S, and Engineering Statement, Intelsat demonstrates

that it is technically qualified to hold the authorization requested herein. Specifically, Intelsat

provides the information currently required by Section 25.114 of the Commission’s rules. In

addition, the Engineering Statement provides information on Intelsat’s compliance with the




5
    47 C.F.R. § 25.114(c).
6
  See Constellation, LLC, Carlyle PanAmSat I, LLC, Carlyle PanAmSat II, LLC, PEP PAS, LLC,
and PEOP PAS, LLC, Transferors and Intelsat Holdings, Ltd., Transferee, Consolidated
Application for Authority to Transfer Control of PanAmSat Licensee Corp. and PanAmSat H-2
Licensee Corp., Memorandum Opinion and Order, FCC 06-85, ¶ 23 (rel. June 19, 2006) (“The
Commission previously has determined that PanAmSat and Intelsat are qualified to hold
licenses.”).


                                                   -2-


Commission’s orbital debris mitigation rules, including a plan for safe station-keeping with the

collocated Galaxy 3C and Intelsat 31 satellites.7

             C. Waiver Requests

         Intelsat requests waiver of the following technical rules:

                (1) Section 25.210(j), which specifies that geostationary space stations must be
                    maintained within a 0.05° east/west station-keeping box; and

                (2) Section 25. 202(a)(1) and Footnote NG104 of the U.S. Table of Allocations.

         Under Section 1.3 of the Commission’s rules, the Commission has authority to waive its

rules “for good cause shown.”8 Good cause exists if “special circumstances warrant a deviation

from the general rule and such deviation will serve the public interest” better than adherence to

the general rule.9 In determining whether waiver is appropriate, the Commission should “take

into account considerations of hardship, equity, or more effective implementation of overall

policy.”10 As shown below, there is good cause for each of the requested technical waivers.

                1. Request for Waiver of Section 25.210(j)

         Intelsat requests a waiver of Section 25.210(j) to permit operation of Intelsat 30 within

0.1° of the 95.1° W.L. orbital location in the east/west direction. Good cause exists to waive

Section 25.210(j). Intelsat plans to operate Galaxy 3C, Intelsat 30 and another planned satellite,

Intelsat 31, at 95.1° W.L. Intelsat shall maintain sufficient spatial separation between these three

spacecraft through the use of orbit eccentricity and inclination offsets. As part of this process,




7
    Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11,567 (2004).
8
    47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969).
9
    Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
10
     WAIT Radio, 418 F.2d at 1159.


                                                  -3-


Intelsat requires greater flexibility with regard to the amount of excursion that each of these

satellites may be permitted to have in the east/west direction.

       Grant of this waiver is consistent with the International Bureau’s waiver of Section

25.210(j) to allow operation of the Satcom SN-4 satellite with a station-keeping tolerance of +/-

0.1°. That order reminded licensees seeking a waiver of Section 25.210(j) to demonstrate that

grant would not cause harmful interference by “provid[ing] information regarding the identity of

known satellites located at, or planned to be located at, the location proposed by the licensee, or

assigned a location in the vicinity such that the station-keeping volume of the respective satellites

might overlap.”11 Intelsat provides this information below.

       The proposed change will not result in harmful interference to adjacent satellite

operators. Intelsat operates Galaxy 25 at 93.1° W.L. and Galaxy 19 at 97° W.L., which are the

nearest adjacent satellites. This slight increase in the station-keeping tolerance will have a

negligible interference impact on the nearest adjacent satellites. Moreover, Intelsat will be able

to manage any interference issues among the satellites.

       Furthermore, grant of the waiver will not affect the station-keeping of any other

spacecraft. No other commercial satellite currently operates within 0.1° of the 95.1° W.L. orbital

location. Nor is there any planned FCC- or non-FCC licensed spacecraft scheduled to be

deployed to this location whose station-keeping volume would overlap that of Intelsat 30.

       Grant of the waiver request will serve the public interest. Operating Intelsat 30 with the

expanded station-keeping tolerance will allow Intelsat to operate Galaxy 3C, Intelsat 30 and

another planned satellite, Intelsat 31, at 95.1° W.L., and maintain sufficient spatial separation

11
  SES Americom, Inc., Application for Modification of Satcom SN-4 Fixed Satellite Space
Station License, Order and Authorization, 20 FCC Rcd 11542, ¶ 12 (2005) (granting waiver of
Section 25.210(j) to permit Satcom SN-4 to operate in a larger station-keeping box).



                                                 -4-


between these three spacecraft through the use of orbit eccentricity and inclination offsets. The

expanded station-keeping tolerance will allow Intelsat to ensure that additional capacity is

available to serve the South American region from the 95.1° W.L. orbital location. Given

Intelsat’s ability to manage potential interference internally and the lack of station-keeping

overlap with other operators, the benefits that will be achieved by grant of the waiver clearly

outweigh the risks.

                 2. Request for Waiver of Footnote 2 of Section 25.202(a)(1) and Footnote
                    NG104 of the U.S. Table of Allocations

          Intelsat also requests waiver of Section 25.202(a)(1) and footnote NG104 of the U.S.

Table of Allocations, which restrict the use of the 11450-11700 MHz band by the non-federal

Fixed-Satellite Service (“FSS”) in the geostationary orbit to international systems only.12 Two of

Intelsat 30’s beams that utilize the 11450-11700 MHz band provide coverage to Puerto Rico or

the southwest coast of the United States.

          Good cause exists to waive the international only requirements for the 11450-11700 MHz

frequency band. The purpose of NG104 and footnote 2 of Sections 25.202(a)(1) is to limit the

number of the FSS service earth stations with which the co-primary fixed service would need to

coordinate.13 Intelsat will provide services in the 11450-11700 MHz frequency band only on a

non-interference/non-protected basis, and therefore will not need to coordinate with fixed service

stations.

          Moreover, grant of this waiver is consistent with the Commission’s precedent. A waiver


12
     See 47 C.F.R. §§ 2.106(a)(1), fn. 2 and 2.106, fn. NG104.
13
  See Satellite Services, 26 RR 2d 1257, 1263-65 (1973). See also EchoStar KuX Corporation
Application for Authority to Construct, Launch and Operate a Geostationary Satellite Using the
Extended Ku-band Frequencies in the Fixed-Satellite Service at the 83º W.L. Orbital Location,
Order and Authorization, DA 04-3162, 9 (Int’l Bur., Sept. 30, 2004) (“EchoStar 83º Waiver”).


                                                 -5-


of the Table of Allocations is generally granted “when there is little potential interference into

any service authorized under the Table of Frequency allocations and when the nonconforming

operator accepts any interference from authorized services.”14 The International Bureau has

found that waiving NG104 and footnote 2 of Section 25.202(a)(1) would not undermine the

purpose of the rules if the party seeking a waiver: (1) will be utilizing earth stations that are

receive-only in these bands and thus “not capable of causing interference into FS stations”

operating in the bands.15 Intelsat satisfies these criteria. The earth stations operating in the

11450-11700 MHz band on Intelsat 30 will not transmit in these bands and Intelsat agrees to

accept any level of interference into those earth stations from fixed service stations in the band.

Accordingly, the earth stations operating in these bands pose no interference concerns with

respect to co-frequency fixed service stations.

         Intelsat also agrees to abide by the customer notification requirements that the

International Bureau has previously imposed when granting waivers of NG104 and footnote 2 of

Section 25.202(a)(1).16 Intelsat will inform its customers in writing, including any customers

receiving end-user services from resellers accessing capacity on Intelsat 30, of the potential for

interference from fixed service operations in the 11450-11700 MHz band.




14
  See The Boeing Company, Order and Authorization, 16 FCC Rcd 22645, 22651 (Int’l Bur. &
OET 2001); Application of Fugro-Chance, Inc. for Blanket Authority to Construct and Operate a
Private Network of Receive-Only Mobile Earth Stations, Order and Authorization, 10 FCC Rcd
2860 (Int’l Bur. 1995) (authorizing MSS in the C-band); see also Application of Motorola
Satellite Communications, Inc. for Modification of License, Order and Authorization, 11 FCC
Rcd 13952-13956 (Int’l Bur. 1996) (authorizing service to fixed terminals in bands allocated the
mobile satellite service).
15
     EchoStar 83° Waiver, ¶ 13.
16
   See, e.g., Intelsat North America Request for Waiver, File No. SAT-MOD-20050610-00122, 3
(stamp grant with conditions Sept. 30, 2005); EchoStar 83º Waiver, ¶ 13.


                                                  -6-


               D. Operational Frequencies

         The following chart shows the frequencies that will be used by the Intelsat 30 and Intelsat

31 satellites at 95.1º W.L., as well as the frequencies that are currently used by the Galaxy 3C

satellite at 95.05° W.L.

                                    Galaxy 3C                   IS-30                     IS-31
      5925 – 6425                       
      6425 – 6675                                                                        
      6675 – 6725                                                                         
      13750– 14000                                                                       
      14000 – 14500                                                                      

      3400 – 3700                                                                         
      3700 – 4200                        
      10950 – 11200                                                                       
      11450 – 11700                                                                      
      11700 – 12200                                                                      


         All of the existing frequencies on Galaxy 3C except for the 5925-6425 MHz and 3700-

4200 MHz band are also on Intelsat 30. In addition, Intelsat 30 contains new frequencies at

6675-6725 MHz, 3400-3700 MHz, and 10950-11200 MHz that are not currently on the Galaxy

3C satellite. The 3400-3600 MHz band will not be used in the United States. Intelsat

understands that the band 3650-3700 MHz may only be used in the United States on a secondary

basis, except with respect to grandfathered earth stations.

               E. Milestone Demonstration and Request for Bond Reduction

         Intelsat 30 will be subject to the milestone and bond posting requirements set forth in

Sections 25.164 and 25.165 of the Commission’s rules because the 6675-6725 MHz, 3400-3700

MHz, and 10950-11200 MHz frequencies that are on Intelsat 30 are not on the Galaxy 3C

satellite.17


17
     47 C.F.R. §§ 25.164 and 25.165.


                                                 -7-


          In accordance with Section 25.164(c)-(e) of the Commission’s rules,18 Intelsat is

providing with this application documentation to demonstrate that it has met the first milestone

required of a geostationary satellite. Specifically, Intelsat is providing a confidential copy of its

construction contract, along with a request for confidential treatment under Section 0.457 and

0.459 of the FCC’s rules.19

          The Commission allows GSO licensees to reduce their bond amounts by 25 percent each

time they meet a satellite milestone.20 Accordingly, Intelsat requests that the Commission

determine that the first milestone for Intelsat 30 has been satisfied and reduce the $3,000,000

bond amount by 25 percent to $2,250,000.

 II.      GRANT OF THIS APPLICATION WILL SERVE THE PUBLIC INTEREST

          Grant of this application will serve the public interest by ensuring that additional capacity

is available to serve the South American region from the nominal 95.1° W.L. orbital location.

The Intelsat 30 capacity will allow an Intelsat customer to greatly expand its service offering in

the region, for the benefit of consumers. In addition, the excess capacity will ensure that this

customer has back-up capacity available in the event it is needed.



18
     47 C.F.R. § 25.164(c)-(e).
19
     47 C.F.R. §§ 0.457 and 0.459.
20
  47 C.F.R. § 25.165(d); Amendment of the Commission’s Space Station Licensing Rules and
Policies, First Report and Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd
10760, ¶ 172 (2003); Amendment of the Commission’s Space Station Licensing Rules and
Policies, First Order on Reconsideration and Fifth Report and Order, 19 FCC Rcd 12637, ¶ 48
(2004) (reducing GSO bond requirement to $3 million but noting that “GSO licensees will
continue to be allowed to reduce their bond amount by 25 percent each time they meet a
milestone.”); Star One S.A., Petition for Declaratory Ruling to Add the Star One C1 Satellite a
65º W.L. to the Permitted Space Station List, 19 FCC Rcd 16334, ¶ 15 (Int’l Bur. 2004)
(“Licensees may reduce the amount of the bond upon meeting each milestone.”).




                                                   -8-


III.   ITU COST RECOVERY

       Intelsat is aware that processing fees are currently charged by the ITU for satellite filings,

and that Commission applicants are responsible for any and all fees charged by the ITU.21

Intelsat is aware of and unconditionally accepts this requirement and responsibility to pay any

ITU cost recovery fees associated with the ITU filings that the Commission makes on behalf of

Intelsat for the satellite proposed in this Application, as well as any ITU filings associated with

any satellite system for which Intelsat may request authorization at a later date.

IV.    10950-11200 MHZ, 11450-11700 MHZ, 13750-14000 MHZ, AND 3600-3650 MHZ
       FREQUENCY BANDS

       Intelsat understands that operations in the 10950-11200 MHz, 11450-11700 MHz, 13750-

14000 MHz, and 3600-3650 MHz frequency bands are subject to certain limitations and

obligations, which Intelsat accepts and will fulfill. Specifically, for operations in the 10950-

11200 MHz frequency band, Intelsat accepts the following conditions:


              Operations in the 10.95-11.2 GHz frequency band shall comply with the terms of
               footnote US211 to the United States Table of Frequency Allocations, 47 C.F.R. §
               2.106, US211, which urges applicants for airborne or space station assignments to
               take all practicable steps to protect radio astronomy observations in the adjacent
               bands from harmful interference.

              Operations in the 10.95-11.2 GHz frequency band is limited to international
               operations in accordance with footnote NG 104 to the United States Table of
               Frequency Allocations, 47 C.F.R. 2.106, NG 104, and footnote 2 of Section
               25.202(a)(1) of the Commission’s rules, 47 C.F.R. § 25.202(a)(1).

       In the 11450-11700 MHz frequency band, Intelsat accepts the following conditions:

              Intelsat’s use of the 11450-11700 MHz band (Earth-to-space) is subject to
               footnote US211 to the United States Table of Frequency Allocations, 47 C.F.R. §
               2.106, US211, which urges applicants for airborne or space station assignments to


21
 See Implementation of ITU Cost Recovery Charges for Satellite Network Filings, Public
Notice, DA 01-2435 (Oct. 19, 2001).


                                                 -9-


               take all practicable steps to protect radio astronomy observations in the adjacent
               bands from harmful interference, consistent with footnote US74.

       In the 13750-14000 MHz frequency band, Intelsat accepts the following conditions:

              In the 13750-14000 MHz band (Earth-to-space), receiving space stations in the
               fixed- satellite service shall not claim protection from radiolocation transmitting
               stations operating in accordance with the United States Table of Frequency
               Allocations.

              Pursuant to footnote US337 of the United States Table of Frequency Allocations,
               47 C.F.R. § 2.106, any earth station in the United States and its possessions
               communicating with the Intelsat 30 space station in the 13750-14000 MHz band
               (Earth-to-space) is required to coordinate through National Telecommunications
               and Information Administration’s (“NTIA”) Interdepartment Radio Advisory
               Committee's (IRAC’s) Frequency Assignment Subcommittee (“FAS”) to
               minimize interference to the National Aeronautics and Space Administration
               Tracking and Data Relay Satellite System, including manned space flight.

              Operations of any earth station in the United States and its possessions
               communicating with the Intelsat 30 space station in the 13750-14000 MHz band
               (Earth-to-space) shall comply with footnote US356 to United States Table of
               Frequency Allocations, 47 C.F.R. § 2.106, US356 which specifies a mandatory
               minimum antenna diameter of 4.5 meters and a non-mandatory minimum and
               maximum equivalent isotropically radiated powers (e.i.r.p.). Operations of any
               earth station located outside the United States and its possessions communicating
               with the Intelsat 30 space station in the 13750-14000 MHz band (Earth-to-space)
               shall be consistent with footnote 5.502 to the ITU Radio Regulations, which
               allows a minimum antenna diameter of 1.2 meters for earth stations of a
               geostationary satellite orbit network and specifies mandatory power limits.

              Operators of earth stations accessing the Intelsat 30 space station in the 13750-
               14000 MHz band are encouraged to cooperate voluntarily with the National
               Aeronautics and Space Administration (NASA) in order to facilitate continued
               operation of NASA’s Tropical Rainfall Measuring Mission (TRMM) satellite.22


22
  NASA’s TRMM satellite system radar in the 13.793-13.805 GHz band remains operational
and is a highly valuable and visible United States asset with a broad range of international users.
Accordingly, NTIA has requested cooperation from the Commission and non-Federal
Government entities in providing assistance in reducing interference with the TRMM radar.
Specifically, NTIA requests that FSS earth stations in the 13.793 - 13.805 GHz band located
south of 39° N. and east of 110° W. operate with emission levels below —150 dBW/600 kHz at
the TRMM space station receiver. Letter from Frederick R. Wentland, Acting Associate
Administrator, Office of Spectrum Management, NTIA, to Don Abelson, Chief, International
Bureau, FCC (February 28, 2002). Considering the secondary nature of the TRMM operation,
NTIA’s request is not a condition of this authorization. The Commission, however, urges all


                                               -10-


        In the 3600-3650 MHz frequency band, Intelsat accepts the following condition:

               The operation of the Intelsat 30 space station in the 3600-3650 MHz band (space-
                to-space) is limited to international operations in accordance with footnote US
                245 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US
                245.

 V.     CONCLUSION

        Based on the foregoing, Intelsat respectfully requests that the Commission grant this

satellite application.


                                              Respectfully submitted,

                                              /s/ Susan H. Crandall

                                              Susan H. Crandall
                                              Assistant General Counsel
                                              Intelsat Corporation

Jennifer D. Hindin
Colleen King
WILEY REIN LLP
1776 K Street, N.W.
Washington, DC 20006

October 25, 2012




operators of earth stations accessing the Intelsat 30 space station in the 13.75 - 14.0 GHz band to
cooperate voluntarily with NASA in order to facilitate continued operation of the TRMM
satellite.


                                               -11-


                                           Exhibit A
               FCC Form 312, Response to Question 34: Foreign Ownership
        The Commission previously approved foreign ownership in Intelsat License LLC
(“Intelsat”), in the Intelsat-Serafina Order.1 In December 2009 and October 2011, the
Commission also approved pro forma changes in Intelsat’s foreign ownership.2 There have been
no other material changes to Intelsat’s foreign ownership since the date of the Intelsat-Serafina
Order.




1
      Intelsat Holdings, Ltd. and Serafina Holdings Limited, Consolidated Application for
Consent to Transfer of Control of Holders of Title II and Title III Authorizations, Memorandum
Opinion and Order, 22 FCC Rcd 22, 151 (2007).
2
       See Intelsat North America LLC, Intelsat LLC, PanAmSat Licensee Corp., PanAmSat H-2
Licensee Corp., and Intelsat New Dawn Company, Ltd., Applications for Pro Forma Transfer of
Control, File Nos. SAT-T/C-20091125-00128, SAT-T/C-20091125-00124, SAT-T/C-20091125-
00127, SAT-T/C-20091125-00125, SAT-T/C-20091125-00126, SES-T/C-20091125-01505,
SES-T/C-20091125-01502, SES-T/C-20091125-01506, SES-T/C-20091125-01504 and SES-
T/C-20091125-01503 (granted Dec. 3, 2009); Intelsat Application for Pro Forma Transfer of
Control, File Nos. SAT-T/C-20110810-00160, SAT-T/C-20110811-00161, SES-T/C-20110811-
00948, SES-T/C-20110812-00963 (granted Oct. 13, 2011), and 0004825139 (granted Oct. 19,
2011).


                                             Exhibit B
             FCC Form 312, Response to Question 36: Cancelled Authorizations
Intelsat License LLC (“Intelsat”) has never had an FCC license “revoked.” However, on June
26, 2000, the International Bureau “cancelled” two Ka-band satellite authorizations issued to a
former Intelsat entity, PanAmSat Licensee Corp. (“PanAmSat”),3 based on the Bureau’s finding
that PanAmSat had not satisfied applicable construction milestones.4 In that same order, the
Bureau denied related applications to modify the cancelled authorizations. PanAmSat filed an
application for review of the Bureau’s decision, which the Commission denied, and subsequently
filed an appeal with the United States Court of Appeals for the District of Columbia Circuit,
which was dismissed in January 2003 at PanAmSat’s request. Notwithstanding the fact that the
Bureau’s action does not seem to be the kind of revocation action contemplated by question 36,
Intelsat is herein making note of the decision in the interest of absolute candor and out of an
abundance of caution. In any event, the Bureau’s action with respect to PanAmSat does not
reflect on Intelsat’s basic qualifications, which are well-established and a matter of public record.




3
       All licenses previously held by PanAmSat Licensee Corp. have been assigned to Intelsat
License LLC. See IBFS File Nos. SAT-ASG-20101203-00252 (granted Dec. 23, 2010), SES-
ASG-20101203-0150 (granted Dec. 20, 2010), and SES-ASG-20101206-01502 (granted Dec.
20, 2010).
4
         See PanAmSat Licensee Corp., Memorandum Opinion and Order, 15 FCC Rcd 18720 (IB
2000).


                                          Exhibit C
                          FCC Form 312, Response to Question 40:
                Officers, Directors, and Ten Percent or Greater Shareholders

The officers and directors/managers of Intelsat License LLC are as follows:
Officers:
Michael McDonnell, Chairman
Flavien Bachabi, Deputy Chairman
Phillip Spector, Secretary
Simon Van De Weg, Director, Finance

Board of Managers:
Michael McDonnell
Flavien Bachabi
Phillip Spector

The business address of all Intelsat License LLC officers and members of the Board of Managers
is:

4 rue Albert Borschette
L-1246 Luxembourg

Intelsat License LLC is a Delaware limited liability company that is wholly owned by Intelsat
License Holdings LLC, also a Delaware limited liability company. Intelsat License Holdings
LLC is wholly owned by Intelsat Jackson Holdings S.A., a Luxembourg company. Intelsat
Jackson Holdings S.A. is wholly owned by Intelsat (Luxembourg) S.A., a Luxembourg
company. Intelsat (Luxembourg) S.A. is wholly owned by Intelsat S.A., a Luxembourg
company. Intelsat S.A. is wholly owned by Intelsat Holdings S.A., a Luxembourg company.
Intelsat Holdings S.A. is wholly owned by Intelsat Investment Holdings S.à r.l., a Luxembourg
company. Intelsat Investment Holdings S.à r.l. is wholly owned by Intelsat Global Holdings
S.A., a Luxembourg company. Each of these entities may be contacted at the following address:
4 rue Albert Borschette, L-1246 Luxembourg.
Intelsat Global Holding S.A.’s ownership was approved by the Commission as part of the
Intelsat-Serafina Order and the recent Intelsat Pro Forma and is incorporated by reference. See
Intelsat Holdings, Ltd. and Serafina Holdings Limited, Consolidated Application for Consent to
Transfer of Control of Holders of Title II and Title III Authorizations, Memorandum Opinion and
Order, 22 FCC Rcd 22,151 (2007) (“Intelsat-Serafina Order”); Intelsat Application for Pro
Forma Transfer of Control, File Nos. SAT-T/C-20110810-00160, SAT-T/C-20110811-00161,
SES-T/C-20110811-00948, SES-T/C-20110812-00963 (granted Oct. 13, 2011), and 0004825139
(granted Oct. 19, 2011) (“Intelsat Pro Forma”). On May 16, 2012, the International Bureau
granted an application to transfer control of Intelsat pursuant to a public offering of newly issued
voting shares by Intelsat, subsequent voting share sales by current shareholders and possible
private placements of newly issued voting shares. In the Matter of Intelsat Global Holdings,
S.A., Applications to Transfer Control of Intelsat Licenses and Authorizations from BC Partners
Holdings Limited to Public Ownership, Order, DA 12-768 (rel. May 16, 2012). This transaction
has not yet been consummated.



Document Created: 2012-10-25 14:57:23
Document Modified: 2012-10-25 14:57:23

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