Attachment GTD LETTER

GTD LETTER

DECISION submitted by INTESEL NORTH AMERICA LLC

GRANT LETTER

2004-09-30

This document pretains to SAT-MOD-20040727-00148 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2004072700148_398484

July 27,2004



Ms. Marlene H. Dortch
Secretary
Federal Communications Commission
236 Massachusetts Avenue, N.E. Suite 110
Washington, D.C. 20002

          Re:     Intelsat LLC Request for Extensior of Launch Milestone Date for IA-8; Call Sign
                  S2 160; File No. SAT-MOD-20030 ;07-00097

Dear Ms. Dortch:

        Intelsat North America LLC (“Intelsat”), F irsuant to Section 25.1 17(e) of the Federal
Communications Commission’s (“Commission” c . “FCC”) rules, hereby requests an extension
of the launch milestone date for the Intelsat Amer: bas (IA-8) satellite (formerly known as
Telstar-8).’ Specifically, Intelsat requests that the       milestone be extended for six months
until March 30, 2005. As verified below, this              an extension of the launch milestone is
necessary due to unforeseeable circumstances                      control. In addition, grant of the
requested extension would serve the public


                                                    \
       The Commission originally authorized Lor 1 SpaceCom Corporation (“Loral”) to launch
and operate the former Telstar-8 satellite.* On Oct ber 27,2003, the International Bureau issued
an order granting Loral extensions of both the con         and launch milestone dates for the
~atellite.~
          The satellite’s current launch milestone              30, 2004.4 On March 17,2004,




                                                    4
  Intelsat has filed this request and an FCC Form 3 2 electronically via the International
Bureau’s Filing System. Intelsat has sent an FCC orm 159 with fee code “CRY” and a check in
the amount of $705.00 to Mellon Bank in Pittsburg/h.

2 Loral Space & Communications Ltd., Memorandum Opinion and Order, 11 FCC Rcd 20441
(Int’l Bur. 1996).

  Loral SpaceCom Corporation,                           Application for ModiJication of Fixed
Satellite Service Space Station                         Request for Extension of Milestones and
Waiver or Petition for                                  Opinion and Order, 18 FCC Rcd 2 1851
(Int’l Bur. 2003).

    Id. at para. 14.


Ms. Marlene Dortch, Secretary
July 27, 2004
Page 2


Intelsat acquired the Telstar 8 satellite from Loral dnd renamed it Intelsat Americas 8 (IA-8):
As discussed below, good cause exists to extend thb IA-8 launch milestone until March 30, 2005.

        Intelsat is hlly committed to launching an             the IA-8 satellite. Construction of
the satellite is complete.6 However, due to                                Intelsat’s control
recently encountered by Sea Launch                                     which is the launch
provider for IA-8, the satellite’s                                       and will not occur by the
current September 30,2004




                                                     1
         On June 29,2004 (GMT), a Sea Launch Ze it-3SL launch vehicle lifted off from the
company’s equatorial launch site carrying Loral’s elstar- 18 communications ~atellite.~     The
upper stage of the launch vehicle, however, shut d wn about 54 seconds early, which caused the
satellite to be released into an orbit approximately 4,000 km short of the 35,786 km target
apogee.8 The cause of the premature shutdown of he upper stage is under investigation by Sea




                                                     i
Launch.’ Until that investigation has been comple d, Sea Launch has temporarily halted
launches aboard the Zenit-3SL rocket, including th launch of IA-8. Although Sea Launch has
indicated that it currently expects to complete the I -8 launch this year, and has indicated a
tentative launch date of 3 1 October 2004, the actua launch date will depend on the results of the
Telstar- 1 8 anomaly investigation, including clear d termination of the root cause of the anomaly
as well as the implementation of the appropriate co ective actions. The anomaly investigation
has just been initiated by Sea Launch and Intelsat c       predict how long this process will take.




2004), available at http://www.boeinrz.com/news/re..eases/2004/q3/nr    040702m.html; See also
Loral News Release, Loral-Built Telstar 18 Satellite Launched (“Boeing News Release”);
Satellite to Achieve Its Specified Life (dated June 29, 2004), available at
http://www.loral.com/inthenews/O4O629.     html.


Ms. Marlene Dortch, Secretary
July 27,2004
Page 3


For these reasons, Intelsat seeks a six-month exten ion to account for a possible further slip in
the launch schedule.

        Because this problem concerning the        launch vehicle was clearly outside of
Intelsat’s control, the six-month launch                   sought herein is warranted.“ As
noted above, the satellite is complete                        to launch it in August until the
launch vehicle problem described                                the Telstar- 18 launch. Thus,
this request does not raise a warehousing concern.

        For the reasons stated above, Intelsat LLC              requests that the Commission
extend the launch milestone for the IA-8 satellite                        Should the Commission
staff have any questions concerning this request,                         D. Hindin of Wiley Rein
& Fielding LLP at (202) 719-4975.

                                              Resp4tfully submitted,




l o 47 C.F.R. 25.1 17(e). The Commission has             quests for milestone extensions “when
the delay in implementation is due to circums            ond the control of the licensee.”
American Telephone and Telegraph Company              ation for Modijcation of Construction
Permit and License for the Telstar 402 Satell             cd 2607,2607 (1994) (Order and
Authorization); See GE American Communi                     equest for Extension of Time to
Construct, Launch, and Operate a Ka-band                      in the Fixed-Satellite Service, 16
FCC Rcd 11038 (2001) (Order and Authori                        instance where the Commission
has denied a milestone extension request, const        of the satellite either had not begun or was
not continuing, thus raising questions regar                    intention to proceed.”).
11
  The Commission’s policy of requiring a                       ne schedule is intended to
prevent orbital locations from being ‘ware                  while they decide whether to
proceed with their plans. Application of                     ications, Inc. For Orbital
Reassignment and for Modijication of A                        t and Launch the Satcom H-1
Domestic Fixed Satellite, 7 FCC Rcd 5 169,5 170 (1/992) (Memorandum Opinion and Order).



Document Created: 2004-10-01 07:48:27
Document Modified: 2004-10-01 07:48:27

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