Attachment Intelsat - Grant Sep

Intelsat - Grant Sep

DECISION submitted by IB,FCC

Grant

2014-09-25

This document pretains to SAT-AMD-20140204-00019 for Amended Filing on a Satellite Space Stations filing.

IBFS_SATAMD2014020400019_1072945

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                                                                                  File#_SP1—BMD—RolfGactt—COo!9                              sprnep —2001001—COl(c$
$2388        SAT—AMD—20140204—00019       182014000205
Intelsat License LLC                                     |                                                     ;
INTELSAT 702                                             |                        Call Sign SA3SS GrantDate_J fas id
                                                                                  (or other identifier)
                                                                                                          TermDates (S€€ ;               Approved by OMB
                                                                                                                ~.. conddtions                  3060—0678

   Date & Time Filed: Feb 4 2014 6:18:30:886PM                 4    mal Dorear _| Apy
   File Number: SAT—AMD—20140204—00019                       +uih codfions                                         . Duall               h
                                                                                                     Chief         Sfellde Riigg Bronc
        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:
   Amendment to Pending Application for Modification ofAuthority for Intelsat 702
    1—8. Legal Name of Applicant

                Name:        Intelsat License 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


                                   Intelsat License LLC
           IBFS File Nos. SAT—MOD—20121001—00163, SAT—AMD—20140204—00019
                                      Call Sign $2388

The application of Intelsat License LLC (Intelsat), IBFS File No. SAT—MOD—20121001—00163,
as amended by IBFS File No. SAT—AMD—20140204—00019, to modify the authorization for its
Intelsat 702 space station (Call Sign $2388) is GRANTED.‘ Specifically, Intelsat is authorized
to operate Intelsat 702 in inclined orbit" at the 32.9° E.L. orbital location to provide Fixed—
Satellite Service (FSS) in the 3700—4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—
space), 10.95—11.2 GHz (space—to—Earth), 11.45—11.70 GHz (space—to—Earth) 12.5—12.75 GHz
(space—to—Earth), and 14.0—14.5 GHz (Earth—to—space) frequency bands." Intelsat is also
authorized to perform telemetry, tracking, and command operations necessary to maintain
Intelsat 702 at the 32.9° E.L. orbital location using the following center frequencies: 3947.5
MHz, 3948.0 MHz, 3952.5 MHz and 3952.0 MHz (space—to—Earth); and 6173.7 MHz and 6176.3
MHz (Earth—to—space). Operations under this authorization must be in accordance with the terms
and conditions contained in Intelsat‘s application and the Federal Communications
Commission‘s rules not waived herein, and are subject to the following conditions:
       1.      Intelsat must prepare the necessary information, as may be required, for
submission to the International Telecommunication Union (ITU) to initiate and complete the
advance publication, international coordination, due diligence, and notification process of 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,
coordination agreements are successfully completed. Any radio station authorization for which
coordination has not been completed may be subject to additional terms and conditions as


‘ The application was placed on Public Notice as accepted for filing on November 9, 2012. The amendment was
placed on Public Notice as accepted for filing on January 11, 2013. See Policy Branch Information, Satellite Space
Applications Acceptedfor Filing, Public Notice, Report No. SAT—00910 (IBFS File No. SAT—MOD—20121001—
00163); and Policy Branch Information, Satellite Space Applications Acceptedfor Filing, Public Notice, Report No.
SAT—01001 (IBFS File No. SAT—AMD—20140204—00019). No comments were filed. On October 19, 2012,
Intelsat was granted special temporary authority to drift Intelsat 702 from 47.5 E.L. to 33.0 E.L. to and operate it at
the 33.0° E.L. orbital location. SAT—STA—20121001—00164. This special temporary authority was extended through
October of 2013. See IBFS File Nos. SAT—STA—20121211—00215, SAT—STA—20130212—00021, SAT—STA—
20130410—00058, SAT—STA—20130607—00080, SAT—STA—20130808—00104. On November 1, 2013, Intelsat was
granted special temporary authority to drift to and operate Intelsat 702 at the 32.9° E.L. orbital position. SAT—STA—
20131023—00124. This authority was extended through August of 2014. See IBFS File Nos. SAT—STA—20131017—
00121, SAT—STA—20131125—00139, SAT—STA—20131219—00147, SAT—STA—20140123—00007, SAT—STA—
20140225—00027, SAT—STA—20140424—00041, SAT—STA—20140620—00073. An application for extension of this
authority was filed on August 22, 2014 and is currently pending. SAT—STA—20140822—00092.

* On June 29, 2011, Intelsat notified the Commission of the commencement of inclined orbit operations for Intelsat
702. See Letter from Susan H. Crandall, Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary,
FCC, dated June 29, 2011, available in IBFS File No. SAT—A/O—20000119—00002. The last north—south station—
keeping maneuver occurred on May 30, 2011. I¢d.

* Intelsat indicates that although Intelsat 702 is also capable of operating in the 11.7—11.95 GHz band, it does not
plan to operate Intelsat 702 in this band at the 32.9° E.L. orbital location, thus we do not authorize the use of these
frequencies at this location. Intelsat 702 operates on all of the same frequencies as Intelsat New Dawn except for the
5850—5925 MHz, 6425—6500 MHz, and 3625—3700 MHz bands. In addition, Intelsat 702 operates in the 12500—
12750 MHz band, which is not used by Intelsat New Dawn.


                                    Intelsat License LLC          .
            IBFS File Nos. SAT—MOD—20121001—00163, SAT—AMD—20140204—00019
                                       Call Sign $2388

required to effect coordination of the frequency assignments with other Administrations. 47
C.FR. § 25.111(b).
       2.      While at the 32.9° E.L. orbital location, Intelsat must maintain the Intelsat 702
space station with an east/west longitudinal station—keeping tolerance of +/— 0.05 degrees.
       3.     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.
        4.      Intelsat must operate Intelsat 702 at the 32.9° E.L. orbital location in compliance
with all existing or future coordination agreements for this location.
       5.      Intelsat is authorized to operate the Intelsat 702 space station in the 3700—4200
MHz and 5925—6425 MHz frequency bands as an emergency replacement for operation of these
frequencies on the Intelsat 28 space station.
        6.      Intelsat‘s request that the Part 25 technical waivers originally granted to the
Intelsat 702 spacecraft, Sections 25.202(g), 25.210(a)(1), 25.210(a)(3), 25.210(i) and 25.211(a)
of the Commission‘s rules, 47 C.F.R. §§ 25.202(g), 25.210(a)(1), 25.210(a)(3), 25.210(i) and
25.211(a), continue to apply at the 32.9° E.L. orbital location, is granted subject to the conditions
imposed in the original grant.5
       7.    Intelsat‘s operation of the Intelsat 702 space station in the 10.95—11.2 GHz and
11.45—11.7 GHz bands is subject to footnote US211 to the United States Table of Frequency

* Intelsat 702 is co—located with Intelsat New Dawn (Call Sign $2751) — now known as Intelsat 28 — which currently
operates at 32.8° E.L. IBFS File No. SAT—MOD—20101029—00228. After Intelsat New Dawn‘s launch on April 22,
2011, Intelsat was unable to deploy the C—band antenna on the spacecraft, thus Intelsat now operates Intelsat New
Dawn on only its authorized Ku—band frequencies. Because Intelsat 702 uses the 3700—4200 MHz and 5925—6425
MHz frequency bands that were authorized for Intelsat New Dawn, we grant Intelsat authority to use these
frequencies on Intelsat 702 as if it were an emergency replacement space station for Intelsat New Dawn in these C—
band frequencies. This action is consistent with prior Commission precedent. See, e.g., Loral Spacecom Corp.,
Order and Authorization, 13 FCC Red 16438 (Sat. Div. 1998) (granted application filed in April 1997 requesting
authority to launch and operate a ground spare as an emergency replacement for the Satcom IV satellite that suffered
an in—orbit failure in January 1997); Volunteers in Technical Assistance, Order, 12 FCC Red 3094 (Int‘l Bur. 1997)
(granted application filed in January 1996 to launch and operate an emergency replacement satellite for the
VITASAT—1 satellite that was destroyed by launch failure in August 1995; replacement satellite to be launched by
March 1997); American Telephone and Telegraph Company, Order and Authorization, DA 95—1972, 10 FCC Red
12132 (Int‘l Bur. 1995) (authorizing the launch and operation of Telstar 402R by December 1995, which was to
serve as an emergency replacement satellite for the Telstar 402 satellite lost shortly after its launch in September
1994); Hughes Communications Galaxy, Inc., Memorandum Opinion, Order and Authorization, 8 FCC Red 5089
(1993) (granting Hughes‘s October 1992 application to construct, launch, and operate an emergency replacement
satellite by December 1994 to replace the satellite that failed in August 1992); and GE American Communications,
Inc., Order and Authorization, 7 FCC Red 3212 (Com. Car. Bur. 1992) (granting GE‘s October 1991 application to
operate the in—orbit Anik D satellite as an emergency replacement for the Satcom IV satellite which failed in the fall
of 1991).
5 See Applications ofIntelsat LLC For Authority to Operate, and to Further Construct, Launch and Operate C—Band
and Ku—Band Global Satellites That Form a Global Communications System in Geostationary Orbit, Memorandum
Opinion and Order and Authorization , 15 FCC Red 15460, at Appendix C (2000) , recon. denied, 15 FCC Red
24234.


                                   Intelsat License LLC
           IBFS File Nos. SAT—MOD—20121001—00163, SAT—AMD—20140204—00019
                                          Call Sign $2388

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.
        8.     Intelsat‘s operation of the Intelsat 702 space station in the 10.95—11.2 GHz and
11.45—11.7 GHz bands is limited to international operations in accordance with footnote NG 52
to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, NGS2.
       9.      Intelsat 702 is not authorized to provide FSS in the 12.5—12.70 GHz frequency
band in International Telecommunication Union (ITU) Region 2.
       10.     Intelsat 702 is not authorized to provide FSS in the 12.70—12.75 GHz frequency
band in the space—to—Earth direction in ITU Region 2.
        11. Intelsat‘s operation of the Intelsat 702 space station in the 14.47—14.5 GHz frequency
band is subject to US342 of the United States Table of Frequency Allocations, 47 C.F.R § 2.106,
US342, which states that services operating in the 14.47—14.5 GHz band shall take all practicable
steps to protect the radio astronomy service from harmful interference.

         12.    Operations of Intelsat 702 to or from the United States must comply with the
power levels specified in Section 25.212 of the Commission‘s rules, 47 C.F.R. § 25.212,, unless
Intelsat coordinates any operations using power levels exceeding the levels in Section 25.212
with all potentially affected adjacent satellites within 6 degrees orbital separation of the 32.9°
E.L. orbital location. Intelsat must inform the Commission of the power levels it has
coordinated. In addition, Intelsat must inform all affected earth station operators that Section
25.220 of the Commission‘s rules applies to operations that exceed the power levels specified in
Section 25.212. In no event shall: (1) the uplink power density level of Intelsat 702‘s digital
carriers operating in the 5925—6425 MHz and 14.0—14.5 GHz bands exceed —38.7 dBW/Hz and —
45 dBW/Hz, respectively; (2) the downlink EIRP density of the Intelsat 702 digital carriers
operating in the 3700—4200 MHz band exceed —32 dBW/Hz; or (3) the downlink EIRP density of
the Intelsat 702 digital carriers operating in the 10.95—11.2 GHz, 11.45—11.7 GHz, and 12.5—12.75
GHz bands exceed —20 dBW/Hz."
        13.    Intelsat‘s operation of Intelsat 702 at the 32.9° E.L. orbital location in the 3700—
4200 MHz (space—to—Earth), and 5925—6425 MHz (Earth—to—space), 10.95—11.2 GHz (space—to—
Earth), 11.45—11.70 GHz (space—to—Earth), and 14.0—14.5 GHz (BEarth—to—space) frequency bands
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 ofParties, 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.


° See Engineering Exhibit at 8.


                                                       Intelsat License LLC
           IBFS File Nos. SAT—MOD—20121001—00163, SAT—AMD—20140204—00019
                                                         Call Sign $2388

          14.      This grant of authority is without prejudice to any decision with respect to any
replacement expectancy at the nominal 33° E.L. orbital location in the 3625—3700 MHz, 5850—
5925 MHz, and 6425—6500MHz bands."
       15.    Nothing in this authorization extends the license term for this space station, Call
Sign $2388, which expires on July 18, 2016.
        16.    Intelsat is afforded thirty days from the date of release ofthis grant and
authorization to decline this authorization as conditioned. Failure to respond within this period
will constitute formal acceptance of the authorization as conditioned.
        17.    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.


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" Intelsat 702 provides service at 32.9° E.L. onall of the same C—band frequencies that were authorized for Intelsat
New Dawn except for the 3625—3700, 5850—5925 MHz, and 6425—6500 MHz MHz bands.


9—16. Name of Contact Representative

            Name:          Jennifer 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 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
                                                  g34 b4. Modification of License or Registration
   g4 al. Earth Station
                                                 b5. Assignment of License or Registration
   f@, 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) bl 1. 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
                                                  g4 b13. Amendment to a Pending Database Entry Application
                                                  C3 b14. Modification of Database Entry


  17¢. 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).
3 Governmental Entity         ¢2y Noncommercial educational licensee
¢*4 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:
     $2388
                                             10/01/2012                                           SATMOD2012100100163


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:

E a. Fixed Satellite
D 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
D g. Other (please specify)


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
23 Common Carrier       €) 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:
C3 Connected to a Public Switched Network   g4 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).
E 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.
y a Fixed Earth Station
gy4 b. Temporary—Fixed Earth Station
¢3 o. 12/14 GHz VSAT Network
g4 d. Mobile Earth Station
@ c Geostationary Space Station
C3 £f. Non—Geostationary Space Station
g4 g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
{ Transmit/Receive C3 Transmit—Only             J 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
    E] 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 £— 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
    E] n —— authorization to extend milestones
    D o —— Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental         34 Yes m No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commussion‘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?                            » Yes @ No




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




31. Is the applicant a corporation organized under the laws of any foreign government?                                 1 Y° @ N 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    36 Y° & N 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 3 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?                                  @ Yes      4 No
IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.

                                                                                                                          EngineeringStatement




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license              @ Yes      <4 No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Comumission? 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    & 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   C 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      «y 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,        y 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 oris 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 License LLC,            pursuant to Section 25.116 of the rules of the Federal
     Communications Commission,              hereby amends the pending modification application seeking
     authority to relocate Intelsat 702                   (Call Sign §$2388)         to,   and to operate the satellite at,
     33.0 E.L.       With this amendment,            Intelsat seeks to change the requested orbital location
Legal Narrative




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.
                                                                                                                              o 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
 C3 Unincorporated Association
 ) Partnership
 g4 Corporation
 «4 Governmental Entity
 @ Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Susan H. Crandall                                                      Assoc. 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


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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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43. Description. (Summarize the nature of the application and the services to be provided).

Intelsat License LLC,          pursuant to Section 25.116 of the rules of the Federal Communications
Commission,      hereby amends the pending modification application seeking authority to relocate
Intelsat 702       (Call Sign $2388)        to,   and to operate the satellite at,            33.0 E.L.   With this
amendment,     Intelsat seeks to change the requested orbital location from 33.0 E.L.                        to 32.9 E.L.   to
ensure safe station—keeping of Intelsat 702 with neighboring Eutelsat space stations.




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Document Created: 2015-01-13 14:05:28
Document Modified: 2015-01-13 14:05:28

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