Attachment Narrative & Exhibits

This document pretains to SAT-LOA-20160411-00035 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2016041100035_1133201

                                        Before the
                             Federal Communications Commission
                                   Washington, DC 20554




      In the Matter of

      Intelsat License LLC                               File No. SAT-A/O- _____________

      Application for Authority to Drift to and
      Operate JCSAT-RA, an In-orbit Satellite,
      at 169.0º E.L.



              APPLICATION FOR AUTHORITY TO OPERATE JCSAT-RA,
                     AN IN-ORBIT SATELLITE, AT 169.0º E.L.


       Intelsat License LLC (“Intelsat”), pursuant to Section 25.114 of the Federal

Communications Commission’s (“FCC” or “Commission”) rules,1 hereby requests authority to

drift to and operate JCSAT-RA, an in-orbit satellite, at the 169.0° E.L. orbital location. JCSAT-

RA is a non-common carrier C- and Ku-band satellite that Intelsat will take control over pursuant

to a commercial agreement with its owner, SKY Perfect JSAT Corporation (“JSAT”). Intelsat

expects to have the satellite on station at 169.0° E.L. in the second quarter of 2017, where it will

be collocated with Intelsat 8 (call sign S2460) and Intelsat 805 (call sign S2404). JCSAT-RA

will ensure station-kept service continuity until Horizons 3e (call sign S2947) is launched to

replace Intelsat 8 and Intelsat 805.

       As demonstrated below, Intelsat is legally and technically qualified to operate JCSAT-

RA as proposed. Moreover, there is good cause for waiver of certain limited technical



1
       47 C.F.R. § 25.114.

                                                     1


requirements. Grant of this application will serve the public interest by ensuring service

continuity and adding new capacity at the nominal 169° E.L. location. In accordance with the

Commission’s requirements,2 this application has been filed electronically as an attachment to

FCC Form 312 and Schedule S.

I.     BACKGROUND AND PROPOSED OPERATIONS

       JCSAT-RA was launched on August 21, 2009, and is currently located at 128° E.L.

Japan is the current licensing administration of the JCSAT-RA satellite. Pursuant to a

commercial agreement between Intelsat and JSAT, Intelsat will acquire control of JCSAT-RA

from JSAT once the satellite leaves the 128° E.L. station-keeping box, which is currently

expected to be sometime in January 2017. Intelsat seeks U.S. licensing authority to drift JCSAT-

RA to, and operate the satellite at, 169.0° E.L. in order to ensure continuity of service for

existing customers. JSAT has informed the Japanese regulator that the satellite will be re-

flagged to U.S. licensing. Intelsat expects JCSAT-RA to remain at 169.0° E.L. until the arrival

of Horizons 3e, currently expected to be in the first quarter of 2019.

       Currently, Intelsat 8 and Intelsat 805 are providing service at the nominal 169° E.L.

orbital location.3 Intelsat intends to launch Horizons 3e in the third quarter of 2018 to replace

both Intelsat 8 and Intelsat 805 at the nominal 169° E.L. orbital location.4 To bridge any gaps in



2
       47 C.F.R. § 25.114(c).
3
       Intelsat 8 is authorized to operate at 168.9° E.L. See Policy Branch Information; Actions
Taken, Report No. SAT-01139, File No. SAT-MOD-20151021-00073 (Feb. 26, 2016) (Public
Notice). Intelsat 805 is authorized to operate at 169.0° E.L. See Policy Branch Information;
Actions Taken, Report No. SAT-01139, File Nos. SAT-MOD-20151020-00072 and SAT-AMD-
20151120-00077 (Feb. 26, 2016) (Public Notice).
4
       Horizons-3 License LLC, Application for Authority to Launch and Operate Horizons 3e,
a Replacement Satellite with New Frequencies, at 169.0° E.L., File No. SAT-LOA-20151202-
00080 (filed Dec. 2, 2015) (“Horizons 3e Application”).

                                                      2


service that might otherwise occur between the retirement or start of inclined orbit operation of

Intelsat 8 and Intelsat 805 and the arrival of Horizons 3e, JCSAT-RA will be collocated with

Intelsat 8 and Intelsat 805. Intelsat seeks authority to begin drifting JCSAT-RA from the 128°

E.L. orbital location in January 2017, and anticipates that the satellite will be operational at

169.0° E.L. by the second quarter of 2017. The end of service life of JCSAT-RA is estimated to

be the end of 2024.

          The chart below illustrates the frequencies that will be used by JCSAT-RA and Horizons

3e, as well as the frequencies that currently are used by the Intelsat 8 and Intelsat 805 satellites,

at the nominal 169° E.L. orbital location.



                                Intelsat 8        Intelsat 805       Horizons 3e         JCSAT-RA
        3400-3700 MHz                                                  
        3700-3940 MHz                                                                    
        3940-4200 MHz                                                                   
        5850-5925 MHz                                                    
        5925-6225 MHz                                                                    
        6225-6425 MHz                                                                     
        6425-6485 MHz                                                                     
        6485-6650 MHz                                                                        
    10850-11700 MHz                                                                        
    12200-12250 MHz                                                                       
    12250-12500 MHz                                                                      
    12500-12750 MHz                                                                     
    12920-13250 MHz                                                                        
    13750-13997 MHz                                                                       
    13997-14000 MHz                 5
                                                                                           
    14000-14250 MHz                                                                     
    14250-14500 MHz                                                                      




5
          Included for the purpose of authorizing Intelsat 8’s use of the 13998.0 MHz command
link.

                                                      3


       JCSAT-RA contains new frequencies at 12200-12250 MHz and 13750-13997 MHz that

are not currently on either Intelsat 8 or Intelsat 805. As Intelsat explains in its pending

application, Horizons 3e will operate in both of these frequency bands in addition to two other

new frequency bands.6 Intelsat has – in the Horizons 3e application – already requested the

United States make ITU filings for the new frequency bands, including the 12200-12250 MHz

and 13750-13997 MHz bands.

II.    INTELSAT IS QUALIFIED TO HOLD THE AUTHORIZATION REQUESTED
       HEREIN

       A.      Legal Qualifications

       Intelsat is legally qualified to hold the space station authorization requested in this

application. The information provided in the attached Form 312 demonstrates Intelsat’s

compliance with the Commission’s basic legal qualifications.7 In addition, Intelsat already holds

multiple Commission satellite licenses, and its legal qualifications are a matter of record before

the Commission.8




6
       Horizons 3e Application, Legal Narrative at 8.
7
       Because JCSAT-RA, like all other satellites licensed to Intelsat, will operate on a non-
common carrier basis, Section 310(b) is not applicable to this license. See Applications of The
News Corp. Ltd. and The DIRECTV Group, Inc. (Transferors) and Constellation, LLC, Carlyle
PanAmSat I, LLC, Carlyle PanAmSat II, LLC, PEP PAS, LLC and PEOP PAS, LLC
(Transferees) for Authority to Transfer Control of PanAmSat Licensee Corp., Public Notice, 19
FCC Rcd 15424, 15425 n.5 (Int’l Bur. 2004).
8
        See Constellation, LLC, Carlyle PanAmSat I, LLC, Carlyle PanAmSat II, LLC, PEP PAS,
LLC, and PEOP PAS, LLC, Transferors and Intelsat Holdings, Ltd., Transferee, Consol.
Application for Authority to Transfer Control of PanAmSat Licensee Corp. and PanAmSat H-2
Licensee Corp., Memorandum Opinion and Order, 21 FCC Rcd 7368, 7381 (¶ 23) (2006) (“The
Commission previously has determined that PanAmSat and Intelsat are qualified to hold
licenses.”).

                                                      4


       B.      Technical Qualifications

       As demonstrated in the attached Form 312, Schedule S, and Engineering Statement,

Intelsat is technically qualified to hold the authorization requested herein. Specifically, Intelsat

provides the information required by Section 25.114 of the Commission’s rules.9 In addition,

Intelsat’s Engineering Statement provides information on compliance with the Commission’s

orbital debris mitigation rules.10

III.   REQUEST FOR TECHNICAL WAIVERS

       Intelsat requests a waiver of Sections 2.106 and 25.202(a)(1) of the Commission’s rules

to enable JCSAT-RA to use the 12200-12750 MHz band to provide downlink fixed satellite

services (“FSS”). In addition, Intelsat requests a waiver of Section 25.210(a)(3), which requires

that FSS satellites providing domestic service in the conventional C-band have the ability to

switch polarization sense upon ground command, and Section 25.210(i)(1), which requires FSS

satellites to achieve antenna cross-polarization isolation such that the ratio of the on-axis co-

polar gain to the on-axis cross-polar gain of the antenna in the assigned frequency band be at

least 30 dB within its primary coverage area.

       Under Section 1.3 of the Commission’s rules, the Commission has authority to waive its

rules “for good cause shown.”11 Good cause exists if “special circumstances warrant a deviation

from the general rule and such deviation will serve the public interest” better than adherence to




9
      This application is filed pursuant to the modified Part 25 rules, which Intelsat understands
the FCC will apply to pending applications as soon as these rules become effective. See
Comprehensive Review of Licensing and Operating Rules for Satellite Services, Second Report
and Order, 30 FCC Rcd 14713, 14825 ¶ 363 (2015) (“Part 25 Second Report and Order”).
10
       See Engineering Statement at 5-7; Mitigation of Orbital Debris, Second Report and
Order, 19 FCC Rcd 11567 (2004).
11
       47 C.F.R. § 1.3; WAIT Radio v. FCC, 418 F.2d 1153, 1159 (D.C. Cir. 1969).

                                                      5


the general rule.12 In determining whether a waiver is appropriate, the Commission should “take

into account considerations of hardship, equity, or more effective implementation of overall

policy.”13 As shown below, there is good cause for each of the requested technical waivers.

        A.      Sections 2.106 and 25.202(a)(1)

        Intelsat requests waiver of Sections 2.106 and 25.202(a)(1) of the Commission’s rules to

the extent necessary to allow Intelsat to provide downlink FSS in the 12200-12750 MHz band.

In the U.S. Table of Frequency Allocations, the 12200-12700 MHz band is allocated to fixed

service (“FS”) and broadcasting-satellite service (“BSS”) and the 12700-12750 MHz frequency

band is allocated to FS, Mobile Service (“MS”) and FSS (Earth-to-space).14 Section

25.202(a)(1) allocates the 12700-12750 MHz frequency band for Earth-to-space FSS

transmissions.15 JCSAT-RA will operate in the 12200-12700 MHz and 12700-12750 MHz

frequency bands in the space-to-Earth direction, which is in accordance with the Region 3

allocation.16

        The FCC has previously granted waivers to Intelsat 8 and Intelsat 805 to provide service

in the 12250-12750 MHz bands and 12500-12750 MHz bands, respectively, at the nominal 169º

E.L. orbital location.17 Good cause exists to grant a waiver here because, just as the Commission

recognized with respect to Intelsat 8 and Intelsat 805, JCSAT-RA is unlikely to cause harmful


12
        Northeast Cellular Telephone Co. v. FCC, 897 F.2d 1164, 1166 (D.C. Cir. 1990).
13
        WAIT Radio, 418 F.2d at 1159.
14
        47 C.F.R. § 2.106.
15
        47 C.F.R. § 25.202(a)(1).
16
        See 47 C.F.R. § 2.106.
17
       See Policy Branch Information; Actions Taken, Report No. SAT-00987, File No. SAT-
MOD-20130830-00110 (Dec. 20, 2013) (Public Notice); Intelsat License LLC, Request for
Special Temporary Authority to Drift Intelsat 805 to, and Operate at, 169.0° E.L., File No. SAT-
STA-20151002-00068, at 1-2 (stamp grant Nov. 25, 2015).

                                                    6


interference to existing or future users operating in accordance with the Table of Frequency

Allocations in International Telecommunications Union (“ITU”) Region 2 and the Commission’s

rules.18

           First, the operations of JCSAT-RA will not cause harmful interference in the 12200-

12700 MHz band. Operating at 169.0º E.L., JCSAT-RA will operate at least 15.8º away from—

and with no risk of providing harmful interference to—the nearest BSS network that could

service any portion of ITU Region 2 pursuant to the ITU Region 2 BSS Plan.19 Terrestrial

systems operating within the United States will not be subjected to harmful interference because

JCSAT-RA’s transmissions in the band will comply with ITU power flux-density (“PFD”)

limits.20

           Second, JCSAT RA’s operations in the 12700-12750 MHz band will not cause harmful

interference. Intelsat will protect terrestrial stations by complying with ITU PFD limits.

Additionally, Intelsat will operate in these frequencies in Region 2 on a non-protected basis and

will therefore not claim protection from interference caused by an FSS earth station operating in

that region.

           Good cause therefore exists to waive Sections 2.106 and 25.202(a)(1) with respect to

JCSAT-RA’s operations in the 12200-12750 MHz band because waiver will not result in


18
       See Intelsat License LLC, Application to Modify Authorization for Intelsat 8 (S2460), File
Nos. SAT-MOD-20120619-00100 & SAT-AMD-20120815-00131, at 2-3 (stamp grant Aug. 9,
2013); Intelsat License LLC, Request for Special Temporary Authority to Drift Intelsat 805 to,
and Operate at, 169.0° E.L., File No. SAT-STA-20151002-00068, at 1-2 (stamp grant Nov. 25,
2015).
19
        Under the ITU Region 2 BSS Plan, no BSS system may occupy a nominal orbital
position further west than 175.2° W.L. in the 12200-12700 MHz band or further east than 54°
W.L. in the 12500-12700 MHz band or 44° W.L. in the 12200-12500 MHz band. International
Telecommunication Union, Radio Regulations, Appendix 30, Annex 7 (2012).
20
           See Engineering Statement at 4.

                                                      7


harmful interference to or otherwise adversely affect any other operator. Moreover, waiver will

enable Intelsat to maintain continuity of service for existing customers in the time period

between the retirement or start of inclined orbit operation of Intelsat 8 and Intelsat 805 and the

arrival of Horizons 3e. The requested waiver is in the public interest because it allows Intelsat to

continue providing a high level of service without causing harmful interference.

       B.      Sections 25.210(a)(3) and 25.210(i)(1)

       Intelsat also requests a waiver of Sections 25.210(a)(3) and 25.210(i)(1) of the

Commission’s rules, which govern antenna polarization requirements for FSS satellites. There is

good cause to waive both of these requirements because the Commission recently eliminated

Sections 25.210(a)(3) and 25.210(i)(1) in the Part 25 streamlining proceeding.21 The

Commission’s December Second Report and Order, however, is not yet effective. Given that the

Commission has concluded that these rule provisions no longer serve the public interest, waiver

of their requirements is warranted.

IV.    REQUEST FOR GRANT WITHOUT MILESTONES OR A BOND

       To the extent necessary, Intelsat requests a waiver of Sections 25.164(a) and 25.16522 of

the rules for any possible milestone or bond associated with the operation of the 12200-12250

MHz and 13750-13997 MHz frequency bands, which are on JCSAT-RA, but are not currently

authorized for operation by either Intelsat 8 or Intelsat 805. Intelsat understands that when the

modified milestone and bond requirements adopted in the Part 25 Second Report and Order




21
       Part 25 Second Report and Order at 14817, ¶ 333.
22
       47 C.F.R. §§ 25.164(a) and 25.165.

                                                     8


come into force, the FCC will apply them to pending space station applications, such as this

one.23

         The Commission should grant this application without imposing a bond because there is

no risk of warehousing.24 Because JCSAT-RA already is in orbit and operating, all milestones

for this satellite have been satisfied and Intelsat should not be required to post a bond. Indeed,

JCSAT-RA will be able to provide service from the 169.0° E.L. location in a much more timely

manner than the five years that would be allowed to an applicant intending to construct, launch,

and operate a new satellite at this location.25 Moreover, warehousing is clearly not a concern in

this case given that, as its pending application demonstrates, Horizons 3e also will use the

12200-12250 MHz and 13750-13997 MHz frequency bands.26 The Commission has granted

similar applications for in-orbit satellites without imposing milestones or a bond, and

accordingly should do the same here.27




23
         See supra note 9.
24
        See Amendment of the Commission's Space Station Licensing Rules and Policies, First
Report and Order and Further Notice of Proposed Rulemaking, 18 FCC Rcd 10760, ¶ 170 (2003)
(“By making the bond payable upon failure to meet any milestone . . . we further strengthen our
protections against speculation and warehousing.”).
25
        See Loral Skynet Network Services, Inc., 21 FCC Rcd 14365 (Int’l Bur. 2006) (“Because
Telstar 18 is in-orbit and operating, Loral is not required to post a bond.”).
26
         Horizons 3e Application, Legal Narrative at 8.
27
       See Application of PanAmSat Licensee Corp. to Modify Authorization for Galaxy 11, File
No. SAT-MOD-20080225-00051 (stamp grant July 22, 2008); PanAmSat Licensee Corp.,
Application to Modify Authorization to Relocate Intelsat 5 to 169.0° E.L., File No. SAT-MOD-
20080725-00150 (stamp grant Oct. 17, 2008).

                                                     9


V.     GRANT OF THIS APPLICATION WILL SERVE THE PUBLIC INTEREST

       The authorization requested herein will serve the public interest by ensuring continuity of

service and providing additional capacity in the United States and Asia Pacific region from the

nominal 169° E.L. orbital location until the arrival of Horizons 3e.

VI.    USE OF THE 13750-14000 MHZ FREQUENCY BAND

       Intelsat understands that operations in the 13750-14000 MHz frequency bands are subject

to certain limitations and obligations, which Intelsat accepts and will fulfill. For operations in

this band, Intelsat accepts the following conditions:

              In the 13750-14000 MHz band (Earth-to-space), receiving space stations in the
               fixed-satellite service shall not claim protection from radiolocation transmitting
               stations operating in accordance with the United States Table of Frequency
               Allocations.

              Pursuant to footnote US337 of the United States Table of Frequency Allocations,
               47 C.F.R. § 2.106, any earth station in the United States and its possessions
               communicating with the JCSAT-RA space station in the 13750-13800 MHz band
               (Earth-to-space) is required to coordinate through National Telecommunications
               and Information Administration’s (“NTIA”) Interdepartment Radio Advisory
               Committee’s (“IRAC”) Frequency Assignment Subcommittee (“FAS”) to
               minimize interference to the National Aeronautics and Space Administration
               Tracking and Data Relay Satellite System, including manned space flight.

              Operations of any earth station in the United States and its possessions
               communicating with the JCSAT-RA space station in the 13750-14000 MHz band
               (Earth-to-space) shall comply with footnote US356 to United States Table of
               Frequency Allocations, 47 C.F.R. § 2.106, US356 which specifies a mandatory
               minimum antenna diameter of 4.5 meters and a non-mandatory minimum and
               maximum equivalent isotropically radiated powers (“e.i.r.p.”). Operations of any
               earth station located outside the United States and its possessions communicating
               with the JCSAT-RA space station in the 13750-14000 MHz band (Earth-to-space)
               shall be consistent with footnote 5.502 to the ITU Radio Regulations, which
               allows a minimum antenna diameter of 1.2 meters for earth stations of a
               geostationary satellite orbit network and specifies mandatory power limits.

              Operators of earth stations accessing the JCSAT-RA space station in the 13750-
               14000 MHz band are encouraged to cooperate voluntarily with the National
               Aeronautics and Space Administration (“NASA”) in order to facilitate continued
               operation of NASA’s Tropical Rainfall Measuring Mission (“TRMM”) satellite.

                                                     10


VII.    ORBITAL DEBRIS STATEMENT

        Intelsat has assessed and limited the probability of the JCSAT-RA space station

becoming a source of debris as a result of collision with large debris or other operational space

stations at 169.0° E.L. When the drift of JCSAT-RA is completed, Intelsat 8 will be operating at

168.9° E.L and Intelsat 805 will be operating at 169.0° E.L. JCSAT-RA and Intelsat 805 will

operate co-located at 169.0 E.L until traffic transition is complete, at which time Intelsat 805 is

expected, subject to receipt of FCC approval, to be moved to 169.1 E.L. Once launched,

Horizons 3e will operate at 169.0° E.L. While these satellites are nominally collocated with

JCSAT-RA, Intelsat will ensure that sufficient spatial separation is achieved between these two

satellites through the use of orbit eccentricity and inclination offsets and thus minimize the risk

of collision.

        With the exception of Intelsat 805 and Horizons 3e for the purpose of traffic transition,

JCSAT-RA will not be located at the same orbital location as another satellite or at an orbital

location that has an overlapping station keeping volume with another satellite. Further, Intelsat

is not aware of any other FCC-licensed system, or any other system applied for and under

consideration by the FCC, having an overlapping station-keeping volume with JCSAT-RA at

169.0° E.L. Finally, Intelsat is not aware of any system with an overlapping station-keeping

volume with JCSAT-RA at 169.0° E.L. that is the subject of an ITU filing and that is either in

orbit or progressing toward launch.

        Intelsat expects to operate JCSAT-RA at 169.0° E.L. until the arrival of Horizons 3e.

Although plans for JCSAT-RA post the arrival of Horizons 3e are not yet known, to the extent

that Intelsat License LLC remains the licensee of JCSAT-RA at the end of the satellite’s

maneuver life, Intelsat will dispose of the spacecraft by moving it to an altitude above the


                                                     11


altitude established by the Inter-Agency Space Debris Coordination Committee (“IADC”)

formula. Intelsat has reserved 10.2 kilograms of hydrazine for this purpose.28 In calculating the

disposal orbit, Intelsat has used simplifying assumptions as permitted under the Commission’s

Orbital Debris Report and Order.29

VIII. CONCLUSION

       In light of the foregoing, Intelsat respectfully requests that the Commission grant the

authorization requested herein.



                                                  Respectfully submitted,

                                                  /s/ Susan H. Crandall

                                                  Susan H. Crandall
                                                  Associate General Counsel
                                                  Intelsat Corporation

Jennifer D. Hindin
Colleen King
WILEY REIN LLP
1776 K Street, N.W.
Washington, DC 20006

April 11, 2016




28
       See Engineering Statement at 6.
29
       Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 (2004).

                                                   12


                                     Exhibit A
               FCC Form 312, Response to Question 34: Foreign Ownership

        The Commission previously approved foreign ownership in Intelsat License LLC
(“Intelsat”), in the Intelsat-Serafina Order.1 In December 2009 and October 2011, the
Commission also approved pro forma changes in Intelsat’s foreign ownership.2 There have been
no other material changes to Intelsat’s foreign ownership since the date of the Intelsat-Serafina
Order.




1
      Intelsat Holdings, Ltd. and Serafina Holdings Limited, Consolidated Application for
Consent to Transfer of Control of Holders of Title II and Title III Authorizations, Memorandum
Opinion and Order, 22 FCC Rcd 22151 (2007).
2
       See Intelsat North America LLC, Intelsat LLC, PanAmSat Licensee Corp., PanAmSat H-2
Licensee Corp., and Intelsat New Dawn Company, Ltd., Applications for Pro Forma Transfer of
Control, File Nos. SAT-T/C-20091125-00128, SAT-T/C-20091125-00124, SAT-T/C-20091125-
00127, SAT-T/C-20091125-00125, SAT-T/C-20091125-00126, SES-T/C-20091125-01505,
SES-T/C-20091125-01502, SES-T/C-20091125-01506, SES-T/C-20091125-01504 and SES-
T/C-20091125-01503 (granted Dec. 3, 2009); Intelsat Application for Pro Forma Transfer of
Control, File Nos. SAT-T/C-20110810-00160, SAT-T/C-20110811-00161, SES-T/C-20110811-
00948, SES-T/C-20110812-00963 (granted Oct. 13, 2011), and 0004825139 (granted Oct. 19,
2011).


                                       Exhibit B
             FCC Form 312, Response to Question 36: Cancelled Authorizations

Intelsat License LLC (“Intelsat”) has never had an FCC license “revoked.” However, on June
26, 2000, the International Bureau “cancelled” two Ka-band satellite authorizations issued to a
former Intelsat entity, PanAmSat Licensee Corp. (“PanAmSat”),3 based on the Bureau’s finding
that PanAmSat had not satisfied applicable construction milestones.4 In that same order, the
Bureau denied related applications to modify the cancelled authorizations. PanAmSat filed an
application for review of the Bureau’s decision, which the Commission denied, and subsequently
filed an appeal with the United States Court of Appeals for the District of Columbia Circuit,
which was dismissed in January 2003 at PanAmSat’s request. Notwithstanding the fact that the
Bureau’s action does not seem to be the kind of revocation action contemplated by question 36,
Intelsat is herein making note of the decision in the interest of absolute candor and out of an
abundance of caution. In any event, the Bureau’s action with respect to PanAmSat does not
reflect on Intelsat’s basic qualifications, which are well-established and a matter of public record.




3
       All licenses previously held by PanAmSat Licensee Corp. have been assigned to Intelsat
License LLC. See IBFS File Nos. SAT-ASG-20101203-00252 (granted Dec. 23, 2010), SES-
ASG-20101203-0150 (granted Dec. 20, 2010), and SES-ASG-20101206-01502 (granted Dec.
20, 2010).
4
         See PanAmSat Licensee Corp., Memorandum Opinion and Order, 15 FCC Rcd 18720 (IB
2000).


                                            Exhibit C
                            FCC Form 312, Response to Question 40:
                  Officers, Directors, and Ten Percent or Greater Shareholders

The officers and directors/managers of Intelsat License LLC are as follows:

Officers:
Franz Russ, Deputy Chairman
Michelle Bryan, Secretary
Mirjana Hervy, Director, Finance

Board of Managers:
Franz Russ
Michelle Bryan

The business address of all Intelsat License LLC officers and members of the Board of Managers is:
4 rue Albert Borschette
L-1246 Luxembourg

Intelsat License LLC is a Delaware limited liability company that is wholly owned by Intelsat
License Holdings LLC, also a Delaware limited liability company. Intelsat License Holdings LLC is
wholly owned by Intelsat Jackson Holdings S.A., a Luxembourg company. Intelsat Jackson
Holdings S.A. is wholly owned by Intelsat (Luxembourg) S.A., a Luxembourg company. Intelsat
(Luxembourg) S.A. is wholly owned by Intelsat Investments S.A., a Luxembourg company. Intelsat
Investments S.A. is wholly owned by Intelsat Holdings S.A., a Luxembourg company. Intelsat
Holdings S.A. is wholly owned by Intelsat Investment Holdings S.à r.l., a Luxembourg company.
Intelsat Investment Holdings S.à r.l. is wholly owned by Intelsat S.A., a Luxembourg company.
Each of these entities may be contacted at the following address: 4 rue Albert Borschette, L-1246
Luxembourg.

Intelsat S.A.’s ownership was approved by the Commission as part of the Intelsat-Serafina Order
and the recent Intelsat Pro Forma and is incorporated by reference. See Intelsat Holdings, Ltd. and
Serafina Holdings Limited, Consolidated Application for Consent to Transfer of Control of Holders
of Title II and Title III Authorizations, Memorandum Opinion and Order, 22 FCC Rcd 22151 (2007)
(“Intelsat-Serafina Order”); Intelsat Application for Pro Forma Transfer of Control, File Nos. SAT-
T/C-20110810-00160, SAT-T/C-20110811-00161, SES-T/C-20110811-00948, SES-T/C-20110812-
00963 (granted Oct. 13, 2011), and 0004825139 (granted Oct. 19, 2011) (“Intelsat Pro Forma”). On
May 16, 2012, the International Bureau granted an application to transfer control of Intelsat pursuant
to a public offering of newly issued voting shares by Intelsat, subsequent voting share sales by
current shareholders and possible private placements of newly issued voting shares. In the Matter of
Intelsat Global Holdings, S.A., Applications to Transfer Control of Intelsat Licenses and
Authorizations from BC Partners Holdings Limited to Public Ownership, Order, DA 12-768 (rel.
May 16, 2012). This change of control has not yet been fully consummated.



Document Created: 2016-04-11 18:55:20
Document Modified: 2016-04-11 18:55:20

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