Attachment Intelsat-Grant April

Intelsat-Grant April

DECISION submitted by IB,FCC

grant

2010-04-02

This document pretains to SAT-A/O-20091223-00151 for Authority to Operate on a Satellite Space Stations filing.

IBFS_SATAO2009122300151_808873

  $2804         SAT—A/0—20091223—00151
  Intelsat North America LLC                   152008003224
  Intelsat 25


                                                                                                                        Approved by OMB
                                                                                                                               3060—0678


Date & Time Filed: Dec 23 2009 5:29:09:750PM
 $2804          SAT—A/O0—20091223—00151       182009008224
 Intelsat North America LLC

                       APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                         FCC Use Only
                                          FCC 312 MAIN FORM
                                        FOR OFFICIAL USE ONLY


APPLICANT INFORMATION
Enter a description of this application to identify it on the main menu:
Application to Operate the Intelsat 25 Satellite at 31.5 W.L.
  1—8. Legal Name ofApplicant
            Name:             Intelsat North America LLC       Phone Number:             202—944—7848
            DBA Name:                                          Fax Number:               202—944—7870
            Street:           c/o Intelsat Corporation         E—Mail:                   susan.crandall@intelsat.com
                              3400 International Drive, N.W.

            City:             Washington                       State:                     DC
            Country:          USA                        *     Zipcode:                  20008             —3006
            Attention:        Susan H. Crandall




                                                                                                       File #8/47'& /4/0 ooo imgA—AAlK ,

                                                                                                       Call Sign 807502 Grant Date              6/4 Z/_/_ /8 .
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                                       Attachment to Grant
                                   Intelsat North America LLC
                             IBFS File No. SAT—A/O—20091223—00151
                                         Call Sign: $2804




The request of Intelsat North America LLC (Intelsat) for authority to operate a C— and Ku—band
space station, Intelsat 25 (Call Sign $2804), at the 31.5° W.L. orbital location, IBFS File No.
SAT—A/O—20091223—00151, is GRANTED. Accordingly, Intelsat IS AUTHORIZED to provide
Fixed Satellite Service (FSS) at 31.5° W.L. in the 3400—4200 MHz (space—to—Earth), 11450—
11700 MHz (space—to—Earth), 12250—12750 MHz (space—to—Earth), 5845—6645 MHz (Earth—to—
space), and 13750—14500 MHz bands (Earth—to—space). Intelsat is also authorized to operate
telemetry, tracking, and telecommand (TT&C) for Intelsat 25 at the 31.5 ° W.L. orbital location
using the following center frequencies: 6173.7 MHz (telecommand), 6176.3 MHz
(telecommand), 3947.5 MHz (telemetry), 3948 MHz (telemetry), 3952 MHz (telemetry), 3952.5
MHz (telemetry), 3950 MHz (tracking), 11198 MHz (tracking), 11452 MHz (tracking), 11701
MHz (tracking), and 12501 MHz (tracking). This authorization is granted in accordance with the
technical specifications set forth in Intelsat‘s application, the Federal Communication
Commission‘s (Commission) rules, and subject to the following conditions:

   1. Intelsat shall prepare all necessary information that may be required for submission to the
      International Telecommunication Union (ITU) to initiate and complete the advance
      publication, international coordination, due diligence, and notification procedures for this
      space station, in accordance with the ITU Radio Regulations. Intelsat shall be held
      responsible for all cost recovery fees associated with these ITU filings. No protection
      from interference caused by radio stations authorized by other Administrations is
      guaranteed unless coordination and notification procedures are timely completed or, with
      respect to individual Administrations, by successfully completing coordination
      agreements. Any radio station authorization for which coordination has not been
      completed may be subject to additional terms and conditions as required to effect
      coordination of the frequency assignments with other Administrations. 47 C.F.R. §
      25.111(b).

   2. In connection with the provision of service in any particular country, Intelsat is obliged to
      comply with the applicable laws, regulations, rules, and licensing procedures of that
      country.

   3. While at the 31.5° W.L. orbital location, Intelsat shall maintain the Intelsat 25 space
      station with an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.


                                                                        File #5)/47—' fi/{) ~»~Adg hss C2AX,


                                                                        Call Sign 5’02 Grant Date 242
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                                                         &A \/ Y , /    (or otheridentifiert)
                                                    cuCoamissiors                               Term Dtltu!
                                                    22                  From {‘924/& —               To:      /   O;UQS
                                                   GRANTED
                                                 International Bureau   Approved: _<


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                                               Attachment to Grant
                                           Intelsat North America LLC
                                   IBFS File No. SAT—A/O—20091223—00151
                                               Call Sign: $2804



    4. Intelsat‘s request for waiver of Section 25.211(a) of the Commission‘s rules, 47 C.F.R. §
       25.11(a), IS GRANTED. Section 25.211(a) requires that downlink analog video
       transmissions in the 3700—4200 MHz band be transmitted only on a center frequency of
       3700+20N MHz, where N=1 to 24. The corresponding uplink frequency shall be 2225
       MHz higher. Intelsat states that Intelsat 25 utilizes 36 MHz and 72 MHz wide
       transponders, and that the placement of TV/FM signals within the 72 MHz might result in
       non—compliance with Section 25.211(a). Because the closest co—frequency satellites to
       Intelsat 25 are Intelsat 903 and Intelsat 907, Intelsat states that it will be able to internally
       coordinate Intelsat 25‘s TV/FM transmissions with Intelsat 903 and Intelsat 907. As a
         condition of this waiver, Intelsat must accommodate future satellite networks that are
         compliant with Section 25.211(a). Further, Intelsat must operate Intelsat 25 pursuant to
         any existing or future coordination agreements for this location.

    5. Intelsat‘s request for waiver of Section 25.210(a)(3) of the Commiussion‘s rules, 47 C.F.R.
       § 25.210 (a)(3), IS GRANTED. Section 25.210(a)(3) requires all FSS space stations used
       for domestic service in the 3700—4200 MHz and 5925—6425 MHz bands to be capable of
       switching polarization sense upon ground command. The Commission requires polarity—
       switching capability for two reasons: 1) to provide U.S.—licensed satellites with the
       flexibility to operate at different orbital locations, and (2) to mitigate potential
       interference between adjacent fixed—satellite systems transmitting analog television
       signals.‘ This waiver grant is based upon a finding that the ability to switch polarization
       is not currently necessary to protect other satellites at adjacent orbital locations from
       harmful interference, because the only C—band space stations operating within two
       degrees of Intelsat‘s proposed location are operated by Intelsat (Intelsat 801 at 29.5° W.L.
       and Intelsat 903 at 34.5° W.L.) and because the Intelsat 25 space station operations will
       be in compliance with existing coordination agreements. As a condition of granting this
       waiver, Intelsat must accommodate future satellite networks that are compliant with
       Section 25.210(a)(3). Further, Intelsat must operate Intelsat 25 pursuant to any existing
       or future coordination agreements for this location.

    6. Intelsat‘s request for waiver of Section 25.202(g) of the Commission‘s rules, 47 C.F.R. §
       25.202(g), IS GRANTED. Section 25.202(g) requires "telemetry, tracking and
       telecommand (TT&C) functions for U.S. domestic satellites shall be conducted at either
       or both edges of the allocated band(s). Frequencies, polarization and coding shall be
       selected to minimize interference into other satellite networks and within their own
       satellite system." Intelsat requests this waiver for the proposed use of 3630 MHz for
       telemetry because the 3630 MHz telemetry frequency is not at the edge of the 3600—3700
       MHz "extended" C—band. This waiver grant is based upon the following findings:




‘ Telesat Canada; Petition for Declaratory Ruling for of Inclusion of ANIK F3 on the Permitted Space Station List,
Order, 22 FCC Red 588 (para. 10) (Int‘l Bur., Sat. Div. 2007).


                                         Attachment to Grant
                                     Intelsat North America LLC
                               IBFS File No. SAT—A/O—20091223—00151
                                           Call Sign: S$2804



               (a)    Intelsat 25 will be operated at 31.5° W.L., which is outside the U.S.
               domestic satellite arc.

               (b)    3630 MHz is not within the 3700—4200 MHz band allocated for FSS in the
               United States.

        As a condition of granting this waiver, Intelsat must accommodate future space station
        networks that are compliant with Section 25.202(g). Further, Intelsat must operate
        Intelsat 25 pursuant to any existing or future coordination agreements for this location.

    7. Intelsat shall not permit any earth station in the United States and its possessions to
       operate with the Intelsat 25 space station in the bands 3400—3600 MHz and 5845—5850
       MHz.

    8. Intelsat shall inform its customers and operators using the band 3400—3600 MHz of the
       potential for interference from U.S. Government operations worldwide.

    9. Intelsat‘s use of the 3600—3650 MHz (space—to—Earth) band is subject to footnote US245
       of the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US245, which
       states that the 3600—3650 MHz use of the non—Federal fixed—satellite service is limited to
       international inter—continental systems and is subject to case—by—case electromagnetic
       compatibility analysis.

    10. Intelsat‘s use of the 3650—3700 MHz (space—to—Earth) band is subject to footnote NG185
        of the United States Table of Frequency Allocations, 47 C.F.R. § 2.106 NG185, which
        states that the 3650—3700 MHz use of the non—Federal fixed—satellite service is limited to
        international inter—continental systems.

    11. In the 5845—5850 MHz band (Earth—to—space), receiving space stations in the fixed—
        satellite service shall not claim protection from radiolocation transmitting stations
        operating in accordance with the United States Table of Frequency Allocations or ITU
        Radio Regulations.

    12. Intelsat‘s use of the 5850—5925 MHz band (Earth—to—space) is subject to footnote US245
        of the United States Table of Frequency Allocations, 47 C.F.R. §2.106, US245, which
        states that the 5850—5925 MHz use of the non—Federal fixed—satellite service is limited to
        international inter—continental systems and is subject to case—by—case electromagnetic
        compatibility analysis. Intelsat shall not claim protection from radiolocation transmitting
        stations operating in accordance with footnote G2."

    13. Intelsat‘s use of the 11450—11700 MHz band (Earth—to—space) is subject to footnote

* For technical information of these radiolocation systems, see NTIA Report 83—115, Spectrum Resource
Assessment in the 5650—5925 MHz Band, and NTIA Report 00—373, Measured Occupancy of 5850—5925 MHz and
Adjacent 5—GHz Spectrum in the United States at http://www.its.bldrdoc.gov/pub/pubs.php.


                                               Attachment to Grant
                                           Intelsat North America LLC
                                   IBFS File No. SAT—A/O—20091223—00151
                                               Call Sign: $2804



         US211 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US211,
         which urges applicants for airborne or space station assignments to take all practicable
         steps to protect radio astronomy observations in the adjacent bands from harmful
         interference, consistent with footnote US74.

    14. The operation of the Intelsat 25 space station in the 11450—11700 MHz band (Earth—to—
        space) is limited to international operations in accordance with footnote NG 104 to the
        United States Table of Frequency Allocations, 47 C.F.R. § 2.106, NG 104, and footnote 2
        of Section 25.202(a)(1) of the Commission‘s rules, 47 C.F.R. § 25.202(a)(1).

    15. In the 13750—14000 MHz band (Earth—to—space), receiving space stations in the fixed—
        satellite service shall not claim protection from radiolocation transmitting stations
        operating in accordance with the United States Table of Frequency Allocations.

    16. Pursuant to footnote US337 of the United States Table of Frequency Allocations, 47
        C.F.R. § 2.106, any earth station in the United States and its possessions communicating
        with the Intelsat 25 space station in the 13750—14000 MHz band (Earth—to—space) is
        required to coordinate through National Telecommunications and Information
        Administration‘s (NTIA‘s) Interdepartment Radio Advisory Committee‘s (IRAC‘s)
        Frequency Assignment Subcommittee (FAS) to minimize interference to the National
        Aeronautics and Space Administration Tracking and Data Relay Satellite System,
        including manned space flight.

    17. Operations of any earth station in the United States and its possessions communicating
        with the Intelsat 25 space station in the 13750—14000 MHz band (Earth—to—space) shall
        comply with footnote US356 to United States Table of Frequency Allocations, 47 C.F.R.
        § 2.106, US356 which specifies a mandatory minimum antenna diameter of 4.5 meters
        and a non—mandatory minimum and maximum equivalent isotropically radiated powers
        (e.i.r.p.). Operations of any earth station located outside the United States and its
        possessions communicating with the Intelsat 25 space station in the 13750—14000 MHz
        band (Earth—to—space) shall be consistent with footnote 5.502 to the ITU Radio
        Regulations, which allows a minimum antenna diameter of 1.2 meters for earth stations
        of a geostationary satellite orbit network and specifies mandatory power limits.

    18. Operations of any earth station in the United States and its possessions communicating
        with the Intelsat 25 space station in the 13770—13780 MHz band (Earth—to—space) shall
        comply with footnote US357 to United States Table of Frequency Allocations, 47 C.F.R.
        § 2.106, US357, which specifies that a required maximum e.i.r.p. density of emissions
        not exceed 71 dBW in any 6 MHz band for communications with a space station in
        geostationary—satellite orbit." Operations of any earth station located outside the United
        States and its possessions communicating with the Intelsat 25 space station in the 13770—

* Footnote US357 places a restriction on FSS earth station operations in order to protect government operations in
the band, including manned space flight. 47 C.F.R. § 2.106, US357.


                                               Attachment to Grant
                                           Intelsat North America LLC
                                   IBFS File No. SAT—A/O—20091223—00151
                                               Call Sign: $2804



         13780 MHz band (Earth—to—space) shall comply with footnote 5.503 to the ITU Radio
         Regulations, which specifies a required maximum e.i.r.p. density of emissions (limit is
         dependent on antenna diameter) for communications with a space station in
         geostationary—satellite orbit.

    19. Operators of earth stations accessing the Intelsat 25 space station in the 13750—14000
        MHz band are encouraged to cooperate voluntarily with the National Aeronautics and
        Space Administration (NASA) in order to facilitate continued operation of NASA‘s
        Tropical Rainfall Measuring Mission (TRMM) satellite.*

    20. Intelsat‘s operation of the 3400—4200 MHz, 5850—6645 MHz in the C— and extended C—
         band, and operation of the 11450—11700 MHz, 12500—12750 MHz, and 13750—14500
         MHz frequencies in the Ku— and extended Ku—bands at the 31.5° W.L. orbital location is
         subject to the following conditions:

             (a) Intelsat shall remain a signatory to the Public Services Agreement between
                 Intelsat and the International Telecommunications Satellite Organization (ITSO)
                 that was approved by the ITSO Twenty—fifth Assembly of Parties, as amended.

             (b) No entity shall be considered a successor—in—interest to Intelsat under the ITSO
                 Agreement for licensing purposes unless it has undertaken to perform the
                 obligations of the Public Services Agreement approved by the Twenty—fifth
                 Assembly of Parties, as amended.

    21. The license term for this space station, Call Sign $2804, expires on July 7, 2023, which is
    fifteen years from the launch date of July 7, 2008.

    22. Intelsat is afforded thirty days fromthe date of this action to decline this authorization as
    conditioned. Failure to respond within this period will constitute formal acceptance of the
    authorization as conditioned.




* NASA‘s TRMM satellite system radar in the 13.793—13.805 GHz band remains operational and is a highly
valuable and visible United States asset with a broad range of international users. Accordingly, NTIA has requested
cooperation from the Commission and non—Federal Government entities in providing assistance in reducing
interference with the TRMM radar. Specifically, NTIA requests that FSS earth stations in the 13.793 — 13.805 GHz
band located south of 39° N. and east of 110° W. operate with emission levels below —1 50 dBW/600 kHz at the
TRMM space station receiver. Letter from Frederick R. Wentland, Acting Associate Administrator, Office of
Spectrum Management, NTIA, to Don Abelson, Chief, International Bureau, FCC (February 28, 2002). Considering
the secondary nature of the TRMM operation, NTIA‘s request is not a condition of this authorization. The
Commission, however, urges all operators of earth stations accessing the Intelsat 25 space station in the 13.75 — 14.0
GHz band to cooperate voluntarily with NASA in order to facilitate continued operation of the TRMM satellite.


                                       Attachment to Grant
                                   Intelsat North America LLC
                             IBFS File No. SAT—A/O—20091223—00151
                                         Call Sign: $2804



23. This action is issued pursuant to Section 0.261 of the Commission‘s rules on delegated
   authority, 47 C.F.R. § 0.261, and is effective immediately. Petitions for reconsideration
   under Section 1.106 or applications for review under Section 1.115 of the Commission‘s
   rules, 47 C.F.R. §§ 1.106, 1.115, may be filed within 30 days of the date of the public notice
   indicating that this action was taken.


  9—16. Name of Contact Representative
            Name:           Jennifer D. Hindin                    Phone Number:                        202—719—4975
            Company:        Wiley Rein LLP                        Fax Number:                          202—719—7049
            Street:          1776 K Street, NW                    E—Mail:                              jhindin@wileyrein.com


            City:           Washington                            State:                                DC
            Country:         USA                                  Zipcode:                             20006      —
            Attention:                                            Relationship:                        Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                  b.
classification that applies to thisfiling for      b1. Application for License of New Station
both questions a. and b. Choose only one        (N/A) b2. Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 17b.                   (N/A) b3. Amendment to a Pending Application
                                                (N/A) b4. Modification of License or Registration
  a.                                            (N/A) b5. Assignment of License or Registration
(N/A) al. Earth Station                         (N/A) b6. Transfer of Control of License or Registration
  ) a2. Space Station                           (N/A) b7. Notification of Minor Modification
                                                (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite

                                                    b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                £34 b10. Replacement Satellite Application — no new frequency bands
                                                &4 b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                    b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


  17¢. Is a fee submitted with this application?
g, IfYes, complete and attach FCC Form 159.
  If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
       Governmental Entity         Noncommercial educational licensee
C3 Other(please explain):

17¢. Fee Classification     BNY — Space Station (Geostationary)


18. If this filing is in reference to an existing station, enter:
(a) Call sign of station:
   Not Applicable




19. If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                     (b) File number of pending application:

Not Applicable                                                              Not Applicable


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

[fl a. Fixed Satellite
     b. Mobile Satellite
     c. Radiodetermination Satellite
D d. Earth Exploration Satellite
D e. Direct to Home Fixed Satellite
     £f. Digital Audio Radio Service
     g. Other (please specify)


21. STATUS: Choose thebutton next to the applicable status. Choose       22. If earth station applicant, check all that apply.
only one.                                                                Not Applicable
   Fag Common Carrier            Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
      J Connected to a Public Switched Network        C Not connected to a Public Switched Network             N/A

24. FREQUENCY BAND(S): Place an "X" in the box(es) next to all applicable frequency band(s).
    a. C—Band (4/6 GHz) E b. Ku—Band (12/14 GHz)
   D c.Other (Please specify upper and lower frequencies in MHz.)
              Frequency Lower:    Frequency Upper: (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.

 (N/A)    a. Fixed Earth Station
 (N/A)    b. Temporary—Fixed Earth Station
 (N/A)    c. 12/14 GHz VSAT Network
 (N/A)    d. Mobile Earth Station
     e.   Geostationary Space Station.
     £f. Non—Geostationary Space Station
 CY S Other (please specify)




26. TYPE OF EARTH STATION               FACILITY: Not Applicable
PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
 apply.)

 ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental     {p Yes   No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.FR. §§ 1.1308 and 1.1311, as an exhibit to this application. A Radiation Hazard
Study must accompany all applications for new transmitting facilities, major modifications, or major amendments.


 ALIEN OWNERSHIP
Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or aeronautical fixed radio station
services are not required to respond to Items 30—34.


29. Is the applicant a foreign government or the representative of any foreign government?                                C Yes    No




30. Is the applicant an alien or the representative of an alien?                                                            Yes No {3 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                      Yes    No C N/A




32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by       «3 Yes   No   N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?




33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          CR e) No      N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?




34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.


BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules?                                Yes f‘3 No
 IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.
                                                                                                                         Technical Exhibit




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license             Yes g4 No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances.




37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    O Yes
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,            Yes |@No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition? IfYes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   O Yes
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.


 40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
 address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer‘s
 voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of
 beneficiaries. Also list the names and addresses of the officers and directors of the Filer.




 41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is        Yes   No
 subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
 1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
 47 CFR 1.2002(b) for the meaning of &quot;party to the application&quot; for these purposes.




 42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? IfYes,     Yes @ No
 answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
 proceed to question 43.




| 42b. What administration has licensed or is in the process of licensing the space station? If no license will be
 issued, what administration has coordinated or is in the process of coordinating the space station?


43. Description. (Summarize the nature of the application and the services to be provided).     (If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
     Intelsat North America LLC herein seeks FCC authorization to operate a non—common carrier
     C— and Ku—band satellite,               to be known as Intelsat 25,                at the 31.5 W.L.            orbital location.




  Legal Narrative


43a. Geographic Service Rule Certification                                                                                        A
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
coverage requirements specifiedin 47 C.F.R. Part 25.

                                                                                                                              3 B
By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.


By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.



CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.


44.    Applicant is a (an): (Choose the button next to applicable response.)


 C Individual
 C Unincorporated Association
      Partnership
      Corporation
 C3 Governmental Entity
 ) Other (please specify)       Limited Liability Company



45. Name of Person Signing                                                46. Title of Person Signing
Susan H. Crandall                                                         Asst. General Counsel, Intelsat Corporation
47. Please supply any need attachments.
 1:




            WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                   (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                   (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


Completed Schedule S




10


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing
instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of
information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you,
please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554.
We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to
PRA@fce.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS.

Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This
collection has been assigned an OMB control number of 3060—0678.

THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.




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Document Created: 2019-04-10 19:50:18
Document Modified: 2019-04-10 19:50:18

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