Attachment Intelsat - Grant Jul

This document pretains to SAT-LOA-20101014-00219 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2010101400219_907853

                                                                             | File #_SAT— LoRA — 2010 ioi4t—00219,

                                                                              Call Sign S2817 GrantDate_67 /26/11
                                                                              (or other identifier)
                                                                  f                  gee. 4           Term Dates SeY:{4         Approved by OMB
                                                           5                  From_conmitions               po: Conmifions            3060—0678
                                                     | GRANTED*                 mm
Date & Time Filed: Oct 14 2010 11:58:51:786aM—       |_MicmationalBureau_| Approved:
File Number: SAT—LOA—20101014—00219                  *with conditions
Callsign/Satellite ID: $2817

                      APPLICATION FOR SATELLITE SPACE STATION AUTHORIZATIONS                                    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:
Application to Launch and Operate Intelsat 18, a Replacement Satellite With New Frequencies, at 180.0 E.L.
  1—8. Legal Name ofApplicant
           Name:          Intelsat North America LLC           Phone Number:                           202—944—7848
           DBA Name:                                           Fax Number:                             202—944—7870
           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


                                            Attachment to Grant
                                IBFS File No. SAT—LOA—20101014—00219
                                            Call Sign: S$2817
                                              July 26, 2011

The application of Intelsat License LLC (formerly, Intelsat North America LLC)(Intelsat) for authority to
construct, launch and operate a C—/Ku—band Geostationary Orbit (GSO) space station, to be known at
Intelsat—18, at the 180° E.L. orbital location, IBFS File No. SAT—LOA—20101014—00219, IS GRANTED.
Accordingly, Intelsat is authorized to operate the Intelsat—18 space station at the 180° E.L. orbital location
to provide Fixed Satellite Services (FSS) in the 3700—4200 MHz (space—to—Earth), 5925—6425 MHz
(Earth—to Space), 10.95—11.20 GHz (space—to—Earth), 11.45—11.70 GHz (space—to—Earth), 12.25—12.50 GHz
(space—to—Earth), 12.50—12.75 GHz (space—to—Earth) and 14.0—14.5 GHz (Earth—to—space) frequency bands.
Intelsat is also authorized to conduct telemetry, tracking, and telecommand (TT&C) operations using
frequencies centered on 6173.7 MHz and 6176.3 MHz (Earth—to—space) and 3947.5 MHz and 3952.5 MHz
(space—to—Earth). This authorization is granted in accordance with the terms, conditions, and technical
specifications contained in Intelsat‘s application, the Federal Communications Commission‘s rules, not
waived herein, and is subject to the following conditions:

         1.      Intelsat shall 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
ITU filings. We also note that 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. See 47 C.F.R. § 25.111(b).

       2.      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.

        3.       Intelsat shall operate the Intelsat—18 space station at the 180° E.L. orbital location in
compliance with all existing or future coordination agreements.

        4.      While at the 180° E.L. orbital location, Intelsat must maintain the Intelsat 18 space
station with an east/west longitudinal station—keeping tolerance of +/—0.05 degrees.

         5.       Intelsat‘s request for waiver of Section 25.114(d)(3) of the Commission‘s rules, 47 C.F.R.
§ 25.114(d)(3), IS GRANTED. Section 25.114(d)(3) requires predicted space station antenna gain
contours(s) for each transmit and each receive antenna beam and nominal orbital location requested.
Intelsat states that with respect to the wide coverage and omni—directional antenna gain diagrams
(Exhibits 6U, 6V, 6X and 6Y of the Engineering Statement) and the C—band and Ku—band ULPC antenna
gain diagrams (Exhibits 6Z1 and 6Z2 of the Engineering statement), the satellite manufacturer did not
provide in the format required by 25.114(d)(3). Instead, Intelsat has provided a descriptive
characterization of these beam patterns in addition to the beam patterns provided by the manufacturer.
We find that the exhibits of the antenna beams provided by Intelsat, together with the descriptive
characterization of the wide coverage and omni—directional antenna gain diagrams provided in the
application, fulfill the requirements of 25.114(d)(3).

        6.      Intelsat‘s request for a waiver of 25.202(g) of the Commission‘s rules, 47 C.F.R.
25.202(g), IS GRANTED. Intelsat requests a waiver of Section 25.202(g) of the Commission‘s rules to
allow it to conduct command functions for the Intelsat—18 space station in the 6173.7 and 6176.3 MHz


                                             Attachment to Grant
                                  IBFS File No. SAT—LOA—20101014—00219
                                              Call Sign: $2817
                                                July 26, 2011

frequencies and telemetry on the 3947.5 MHz and 3952.5 MHz frequencies. Section 25.202(g) limits
space station operators to TT&C links at the band edges 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.
Intelsat maintains that the specific command and telemetry channels for Intelsat—18 are a subset of those
on Intelsat 701 (the satellite it is replacing) and were chosen to minimize any hardware impact on
Intelsat‘s ground control stations.‘ In addition, Intelsat states Intelsat—18 will operate at the 180° E.L.
orbital location, where the telemetry frequencies of adjacent satellites may or may not be located at the
edge of the operating band." Intelsat states that the nearest co—frequency satellites to Intelsat 18 are
Intelsat 602 (Call Sign $2389) at 177.85° E.L. and SES World Skies NSS—9 (Call Sign $2756) at 183°
E.L. Intelsat states that operation of the Intelsat TT&C will be conducted within the conditions
previously coordinated with SES World Skies.* This waiver grant is based upon the finding that
placement of TT&C in the center of the standard C—band has already been coordinated for the existing
satellite at this orbital location, and therefore operation of the new satellite would not negatively alter the
potential impact on adjacent satellites or require additional coordination. As a condition of this waiver,
Intelsat must accommodate future space station networks that are compliant with Section 25.202(g).
Further, Intelsat must operate the C—band frequencies of Intelsat 18 pursuant to any existing or future
coordination agreements for this location.

         7.      Intelsat‘s requests for waivers of footnote NG104 of the United States Table of
Allocations, 47 C.F.R. § 2.106, and of footnote 2 to Section 25.202(a)(1) of the Commission‘s rules, 47
C.E.R. § 2.202(a), in order to use the 10.95—11.2 GHz and 11.45—11.7 GHz frequency bands to offer
domestic services on a non—interference basis in the United States ARE GRANTED, as conditioned. We
find that waiver does not undermine the purpose of the rules because the waiver involves only passive
receive—only earth stations that are not capable of causing interference into fixed stations operating in the
same bands." Furthermore, because Intelsat has agreed to accept any level of interference from fixed
stations into its receive—only earth stations‘ operations in these bands, fixed station operators are not be
required to coordinate their station operations with the space station operator‘s receive—only earth
stations‘ operations. Under these circumstances, we determine that an additional coordination burden is
not placed upon fixed station operators and their ability to expand service in the future would not be
restricted in any manner.

         8.       Intelsat shall operate its earth stations in the 10.95—11.20 GHz and 11.45—11.70 GHz
bands that provide domestic service in the United States on an unprotected, non—interference basis relative
to fixed stations and, as such, Intelsat may not cause harmful interference to, or claim protection from,
fixed stations to which frequencies in the 10.95—11.20 GHz and 11.45—11.70 GHz bands have either



‘ Legal Narrative at 5.
* Id.
* Id. at 5—6.
* Id. at 6.
° See PanAmSat Licensee Corp., Application for Authority to Use Extended Ku—band Frequencies for Domestic
Service, Order and Authorization, 20 FCC Red 14642 (Int‘l Bur. Sat. Div. rel. Sept. 15, 2005).

© See id., 20 FCC Red at 14646.


                                            Attachment to Grant
                                 IBFS File No. SAT—LOA—20101014—00219
                                             Call Sign: $2817
                                               July 26, 2011

already been assigned, or to which frequencies in the 10.95—11.20 GHz and 11.45—11.70 GHz bands may
be assigned at a later date.                                                                ‘

         9.      Intelsat is required to inform its customers, in writing, including end—users receiving
service from resellers accessing capacity on the Intelsat 18 space station, that domestic service in the
United States in the 10.95—11.20 GHz and 11.45—11.70 GHz bands is being provided on an uncoordinated
basis, and that the potential exists that future—licensed fixed stations may cause harmful interference to
these unprotected earth stations.

         10.    Intelsat‘s use of the 10.95—11.2 GHz and the 11.45—11.7 GHz frequency bands is subject
to footnote US211 to the United States Table of Frequency 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.

        11.        Use of the 12.25—12.7 GHz frequency band is not permitted for GSO Fixed—Satellite
Service, Direct Broadcast Satellite service, Broadcasting—Satellite Service, or Direct—to—Home service in
ITU Region 2.

         12.    Use of the 12.7—12.75 GHz frequency band is not permitted for Fixed—Satellite Service in
the space—to—Earth direction in ITU Region 2.

         13.    Pursuant to footnote US342 of the United States Table of Frequency Allocations, 47
C.ER. § 2.106, services operating in the 14.47—14.50 GHz band shall take all practicable steps to protect
the radio astronomy service from harmful interference.

        14.      Intelsat shall comply with the power levels specified in Section 25.212 of the
Commussion‘s rules unless it 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
180° E.L. orbital location. Intelsat shall 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
Commuission‘s rules applies to operations that exceed the power levels specified in Section 25.212. In no
event shall the uplink power density level of Intelsat—18‘s digital carriers exceed —38.7 dBW/Hz and the
downlink EIRP density of such carriers exceed —33.2 dBW/Hz for the C—band. Further, in no event shall
the uplink power density of Intelsat—18 ‘s digital carriers exceed —45 dBW/Hz and the downlink EIRP
density of such carriers exceed —24.5 dBW/Hz for the Ku—band.

         15.     Intelsat‘s operation of Intelsat 18 at the 180° E.L. orbital location in the 3700—4200 MHz
(space —to—Earth), 5925—6425 MHz (Earth—to—space), 10.95—11.20 GHz (space —to—Earth), 11.45—11.70
GHz (space —to—Earth), 12.50—12.75 GHz (space —to—Earth), and 14.0—14.5 GHz (Earth—to—space) 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 of Parties, 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.


                                               Attachment to Grant
                                  IBFS File No. SAT—LOA—20101014—00219
                                              Call Sign: $2817
                                                July 26, 2011

        16.      Intelsat—18 must begin providing service at the 180° E.L. orbital locations in the 3700—
4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to Space), 10.95—11.20 GHz (space—to—Earth), 11.45—
11.70 GHz (space—to—Earth), 12.50—12.75 GHz (space—to—Earth) and 14.0—14.5 GHz (Earth—to—space)
frequency bands before the satellite it is replacing, Intelsat 701 (Call Sign $2400), discontinues service at
the 180° E.L. orbital location. Failure to meet this milestone shall render this authorization to operate in
these frequency bands NULL and VOID.

          17. _ With respect to the 12.25—12.50 GHz (space—to—Earth) frequency band, Intelsat submitted
evidence that it had met the first three milestones required for a geostationary satellite pursuant to Section
25.164 of our rules, 47 C.F.R. § 25.164, and requested that the bond requirement pursuant to Section
25.165, 47 C.F.R. § 25.165, of our rules be reduced accordingly. Based on the evidence provided, the
Satellite Division finds that Intelsat has satisfied the first three milestones (execute a binding non—
contingent contract for construction, complete the critical design review, and commence construction)
required for a geostationary satellite. The milestone and bond requirements are adjusted accordingly.

              a.   Intelsat‘s space station at the 180° E.L. orbital location must be constructed, launched,
                   and placed into operation in accordance with the technical parameters and terms and
                   conditions of this authorization within two years following the date of this authorization
                   (July 26, 2013); and

              b.    Intelsat must file a bond with the Commission in the amount of $750,000, pursuant to the
                   procedures set forth in Public Notice, DA 03—2602, 18 FCC Red 16283 (2003), within 30
                   days of the date of this grant (August 25, 2011).
Failure to meet either of these dates shall render this authorization to operate in the 12.25—12.50 GHz
(space—to—Earth) frequency band NULL and VOID.

        18.        The license term for the space station is 15 years and will begin on the date that Intelsat
certifies to the Commission that Intelsat 18 has been successfully placed into orbit and its operations fully
conform to the terms and conditions of this authorization. Intelsat is directed to file its certification of
commencement of operation with the Commission within five business days of Intelsat 18 being placed
into operation at the 180° E.L. orbital location.

         19.     Intelsat is afforded 30 days from the date of release of this grant and authorization to
decline this authorization as conditioned. Failure to respond within this period will constitute formal
acceptance of the authorization as conditioned.

        20.        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 of the Commission‘s rules or applications for reconsideration 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 public notice indicating
that this action was taken.
                                                                     | File#_S6Ot—Lo8— 2010 1oit—0o0219

                                                                     Call Sign 8287 _ GrantDate_O7/26/)
                                                                      (or other identifier)
                                                     TmS                      see .            Term Dates CE _
                                                    We               From Cendifions                o     conditions
                                           |     GRANTED*®                  rmmnel
                                           {_L'.*tun;:aimml Bureau   Approved:                        « IIM
                                               with cafié{:fions                                S*eép& J Dual!I
                                                                                              CmeE Setetlite Pd?(:j Branch


  9—16. Name of Contact Representative
            Name:           Jennifer D. 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:      Jennifer D. Hindin                     Relationship:                       Legal Counsel


CLASSIFICATION OF FILING
17. Choose the buttonnext to the                  b.
classification that applies to thisfiling for   g°4 b1. Application for License of New Station
both questions a. and b. Choose only One         mya) p2, Application for Registration of New Domestic Receive—Only Station
for 17a and only one for 17b.                    (N/A) b3. Amendment to a Pending Application
                                                 (N/A) b4. Modification of License or Registration
  a.                   .                         (N/A) b5. Assignment of License or Registration
(N/A) al. Earth Statl(‘)n                        (N/A) b6. Transfer of Control of License or Registration
   ) a2. Space Station                           (N/A) b7. Notification of Minor Modification
                                                 (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed Satellite

                                                C b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                g¢74y b10. Replacement Satellite Application — no new frequency bands
                                                ) b1l. Replacement Satellite Application — new frequency bands (Not eligible for streamlined
                                                processing)
                                                £4 b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                (N/A) b13. Other (Please specify)


  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).
  £4 Governmental Entity ;4 Noncommercial educational licensee
g74 Other(please explain):

17¢. Fee Classification     BNY — Space Station (Geostationary)


18. If this filing is in reference to an existing station, enter:
(a) Call sign of station:
    Not Applicable




19. If this filing is an amendment to a pending application enter:
(a) Date pending application was filed:                                     (b) File number of pending application:

Not Applicable                                                              Not Applicable


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 £. Digital Audio Radio Service
D g. Other (please specify)


21. STATUS: Choose thebutton next to the applicable status. Choose       22. If earth station applicant, check all that apply.
only one.                                                                Not Applicable
  C3 Common Carrier @ Non—Common Carrier

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one.Are these
facilities:
      g4 Connected to a Public Switched Network g"4 Not connected to a Public Switched Network g 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.

 (N/A) a. Fixed Earth Station
 (N/A) b. Temporary—Fixed Earth Station
 (N/A) c. 12/14 GHz VSAT Network
 (N/A) d. Mobile Earth Station
 fg, e. Geostationary Space Station.
 4 £. Non—Geostationary Space Station
 «4 g. Other (please specify)




26. TYPE OF EARTH STATION                FACILITY: Not Applicable
PURPOSE OF MODIFICATION


 27. The purpose of this proposed modification is to: (Place an "X" in the box(es) next to all that   Not Applicable
 apply.)

 ENVIRONMENTAL POLICY


 28. Would a Commission grant of any proposal in this application or amendment have a significant environmental     3 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?                                «3 Yes @No




30. Is the applicant an alien or the representative of an alien?                                                          «3 Yes m No g3 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                    ; Yes @No & 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       o Yes @ No C 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          @ Yes C No ol 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 C No
 IfYes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.
                                                                                                                        Legal Narrative




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license        @ Yes {} 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.             Engineering Statemen




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.                                                                                           Orbital Letter




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,       3 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
                                                                                                                            Certification
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.
                                                                                                                             Photograph 1




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    Photograph 2
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,      3 Yes fod 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.)
     Intelsat North America LLC, pursuant to Section 25.114 of the rules of the Federal
     Communications Commission,                hereby applies to launch and operate a replacement C/Ku—band
     satellite with new frequencies,                   to be known as Intelsat 18,                at the 180.0 E.L.           orbital
     location.




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 specifiedin 47 C.F.R. Part 25.
                                                                                                                               3 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.
                                                                                                                              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.E.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.


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


 C Individual
 «4 Unincorporated Association
 g74 Partnership
 g74 Corporation
 «74 Governmental Entity
 #g, Other (please specify)    Limited Liability Company



45. Name of Person Signing                                               46. Title of Person Signing
Susan H. Crandall                                                        Asst. General Counsel, Intelsat Corporation
47. Please supply any need attachments.
 1:                                              2:                                               3:




           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).



Completed Schedule S




10


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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104—13, OCTOBER
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11



Document Created: 2011-07-26 15:46:24
Document Modified: 2011-07-26 15:46:24

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