Attachment STA Request

This document pretains to SAT-STA-20140919-00102 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014091900102_1061781

September 19, 2014 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 the Intelsat 30 Satellite (File Nos. SAT-LOA-20121025-00187; SAT-AMD-20121221-00220); Call Sign S2887 Dear Ms. Dortch: Intelsat License LLC (“Intelsat”) herein requests a grant of Special Temporary Authority (“STA”) 1 for 30 days, from October 25, 2014 through November 24, 2014, to conduct in-orbit testing (“IOT”) of the Intelsat 30 satellite (Call Sign S2887) at 132.0º W.L. in the bands 10950-11200 MHz, 11450-11700 MHz, and 11700-12200 MHz (downlink), 13750-14000 MHz and 14000-14500 MHz (uplink), as well as run antenna cuts at 3511 MHz (downlink) and 6536 MHz (uplink),2 and to drift the satellite to its permanent location of 95.05° W.L. 3 Intelsat 30 currently is scheduled to be launched on October 16, 2014. In support of its request, Intelsat submits the following information. During IOT of Intelsat 30 at 132.0° W.L., Intelsat will operate in the above referenced C- and Ku-bands. To Intelsat’s knowledge, there are no co-frequency satellites within plus/minus six degrees of 132.0º W.L. 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 space stations during IOT at 132.0º W.L. Intelsat 30 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 1 Intelsat has filed this STA request, an FCC Form 159, and a $930.00 filing fee electronically via the International Bureau's Filing System. 2 The remainder of the satellite’s C-band frequencies—3400-3700 MHz (downlink) and 6425-6725 MHz (uplink)—will be tested at the satellite’s permanent licensed location of 95.05° W.L. 3 See Policy Branch Information; Actions Taken, Report No. SAT-01036, File Nos. SAT-LOA-20121025-00187 and SAT-AMD-20121221-00220 (Aug. 15, 2014) (Public Notice). During the drift from 132.0° W.L. to 95.05º W.L., only the satellite’s TT&C frequencies will be utilized. The TT&C frequencies are: 11198.0 MHz, 11198.5 MHz, 11199.25 MHz, and 11199.75 MHz (space-to-Earth), and 13750.5 MHz and 14003.5 MHz (Earth-to- space).

Ms. Marlene H. Dortch September 19, 2014 Page 2 other FCC licensed system, or any other system applied for and under consideration by the FCC, having an overlapping station-keeping volume with Intelsat 30 at 132.0° W.L. Finally, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 30 that is the subject of an ITU filing and that is either in orbit or progressing towards launch. In addition, in order to conduct IOT in the 10950-11200 MHz and 11450-11700 MHz bands, this application for STA requests a waiver of the footnote NG52 to the U.S. Table of Frequency Allocations, which limits the use of 10700-11700 MHz to “international systems.” 4 Intelsat seeks waiver to permit the Intelsat 30 satellite to operate in 10950-11200 MHz and 11450-11700 MHz at 132.0° W.L. for the limited purpose of IOT. 5 The Commission may grant a waiver for good cause shown. 6 The Commission typically grants a waiver where the particular facts make strict compliance inconsistent with the public interest. 7 In granting a waiver, the Commission may take into account considerations of hardship, equity, or more effective implementation of overall policy on an individual basis.8 Waiver is therefore appropriate if special circumstances warrant a deviation from the general rule, and such a deviation will serve the public interest. Good cause exists to waive the international only requirements for the use of the 10950-11200 MHz and 11450-11700 MHz frequency bands. The purpose of the international only rule in the 10700-11700 MHz band is to limit the number of the FSS service earth stations with which the co-primary fixed service would need to coordinate. 9 Intelsat will provide services in the 10950-11200 MHz and 11450- 11700 MHz frequency bands only on a non-interference/non-protected basis, and therefore will not need to coordinate with fixed service stations. Additionally, IOT will be conducted for only a short duration. Moreover, grant of this waiver is consistent with the Commission’s precedent. A waiver of the Table of Allocations is generally granted “when there is little potential interference into any service authorized under the Table of Frequency allocations and when the nonconforming operator accepts any interference from authorized services.” 10 The International Bureau has found that waiving the international only 4 See 47 C.F.R. § 2.106 fn. NG52. 5 Intelsat has received waiver of footnote NG52 for operations in the 11450-11700 MHz band at the 95.05° W.L. location. See Intelsat License LLC, Application for Authority to Launch and Operate Intelsat 30 Satellite, File Nos. SAT-LOA-20121025-00187 and SAT-AMD-20121221-00220, ¶ 15 (stamp grant Aug. 14, 2014). 6 47 C.F.R. §1.3. 7 N.E. Cellular Tel. Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990) (“Northeast Cellular”). 8 WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969); Northeast Cellular, 897 F.2d at 1166. 9 See Satellite Services, 26 RR 2d 1257, 1263-65 (1973). See also EchoStar KuX Corporation Application for Authority to Construct, Launch and Operate a Geostationary Satellite Using the Extended Ku-band Frequencies in the Fixed-Satellite Service at the 83º W.L. Orbital Location, Order and Authorization, DA 04-3162, 9 (Int’l Bur., Sept. 30, 2004) (“EchoStar 83º Waiver”). 10 See The Boeing Company, Order and Authorization, 16 FCC Rcd 22645, 22651 (Int’l Bur. & OET 2001); Application of Fugro-Chance, Inc. for Blanket Authority to Construct and Operate a Private Network of Receive- Only Mobile Earth Stations, Order and Authorization, 10 FCC Rcd 2860 (Int’l Bur. 1995) (authorizing MSS in

Ms. Marlene H. Dortch September 19, 2014 Page 3 restriction would not undermine the purpose of the rules if the party seeking a waiver will be utilizing earth stations that are receive—only in these bands and thus "not capable of causing interference into FS stations" operating in the bands."‘ The earth stations operating in the 10950—1 1200 MHz and 11450— 11700 MHz bands on Intelsat 30 will not transmit in these bands and Intelsat agrees to accept any level of interference into those earth stations from fixed service stations in these bands. Accordingly, the earth stations operating in these bands pose no interference concerns with respect to co—frequency fixed service stations. The IOT of Intelsat 30‘s Ku—band payload and the running of antenna cuts in certain C—band frequencies at 132.0° W.L. is a critical step in ensuring that the satellite will be fully operational at 95.05° W.L. This, in turn, will ensure continuity of service to customers at the 95.05° W.L. location, and thereby promotes the public interest. For the reasons set forth herein, Intelsat respectfully requests that the Commission grant this request. Sincerely, CapN¥Eso @4@/7\ Cynthia J. Grady Regulatory Counsel Intelsat Corporation ce: Stephen Duall Jay Whaley Cindy Spiers the C—band); see also Application ofMotorola Satellite Communications, Inc. for Modification ofLicense, Order and Authorization, 11 FCC Red 13952—13956 (Int‘l Bur. 1996) (authorizing service to fixed terminals in bands allocated the mobile satellite service). ‘‘ EchoStar 83° Waiver, [ 13.


Document Created: 2014-09-19 16:51:55
Document Modified: 2014-09-19 16:51:55
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