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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