Attachment GRANT

GRANT

DECISION submitted by IB,FCC

GRANT

2009-06-15

This document pretains to SAT-AMD-20080114-00011 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2008011400011_717320

                                                1820 08000097
                                 0114-00011
                      T-AMD-2008
 s2659            oSAAmencallG
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                                                                                                                                   Approved by OMB
                                                                                                                                          3060—0678


ware & lime Filed: Jan 14 2008 3:26:15:030PM
File Number: SAT—AMD—20080114—00011

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   FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM                                     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:
$2659 — Amendment to Pending 17/24 GHz BSS Application
1—8. Legal Name of Applicant


             Name:            Intelsat North America LLC          Phone Number:                     202—944—7848
             DBA                                                  Fax Number:                       202—944—7870
             Name:
             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




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                                   Intelsat North America LLC
                             File Nos. SAT—LOA—20050210—00028,
                    SAT—AMD—20051118—00241, SAT—AMD—20080114—00011,
                   SAT—AMD—20080617—00126, and SA¥AT—AMD—20080701—00134
                                          Call Sign $2659
                              Attachment — Conditions of Authorization
                                              June 15, 2009

Intelsat North America LLC‘s (Intelsat‘s) request for authority to construct, launch, and operate a
17/24 GHz Broadcasting—Satellite Service (BSS) space station, Galaxy BSS—4, at the 122.90°
W.L. orbital location, Call Sign $2659, which is offset 0.10° from the 123° W.L. orbital location
specified in Appendix F to the 17/24 GHz BSS Report and Order, FCC 07—76, 22 FCC Red 8842
(rel. May 4, 2007) at a reduced power and without full interference protection is GRANTED.!
Accordingly, Intelsat is authorized to use the 24.75—25.25 GHz frequency band (Earth—to—space)
and the 17.3—17.8 GHz frequency band (space—to—Earth), with the 17.7—17.8 GHz (space—to—Earth)
frequency band limited to international service only. Intelsat‘s authorization is subject to the
terms, conditions, and technical specifications set forth in its applications, this Attachment, and
the Federal Communications Commission‘s rules.

         1.       Intelsat may operate its Galaxy BSS—4 space station up to powerflux density
                  (PFD) levels that are reduced from those specified in 47 C.F.R §§ 25.208(c) and
                  25.208(w) in accordance with the following calculation methodology: For a
                  given location on the surface of the Earth at which the required PFD reduction
                  value needs to be determined, calculate the topocentric angular separation ‘q" of
                  the 119.0° W.L. and 123° W.L. geostationary orbital locations, and the
                  corresponding off—axis gain Goo1(q) of the antenna specified in Section
                  25.224(a)(1) at that angular separation. For the same location on the surface of
                  the Earth, also calculate the topocentric angular separation of the 119° W.L. and
                  122.90° W.L. geostationary orbital locations, and the gain of the antenna
                  ‘Gcor(@)‘ specified in Section 25.224(a)(1) at that angular separation. Then,
                  perform the subtraction Geor(@) — Geori[(@). The result is the required reduction in
                  the PFD from the value specified in the applicable subsection of Section
                  25.208(c), or in Section 25.208(w)." Intelsat‘s Galaxy BSS—4 space station



‘ The application was placed on Public Notice as accepted for filing on July 2, 2008. Policy Branch
Information, Satellite Space Applications Accepted for Filing, Public Notice, Report No. SAT—00535 (rel.
July 2, 2008); Policy Branch Information, Satellite Space Applications Accepted for Filing, Public
Notice, Report No. SAT—00537 (rel. July 11, 2008) (corrections). Comments were filed by Pegasus
Development DBS Corporation (Pegasus) and SES Americom Inc. (SES) on August 1, 2008. No
petitions to deny were filed against this application. In its comment filed against all pending 17/24 GHz
BSS applications, including its own applications, Pegasus sought a "clarification" regarding Commission
policies relating to 47 C.F.R. §§ 25.158(c) (prohibition on transfer of place in application queue) and
25.165 (bond requirement). The issues raised by Pegasus are not relevant to the processing of this
application and, instead, relate to a request to assign an application to Pegasus from DIRECTV
Enterprises, LLC (DIRECTV). IBFS File No. SAT—AMD—20080916—00188. Accordingly, we will not
address Pegasus‘s comment in this grant.

> For the purposes of this calculation, the antenna diameter ‘D‘ should be assumed to be 0.45 meters,
which is the minimum—diameter antenna for which 17/24 GHz licensees may claim protection from
interference, according to Section 25.224(a), the wavelength °A‘ should be assumed to be 0.017131
meters, corresponding to a frequency of 17.5 gigahertz, and the value of ‘n‘ can be assumed to be 0.65, as


                 transmissions shall meet the reduced PFD limits under all atmospheric
                  conditions. The PFD levels of Galaxy BSS—4‘s transmissions shall not exceed
                 the maximum pfd levels stated in its application.

        2.        Intelsat is authorized to operate the on—station command links of the Galaxy BSS—
                  4 space station using one megahertz of assigned bandwidth at each of the uplink
                  center frequencies 24751.5 MHz (right—hand circular polarization) and 25248.5
                  MHz (left—hand circular polarization); and operate the on—station telemetry links
                  of the Galaxy BSS—4 space station using 350 kilohertz of assigned bandwidth at
                  each of the downlink center frequencies 17303.0 MHz (right—hand circular
                  polarization) and 17303.5 MHz (Ileft—hand circular polarization). Intelsat is also
                  authorized to operate the pointing beacon links of the Galaxy BSS—4 space station
                  using 50 kilohertz of assigned bandwidth at each of the downlink center
                  frequencies 17301.0 MHz (right—hand circular polarization) and 17301.5 MHz
                  (left—hand circular polarization).

         3.       Intelsat‘s request for a limited waiver of 47 C.F.R. § 25.202(g) for launch and
                  early orbit (LEOP) operations is GRANTED. Section 25.202(g) limits space
                  station operators to telemetry, tracking, and command (TT&C) links in the same
                  frequency bands as their primary service operations." The purpose of this rule is
                  to simplify the coordination process among space stations at adjacent orbit
                  locations, to provide an incentive for a space station operator to maximize the
                  efficiency of its system‘s TT&C operations and to minimize the constraints
                  placed on other space station operations. We find that Intelsat has demonstrated
                  good cause for a waiver based on: 1) the present lack of 17/24 GHz TT&C
                  facilities around the world; 2) the limited duration of its LEOP operations; and 3)
                  its ability to coordinate C or Ku—band LEOP operations. Accordingly, Intelsat is
                  authorized to use the center frequencies 5925.5 MHz (vertical polarization) and
                  6424.5 MHz (horizontal polarization) for LEOP global telecommand
                  transmissions (Earth—to—space), with one megahertz of assigned bandwidth at
                  each center frequency. Intelsat is also authorized to use the center frequencies
                  4197.0 MHz (vertical polarization) and 4198.5 MHz (vertical polarization) for
                  LEOP global telemetry transmissions (space—to—Earth), with 350 kilohertz of
                  assigned bandwidth at each center frequency. As a condition of this waiver,
                  Intelsat shall coordinate its LEOP operations with all potentially—affected
                  operators of other authorized radiocommunication systems. In the absence of a
                  coordination agreement regarding such operations, Intelsat‘s operations shall be
                  on a non—harmful interference basis i. e., Intelsat shall not cause harmful
                  interference to, and shall not claim protection from interference caused to it by,
                  any other lawfully operating radiocommunication system. Further, Intelsat must
                  terminate operations immediately upon notification of harmful interference to a
                  lawfully operating radiocommunication system.

         4.       Intelsat‘s request for a waiver of 47 C.F.R. § 25.202(g) to use C—band frequencies
                  for on—station TT&C is DENIED. Intelsat initially requested authority to operate


stated in Section 25.224. Intelsat North America LLC, Order and Authorization, DA 09—1132 (rel. May
26, 2009) (Intelsat Order).

‘ 47 C.F.R. § 25.202(g).


its BSS space station at the 121° W.L. orbital location, and requested the waiver
based on its authority to use C—band frequencies at this location. In amending its
application, Intelsat clarified that its on—orbit TT&C would be limited to
emergency operations, however, Intelsat failed to revise its waiver to include a
demonstration relevant to the 122.90° orbital location. In addition, to be
effective for emergency use, frequencies must be set aside for use at any time for
the life of the space station, effectively precluding or conflicting with the use of
spectrum by other operators on a long—term basis. We find that Intelsat has failed
to show good cause justifying a waiver of Section 25.202(g) for emergency on—
station TT&C.

Intelsat shall maintain its 17/24 GHz BSS space station with an east—west
longitudinal station—keeping tolerance of + 0.05 of the assigned 122.90° W .L.
orbital location.

Intelsat is reminded to take into consideration the geographic service
requirements of Section 25.225 of the Commission‘s rules when designing its
space station system. 47 C.F.R. § 25.225.

Intelsat‘s authorization to construct, launch, and operate its Galaxy BSS—4 space
station at the 122.90° W.L. orbital location will be null and void with no further
action on the Commission‘s part if the space station is not constructed, launched,
and placed into operation in accordance with the technical parameters, terms and
conditions of this authorization by these specified time periods following the date
of authorization:

a. Execute a binding contract for construction within one year (June 15, 2010)
b. Complete the Critical Design Review of the space station within two years
   (June 15, 2011)
c. Commence Construction of the space station within three years
   (June 15, 2012)
d. Launch and begin operations on the space station within five years
     (June 15, 2014)
e.    Intelsat must file a bond with the Commission in the amount of $3 million,
     pursuant to the procedures set forth in 47 C.F.R. § 25.165, within 30 days of
     the grant of this authorization.

The license term for Intelsat‘s 17/24 GHz BSS space station (Call Sign $2659) is
fifteen years, the term for non—broadcast 17/24 GHz BSS space station licensees.
The license terms begins to run on the date that Intelsat certifies to the
Commission that the space station has been successfully placed into orbit and its
operation fully conforms to the terms and conditions of this authorization. 47
C.F.R. § 25.121(a). Intelsat shall file this certification with the Chief, Satellite
Division, International Bureau, within ten business days of the space station
being put into operation.

On June 30of each year, Intelsat must file a report with the International
Bureau and the Commission‘s Columbia Operations Center in Columbia,
Maryland, containing the information current as of May 31" of that year,
pursuant to Section 25.210(1) of the Commission‘s rules. 47 C.F.R. § 25.210(1).


         10.      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 of other Administrations.*

         11.      This authorization and all conditions contained herein are subject to the final
                  outcome of the Commission‘s rulemaking in IB Docket No. 06—123 and any
                  requirements subsequently adopted therein.

         12.      Intelsat has thirty days from the date of release of this authorization to decline the
                  authorization as conditioned. Failure to respond within this period will constitute
                  formal acceptance of the authorization as conditioned.

         13. .    Intelsat‘s request for a partial waiver of 47 C.F.R. § 25.114(d)(3), which requires
                  the applicant to submit predicted space station antenna gain contour(s) for each
                  transmit and receive antenna beam, is GRANTED. The main purpose of the
                  antenna gain contour diagrams is to allow evaluation of the potential for harmful
                  interference with other operators and services in the frequency band. It also
                  facilitates the applicant‘s preparation of information that may be required for
                  submission to the International Telecommunication Union (ITU) to initiate and
                  complete coordination procedures." Intelsat complied with the rule for all beams
                  except its 24 gateway receive (GR) and 24 ubiquitous transmit (UT) spot beams."
                  For each of the GR and UT beams, Intelsat provided the antenna gain contour
                  information in .pdf format, instead of the required .gxt format, with one
                  exception.‘ Intelsat maintains that providing the information in .gxt format for
                  each of the 48 beams in Schedule S would pose an undue hardship.‘ While


* In its comments, SES requests that certain conditions relating to ITU procedures be included in each
17/24 GHz BSS authorization. Most of the conditions sought by SES are included in this condition,
which is a standard condition on space station authorizations. SES, however, also seeks to impose a
customer notification requirement. We see no reason to impose such a condition on this authorization at
this time. See 47 C.F.R. 25.111(b), and Intelsat Order, at para. 19.

* The .gxt format is compatible with the ITU‘s Radiocommunication Bureau‘s Graphical Interference
Management (GIMS) software used to perform interference and pfd analyses using GIMS. A description
of the GIMS software package can be found on the Internet at http://www.itu.int/ITU—
R/software/space/gims/indexhtml (last visited April 17, 2009).

5 Intelsat North America LLC, File No. SAT—AMD—200800701—00134, Exhibit A, at 1

‘ Intelsat did file one representative GR and UT beam in the required .gxt format.

® Intelsat North America LLC, File No. SAT—AMD—20080701—00134, Exhibit A, at 2.


                 Intelsat‘s .pdf format submission was not in compliance with the rule, in this
                 limited instance, we were able to complete our technical review of the antenna
                 gain contour information and determine that the Galaxy BSS—4 space station
                 meets the Commission‘s technical requirements. Nonetheless, obtaining the
                 antenna beam pattern information in the .gxt file format facilitates the space
                 station ITU coordination process. Consequently, as a condition of granting this
                 waiver, any antenna beam diagrams submitted by Intelsat for purposes of its ITU
                 submissions for this space station must be provided in .gxt format.

        14.      Intelsat‘s request for waivers of 47 C.F.R. §§ 25.114(c)(4)(i), 25.114(c)(4)(iii),
                 25.114(c)(8), and 25.114(d)(5), to the extent the rules request technical
                 information in a particular format DISMISSED as moot." Our review of the
                 application shows that no waivers are necessary because Intelsat submitted the
                 information in the format required by our rules."

        15.      This grant is issued pursuant to Section 0.261 of the Commission‘s rule on
                 delegated authority, 47 C.F.R. § 0.261, and is effective upon release. Petitions
                 for reconsideration under Section 1.106 or applications for review under Section
                 1.115 of the Commission‘s rules, 47 C.E.R. §§ 1.106, 1.115, may be filed within
                 30 days of the date of this order.


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° Intelsat North America LLC, File Nos. SAT—AMD—20080617—00126, Exhibit A, and SAT—AMD—
20080701—00134, Exhibit A.

° Intelsat‘s applications included the information required under the rules. See Intelsat North America
LLC, File Nos. SAT—AMD—20080114—00011, Exhibit 8; SAT—AMD—20080617—00126, Exhibit A; and
SAT—AMD—20080701—00134, Sections S9 and S10 of Schedule S.


9—16. Name of Contact Representative

            Name:          Susan H. Crandall                       Phone Number:                        202—944—7848

            Company:       Intelsat Corporation                    Fax Number:                          202—944—7870

            Street:        3400 International Drive, N.W.          E—Mail:                              susan.crandall@intelsat.com


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


CLASSIFICATION OF FILING
17. Choose the button next to the
classification that applies to this filing for    (N/A) 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.                      @ b3. Amendment to a Pending Application
                                                   £} b4. Modification of License or Registration
   {3 al. Earth Station
                                                   b5. Assignment of License or Registration
   @ a2. Space Station                             b6. Transfer of Control of License or Registration
                                                 ' C b7. Notification of Minor Modification
                                                  (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                  Satellite
                                                   (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                  States
                                                  (N/A) b10. Other (Please specify)
                                                    (N/A) b11. Application for Earth Station to Access a Non—U.S .satellite Not Currently Authorized
                                                  to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                     {(N/A) b12. Application for Database Entry
                                                   {4, b13. Amendment to a Pending Database Entry Application
                                                   {} b14. Modification of Database Entry


  17¢. Is a fee submitted with this application?
@) If Yes, complete and attach FCC Form 159.       If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
C3 Governmental Entity        L73 Noncommercial educational licensee
g£74 Other(please explain):

17d.

Fee Classification CWY — Space Station Amendment(Geostationary)




18. If this filing is in reference to an     19. If this filing is an amendment to a pending application enter both fields, if this filing is a
existing station, enter:                     modification please enter only the file number:
(a) Call sign of station:                    (a) Date pending application was filed:              (b) File number:
     $2659
                                             02/10/2005                                           SATLOA2005021000028


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:

D a. Fixed Satellite
E] b. Mobile Satellite
D c. Radiodetermination Satellite
 D d. Earth Exploration Satellite
 D e. Direct to Home Fixed Satellite
 D f. Digital Audio Radio Service
 E g. Other (please specify)               17/24 GHz BSS


21. STATUS: Choose the button next to the applicable status. Choose      |22. If earth station applicant, check all that apply.
only one.                                                                D Using U.S. licensed satellites
C3 Common Carrier        g Non—Common Carrier                            D Using Non—U.S. licensed satellites

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
C Connected to a Public Switched Network         C3 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).
D a. C—Band (4/6 GHz)          D b. Ku—Band (12/14 GHz)
El c.Other (Please specify upper and lower frequencies in MHz.)
        Frequency Lower: 17300              Frequency Upper: 25500           (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.
 {24 a. Fixed Earth Station
 C3 b. Temporary—Fixed Earth Station
 £4 o. 12/14 GHz VSAT Network
 g:4 d. Mobile Earth Station
 @ & Geostationary Space Station
 3 f. Non—Geostationary Space Station
 {} & Other (please specify)



26. TYPE OF EARTH STATION FACILITY:
{4 Transmit/Receive g* Transmit—Only            g*% Receive—Only   gy N/A
"For Space Station applications, select N/A."


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an ‘X" in the box(es) next to all that apply.)


    D a —— authorization to add new emission designator and related service
    D b —— authorization to change emission designator and related service
    D c —— authorization to increase EIRP and EIRP density
    D d —— authorization to replace antenna
     D e —— authorization to add antenna
     D f —— authorization to relocate fixed station
     D g — authorization to change frequency(ies)
     D h —— authorization to add frequency
     D i —— authorization to add Points of Communication (satellites & countries)
     D j —— authorization to change Points of Communication (satellites & countries)
         k —— authorization for facilities for which environmental assessment and
radiation hazard reporting is required
     E 1—— authorization to change orbit location
     D m —— authorization to perform fleet management
     D n —— authorization to extend milestones
     E o —— Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental          {y Yes @ No
impact as defined by 47 CFR 1.13077 IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.ER. 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
acronautical fixed radio station services are not required to respond to Items 30—34.                                                 j


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




 30. Is the applicant an alien or the representative of an alien?                                                       4 Yes m No ¢4 N/A




 31. Is the applicant a corporation organized under the laws of any foreign government?                                 (a) Yes @ No {3 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    4 Yes @ No 4 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          & Yss o No 53 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?                                  & Yos       C No
If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.


                                                                                                                          TechnicalDescription




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license              @ Yes       3 No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? If Yes, 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    C» Yes   @No
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,        «y 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   y Yes    @No
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 benefficiary(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      C3 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 "party to the application" for these purposes.




42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? IfYes,           «y Yes      i 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.)

     Amendment to conform to new 17/24 GHz Broadcasting Satellite Service                                          (‘BSS‘)   rules.      See
     Exhibit A.




Exhibits A—E




10


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 specified in 47 C.F.R. Part 25.

                                                                                                                              4 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.
                                                                                                                              c C
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.




11


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

 3 Individual
 {} Unincorporated Association
 {£74 Partnership
 g3y Corporation
 g£74 Governmental Entity
 @ Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Susan H. Crandall                                                      Assistant General Counsel, Intelsat Corporation
       ——>


             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).




12


FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT

The public reporting for this collection of information is estimated to average 2 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 jboley@fcee.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.



Document Created: 2019-05-23 14:27:19
Document Modified: 2019-05-23 14:27:19

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