Attachment STA Request

This document pretains to SAT-STA-20141222-00136 for Special Temporal Authority on a Satellite Space Stations filing.

IBFS_SATSTA2014122200136_1071879

                                                                                      INTELSAT
                                                                                        nvision. Connect. Transform.




December 22, 2014



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

Re:     Request for Extension of Special Temporary Authority to Drift Intelsat 7 and Operate TT&C
        Frequencies at 18.2° W.L.
        Call Sign $2229


Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") herein requests an additional 30 days, commencing December 29,
2014, of the Special Temporary Authority ("STA")‘ previously granted Intelsat to drift Intelsat 7 (call
sign $2229) from 68.65° E.L. to 18.2° W.L. and operate the satellite‘s TT&C frequencies at 18.2° W.L.
Intelsat 7 arrived on—station on December 3, 2014 and is temporarily collocated with the Intelsat 901
satellite, which currently operates at the 18.0° W.L. orbital location." Intelsat has a pending STA to
operate Intelsat 7‘s TT&C and communications frequencies at 18.2° W.L.*

On—station, Intelsat will continue to utilize the satellite‘s TT&C frequencies in conformance with its
coordination agreements related to that location or on a non—interference, non—protected basis. The
specific TT&C frequencies are 13998 MHz (RHCP) in the uplink and 11451 MHZ (H and LHCP) and
11453 MHz (V and LHCP) in the downlink.

Grant of this STA extension request will not result in increased risk of harmfulinterference. Should any
interference occur, Intelsat will take all reasonable steps to eliminate such interference. Additionally,


‘ Intelsat has filed this STA request, an FCC Form 159 and a $920.00 filing fee electronically via the International
Bureau‘s Filing System.

* See Policy Branch Information; Actions Taken, Report No. SAT—01025, File No. SAT—STA—20140421—00039
(June 27, 2014) (Public Notice).

* See The Applications ofIntelsat LLC For Authority to Operate, and to Further Construct, Launch, and Operate
C—band and Ku—band Satellites that Form a Global Communications System in Geostationary Orbit, 15 FCC Red
15460, File Nos: SAT—A/O—20000119—00002 to SAT—A/O—20000119—00018; SAT—AMD—20000119—00029 to
SAT—AMD—20000119—00041; and SAT—LOA—20000119—00019 to SAT—LOA—20000119—00028 (2000).

* See Policy Branch Information; Satellite Space Applications Acceptedfor Filing, Report No. SAT—01053, File
No. SAT—STA—20141022—00112 (Nov. 14, 2014) (Public Notice).

Intelsat Corporation
7900 Tysons One Place, Mclean, VA 22102—5972 USA www.intelsat.com T +1 703—559—6800


Ms. Marlene Dortch
December 22, 2014
Page 2




Intelsat agrees to operate Intelsat 7 at 18.2° W.L. in accordance with the frequency—related conditions in
the Commission‘s 2004 order granting authority for the Intelsat 7 satellite to operate at 68.5° E.L."

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 7 will not be located in
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 7 at 18.2° W.L.
Finally, Intelsat is not aware of any system with an overlapping station—keeping volume with Intelsat 7
at 18.2° W.L. that is the subject of an ITU filing and thatis either in orbit or progressing towards launch.

Grant of this STA extension request will allow Intelsat to continue providing TT&C services to the
Intelsat 7 satellite at 18.2° W.L., which ensures safe station—keeping of the satellite.

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

Sincerely,

    hy    Thk               /j
Cyén‘tgh; Grady      9              ayéa/
Regulatory Counsel
Intelsat Corporation


ce: Stephen Duall
    Jay Whaley
    Cindy Spiers




5 See PanAmSat Licensee Corp. Application for Authority to Launch and Operate a Hybrid Communications
Satellite Known at 68.5° E.L., Order and Authorization, 19 FCC Red 6137, File Nos. SAT—LOA—19960202—00017,
SAT—AMD—19960411—0055, SAT—AMD—19971119—00187, SAT—AMD—19991217—00129, and SAT—STA—
20001115—00162 (2004). Intelsat 7‘s location subsequently was changed to 68.65° E.L. See supra n.3.

° At the nominal 18.0° W.L. orbital location, Intelsat 7 will be collocated with the Intelsat 901 satellite. Intelsat 7
and Intelsat 901 will operate in separate station keeping boxes, and Intelsat will coordinate their operations
internally.



Document Created: 2014-12-22 15:34:22
Document Modified: 2014-12-22 15:34:22

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