Attachment GRANT

GRANT

DECISION submitted by FCC,IB

GRANT

2009-07-28

This document pretains to SAT-AMD-20080114-00012 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2008011400012_727413

                                                                    "{viadsBR @ 99, |                          U lW—s
                                                                                                                               Approved byo—OM
                                                                                                                                      soc      B8
                                                                                                                                             067
                                                                                                   IBFS Nos.
                                                                    Call Sign: $2660              2295
                                                                                    021 07—% %(?1
                                                                    SAT—LOA—2005 0 080617—
Date & Time Filed: Jan 14 2008 3:29:38:4
                                         53PM                            x D—2
                                                                    SAT—AM     —20
                                                                                           —00240
                                                                                            0
                                                                     SsAT—AMD—20051118
File Number: SAT—AMD—20080114—00012                                  SsAT—AMD—2008011
                                                                                         4—00012
                                                                                           —00135
                                                                     SsAT—AMD—20080701

   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:
$2660 — 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




                                                          International Buréau    Approved:                        zo
                                                         CisBn cosd Niotk,                  Cmie%, Semtelirie Danstoo 4


                                   Intelsat North America LLC
                             File Nos. SAT—LOA—20050210—00029,
                    SAT—AMD—20051118—00240, SAT—AMD—20080114—00012,
                   SAT—AMD—20080617—00125, and SAT—AMD—20080701—00135
                                          Call Sign $2660
                               Attachment — Conditions of Authorization
                                              Julyz$, 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—3, at the 99.10° W.L.
W.L. orbital location, Call Sign $2660, which is offset 0.10° from the 99° 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—3 space station up to power flux density
                  (PFD) levels that are reduced from those specified in 47 CF.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 99° W.L. and 103° W.L. geostationary orbital locations, and the
                  corresponding off—axis gain Gooi(@) 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 99.10° W .L.
                  and 103° W.L. geostationary orbital locations, and the gain of the antenna
                  ‘Geor(@)‘ specified in Section 25.224(a)(1) at that angular separation. Then,
                  perform the subtraction Geor(@) — Geoi(@). The result is the required reduction in
                  the PFD from the value specified in the applicable subsectionof Section
                  25.208(c), or in Section 25.208(w)." Intelsat‘s Galaxy BSS—3 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.E.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. 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 stated in Section 25.224. Intelsat
North America LLC, Order and Authorization, DA 09—1132 (rel. May 26, 2009) (Intelsat Order).


                  transmissions shall meet the reduced PFD limits under all atmospheric
                  conditions. The PFD levels of Galaxy BSS—3°‘s transmissions shall not exceed
                  the maximum PFD levels stated in its application.

         2.       Intelsat shall maintain its 17/24 GHz BSS space station with an east—west
                  longitudinal station—keeping tolerance of + 0.05 of the assigned 99.10° W.L.
                  orbital location.

         3.       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.

         4.       Division ofSpectrum at the 99° W.L. Appendix F Orbital Location. Grant of this
                  application is subject to the provisions regarding division of spectrum contained
                  in Section 25.158(d) of the Commission‘s rules. Accordingly, in the event that
                  applications relating to call sign $2711 at the 99° W.L. Appendix F orbital
                  location are also granted, the available bandwidth at the orbital location will be
                  divided among the licensees at this location.* The following procedures apply to
                  the selection of spectrum by Intelsat:

                         a. Ensuring Contiguous Bandwidth Selections. Section 25.158(d)(6)
                         requires that each licensee‘s bandwidth selection shall not preclude other
                         licensees from selecting contiguous bandwidth. To implement the
                         selection of bandwidth at this location, operations for telemetry, tracking,
                         and telecommand (TT&C), service—link, and feeder—link band will be as
                         follows:

                                i. Downlink Transmissions. Telemetry and beacon transmissions in
                                the space—to—Earth direction may be conducted in an 11—megahertz
                                band segment at 17.300—17.311 GHz, an 11—megahertz band segment
                                at 17.689—17.700 GHz, and/or a 10—megahertz band segment at
                                17.790—17.800 GHz. The remaining portions of the 17.3—17.8 GHz
                                band may be used for service links in the space—to—Earth direction.

                                ii. Uplink Transmissions. Telecommand transmissions in the Earth—
                                to—space direction may be conducted in an 11—megahertz band
                                segment at 24.750—24.761 GHz, an 11—megahertz band segment at
                                25.139—25.150 GHz, and/or a 10—megahertz band segment at 25.240—
                                25.250 GHz. On our own motion, we grant a limited waiver of



* For purposes of this condition, the 99° W.L. Appendix F orbital location means the precise 99° W.L.
geostationary orbital location and other geostationary orbital locations offset from the 99° W.L. orbital
location.

* At the 99° W.L. Appendix F orbital location, Intelsat applied for authority to operate in the 17.3—17.8
GHz (space—to—Earth) and the 24.75—25.25 GHz (Earth—to—space) frequency bands. In contrast, DIRECTV
applied for authority to operate in the 17.3—17.7 GHz (space—to—Earth) and the 24.75—25.15 GHz (Earth—
to—space) frequency bands. Accordingly, there is no need to divide the 17.7—17.8 GHz (space—to—Earth)
and the 25.15—25.25 GHz (Earth—to—space) frequency bands at this orbital location, and those bands are
not subject to this condition.       '


    § 25.202(g) of the Commission‘s rules, 47 C.F.R. § 25.202(g), to
    permit TT&C operations in the 25.139—25.150 GHz band segment
  . Section 25.202(g) requires that "telemetry, tracking and
    telecommand functions for U.S. domestic satellites shall be
    conducted at either or both edges of the allocated band(s)." The
    allocated uplink band in this service is the 24.75—25.25 GHz band.
    The 25.139—25.150 GHz uplink band segment is a necessary
    counterpart to the 17.689—17.700 GHz downlink band segment. We
    grant this limited waiver to allow productive use of the 25.139—
    25.150 GHz uplink band segment that would otherwise be unused.
    This waiver only applies to use of the 25.139—25.150 GHz uplink
    band segment at the 99° W.L. Appendix F orbital location. The
    remaining portions of the 24.75—25.25 GHz band may be used by
    Intelsat for feederlinks in the Earth—to—space direction.

b. Selection Process. Intelsat will be allowed to select its the particular
band segments ("Selected Assignments") no earlier than 60 .days before
it plans to launch its satellite, and no later than 30 days before it plans to
launch its satellite, by submitting a letter to the Secretary of the
Commission. Intelsat shall serve copies of this letter to the other 17/24
GHz BSS Licensee at the 99° W.L. Appendix F orbital location. See 47
C.FR. § 1.47.

    i.. Selection ofDownlink TT&C. Intelsat may make up to two
    telemetry and/or beacon downlink frequency channel selections in
    the 17.3—17.7 GHz TT&C band segments with an bandwidth of one
    megahertz each: one in the 17.300—17.311 GHz TT&C band
    segment, and one in the 17.689—17.700 GHz TT&C band segment.
    Intelsat may also make up to one telemetry and/or beacon downlink
    frequency channel assignment selection with an bandwidth of one
    megahertz and in the 17.790—17.800 GHz TT&C band segment.

    i. Selection of Uplink TT&C. In the 24.75—25.25 GHz TT&C band
    segments, Intelsat may make up to three telecommand uplink
    frequency channel assignment selections with an bandwidth of one
    megahertz each: one in the 24.750—24.761 GHz TT&C band
    segment, one in the 25.139—25.150 GHz TT&C band segment, and
    one in the 25.240—25.250 GHz TT&C band segment.

    iii. Selection ofSpectrum within the 17.3—17.7 GHz bandfor Service—
    Link Operations and within the 24.75—25.15 GHz bandfor Feeder—
    Link Operations. In the 17.3—17.7 GHz band segment, the Selected
    Assignment shall give Intelsat access to 1/m of the quantity of
    spectrum in the band segment, for transmission on a primary basis,
    where "m" is the number of 17/24 GHz BSS Licensees authorized to
    provide service in the band segment at the 99° W.L. Appendix F
    orbital location at the time the Selected Assignment is chosen. In the
    17.3—17.7 GHz band segment, the Selected Assignment shall be
    chosen such that the lower band edge of the assignment is an integer
    multiple of 378/m megahertz fromthe band edge of the lower TT&C
    band segment, at 17.311 GHz, and the upper band edge of the


                           assignment is 378/m megahertz above the lower band edge of the
                           assignment. The edges of the corresponding feeder—link Selected
                           Assignment shall be 7450 MHz above the lower and upper band
                           edges of the service—link Selected Assignment.

                           tv. Selection ofSpectrum within the 17.7—17.8 GHz bandfor Service—
                           Link Operations and within the 25.15—25.25 GHz Bandfor Feeder—
                           Link Operations. In the 17.7—17.8 GHz band segment, the Selected
                           Assignment shall give Intelsat access to 1/n of the quantity of
                           spectrum in the band segment, for transmission on a primary basis,
                           where "n" is the number of 17/24 GHz BSS Licensees authorized to
                           provide service in the band segment at the 99° W.L. Appendix F
                           orbital location at the time the Selected Assignment is chosen. In the
                           17.7—17.8 GHz band segment, the Selected Assignment shall be
                           chosen such that the lower band edge of the assignment is an integer
                           multiple of 90/n megahertz from the lower band edge at 17.7 GHz,
                           and the upper band edge of the assignment is 90/n megahertz above
                           the lower band edge of the assignment. The edges of the
                           corresponding feeder—link band for the Selected Assignment shall be
                           7450 MHz above the lower and upper band edges of the Selected
                           Assignment.

                           Operations Within and Outside of the Selected Assignments. Intelsat
                           shall operate on a primary basis relative to the other 17/24 GHz BSS
                           Licensee within its Selected Assignments. Intelsat may also operate
                           in other portions of the 17.3—17.7 GHz, 17.7—17.8 GHz, and 24.75—
                           25.25 GHz frequency bands outside its own Selected Assignments
                           on a secondary basis with respect to operations of the other 17/24
                           GHz BSS Licensee in its respective Selected Assignments. Each
                           17/24 GHz BSS Licensee at the 99° W.L. Appendix F orbital
                           location that launches a satellite to that location shall serve a Notice
                           of Successful Launch, by letter to the Chief, Satellite Division,
                           International Bureau, Federal Communications Commission. Copies
                           of the letter shall be served on the other 17/24 GHz BSS Licensee at
                           the 99° W.L. Appendix F orbital location. Within one week of
                           receiving written notice of a successful launch, the 17/24 GHz BSS
                           Licensee operating at the 99° W.L. Appendix F orbital location
                           within the Selected Assignments of the newly launched satellite will
                           be required to cease operations on such selected assignments.

       5.      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 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

547 CFR. § 25.202(g).


               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 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 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 7.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.

       6.      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 the 121° W.L.
               orbital location and requested a waiver based onits authority to use C—band
               frequencies at that orbital 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 99.10° W.L. 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.

       7.      Intelsat‘s authorization to construct, launch, and operate its Galaxy BSS—3 space
               station at the 99.10° 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:          j

               a. Execute a binding contract for construction within one year (July Z_%_, 2010)
               b. Complete the Critical Design Review of the space station within two years
                    (July 2%, 2011)
               c. Commence Construction of the space station within three years
                    (July 2%, 2012)
               d. Launch and begin operations on the space station within five years
                    (July 2%, 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.


© Intelsat North America LLC, IBFS File No. SAT—AMD—20080114—00012, Exh. D, and SAT—LOA—
20050210—00029, at 10.


        8.       Intelsat North America LLC shall complete coordination of the physical
                 operations of the space station with operators of space stations with overlapping
                 station—keeping volumes within two years and two months of the grant of this
                 authorization. Intelsat shall notify the Chief, Satellite Division, International
                 Bureau, Federal Communications Commission, in writing, within 10 business
                 days of completion of such coordination. Failure to meet thls condition shall
                 render this authorization null and void.

        9.       The license term for Intelsat‘s 17/24 GHz BSS space station (Call Sign $2660) 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, Federal Communications Commission, within ten
                 business days of the space station being put into operation.

         10.     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).

         11.     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.‘

         12.     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.

         13.     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.



‘ 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.


         14.      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
                  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—3 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.

         15.      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 ARE DISMISSED as moot." Ourreview of
                  the application shows that no waivers are necessary because Intelsat submitted
                  the information in the format required by our rules."




® 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/index.html (last visited April 17, 2009).

° Intelsat North America LLC, File No. SAT—AMD—200800701—00135, 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—00135, Exhibit A, at 2.
" Intelsat North America LLC, File Nos. SAT—AMD—20080617—00125, Exhibit A, and SAT—AMD—
20080701—00135, Exhibit A.

} Intelsat‘s applications included the information required under the rules. See Intelsat North America
LLC, File Nos. SAT—AMD—20080114—00012, Exhibit 8; SAT—AMD—20080617—00125, Exhibit A; and
SAT—AMD—20080701—00135, Sections S9 and S10 of Schedule S.


16.   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.F.R. §§ 1.106, 1.115, may be filed within
      30 days of the date of this order.




                                                 Call Sign: 2650
                                                 SAT—LOA—20050210—00029         BFS Nos.
                                                 SAT—AMD—20080617—00125
                                                 SAT—AMD—20051118—00240
                                                 SAT—AMD—20080114—00012
                                                 SAT—AMD—20080701—00135




                         International Bureau   Appm%d. *yotc?            n nnin imreaanatstmimee~

                        Lotin cond*ide3               Cian &; SecteNokE OrntPei54)


9—16. Name of Contact Representative

            Name:          Susan Crandall                         Phone Number:                        202—944—7860
            Company:       Intelsat Corporation                   Fax Number:                          202—944—7860
            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
                                                  {34 b4. Modification of License or Registration
   C al. Earth Station
                                                  b5. Assignment of License or Registration
   {&, a2. Space Station                          b6. Transfer of Control of License or Registration
                                                   g3 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             '
                                                  {3 b13. Amendment to a Pending Database Entry Application
                                                  ¢3 b14. Modification of Database Entry


 17c¢. Is a fee submitted with this application?
) IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
Cp Governmental Entity        C Noncommercial educational licensee
34 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:
     $2660
                                             02/10/2005                                           SATLOA2005021000029


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 £. 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        @y 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:
«4 Connected to a Public Switched Network  {4 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)
E 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 ofstation that applies. Choose only one.
{£74 a. Fixed Earth Station
g74 b. Temporary—Fixed Earth Station
£34 o. 12/14 GHz VSAT Network
«4 d. Mobile Earth Station
& o. Geostationary Space Station
C £f. Non—Geostationary Space Station
{4 g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
{4 Transmit/Receive C Transmit—Only             C3 Receive—Only   @ 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
    E] 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
    El 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 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.F.R. 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?                             q4 Yes @ No




 30. Is the applicant an alien or the representative of an alien?                                                       34 Yes & No ;3 N/A




 31. Is the applicant a corporation organized under the laws of any foreign government?                                 ; Yes @ No 5; 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    #34 Yes @ No ¢3 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          @ Y°s { No 5 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       y No
IfYes, 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              @ Yos       (a) 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    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,        4 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   «4 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 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        «4 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,         «4 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.)
     Amendment to conform to new 17/24 GHz Broadcasting Satellite Service                                      (‘BSS‘)     rules.      See
     Exhibit A.




Exhibits A—E




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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.


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




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


C Individual
C Unincorporated Association
{ Partnership
> Corporation
 £;4 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).




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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,
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Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
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Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not
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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: 2019-04-13 06:00:53
Document Modified: 2019-04-13 06:00:53

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