Attachment Intelsat - Grant May

Intelsat - Grant May

DECISION submitted by IB,FCC

Grant

2012-05-25

This document pretains to SAT-RPL-20111222-00245 for Replacement Application on a Satellite Space Stations filing.

IBFS_SATRPL2011122200245_953317

                                                                                                  File # gat—RPL—2oil1222—co245
            SAT—RPL—20111222—00245           1B2011005209
$2850
Intelsat License LLC
INTELSAT 19                                                                                       Call Sign $2850_ Grant Date_O5725/12
                                                                                                  (or other identifier)
                                                                                                          see               Term Dates      ©S€C€.5        Approved by OMB
                                                                             Sttem
                                                                                                  From conditions                   To:          heouves         3060—0678
                                                                         GRANTED*
                                                                  |
                                                                  I




                                                                  &
                                                                       International Bureau       Approved:
        Date & Time Filed: Dec 22 2011 1:15:01:376PM                                                                      Step        . Douad|
        File Number: SAT—RPL—20111222—00245
                                                                      gewishcondifions        _
                                                                                                                          Chic€] Saellde %ch Branch
        Callsign/Satellite ID: $2850

                                  APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                                                  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 Launch and Operate Intelsat 19, A Replacement Satellite, at 166.0 E.L.
          1—8. Legal Name ofApplicant
                       Name:          Intelsat License LLC                  Phone Number:                                   202—944—7848
                       DBA Name:                                            Fax Number:                                     202—944—7870
                       Street:        c/o Intelsat Corporation              E—Mail:                                         susan.crandall@intelsat.com
                                      3400 International Drive, N.W.

                       City:          Washington                            State:                                           DC
                       Country:       USA                                   Zipcode:                                        20008           —3006
                       Attention:     Susan H Crandall


                                          Attachment to Grant
                               IBFS File No. SAT—RPL—20111222—00245
                                            Call Sign $2850

The application of Intelsat License LLC (Intelsat) for authority to construct, launch and operate a C—/Ku—
band space station, to be known as Intelsat 19, at the 166.0° E.L. orbital location, IBFS File No.
SAT—RPL—20111222—00245, as supplemented, IS GRANTED.‘ Accordingly, Intelsat is granted
authority to operate Intelsat 19 at the 166.0° E.L. orbital location to provide Fixed—Satellite Services (FSS)
in the 3700—4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), 12.25—12.75 GHz (space—to—
Earth), and 14.0—14.5 GHz (Earth—to—space) frequency bands and to conduct telemetry, tracking, and
command operations using the center frequencies of 14.0005 GHz and 14.003 GHz (Earth—to—space) and
12.2535 GHz, 12.254 GHz, 12.256 GHz and 12.2565 GHz (space—to—Earth). This authorization shall be in
accordance with the technical specifications set forth in Intelsat‘s application, Federal Communications
Commission (Commission) rules not waived herein, and is subject to the following conditions:
         1.      Intelsat shall 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 of the frequency assignments of other administrations. See 47 C.F.R. § 25.111(b).
        2.      Intelsat is obliged to comply with the applicable laws, regulations, rules, and licensing procedures
of any country in which it seeks to provide service.
         3.      Intelsat shall operate Intelsat 19 at the 166.0° E.L. orbital location in compliance with all existing
or future coordination agreements for this location.
         4.        While at the 166.0° E.L. orbital location, Intelsat shall maintain Intelsat 19 with an east/west
longitudinal station—keeping tolerance of +/— 0.05 degrees.
        5.       Intelsat‘s request for a waiver of Section 25.210(a)(3) of the Commission‘s rules, 47 C.F.R. §
25.210 (a)(3), IS GRANTED. Section 25.210(a)(3) requires all FSS space stations used for domestic service in
the 3700—4200 MHz and 5925—6425 MHz bands to be capable of switching polarization sense upon ground
command. The Commission requires polarity—switching capability for two reasons: (1) to provide U.S.—licensed
satellites with the flexibility to operate at different orbital locations, and (2) to mitigate potential interference
between adjacent fixed—satellite systems transmitting analog television signals. This waiver grant is based upon a
finding that the ability to switch polarization is not currently necessary to protect other satellites at adjacent orbital
locations from harmful interference, because there is no co—frequency C—band space station operating within two
degrees of Intelsat‘s proposed location. Intelsat states that the nearest co—frequency C—band space station is
Intelsat 5 at 169.0° E.L. As a condition of granting this waiver, Intelsat must accommodate future satellite
networks that are compliant with Section 25.210(a)(3). Further, Intelsat must operate Intelsat 19 pursuant to any
existing or future coordination agreements for this location.



‘ The application was placed on Public Notice as accepted for filing on February 10, 2012. See Policy Branch
Information, Satellite Space Applications Acceptedfor Filing, Public Notice, Report No. SAT—00843, (IBFS File
No. SAT—RPL—20111211—00245). Intelsat filed a supplemental letter stating that it no longer seeks regular
Commission authorization to operate Intelsat 19 in the 12.25—12.75 GHz frequency band for FSS in Region 2. See
Letter from Susan H. Crandall Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary, FCC,
dated May 8, 2012.

> Legal Narrative at 5.


                                          Attachment to Grant
                               IBFS File No. SAT—RPL—20111222—00245
                                            Call Sign S$2850

          6.     Intelsat‘s request for a waiver of Section 25.210(i)(1) of the Commission‘s rules, 47 C.F.R. §
25.210(i)(1), IS GRANTED. Section 25.210(i)(1) requires that satellites be designed to provide a cross—
polarization isolation such that the ratio of the on—axis co—polar gain to the on—axis cross—polar gain of the antenna
in the assigned frequency band will be at least 30 dB within its primary coverage area. Intelsat states that Intelsat
19 does not meet the 30 dB requirement within a limited portion of the coverage areas of the Intelsat 19‘s West
Hemi, North East Pacific and South West Pacific transmit beams." Intelsat states that the level of isolation of the
non—compliant Intelsat 19 beams is in excess of 26 dB.* Intelsat reports that this level was the best that the
satellite manufacturer could achieve without causing excessive degradation in the co—polarized gain of the beam
and/or in the size of its coverage area." We agree that waiver in this instance will not produce a significant
increase in interference, except to the applicant itself. As a condition of the waiver, Intelsat shall claim no more
protection from interference from other licensed radio—communication systems operating in accordance with the
Commission‘s rules than if its antennas met Section 25.210(i) of the rules.
        7.        This grant does not authorize Intelsat 19 to use the 12.25—12.75 GHz frequency band is
not authorized in International Telecommunication Union (ITU) Region 2.
         8.        Operations of Intelsat 19 to, from, or within the United States shall comply with the
power levels specified in Section 25.212 of the Commission‘s rules, 47 C.F.R. § 25.212, unless Intelsat
coordinates any operations using power levels exceeding the levels in Section 25.212 with all potentially
affected adjacent satellites within 6 degrees orbital separation of the 166.0° E.L. orbital location. Intelsat
shall inform the Commission of the power levels it has coordinated. In addition, Intelsat must inform all
affected earth station operators that Section 25.220 of the Commission‘s rules applies to operations that
exceed the power levels specified in Section 25.212. In no event shall the uplink power density level of
Intelsat 19‘s digital carriers exceed —38.7 dBW/Hz and the downlink EIRP density of such carriers exceed
—32 dBW/Hz for the C—band. Further, in no event shall the uplink power density of Intelsat 19‘s digital
carriers exceed —45 dBW/Hz and the downlink EIRP density of such carriers exceed —20 dBW/Hz for the
Ku—band.
         9.        Intelsat—19 must begin providing service at the 166.0° E.L. orbital location in the 3700—4200 MHz
(space—to—Earth), 5925—6425 MHz (BEarth—to Space), 12.25—12.75 GHz (space —to—Earth), and 14.0—14.5 GHz
(Earth—to—space) frequency bands before the satellite it is replacing, Intelsat 8 (Call Sign $2460), discontinues
service at the 166.0° E.L. orbital location." Failure to meet this milestone shall render this authorization to operate
in these frequency bands NULL and VOID.
         10.     The license term for the space station is 15 years and will begin on the date that Intelsat certifies
to the Commission that Intelsat 19 has been successfully placed into orbit and its operations fully conform to the
terms and conditions of this authorization. Intelsat is directed to file such certification within five business days
of Intelsat 19 being placed into operation at the 166.0° E.L. orbital location.



* Legal Narrative at 3; Engineering Statement at pages 5 and 6, and Exhibits 5D—1 through 5D—3.
* Legal Narrative at 4.
° 1d.
° Intelsat 8 (Call Sign 2460) was launched in November 1998. See PanAmSat Licensee Corp. Application for
Authority to Construct, Launch and Operate a Hybrid International Communications Satellite, 14 FCC Red 2719
(1998); Policy Branch Information: Actions Taken, Report No. SAT—00358, DA 06—980, File No. SAT—MOD—
20060228—00017 (May 5, 2006) (Public Notice). At the time of launch, Intelsat 8 was named PAS—8 for commercial
purposes, but PAS—5 for FCC filings. In 2007, Intelsat filed a letter notifying the Commission of New Space Station
Names at which time PAS—8/PAS—5 (Call Sign $2460) was renamed Intelsat 8. See Letter from Susan Crandall,
Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary, FCC, dated Jan. 8, 2007.


                                          Attachment to Grant
                               IBFS File No. SAT—RPL—20111222—00245
                                                Call Sign $2850

        11.      Intelsat is afforded 30 days from the date of release of this grant and authorization to decline this
authorization as conditioned. Failure to respond within this period will constitute formal acceptance of the
authorization as conditioned.

        12.     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 of the
Commission‘s rules or applications for reconsideration 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 public notice indicating that this action was taken.




                                               Tile # SAT— RPL—20l11222— 00245

                                               Call Sign $2850 GrantDate_O5/25/12.
                                               (or other identifier)
                                                       gee..           Term Dates    S€€ _
                                                                                          \'HOY)S
                                               From    CO!'dIhOflS           x To:

                    !   International Bureau   Approved:
                    seuwith conditions                             St          7 _Dual]
                                                                   Chief)    fellite R:l’icd Branc


  9—16. Name of Contact Representative
            Name:            Jennifer D Hindin                     Phone Number:                        202—719—4975
            Company:         Wiley Rein LLP                        Fax Number:                          202—719—7049
            Street:          1776 K Street, NW                     E—Mail:                             jhindin@wileyrein.com


            City:            Washington                            State:                               DC
            Country:         USA                                   Zipcode:                       ~    20006      —
            Attention:      Jennifer D Hindin                      Relationship:                       Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                    b.
classification that applies to thisfiling for    £;4 b1. Application for License of New Station
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 17b.                    (N/A) b3. Amendment to a Pending Application
                                                 (N/A) b4. Modification of License or Registration
  a.                                             (N/A) b5. Assignment of License or Registration
(N/A) al . Earth Station                         (N/A) b6. Transfer of Control of License or Registration
  & a2. Space Station                            (N/A) b7. Notification of Minor Modification
                                                 (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite

                                                g34 b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                , b10. Replacement Satellite Application — no new frequency bands
                                                {4 b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                «34 b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


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

17¢. Fee Classification     BNY — Space Station (Geostationary)


18. If this filing is in reference to an existing station, enter:
(a) Call sign of station:
    Not Applicable




19. If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                     (b) File number of pending application:

Not Applicable                                                          Not Applicable


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. Earth Exploration Satellite
D e. Direct to Home Fixed Satellite
D £. Digital Audio Radio Service
[:] g. Other (please specify)


21. STATUS: Choose thebutton next to the applicable status. Choose       22. If earth station applicant, check all that apply.
only one.                                                                Not Applicable
  C Common Carrier @ Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
       34 Connected to a Public Switched Network g*4 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.

 (N/A) a. Fixed Earth Station
 (N/A) b. Temporary—Fixed Earth Station
 (N/A) c. 12/14 GHz VSAT Network
 (N/A) d. Mobile Earth Station
 «) o. Geostationary Space Station.
 «4 f. Non—Geostationary Space Station
 y & Other (please specify)




26. TYPE OF EARTH STATION                FACILITY: Not Applicable
 PURPOSE OF MODIFICATION


 27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
 apply.)

 ENVIRONMENTAL POLICY


 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental     4 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.F.R. §§ 1.1308 and 1.1311, as an exhibit 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 aeronautical 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?                                y Yes @No




30. Is the applicant an alien or the representative of an alien?                                                          1 Ye @No £ N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                    y Yes @No N/A




32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by       4 Yes @No 3 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 controlled by any other corporation of which more than          @Yes No 3 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, and the 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?                             @ Yos £ 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 application or amendment had any FCC station authorization or license         @ Yes ; No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit 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    , 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,         Yes @ 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   ; 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 of the 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 g4 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 intend to use a non—U.S. licensed satellite to provide service in the United States? IfYes,     ; Yes @ No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing 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 25.114 of the rules of Federal Communications
     Commission, hereby applies to launch and operate a replacement C/Ku—band satellite,                                               to be
     known as Intelsat 19,             at the 166.0 E.L.           orbital location.


   Narrative & Exhibits



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 specifiedin 47 C.F.R. Part 25.
                                                                                                                              C 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.

                                                                                                                              C 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 by license 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 herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies 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.


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


  3 Individual
  C Unincorporated Association
  C Partnership
 C Corporation
 C Governmental Entity
 {&, Other (please specify)     Limited Liability Company


45. Name of Person Signing                                                46. Title of Person Signing
Susan H. Crandall                                                         Asst. General Counsel, Inelsat Corporation
47. Please supply any need attachments.
  1:                                              2:                                              3:




           WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                  (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).




Completed Schedule S




10


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The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of
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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC L&AW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.




11


            May 8, 2012



            FILED ELECTRONICALLY VIA IBFS

            Ms. Marlene H. Dortch, Secretary
            Federal Communications Commission
            445 12th Street, S.W.
INTELSAT.   Washington, DC 20554

                        Re:        Application for Authority to Launch and Operate Intelsat
                                   19, a Replacement Satellite, at 166.0° E.L.;
                                   File No. SAT—RPL—20111222—00245; Call Sign $2850

            Dear Ms. Dortch:

            Intelsat License LLC ("Intelsat") files this letter pursuant to Section 1.65 of
            the Federal Communications Commission‘s ("FCC" or "Commission")
            rules‘ to provide updated information regarding the above—referenced
            pending application for authority to launch and operate Intelsat 19 (call
            sign $2850) at 166.0° E.L. Intelsat 19 currently is scheduled to be
            launched on May 31, 2012, and will replace the Intelsat 8 satellite (call sign
            $2460), which is currently operating at 166.0° E.L.*

            In the Intelsat 19 Application, Intelsat requested authority to operate
            Intelsat 19 using the same Fixed—Satellite Service ("FSS") frequencies as
            the Intelsat 8 satellite it is replacing.* Intelsat no longer seeks permanent
            Commission authorization to operate Intelsat 19 in the 12250 — 12750
            MHz frequency band for FSS in Region 2.° All other technical parameters
            of the pending application remain unchanged. Intelsat respectfully requests
            that the Commission continue to process the pending Intelsat 19
            Application in light of this updated information.



            ! 47 C.F.R. § 1.65.
            * See Policy Branch Information; Satellite Space Applications Acceptedfor
            Filing, Report No. SAT—00843, File No. SAT—RPL—20111222—00245 (Feb.
            10, 2012) (Public Notice) ("Intelsat 19 Application").
            * See PanAmSat Licensee Corp. Applicationfor Authority to Construct,
            Launch and Operate a Hybrid International Communications Satellite, 14
            FCC Red 2719 (1998); Policy Branch Information; Actions Taken, Report
            No. SAT—00358, DA 06—980, File No. SAT—MOD—20060228—00017 (May
            5, 2006) (Public Notice).
            * See Intelsat 19 Application at 5.
            ° Intelsat will seek temporary authorization to operate in these frequencies
            in Region 2 if necessary.


            Intelsat Corporation
            3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F +1 202—944—7898


Ms. Marlene H. Dortch
May 8, 2012
Page 2

Please do not hesitate to contactthe undersigned if you have any questions.

Respectfully submitted,

OLJL,C/.LJLQ\
Sus;r; H. Crandall
Assistant General Counsel
Intelsat Corporation




cc:    Stephen Duall
       Jay Whaley



Document Created: 2012-05-25 14:53:21
Document Modified: 2012-05-25 14:53:21

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