Attachment STA Request

This document pretains to SAT-STA-20120306-00037 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012030600037_942529

March 6, 2012


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

Re:    Request for Special Temporary Authority to Conduct In-Orbit Testing
       of Intelsat 19 (File No. SAT-RPL-20111222-00245)
       Call Sign S2850

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests a grant of Special Temporary
Authority ("STA")1 for 30 days, from June 1, 2012 through June 30, 2012, to
conduct in-orbit testing (“IOT”) of Intelsat 19 (File No. SAT-LOA-20111222-
00245) at 176.0º E.L. in the bands 3700-4200 MHz (downlink), 5925-6425
MHz (uplink), 12250-12750 MHz (downlink), and 14000-14500 MHz
(uplink), and to drift the satellite to its permanent location of 166.0° E.L.2
Intelsat 19 currently is scheduled to be launched on May 20, 2012. In support
of its request, Intelsat submits the following information.

During in-orbit testing of Intelsat 19, Intelsat will operate in the above
referenced C- and Ku-bands. To Intelsat’s knowledge, the co-frequency
satellites within plus/minus six degrees of 176.0º E.L. are GE-23 at 172.0°
E.L., Inmarsat 3-F3 at 178.0° E.L., Intelsat 18 at 180.0° E.L., and Intelsat 602
at 177.85° E.L. Intelsat currently is in coordination discussions with GE
Satellite and Inmarsat, Ltd., the operators, respectively, of GE-23 and Inmarsat
3-F3. With regard to the remaining spacecraft, Intelsat will internally
coordinate the proposed testing with the operations of these satellites. In the
unlikely event that harmful interference occurs, Intelsat will take all necessary
steps to eliminate the interference.

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




1
  Intelsat has filed this STA request, an FCC Form 159 and an $830.00 filing
fee electronically via the International Bureau's Filing System.
2
  See Policy Branch Information; Actions Taken, Report No. SAT-00843, File
No. SAT-RPL-20111222-00245 (Feb. 10, 2012) (Public Notice). During the
drift from 176.0º E.L. to 166.0º E.L., only the satellite’s TT&C frequencies
will be utilized.


Ms. Marlene H. Dortch
March 6, 2012
Page 2



space stations during in—orbit testing at 176.0° E.L. Intelsat 19 will not be
located at the same orbital location as another satellite or at an orbital location
that has an overlapping station—keeping volume with another satellite. Further,
Intelsat is not awate of any other FCC licensed system, or any other system
applied for and under consideration by the FCC, having an overlapping station—
keeping volume with Intelsat 19. Finally, Intelsat is not aware of any system
with an overlapping station—keeping volume with Intelsat 19 that is the subject
of an ITU filing and that is either in orbit or progressing towards launch.

The in—orbit testing of Intelsat 19 at 176.0° E.L. is a critical step in ensuring
that the satellite will be fully operational at 166.0° E.L. This, in turn, will
ensure continuity of service to customers at the 166.0° E.L. location, and
thereby promotes the public interest.

For the reasons set forth herein, Intelsat respectfully requests that the
Commission grant this request.

Sincerely,


 C}Mflm CA@ZO
Susan H. Crandall
Assistant General Counsel

Intelsat Corporation




Ce: Robert Nelson
     Karl Kensinger
     Kathyrn Medley
     Stephen Duall
     Jay Whaley



Document Created: 2012-03-06 15:04:46
Document Modified: 2012-03-06 15:04:46

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