Attachment STA Request

This document pretains to SAT-STA-20121015-00181 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2012101500181_971100

October 15, 2012


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

Re:    Request for Further Extension of Special Temporary Authority to
       Conduct In-Orbit Testing of Intelsat 23
       (File No. SAT-LOA-20110727-00139)
       Call Sign S2831

Dear Ms. Dortch:

Intelsat License LLC (“Intelsat”) herein requests an additional 30 days —from
October 19, 2012 through November 17, 2012 — of the Special Temporary
Authority (“STA”)1 previously granted Intelsat to conduct in-orbit testing
(“IOT”) of Intelsat 23 (Call Sign S2831) at 51.5º W.L. in the bands 3700-4200
MHz (downlink), 5925-6425 MHz (uplink), 11450-11700 MHz, 11700-12200
MHz (downlink), and14000-14500 MHz (uplink), 2 and to drift the satellite to its
permanent location of 53.0° W.L.3 The launch of Intelsat 23 was delayed and
occurred on October 14, 2012. In support of its extension request, Intelsat
submits the following information.

During in-orbit testing of Intelsat 23, Intelsat will operate in the above
referenced C- and Ku-bands. To Intelsat’s knowledge, the only co-frequency
satellites within plus/minus six degrees of 51.5º W.L. are Intelsat 707 at 53.0º
W.L., Intelsat 805 at 55.5º W.L., Galaxy 11 at 55.5° W.L., Intelsat 1R at 50.0º
W.L., NSS 703 at 47.05º W.L., TDRS 3 at 49.0º W.L., and Inmarsat 3-F4 at

1
  Intelsat has filed this STA request, an FCC Form 159, a $860.00 filing fee and
this supporting letter electronically via the International Bureau’s Filing System
(“IBFS”).
2
  See Intelsat License LLC., Request for Extension of Special Temporary
Authority for Intelsat 23, Call Sign S2831, File No. SAT-STA-20120913-00149
(filed Sept. 13, 2012); Policy Branch Information; Actions Taken, Report No.
SAT-00889, File No. SAT-STA-20120628-00106 (Aug. 10, 2012) (Public
Notice).
3
  See Policy Branch Information; Actions Taken, Report No. SAT-00848, File
No. SAT-LOA-20110727-00139 (Feb. 24, 2012) (Public Notice). During the
drift from 51.5° W.L. to 53.0º W.L., only the satellite’s TT&C frequencies will
be utilized. The TT&C frequencies are 6173.7 (LHCP) and 6176.3 (LCHP)
(uplink) and 3947.5 (RHCP), 3948.0 (RHCP), 3952.0 (RHCP), 3952.5 (RHCP)
(downlink).


Ms. Marlene H. Dortch
October 15, 2012
Page 2


54.0° W.L. Intelsat currently is in coordination discussions with SES World
Skies, the operator of NSS 703; Inmarsat, the operator of Inmarsat 3—F4; and the
United States Government, the operator of the TDRS 3, regarding the Intelsat 23
IOT. With regard to the remaining spacecraft, Intelsat will internally coordinate
the proposed testing with the operations of these satellites. In the unlikely event
that haroful 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
space stations during in—orbit testing at 51.5° W.L. Intelsat 23 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 23. Finally, Intelsat is not aware of any system
with an overlapping station—keeping volume with Intelsat 23 that is the subject
of an ITU filing and that is either in orbit or progressing towards launch.

The in—orbit testing of Intelsat 23 at 51.5° W.L.. is a critical step in ensuring that
the satellite will be fully operational at 53.0° W.L. This, in turn, will ensure
continuity of service to customers at the 53.0° W.L. location, and thereby
promotes the public interest.

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




Suc120
Sincerely,



SusanH. Crandall
Assistant General Counsel
Intelsat Corporation


Ce: Robert Nelson
     Kathyrn Medley
     Stephen Duall
     Jay Whaley
     Cindy Spiers



Document Created: 2012-10-15 18:27:42
Document Modified: 2012-10-15 18:27:42

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