Attachment STA Request

This document pretains to SAT-STA-20120810-00127 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012081000127_962767

August 10, 2012


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

Re:     Request for Special Temporary Authority to Drift Intelsat 706
        Call Sign S2401
        EXPEDITED TREATMENT REQUESTED

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests Special Temporary
Authority ("STA")1 for 30 days, commencing August 16, 2012, to drift
Intelsat 706 (call sign S2401) from 72.0° E.L. to 157.0° E.L., where it
will eventually operate in the C- and Ku-bands2 in inclined orbit.3 As
explained more fully below, Intelsat 706 is being redeployed to 157.0°
E.L. on an emergency basis, in order to free up Intelsat 701 to move to
330.5° E.L. to ensure traffic continuity at 330.5° E.L. in light of the
recently-incurred Intelsat 23 launch delay. Intelsat currently expects to
operate Intelsat 706 at 157.0° E.L. until the satellite is de-orbited in the
second half of 2014.

Intelsat 706 is currently operating at 72.0° E.L.4 Following receipt of
FCC approval, Intelsat 706 will begin drifting to 157.0° E.L. on August

1
  Intelsat has filed this STA request, an FCC Form 159 and an $860.00
filing fee electronically via the International Bureau's Filing System.
2
  Intelsat herein seeks only drift authority and intends shortly to file a
permanent license modification application seeking operational
authority at 157.0° E.L.
3
   Intelsat 706 began operating in inclined orbit mode last year. See
Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch, FCC,
Call Sign S2401 (filed July 20, 2011).
4
  See Policy Branch Information; Actions Taken, Report No. SAT-
00846, File No. SAT-STA-20111230-00253 (Feb. 17, 2012) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00842, File No. SAT-STA-20120109-00002 (Feb. 3, 2012) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00829, File No. SAT-STA-20111209-00237 (Dec. 16, 2011) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00826, File No. SAT-STA-20111107-00214 (Dec. 2, 2011) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00816, File No. SAT-STA-20111010-00196 (Oct. 21, 2011) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-


Ms. Marlene H. Dortch
August 10, 2012
Page 2


16, 2012. It is expected to be on-station at that location in mid-
February 2013. During the drift of Intelsat 706 from 72.0° E.L. to
157.0° E.L., Intelsat will operate only the satellite’s TT&C frequencies
and will coordinate the drift with potentially affected operators.

The specific TT&C frequencies are as follows:

Uplink:

6173.7 (LHCP)
6176.3 (LHCP)

Downlink:

3947.5 (RHCP)
3948.0 (RHCP)
3952.5 (RHCP)
3952.0 (RHCP)

Grant of this STA request is in the public interest because it will allow
Intelsat to begin the redeployment process necessary to ensure
continuity of service at 330.5° E.L., where Intelsat 801 (call sign
S2391) currently operates. Given the recent failure of the Proton
rocket, the launch of Intelsat 23 (call sign S2831), which is to replace
Intelsat 707 (call sign S2398) at 307.0° E.L., will be delayed. As a
result, Intelsat 707 may not have sufficient fuel to be redeployed to
330.5° E.L. as planned. Accordingly, Intelsat has decided to redeploy
Intelsat 701, which currently operates at 157.0° E.L., to 330.5° E.L. in
order to ensure service continuity at the latter location. Intelsat 706 is
being redeployed immediately in order to free up Intelsat 701 to move
to 330.5° E.L.

Grant of this STA request will not result in increased risk of harmful
interference. Intelsat will coordinate the drift with all potentially
affected operators.

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

00813, File No. SAT-STA-20110912-00177 (Oct. 7, 2011) (Public
Notice); Policy Branch Information; Actions Taken, Report No. SAT-
00802, File No. SAT-STA-20110810-00159 (Aug. 19, 2011) (Public
Notice).


Ms. Marlene H. Dortch
August 10, 2012
Page 3


other operational space stations. Except briefly while collocated with
Intelsat 701, Intelsat 706 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
aware 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 706 at 157.0° E.L. Finally, Intelsat is not
aware of any system with an overlapping station—keeping volume with
Intelsat 706 at 157.0° E.L. that is the subject of an ITU filing and that is
either in orbit or progressing towards launch.

Intelsat requests that the Part 25 waivers originally granted to the
Intelsat 706 spacecraft continue to apply at the 157.0° E.L. location,
namely, the waivers of Sections 25.202(g), 25.210(a)(1), 25.210(a)(3),
25.210(i) and 25.211(a) of the Commission‘s rules."

For the reasons set forth herein, Intelsat respectfully requests that the
Commission expeditiously grant this request to allow Intelsat to
commence the Intelsat 706 drift as quickly as possible.

Sincerely,




Susan H. Crandall
Assistant General Counsel
Intelsat Corporation


ce:     Robert Nelson
        Stephen Duall
        Jay Whaley



5 See Applications ofIntelsat LLCfor Authority to Operate and Further
Construct, Launch, and Operate C—Band and Ku—Band Satellites that
Form a Global Communications System in Geostationary Orbit, 15
FCC Red 15460, 15529 (Appendix C) (2000) (Memorandum Opinion
and Order and Authorization), recon. denied, 15 FCC Red 25234
(2000) (Order on Reconsideration).



Document Created: 2012-08-10 15:50:09
Document Modified: 2012-08-10 15:50:09

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