Attachment Intelsat - Grant Oct

This document pretains to SAT-LOA-20110610-00105 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2011061000105_970836

4+See olSC File #_SBT— LoA—20110610 — oo ios Sar— Arib~ 2011 II102 19 182011001 670 52827 SAT—LOA—201 10610—00105 Intelsat License LL C Call Sign $2827 Grant Date_1O/ogh2. _ INTELSAT 27 (or other identifier) > Term Dates See Approved by OMB _cornditions From re —o: __condihitions 3060—0678 - GRANTED® Date & Time Filed: Jun 10 2011 3:01:18:820PM International Bureau Approved: File Number: SAT—LOA—20110610—00105 *with cordlitions Ste . Duall Callsign/Satellite ID: $2827 Chief, Satellite Policg Bronch 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 Replacement Satellite Intelsat 27 at 55.5 WL (304.5 EL) 1—8. Legal Name ofApplicant Name: Intelsat License 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

Intelsat License LLC IBFS File Nos. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215 Call Sign $2827 The application of Intelsat License LLC (Intelsat), IBFS File No. SAT—LOA—20110610—00105, as amended by SAT—AMD—20111111—00215, for authority to construct, launch, and operate a geostationary orbit space station, to be known as Intelsat 27, at the 55.5° W.L. orbital location is GRANTED.!‘ Specifically, Intelsat is authorized to construct and launch Intelsat 27, Call Sign $2827, which will be capable of operating in the 243.52—268.16 MHz, 292.835—317.33 MHz, 3700—4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), 11.45—12.20 GHz (space—to— Earth), 12.50—12.75 GHz (space—to—Earth), and 14.0—14.50 GHz (Earth—to—space) frequency bands. Intelsat is also authorized to operate Intelsat 27 in the 3700—4200 MHz (space—to—Earth), 5925— 6425 MHz (Earth—to—space), 11.45—12.20 GHz (space—to—Earth), 12.50—12.75 GHz (space—to— Earth), and 14.0—14.5 GHz (Earth—to—space) frequency bands at the 55.5° W.L. orbital location. In addition, Intelsat is authorized to conduct telemetry, tracking, and command operations for Intelsat 27 at the 55.5° W.L. orbital location using the center frequencies of 3701.25 MHz, . 3701.75 MHz, 3702.25 MHz, and 3702.75 MHz (space—to—Earth), and 5925.5 MHz and 6424.5 MHz (Earth—to—space). This authorization is subject to the technical specifications set forth in Intelsat‘s application as supplemented and amended and 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 satellite system, 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 with other administrations. See 47 C.F.R. § 25.111(b).— 2. Intelsat shall maintain its Intelsat 27 spacecraft within an east/west longitudinal station— keeping tolerance of + 0.05 degrees of the 55.5° W.L. orbital location. 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. ‘ The application and amendment were placed on Public Notice as accepted for filing on February 3, 2012. See Policy Branch Information, Satellite Space Applications Accepted for Filing, Public Notice, Report No. SAT—00841, (IBFS File No. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215). Intelsat filed a supplemental letter that corrects the minimum perigee disposal altitude represented in the orbital debris section of the Intelsat 27 application. See Letter from Susan H. Crandall Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary, FCC, dated February 23, 2012.

Intelsat License LLC IBFS File Nos. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215 Call Sign $2827 4. 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 Federal Communications Commission.* 5. Operations of Intelsat 27 in the 11.45—11.70 GHz band shall comply with the terms of 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. 6. Operations of Intelsat 27 in the 11.45—11.70 GHz band are limited to international operations in accordance with footnote NG104 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, NG 104, and footnote 2 of Section 25.202(a)(1) of the Commission‘s rules, 47 C.F.R. § 25.202(a)(1). 7. Intelsat shall comply with the power levels specified in Section 25.212 of the Commission‘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 55.5° W.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 Commission‘s rules applies to operations that exceed the power levels specified in Section 25.212. In no event shall the uplink input power spectral density level of Intelsat 27‘s digital carriers exceed —38.7 dBW/Hz into the antenna and the downlink equivalent isotropically radiated power (EIRP) density of such carriers exceed —32 dBW/Hz for the C—band. Further, in no event shall the uplink input power spectral density of Intelsat 27‘s digital carriers exceed —45 dBW/Hz into the antenna and the downlink EIRP density of such carriers exceed —20 dBW/Hz for the Ku—band. | 8. Intelsat‘s request for a waiver of Section 25.210(a)(3) of the Commission‘s rules, 47 C.F.R. § 25.210(a)(3), is GRANTED. Section 25.210(a)(3) requires all Fixed—Satellite Service (FSS) space stations used for domestic service in the 3700—4200 MHz and 5925— 6425 MHz bands to be capable of switching polarization sense upon ground command. The Commission requires polarity—switching capability for two reasons: (1) to provide U.S.—licensed satellites with the flexibility to operate at different orbital locations, and (2) to mitigate potential interference between adjacent fixed—satellite systems transmitting analog television signals. This waiver is based upon a finding that the ability to switch polarization is not currently necessary to protect other satellites at adjacent orbital locations from harmful interference, because the nearest co—frequency satellites adjacent to Intelsat 27 are Intelsat 707, located at 53.0° W.L., Intelsat 9, located at 58.0° W.L, and Intelsat 16, located at 58.1° W.L. Intelsat 707, Intelsat 16, and Intelsat 9 are licensed to Intelsat. Intelsat states that it will internally coordinate the transmissions between these spacecraft and Intelsat 27 to minimize interference. As a condition to this waiver, Intelsat must accommodate future satellite networks that are compliant with Section 25.210(a)(3). 2 See Letter from Phillip L. Spector, Executive Vice President, Business Development & General Counsel, Intelsat, to Marlene H. Dortch, Secretary, FCC (dated Oct. 9, 2012).

. Intelsat License LLC IBFS File Nos. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215 Call Sign $2827 Further, Intelsat must operate Intelsat 27 pursuant to any existing or future coordination agreements for this location. 9. Intelsat‘s request for a waiver of Section 25.202(a)(1) of the Commission‘s rules, 47 CER. § 25.202(a)(1), is GRANTED. Section 25.202(a)(1) lists frequencies that are available for FSS operations. This list does not include the 12.70—12.75 GHz band that Intelsat proposes to use for space—to—Earth FSS operations on Intelsat 27. This waiver is based upon a finding that Intelsat will not use the 12.70—12.75 GHz band to offer service to the United States, but to a number of Central and South American countries and Mexico. Further, in 2004, the Commission granted a waiver of Section 25.202(a)(1) for operation of Intelsat 805 for space—to—Earth FSS operations in the same 12.70—12.75 GHz band and at the same 55.5° W.L. orbital location that Intelsat proposes to operate Intelsat 27. Grant of this waiver is subject to the following conditions: (a) Intelsat shall not cause any harmful interference to existing and future authorized users operating in accordance with the U.S. Table of Frequency Allocations and shall accept any interference from authorized users, including Cable Auxiliary Service (CARS) operators, Broadcast Auxiliary Service (BAS) operators, Private Operational Fixed Point—to—Point Service (OFS) operators and Common Carrier Local TV Transmission Service (LTTS) operators.; (b) In the event of harmful interference to any authorized services operating in accordance with the ITU Table of Frequency Allocations resulting from Intelsat‘s use of the 12.7—12.75 GHz band in Region 2, Intelsat shall immediately cease operations in that band; (c) Before operating in the 12.7—12.75 GHz frequency band in the space—to—Earth direction, Intelsat shall coordinate with any potentially affected terrestrial users in the United States, its Possessions and Territories; (d) Intelsat will prepare any necessary submissions to the International Telecommunication Union and to affected administrations for the completion of the appropriate notification obligations for these frequency assignments in accordance with the ITU Radio Regulations, indicating their operation in accordance with Article 4; (e) Intelsat shall not provide service to the United States or its territories in the 12.7—12.75 GHz frequency band; (£) Intelsat is required to inform its customers in writing, including end—users receiving service from resellers accessing capacity on Intelsat 27, that service; (1) shall be discontinued should a report of harmful interference resulting from this service occur; * Intelsat LLC, Application to Modify Authorization for INTELSAT 805 to Allow the Provision of Fixed—Satellite Service Between Non—U.S. Points in the 12.7—12.75 GHz Frequency Band, Order and Authorization, 19 FCC Red. 2775 (2004)

Intelsat License LLC IBFS File Nos. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215 Call Sign 82827 (2) is being provided pursuant to authority subject to a non—harmful . interference basis, and that the customers therefore are not protected from harmful interference resulting from services that are allocated to this fre— quency band; (g) In the event that Intelsat receives any report of harmful interference, Intelsat shall inform the Commission of this and provide details of how it has been resolved; (b) To further protect services in this band, the power flux density limits (PFD) at the surface of the Earth for transmissions from the satellite in the band 12.7—12.75 GHz shall not exceed —138 dB(W/ m2) per 4 kHz in the service area. (i) The service area is limited to the countries of Peru, Ecuador, Colombia, Venezuela, Panama, Costa Rica, Nicaragua, El Salvador, Honduras, Guatemala, Belize and Mexico and the beam shall be pointed such that the PFD limits at the surface of the Earth do not exceed the following: —148 dB(W/m2) per 4 kHz for Elevation angles 5° or less. —148 + 0.5( —5) dB(W/ m2) per 4 kHz for Elevation angles 5°<= <=25°. —138 dB(W/ m2) per 4 kHz for Elevation angles from 25° to 90°.* 10. Intelsat‘s operation of Intelsat 27 at the 55.5° W.L. orbital location in the C—band frequencies of 3700—4200 MHz (space—to—Earth) and 5925—6425 MHz (Earth—to—space), and the Ku— and extended Ku—band frequencies of 12.5—12.75 GHz (space—to—Earth) and 14.0—14.25 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. 11. Intelsat 27 must begin providing service at the 55.5° W.L. orbital location in the 3700— 4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), 12.50—12.75 GHz (space— to—Earth), and 14.0—14.25 GHz (Earth—to—space), frequency bands before the space station it is replacing, Intelsat 805 (Call Sign $2404), discontinues service at the 55.5° W.L. orbital location. Failure to meet this milestone shall render this authorization to operate in these frequency bands NULL and VOID. 12. Intelsat states that Intelsat 27 will not use the 3400—3700 MHz, 5850—5925 MHz and 6425—6650 MHz bands that are currently authorized on the space station it is replacing, Intelsat 805 (Call Sign $2404). Therefore, this action is without prejudice to any decision regarding Intelsat‘s replacement expectancy to operate a space station in the 3400—3700 * Id. at 2778—79, 11.

Intelsat License LLC IBFS File Nos. SAT—LOA—20110610—00105, SAT—AMD—20111111—00215 Call Sign $2827 MHz, 5850—5925 MHz and 6425—6650 MHz frequency bands at the at the 55.5° W.L. orbital location. 13. Intelsat 27 contains frequencies in the 11.45—12.20 GHz and 14.25—14.50 GHz frequency bands that are not authorized on the Intelsat 805 space station. Thus, operations in these bands are subject to the Commission‘s milestone and bond requirements. As part of its application, Intelsat submitted evidence that it had met the first three milestones for the 11.45—12.20 GHz and 14.25—14.50 GHz frequency bands and requested a reduction in the required bond, pursuant to Section 25.165 of the Commission‘s rules, 47 C.F.R. § 25.165. Based on the evidence provided, the Satellite Division finds that Intelsat has satisfied the first three milestones (execute a non—contingent contract for construction, complete the critical design review, and commence construction) required for a geostationary satellite. As a result, the milestone and bond requirements are reduced. Accordingly, this authorization to operate in the 11.45—12.20 GHz and 14.25—14.50 GHz frequency bands shall become NULL and VOID, with no further action on the Commission‘s part if Intelsat does not meet the following conditions: a. 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 this grant (November 8, 2012); and b. Intelsat 27 must be launched and placed into operation in the 11.45—12.20 GHz and 14.25—14.50 GHz frequency bands at the 55.5° W.L. orbital location within two years following the date of this authorization (October 9, 2014). 14. The license term for the Intelsat 27 space station, Call Sign $2827, is 15 years and will begin on the date that Intelsat certifies to the Commission that the satellite has been successfully placed into orbit and thatits operation fully conforms to the terms and conditions of this authorization. Intelsat is directed to file this certification within five business days of Intelsat 27 commencing operation at the 55.5° W.L. orbital location. 15 . Intelsat is afforded 30 days from the date of release of this action to decline this authorization as conditioned. Failure to respond within this period will constitute formal acceptance of the authorization as conditioned. 16. 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 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 public notice indicating that this action was taken. colos SBT—LOB — 2Ov0OGIO— 00215 File# SAT— AMBD — 2oilli1l— Call Sign 52%2’7 Grant Date_10 /03 /12, (or other identifier) see Term Dates "See _ To conditions From condifions ternational ’.’»ui'r;:gl | Approved: s _i aaas]!—— <~ Te,p . $with conditions ChmeS, delliite ‘90“(3 Bronch

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: Relationship: Legal Counsel CLASSIFICATION OF FILING 17. Choose the buttonnext to the b. classification that applies to thisfiling for «4 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. (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 Station {(N/A) b6. Transfer of Control of License or Registration t&, 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 £4 b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States g4 b10. Replacement Satellite Application — no new frequency bands ) b11. Replacement Satellite Application — new frequency bands (Not eligible for streamlined processing) g4 b12. Petition for Declaratory Ruling to be Added to the Permitted List (N/A) b13. Other (Please specify)

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). C Governmental Entity &3 Noncommercial educational licensee 3 Other(please explain): 17c¢. 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 C 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: C Connected to a Public Switched Network C 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) E 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 @ c Geostationary Space Station. &4 f. Non—Geostationary Space Station «3 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 Boeing Lett the Commission‘s rules, 47 C.F.R. §§ 1.1308 and 1.1311, as an exhibit to this application. A Radiation Hazard ng LeHer 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? «y Yes @ No 30. Is the applicant an alien or the representative of an alien? Yes @No N/A 31. Is the applicant a corporation organized under the laws of any foreign government? y 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 y Yes @No 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 @©Ye No gN/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 Certification foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote. BASIC QUALIFICATION®S

35. Does the Applicant request any waivers or exemptions from any of the Commission‘s Rules? @ Ye { 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 ; 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 cireumstances. 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, {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 ; 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 ; 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, ; 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.) Intelsat License LLC seeks FCC authorization to launch and operate a replacement satellite N with new frequencies, to be known as Intelsat 27, at the 55.5 WL (304.5 EL) orbital location. Narrative & Exhibits 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. £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.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.

44. Applicant is a (an): (Choose the button next to applicable response.) ¢4 Individual «y Unincorporated Association ¢4 Partnership «4 Corporation C» Governmental Entity @, 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: 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

FCC NOTICE REQUIRED BY THE PAPERWORK REDUCTION ACT The public reporting for this collection of information is estimated to average 0.25 — 24 hours per response, including the time for reviewing instructions, searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept your comments regarding the Paperwork Reduction Act aspects of this collection via the Internet if you send them to PRA@fce.gov. PLEASE DO NOT SEND COMPLETED FORMS TO THIS ADDRESS. Remember — You are not required to respond to a collection of information sponsored by the Federal government, and the government may not conduct or sponsor this collection, unless it displays a currently valid OMB control number or if we fail to provide you with this notice. This collection has been assigned an OMB control number of 3060—0678. THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC L&AW 104—13, OCTOBER 1, 1995, 44 U.S.C. SECTION 3507. 11


Document Created: 2012-10-11 12:12:19
Document Modified: 2012-10-11 12:12:19
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