Attachment Intelsat-Grant March

Intelsat-Grant March

DECISION submitted by IB,FCC

grant

2010-03-26

This document pretains to SAT-STA-20100323-00054 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2010032300054_808012

File # SAT— sih— 2010 0323 mo54 _ Call Sign $2804_ Grant Date_03/26/!0 _ o (or other identifier) mss $ From O¥2G/1C Toerm Dates period of Approved by OMB To: daygs __|4 3060—0678 | GRANTED® % /° y Date & Time Filed: Mar 23 2010 3:01:31:766PM *i ternational Bureau_| Approved: STWJ‘{” > ”D/‘é‘ ; gfiS;I?ber. SAT—STA—20100323—00054 | t — — — ded 40,. frong SV * +t . 2lZ;%/&Me felicy Branch 6 s va P FEDERAL COMMUNICATIONS COMMISSION APPLICATION FOR SPACE STATION SPECIAL TEMPORARY AUTHORITY FOR OFFICIAL USE ONLY APPLICANT INFORMATION Enter a description of this application to identify it on the main menu: Request for STA to Conduct IOT for Intelsat 25 (Call Sign $2804) at 31.5 W.L. 1. Applicant Name: Intelsat North America 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—STA—20100323—00054 Call Sign $2804 The request of Intelsat North America LLC (Intelsat) for special temporary authority (STA), IBFS File No. SAT—STA—20100323—00054, IS GRANTED. Accordingly, Intelsat is authorized to conduct in—orbit testing of the Intelsat 25 space station (Call Sign $2804) at the 31.5° W.L. orbital location using the 13750—14000 MHz (Earth—to—space) and 11450—11700 MHz (space—to—Earth) frequency bands for a period of 14 days, commencing on March 26, 2010. This authorization is granted in accordance with the terms, conditions, and technical specifications set forth in Intelsat‘s application, the Commission‘s rules, and the conditions set forth below. 1. All operations shall be on unprotected and non—harmful interference basis, i.e., Intelsat shall not cause harmful interference to, and shall not claim protection from, interference caused to it by any other lawfully operating station. 2. In the event of any harmful interference as a result of the operations of the Intelsat 25 space station during in—orbit testing at the 31.5° W.L. orbital location, Intelsat shall cease operations immediately upon notification of such interference and shall immediately inform the Commission, in writing, of such an event. 3. Intelsat shall maintain Intelsat 25 within an east/west longitudinal station—keeping tolerance of + 0.05 degrees of the 31.5° W.L. orbital location. 4. Operations of the Intelsat 25 space station at the 31.5° W.L. orbital location are limited to in—orbit testing and shall not include any provision of commercial services. 8: Intelsat is granted a waiver of Footnote NG104 to the U.S. Table of Frequency Allocations, Section 2.106 of the Commission‘s rules, 47 C.F.R. §2.106, to conduct IOT operations in the 11450—11700 MHz band (space—to—Earth) subject to conditions 1 & 2 above. 6. Any action taken or expense incurred as a result of operations pursuant to this STA is at Intelsat‘s own risk. 7. Grant of this authorization is without prejudice to any determination that the Commission may make regarding permanent operations of the Intelsat 25 space station at the 31.5° W.L. orbital location. See IBFS File No. SAT—A/O—20091223—00151. 8. 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. 34 file# ShT— ain— 2010 6323 — 000 Call Sign 382 90Y__ Grant Date_2__5__/5_(2_{_'_(:’__ (or other identifier) d w AMibEt Term Dates PCT®©A tros 52 f2/10 To: 14 days CGRANTE M International Bureau Approved: %/m i c _»———d yPe exmussstsend 5’7 en 3. Duaul!! *9 Lordifions Cnmel, Seellite Policy Branch

2. Contact Name: Intelsat North America LLC Phone Number: 202—944—7848 Company: Fax Number: 202—944—7870 Street: c/o Intelsat Corporation E—Mail: jhindin@wileyrein.com 3400 International Drive, N.W. City: Washington State: DC Country: USA Zipcode: 20008 — Attention: Susan H. Crandall Relationship: Legal Counsel (If your application is related to an application filed with the Commission, enter either the file number or the IB Submission ID of the related application. Please enter only one.) 3. Reference File Number or Submission ID 4a. 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). (e) Governmental Entity 3 Noncommercial educational licensee «4 Other(please explain): 4b. Fee Classification CRY — Space Station (Geostationary) 5. Type Request 3 Change Station Location {4y Extend Expiration Date @, Other 6. Temporary Orbit Location 7. Requested Extended Expiration Date

8. Description (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 North America LLC herein requests Special Temporary Authority for 14 days —— from March 25, 2010 through April 7, 2010 —— to conduct in—orbit testing in the 13750—4000 MHz {uplink) and 11450—11700 MHz (downlink) extended Ku—bands for the Intelsat 25 satellite (call sign $2804) at the 31.5 W.L. orbital location. 9. By checking Yes, the undersigned certifies that neither applicant nor any other party to the application is subject @, Yes y No 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. 10. Name of Person Signing 11. Title of Person Signing Susan H. Crandall Asst. Gen. Counsel, Intelsat Corporation 12. Please supply any need attachments. Attachment 1: STA Request Attachment 2: Attachment 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).

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 2 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 information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fec.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LaAW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507.

. March 23, 2010 «Ms. Marlene H. Dortch Secretary Federal Communications Commission 445 12"" Street, S.W. Washington, DC 20554 Re: Request for Special Temporary Authority for Intelsat 25 Call Sign: $2804 . Dear Ms. Dortch: Intelsat North America LLC ("Intelsat") herein requests Special Temporary Authority, ("STA") for 14 days— from March 25, 2010 through April 7, ©2010—to conduct in—orbit testing (CIOT") in the 13750—14000 MHz (uplink) and 11450—11700 MHz (downlink) extended Ku—bands for the Intelsat 25 satellite (call sign $2804) at the 31.5° W.L. orbital location." Intelsat has a pendmg applicationfor authority to operate the Intelsat 25 satellite at 31.5° W.L — In order to conduct IOT in the 11450—11700 MHz band, this application for STA requests a waiver of the footnote NG104 to the U.S. Table of Frequency Allocations, Section 2.106 of the Commission‘s rules, which limits the use of the 11450—11700 MHz frequency bands to "international systems."* The Commission has interpreted this restrlctlon to mean that these bands may be used only to provide international service." Intelsat will conduct IOT using earth station KA258, located in Clarksburg, Maryland. Thus, Intelsat seeks ‘ Intelsat has filed this STA request, an FCC Form 159 and an $830.00 fihng fee electronically via the International Bureau‘s Filing System. > The FCC granted STA for in—orbit testing of the Intelsat 25 satellite‘sC—band : payload effective March 15, 2010. Requestfor Special Temporary Authority for Intelsat 25, Call Sign: $2804, File No. SAT—STA—20100312—00045 (stamp — grant, Mar. 15, 2010). The FCC granted STA for in—orbit testing in the 14000— 14500 MHz (uplink) and 12250—12750 MHz (downlink) band portions of the Ku—band effective March 19, 2010. See Requestfor Special Temporary Authorityfor Intelsat25, Call Sign: $2804, File No. SAT—STA—20100316— 00048 (stamp grant, Mar. 19, 2010). * Intelsat North America LLC, Applicationfor Authority to Operate 00 Intelsat 25, an In—orbit Satellite, at 31.5° W.L., File No. SAT—A/O—20091223— 00151 (filed Dec. 23, 2009) ("Intelsat 25 Apphcatlon”) * See 47 C.F.R. § 2.106 fo. NG104. * See Satellite Services, 26 RR 24 1257, 1263—65 (1973), and GWARC Inquiry, 70 F.C.C.2d 1193, 1252 (1978). Intelsat Corporation . 3400 International Drive NW, Washington DC 20008—3006 USAwww.intelsat.com T +1 202—944—6800 F41 202—944—7898 .

Ms. Marlene H. Dortch . March 23, 2010 Page 2 waiver to permit a U.S. earth station to communicate with the Intelsat 25 satellite at 31.5° W.L. for the limited purpose of IOT. _ The Commission may grant a waiver for good cause shown." The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest.‘ In granting a waiver, the Commission may take into account considerations of hardship, equity, or more éffective implementation of overall policy on an individual basis." Waiver is therefore appropriate if special circumstances warrant a deviation from the general rule, and such a deviation will serve the public interest. As shown below, good cause exists here to grant a waiver allowing the Intelsat 25 satellite to conduct IOT using the 11450—11700 MHz frequencies. Grant of the STA will serve the public interest. Grant will allow Intelsat to begin partial in—orbit testing of the remaining portions of the Intelsat 25 Ku— band payload promptly following the satellite‘s March 15, 2010 arrival at its proposed permanent operating location of 31.5° W.L. Intelsat 25 is a newly acquired in—orbit satellite. Testing is a critical step in ensuring that the satellite will be fully operational at 31.5° W.L. This, in turn, will provide customers with the benefits of additional capacity at the 31.5° W.L. location as quickly as possible. q0 C Waiver is also appropriate in this case on hardship grounds. The Intelsat 25 satellite was a satellite constructed by a non—U.S. operator for operations outside the United States. As such, it includes mostly extended Ku—band frequencies." Intelsat acquired the satellite in a bankruptcy process and intends to operate the satellite primarily outside the United States. As ~ explained in the pending application to operate Intelsat 25 at 31.5° W.L., the Intelsat 25 satellite will use the 13750—14000— MHz and 11450—11700 MHz bands to provide service to the northwestern portion of Africa.‘" Absent the requested waiver, the 13750—14000 MHz portion of Ku—band payload on the Intelsat 25 satellite could not be tested at all with Intelsat‘s U.S. earth station 647 C.F.R. §1.3. ‘ N.E. Cellular Tel. Co. v. FCC, 897 F.24 1164, 1166 (D.C. Cir. 1990) (‘Northeast Cellular"). * WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166. v ° The only conventional Ku—band frequencies on the satellite are the 14000— 14500 MHz (uplink). * Intelsat 25 Application, Engineering Statement at 1.

Ms. Marlene H. Dortch March 23, 2010 Page 3 because these frequencies are paired with the 11450—1 1700 MHz Ku—band frequencies. ' Furthermore, grant of this waiver will not cause harmful interference. The purpose of this footnote is to limit the number of fixed satellite service earth stations with which the co—primary fixed terrestrial services would need to coordinate."" As with any STA, Intelsat will conduct IOT services in the 11450—11700 MHz band on a non—harmful interference basis. Moreover, Intelsat only seeks waiver of footnote NG104 for a limited period—14 days— and for a limited purpose—IOT. In addition, Intelsat has coordinated with co— frequency satellite operators up to six degrees away from 31.5° W.L. Hispasat uses Ku—band frequencies on two satellites located at 30.0° W.L.—Hispasat 1C and Hispasat 1D. Intelsat will operate in accordance with its coordination agreements with Hispasat. Intelsat also operates (or shortly will operate) the other two closest satellites—at 29.5° W.L. and 34.5° W.L.—and thus internally can monitor and coordinate any interference with these two satellites. Grant will also provide the Commission additional time to complete its review of Intelsat‘s pending application for permanent authority to operate the Intelsat 25 satellite at the 31.5° W.L. orbital location. In particular, grant of this STA will provide needed time for completion of inter—agency coordination of the extended band frequencies. Intelsat understands and accepts that a grant of this STA would not prejudge the Commission‘s determination of Intelsat‘s request to operate Intelsat 25 at 31.5° W.L. on a permanent basis, and that testing pursuant to this STA is at Intelsat‘s risk. Intelsat has assessed and limited the probability of the space station becoming a source of debris as a result of collision with large debris or other operational space stations. Intelsat is not aware of any other FCC licensed system, or any _ other system applied for and under considerationby the FCC, having an overlapping station—keeping volume with Intelsat 25 at the 31.5° W.L. location. Finally, Intelsat is not aware of any satellite network with an overlapping station—keeping volume with Intelsat 25 that is the subject of an ITU filing and that is either in orbit or progressing towards launch. " See Satellite Services, 26 RR 2d at 1263—65. See also EchoStar KuX Corporation Applicationfor Authority to Construct, Launch and Operate a Geostationary Satellite Using the Extended Ku—band Frequencies in the Fixed— Satellite Service at the 83 ° W.L. Orbital Location, Order and Authorization, DA 04—3162, [ 9 (Int‘l Bur., Sept. 30, 2004) ("EchoStar 83° Waiver").

— Ms. Matrlene H. Dortch March 23, 2010 Page 4 For the reasons set forth herein, Intelsat respectfully requests that the Commission expeditiously grant this request. Sincerely, > (A¥A.CAARQR_ Susan H. Crandall ‘ Assistant General Counsel Intelsat Corporation ce: Bob Nelson, Karl Kensinger Kathyrn Medley Stephen Duall


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Document Modified: 2019-06-02 19:46:32
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