Intelsat 27 - Letter

LETTER submitted by Intelsat LLC

Letter

2012-10-09

This document pretains to SAT-AMD-20111111-00215 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2011111100215_970576

October 9, 2012

VIA IBFS

Marlene H. Dortch, Secretary
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554

Re:      Application for Authority to Launch and Operate Intelsat 27, a
         Replacement Satellite With New Frequencies, at 304.5° E.L.;
         File Nos. SAT—LOA—20110610—00105 and SAT—AMD—20111111—
         00215; Call Sign $2827

Dear Ms. Dortch:

Intelsat License LLC ("Intelsat") hereby provides clarification and supplemental
information in connection with its pending application to launch a satellite, to
be known as Intelsat 27. The satellite carries a UHF station, and, as indicated in
an amendment filed on November 11, 2011, and a supplement filed September
21, 2012,‘ Intelsatin its current application is not seeking authority from the
Federal Communications Commission ("FCC") to operate the UHF station.
Intelsat acknowledges that construction and launch of the satellite without
obtaining operational authority for the UHF station is at its own risk.

Intelsat expects that the United States will register the satellite under the
Convention on Registration of Objects Launched into Outer Space, and, Intelsat
recognizes that, pursuant to Article VIII of the Treaty on Principles Governing
the Activities of States in the Exploration and Use of Outer Space, including the
moon and Other Celestial Bodies, the United States shall retain jurisdiction and
control over the object. Intelsat further recognizes that the FCC, pursuant to its
licensing procedures® and Article 18 of the International Telecommunication




‘ Intelsat subsequently withdrew the supplement filed September 21, 2012.
Letter from Jennifer D. Hindin, Counsel to Intelsat License LLC to Marlene H.
Dortch, Secretary, FCC, File Nos. SAT—LOA—20110610—00105 and SAT—AMD—
20111111—00215 (dated Oct. 4, 2012).

247 CFR. § 25.113(g).



Intelsat Corporation
3400 International Drive NW, Washington DC 20008—3006 USA www.intelsat.com T +1 202—944—6800 F+1 202—944—7898


Ms. Marlene H. Dortch, Secretary
October 9, 2012
Page 2


Union Radio Regulations," therefore will consider the UHF payload in its
licensing decision, and is a licensing Administration with respect to all aspects
of Intelsat 27 operations. The discussion in the September 21 supplement of the
Italian Administration‘s role as a licensing Administration for the Intelsat 27
UHF payload was not intended to imply any view concerning the jurisdiction
and control afforded the United States or the licensing role of the FCC. Intelsat
recognizes that any operation of the UHF payload will require prior consent
and/or authorization by the FCC, in exercise of its licensing authority. As the
UHF band is limited to military operations in the United States National Table
of Frequency Allocations," Intelsat also acknowledges that any prior consent
and/or authorization by the FCC will require NTIA and DoD concurrence.

Therefore, Intelsat understands and accepts that any license the FCC issues in
the near term for the launch of the Intelsat 27 satellite may include a condition
requiring that any operations in the 243.52—268.16 MHz and 292.835—317.33
MHz frequency bands will require the filing of an application and affirmative
authorization and/or consent of the FCC, in coordination with NTIA and DoD.

Respectfully Submitted,




Phillip L. Spector
Executive Vice President, Business
Development, & General Counsel

ce (via email): Mr. Robert Nelson, FCC
                Karl Kensinger, Esq., FCC
               Mr. Edward Davison, NTIA
               Susan Crandall, Esq., Intelsat
               Jennifer Hindin, Esq., Wiley Rein




* "No transmitting station may be established or operated by a private person or
by any enterprise without a license issued ... by or on behalf of the government
of the country to which the station in question is subject."

*47 C.F.R. § 2.106, footnote G100 ("The bands 235—322 MHz and 335.4—399.9
MHz are also allocated on a primary basis to the mobile—satellite service,
limited to military operations.").



Document Created: 2019-04-15 04:02:11
Document Modified: 2019-04-15 04:02:11

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