Attachment Intelsat 8 SAT-MOD-20130830-00110

Attachment Intelsat 8

This document pretains to SAT-MOD-20130830-00110 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2013083000110_1009872

Before the
Federal Communications Commission
Washington, DC 20554

In the Matter of
File No. SAT-MOD-______________
Intelsat License LLC

Application to Modify Authorization for
Intelsat 8 (S2460)

APPLICATION OF INTELSAT LICENSE LLC TO MODIFY
AUTHORIZATION FOR INTELSAT 8

Intelsat License LLC (“Intelsat”), pursuant to Section 25.117 of the rules of the Federal

Communications Commission (“Commission” or “FCC”), 47 C.F.R. § 25.117, hereby seeks to

modify the authorization for the Intelsat 8 satellite (Call Sign S2460).1 Specifically, Intelsat

seeks to extend the license term for the Intelsat 8 satellite—and extend all previously granted

waivers—for approximately three years through June 30, 2016, which is the current projected

end of service life taking into account the satellite’s most recent relocation to 169.0º E.L.2

In accordance with the requirements of the Commission’s rules,3 this application has

been filed electronically as an attachment to FCC Form 312. Intelsat incorporates by reference

1
Intelsat 8 was formerly known as PAS-5. See Letter from Susan H. Crandall, Intelsat, to
Marlene H. Dortch, FCC, Notification of New Space Station Names (filed Jan. 8, 2007).
2
See Policy Branch Information; Actions Taken, Report No. SAT-00968, File Nos. SAT-MOD-
20120619-00100 and SAT-AMD-20120815-00131 (Aug. 16, 2013) (Public Notice). Intelsat
was granted waivers of Sections 2.106 and 25.202(a)(1) of the Commission’s rules, 47 C.F.R. §
2.106 and 25.202(a)(1).
3
47 C.F.R. § 25.117(c).

1

the technical information previously provided regarding the operations of Intelsat 8.4 Consistent

with Section 1.62 of the Commission’s rules, Intelsat will continue to operate the Intelsat 8

satellite pursuant to the terms and conditions of its expiring license,5 until such time as the

Commission makes a determination with respect to this request.6

I. REQUEST FOR EXTENSION OF LICENSE TERM

Intelsat seeks to extend the license term for the Intelsat 8 satellite for approximately three

years through June 30, 2016. The Intelsat 8 satellite was launched on November 3, 1998, and

placed into service in December 4, 1998.7 Pursuant to Sections 25.121(a) and (d)(1) of the

Commission’s rules, the license term for Intelsat 8 will expire on December 4, 2013.8 That

expiration date is well before the expected end of service life of the satellite. Taking into

account the satellite’s most recent relocation to 169.0º E.L., Intelsat’s most recent estimated end

service life for the Intelsat 8 satellite is June 30, 2016.9

4
The most recent technical information submitted to the Commission relating to Intelsat 8 is
found in the modification application and amendment filed to relocate the Intelsat 8 satellite to
169.0° W.L. See Policy Branch Information; Satellite Space Applications, Accepted for Filing,
Report No. SAT-00895, File No. SAT-AMD-20120815-00131 (Public Notice) (Sept. 7, 2012);
Policy Branch Information; Satellite Space Applications, Accepted for Filing, Report No. SAT-
00883, File No. SAT-MOD-20120619-00100 (Public Notice) (Jul. 20, 2012). These applications
recently were granted. See supra n. 2.
5
See supra n.2.
6
47 C.F.R. § 1.62.
7
PanAmSat Licensee Corp., Order and Authorization, 14 FCC Rcd 2719 (1998); see also Letter
from Joseph A. Godles, Attorney for PanAmSat Corporation, to Marlene H. Dortch, Federal
Communications Commission, PanAmSat Corporation Annual Status Report, (Jul. 1, 2002)
(stating that the satellite was put into service on December 4, 1998).
8
47 C.F.R. §§ 25.121(a) & (d)(1).
9
See Letter from Jennifer Hindin, Counsel for Intelsat License LLC, to Marlene H. Dortch, FCC,
Application to Modify Authorization for Intelsat 8; File No. SAT-MOD-20120619-00100; Call
2

II. PUBLIC INTEREST SHOWING

Grant of this modification application to extend the Intelsat 8 license term—and

previously granted waivers10—will serve the public interest by enabling customers to continue

receiving service from this operational satellite. The Intelsat 8 satellite has at least three years of

useful life remaining. There are no single points of failure on Intelsat 8 that would result in an

inability to de-orbit the satellite. Additionally, the satellite’s TT&C functions are operating

nominally. Extending the license term will promote the continued efficient use of orbital

resources and is consistent with recent decisions by the Commission to extend satellite license

terms.11

In a 2012 modification application, Intelsat provided a post-mission disposal plan for the

Intelsat 8 satellite.12 This plan demonstrates that the Intelsat 8 satellite has sufficient fuel to

dispose of the satellite by moving it to a minimum altitude of 150 kilometers above the

geostationary arc. 13 Intelsat has reserved 28.9 kg kilograms of fuel for this purpose.

Sign S2460 (April 4, 2013); see also Amendment No. 9 to Form F-1 Registration Statement,
Intelsat Global Holdings S.A. (Apr. 9, 2013), available at
http://www.sec.gov/Archives/edgar/data/1525773/000119312513147847/d204908df1a.htm.
10
For operation of the Intelsat 8 satellite at 169.0º E.L., Intelsat has received waivers of Sections
2.106 and 25.202(a)(1), 47 C.F.R. § 2.106 and 25.202(a)(1). See supra n. 2.
11
See, e.g., Policy Branch Information; Actions Taken, Report No. SAT-00905, DA 12-1680,
File No. SAT-MOD-20120629-00109 (Oct. 19, 2012) (Public Notice) (extending license terms
of an SES satellite for an additional five years); Policy Branch Information; Actions Taken,
Report No. SAT-00664, DA 10-236, File No. SAT-MOD-20091119-00123 (Feb. 5, 2010)(Public
Notice) (extending license term of Sirius XM satellites for an additional seven years).
12
See Policy Branch Information; Satellite Space Applications, Accepted for Filing, Report No.
SAT-00883, File No. SAT-MOD-20120619-00100 (Public Notice) (Jul. 20, 2012).
13
The Commission has found that satellites launched prior to March 18, 2002, such as Intelsat 8,
would be designated as grandfathered satellites not subject to a specific disposal altitude. See
Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567, 11600-01 (2004).
3

III. CONCLUSION

For the reasons set forth above, Intelsat respectfully requests that the Commission grant

this modification application.

Respectfully submitted,

Intelsat License LLC

By: /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, D.C. 20006

August 30, 2013

4

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).
5

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).
6

Document Created: 2019-04-12 12:44:20
Document Modified: 2019-04-12 12:44:20

© 2025 FCC.report
This site is not affiliated with or endorsed by the FCC