Attachment Intelsat - Grant Dec

Intelsat - Grant Dec

DECISION submitted by IB, FCC

Grant Re-Issued February 7 2019

2018-12-04

This document pretains to SAT-LOA-20171027-00145 for Application to Launch and Operate on a Satellite Space Stations filing.

IBFS_SATLOA2017102700145_1621714

                                                         $     RE 155060 CA) FEE. 7)2015                        U) FLECT            5)’JDE. op EJC]ES

                                                                                              FiIe#   SAT-LOn-             2oL710Z7- OOt’
S3022           SAT-l_OA-2017102700145       1B20 17003088
Intelsat License LLC
Intelsat 15R                                                                                  Call Sign   53D2Z       Grant Datc    tZ/o’t/i
                                                                                              (or other identifier)
                                                                                                      see             Term Dates 5                 Approved by 0MB
                                                                                              from coifl                    To: I+iC5                     3060—0678
                                                                     GRANTED
                                                                  I ater    tional Durca ii   Approved:
            Date&TimeFile±0ct272017 l]:l8:11:550AM
            File Number: SAT—LOA—20171027—00 145                             CdIh11S                                  S
            Cailsign/Satetlite ID: S3022                                                                              Ch       ,SeiNi9mnth
                                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 for Authority to Launch and Operate Intelsat 15R, a Replacement Satellite with
                                                                                                   new Frequencies at $5.0 E.L.
          1—8. Legal Name ofApplicant
                     Name:          Intelsat License LLC                   Phone Number:                              703—559—7848
                     DBA Name:                                             Fax Number:                                703—559—8539
                     Street:        c/o Intelsat Corporation               E—Mail:                                    susan.crandall@intelsat.com
                                    7900 Tysons One Place
                     City:          McLean                                 State:                                         VA    -




                     Country:       USA                                    Zipcode:                                   22102           —5972
                     Attention:     Susan H. Crandall




        I


                                             ATTACHMENT TO GRANT
                                           Intelsat License LLC
                                IBFS File No. SAT—LOA—20 171027—00145
                        *REISSUED TO REFLECT SURRENDER OF FREQUENCIES*

   IBFS File No(s):        SAT—LOA—20171027—00145’                                                     GRANTED
   Licensee/Grantee:       Intelsat License LLC                                                     With Conditions
   Call Sign:              S3022
   Satellite Name:         Intelsat 15R
   Orbital Location:       85.0° E.L.
   (required station-      (+1- 0.05 degrees east/west)
   keeping tolerance)
   Administration:         United States of America
  Nature of Service:       Fixed-Satellite Service (FSS)                                         International Bureau
                                                                                                   Satellite_Division
  Scope of Grant:          Authority to construct, deploy, and operate a geostationary orbit (GSO) space station
  Previous Grant(s):       N/A
  Service Area(s):         See Schedule S Tech Report
  Frequencies:             10.95-11.2 GHz (space-to-Earth)
                           1 1.45-1 1.7 GHz (space-to-Earth)
                           1 1.7-12.2 GHz (space-to-Earth)
                           12.5-12.75 GHz (space-to-Earth)
                           13.75-14.5 GHz (Earth-to-space)

                           Tracking, telemetry and command center frequencies:
                           11.188, 11.090, 11.092 GHz (space-to-Earth); 14.002, 14.0045 (Earth-to-space)
  Unless otherwise specified herein, operations under this grant must comport with the legal and technical
  specifications set forth by the applicant or petitioner and with Federal Communication Commission’s rules
  not waived herein. This grant is also subject to the following conditions:
       1.    Intelsat must prepare the necessary information, as may be required, for submission to the International
            Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due
            diligence, and notification process of this space station, in accordance with the flU Radio Regulations.
            Intelsat will be held responsible for all cost-recovery fees associated with ITU filings. No protection
            from interference caused by radio stations authorized by other administrations is guaranteed unless
            coordination and notification procedures are timely completed or, with respect to individual
            administrations, coordination agreements are successfully completed. Any radio station authorization for
            which coordination has not been completed may be subject to additional terms and conditions as required
            to effect coordination of the frequency assignments of other administrations. See 47 CFR § 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 must operate Intelsat 15R at the 85.0° E.L. orbital location in compliance with all existing or
            future coordination agreements for this location. In the absence of a coordination agreement, such




  On December 4, 201$, the Satellite Division authorized Intelsat to operate the Intelsat 15R space station at the 85° E.L.
orbital location using the 10.95-11.2 GHz (space-to-Earth), 11.45-11.7 GHz (space-to-Earth), 11.7-12.2 GHz (space-to-
Earth), 12.5-12.75 GHz (space-to-Earth), 17.8-20.2 GHz (space-to-Earth), 13.75-14.0 GHz (Earth-to-space), 14.0-14.5 GHz
(Earth-to-space), 17.3-17.8 GHz (Earth-to-space), and 27.5-30.0 GHz (Earth-to-space) frequency bands. On December 20,
2018, Intelsat notified the Commission that it was surrendering the 17.3-17.8 GHz (Earth-to-space), 17.8-20.2 GHz (space-
to-Earth), and 27.5-30.0 GHz (Earth-to-space) frequency bands and the 20.180 GHz telemetry, tracking, and command
frequency. See letter from Jennifer D. Hindin, Counsel, Intelsat License LLC, to Marlene H. Dortch, Secretary, FCC, dated
Dec. 20, 2018. This grant, as reissued, removes the Ka-band frequencies and associated conditions for the Intelsat 15R space
station.
                                                       Page 1 of 4


                                    ATTACHMENT TO GRANT
                                  Intelsat License LLC
                       IBFS File No. SAT—LOA—20 171027—00145
                *P4SSUED TO REFLECT SURRENDER OF FREQUENCIES*

     operations must comply with applicable provisions of the ITU Radio Regulations as the Commission
     cannot guarantee the success of the required coordination.
4.   Intelsat must maintain the Jsitelsat 15R space station within an east/west longitudinal station-keeping
     tolerance of ± 0.05 degrees of the 85.0° E.L. orbital location.
5.   The operations of Intelsat 15R and associated earth stations must comport with the applicable uplink and
     downlink limits in 47 CFR § 25.140(a)(3) of the Commission’s rules, unless Intelsat coordinates any
     non-conforming operations with the operations of U.S.-licensed geostationary orbit space stations within
     6 degrees of the 85.0° E.L. orbital location. Non-conforming operation must also be coordinated with
     respect to those operations of non-U.S.-licensed space stations within 6 degrees of $5.00 E.L. involving
     approved communications with U.S-licensed earth stations.
6.   Intelsat’s use of the 10.95-11.2 and 11.45-11.7 0Hz frequency bands is limited to international operations
     in accordance with footnote NG52 to the United States Table of Frequency Allocations, 47 CFR § 2.106
     NGS2.
7.   Operations in the 10.95-11.2 GHz and 11.45-11.7 0Hz frequency bands are subject to footnote US211 to
     the United States Table of Frequency Allocations, 47 CFR § 2.106, US2Y1, 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. Although not a
     condition to this authorization, we also note that RAS frequently makes use of observations (passive) in
     bands not allocated to the RAS service. This practice is a result of scientifically valuable signals being
     subject to the Doppler Effect and shifted in frequency outside radio astronomy-allocated bands. For
     assistance with coordination or information about RAS sites, please contact the NSF Spectrum
     Management Unit: esm@nsf.gov.
8.   Pursuant to footnote US337 of the United States Table of Frequency Allocations, 47 CFR § 2.106,
     US337, any earth station in the United States and its possessions communicating with the Intelsat 15R
     space station in the 13.75-13.8 0Hz (Earth-to-space) frequency band is required to coordinate through
     the National Telecommunications and Information Administration (NTIA) Interdepartment Radio
     Advisory Committee (IRAC) Frequency Assignment Subcommittee (FAS) to minimize interference to
     the National Aeronautics and Space Administration (NASA) Tracking and Data Relay Satellite System,
     including manned space flight.
9.   In the 13.75-14.0 0Hz (Earth-to-space) frequency band, receiving space stations in the FSS must not
     claim protection from radiolocation transmitting stations operating in accordance with footnote US356 to
     the United States Table of Frequency Allocations, 47 CFR § 2.106, US356.
10. Operations of any earth station in the United States and its possessions communicating with the Intelsat
    15R space station in the 13.75-14.0 0Hz (Earth-to-space) frequency band must comply with footnote
    U5356 to the United States Table of Frequency Allocations, 47 CFR § 2.106, US356, which specifies a
    mandatory minimum antenna diameter of 4.5 meters and recommended 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 Intelsat 15R space station in the 13.75-14.0
    0Hz (Earth-to-space) frequency band must be consistent with No. 5.502 of the 1TU Radio Regulations,
    which specifies a mandatory minimum antenna diameter of 1.2 meters for earth stations of a
    geostationary satellite orbit network and specifies mandatory power limits.
11. Operations of any earth station in the United States and its possessions communicating with the Intelsat
     YSR space station in the 13.77-13.78 0Hz (Earth-to-space) frequency band must comply with footnote
    US357 to United States Table of Frequency Allocations, 47 CFR § 2.106, US357, which specifies that
    the maximum e.i.r.p. density of emissions not exceed 71 dBW in any 6 MHz band within the 13.77-13.78
    0Hz (Earth-to-space) frequency band for communications with a space station in geostationary-satellite

                                              Page 2 of 4


                                             ATTACHMENT TO GRANT
                                            Intelsat License LLC
                                 JBFS File No. SAT—LOA—20171027—00145
                         *RE4SSUED TO REFLECT SURRENDER OF FREQUENCIES*

              orbit. Operations of any earth station located outside the United States and its possessions
              communicating with the Intelsat 15R space station in the 13.77-13.78 GHz (Earth-to-space) frequency
              band must comply with No. 5.503 of the ITU Radio Regulations, which specifies a required maximum
              e.i.r.p. density of emissions (limit is dependent on antenna diameter) for communications with a space
              station in geostationary-satellite orbit.
          12. Operations of Intelsat 15R in the 14.47-14.5 GHz (Earth-to-space) frequency band is subject to the terms
              of footnotes 5.149 and US342 to the United States Table of Frequency Allocations, 47 CFR §2.106,
              5.149, US 342, which urge applicants to take all practicable steps to protect the radio astronomy service
              from harmful interference. For assistance with coordination or information about RAS sites, please
              contact the NSF Spectrum Management Unit: esm@nsf.gov.
          13. The FSS operations of Intelsat 15R and associated earth stations must comport with the parameters of the
              Appendix 30/30A satellite networks, USABSS-29 and USABSS-48, filed with the ITU for operation in
              the 11.7-12.2 GHz (space-to-Earth) frequency band and any additional conditions resulting from the
              coordination of this network.
         14. The power flux-density (PFD) at the Earth’s surface produced by the emissions from the Intelsat 15R
             space station, in the 10.95-11.2 GHz, 11.45-11.7 GHz and the 12.5-12.75 GHz frequency bands (space-
             to-Earth), must not exceed the applicable power flux-density limits contained in No. 21.16 in Article 21
             of the ITU Radio Regulations.
         15. Prior to commencing operations with the Intelsat 15R space station, Intelsat must file with the
             Commission the information required by Section 25.172 of the Commission’s rules, 47 CFR § 25.172.
         16. Intelsat 15R must begin providing service at the 85.0° E.L. orbital location in the 10.95-11.2 GHz, 11.45-
              11.7 GHz, 11.7-12.2 GHz, 12.5-12.75 GHz (space-to-Earth) and 13.75-14.0 GHz, 14.0-14.5 GHz (Earth-
             to-space) frequency bands before the satellites it is replacing, Intelsat 15 (Call Sign S2789) and Horizons
             2 (Call Sign S2423), discontinue service at the nominal 85.0° E.L. orbital location. Failure to meet this
             condition will render this authorization to operate in these frequency bands NULL and VOID.2
         17. Intelsat’s operation in the 10.95-11.20 GHz, 11.45-11.70 GHz, 12.5-12.75 GHz and 14.0-14.5 GHz
             frequency bands at the 85.0° E.L. orbital location 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 and Thirty-seventh 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 and Thirty-seventh
                               Assembly of the Parties, as amended.
         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 15R 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 15R being placed
             into operation at the 85.0° E.L. orbital location.
    Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
    conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.



2
 Intelsat 15 operates in the 10.95-11.2 GHz, 11.45-11.7 GHz, 12.5-12.75 GHz (space-to-Earth) and 13.75-14.5 GHz bands.
Horizons 2 operates in the 11.7-12.2 GHz (space-to-Earth) and 14.0-14.5 GHz (Earth-to-space) bands. Intelsat Narrative at 3.
                                                       Page 3 of 4


                                      ATTACHMENT TO GRANT
                                      Intelsat License LLC
                           IBFS File No. $AT—LOA—20 171027—00145
                   *1?jS5UED TO REFLECT SURRENDER OF FREQUENC]ES*

This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 CFR § 0.261,
and is effective upon release.

Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
amended, 47 U.S.C. § 309(h).

Action         December 4, 2018
Date:
Term Dates     From: see conditions               To: see conditions

Approved:



              Steph J. Duall
              Chief, Satellite Policy Branch




                                                Page 4 of 4


      9—16. Name of Contact Representative
                Name:            Jennifer D. Hindin                   Phone Number:                       202—719—4975
                 Company:        Wiley Rein                           Fax Number:                         202—719—7049
                 Street:         1776 K Street, NW                    E—Mail:                             jhindin@wileyrein.com


                City:            Washington                           State:                               DC
                Country:         USA                                  Zipcode:                            20006      —5972
                Attention:      Jennifer D. Hindin                    Relationship:                       Legal Counsel

CLASSIFICATION OF FILING
    17. Choose the buttonnext to the                  b.
    classification that applies to thisfiling for
    both questions a. and b. Choose only one        o  bI. Application for License of New Station
                                                    (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
  • 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


                                                    o b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United States
                                                    o blO. Replacement Satellite Application no new frequency bands
                                                                                               —




                                                     • b II. Replacement Satellite Application new frequency bands (Not eligible for streamlined
                                                                                               —




                                                    processing)
                                                    o   b12. Petition for Declaratory Ruling to be Added to the Permitted List
                                                    (N/A) bl3. Other (Please speci’)




2


     17c. Is a fee submitted with this application?
    • If Yes, complete and attach FCC form 159.
      If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
      0 Governmental Entity            Noncommercial educational licensee

    o Other(please explain):
    I 7c. 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




3


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c)
rd)
C
H


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
    • e. Geostationary Space Station.
    o   •   Non—Geostationary Space Station

    O   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       Yes   No
    impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1 30$
                                                                                                       and 1.13 1 1 of
    the Commission’s rules, 47 C.F.R. § 1.1308 and 1.13 11, 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 3 0—34.


5


     29. Is the applicant a foreign government or the representative of any foreign govern
                                                                                           ment?                                   Yes   No



    30. Is the applicant an alien or the representative of an alien?
                                                                                                                                 o Yes   No 0N/A



    31. Is the applicant a corporation organized under the laws of any foreign govern
                                                                                      ment?
                                                                                                                                 0 Yes   No 0N/A



    32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned
                                                                                                   of record or voted by
    aliens or their representatives or by a foreign government or representative thereof or by
                                                                                               any corporation organized         0 Yes   No 0N/A
    under the laws of a foreign country?




    33. Is the applicant a corporation directly or indirectly controlled by any other corpor
                                                                                             ation of which more than              Yes   No 0N/A
    one—fourth of the capital stock is owned of record or voted by aliens, their represe
                                                                                          ntatives, 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 percen
                                                                                             tage of stock they own or vote.

    BASIC QUALIFICATIONS




6


    35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules?
                                                                                                                                 Yes       No
     If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.




    36. Has the applicant or any party to this application or amendment had any FCC station authorization or license
                                                                                                                                 Yes   0   No
    revoked or had any application for an initial, modification or renewal of FCC station authorization, license,
                                                                                                                  or
    construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.




    37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling
    the applicant ever been convicted of a felony by any state or federal court? If Yes, attach as an exhibit, an            o   Yes       No
    explination of circumstances.




    3$. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,
                                                                                                                                 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? If Yes, 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
    matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstance
                                                                                                                     s.
                                                                                                                             o   Yes       No




7


    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 fiduciazy control, indicate the beneficiary(i
                                                                                                             es) 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 Cf R 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? If Yes,           Yes   No
    answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate.
                                                                                                                If No,
                                                                                                                               0
    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?




8


    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 hereby applies to launch and operate a Ku—band
                                                                             replacement satellite
         with new frequencies, to be known as Intelsat 15R, at the 85.0 E.L. orbital
                                                                                     location.



      Legal Narrative


    43a. Geographic Service Rule Certification
    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.


    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.


    By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic               OC
    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.

                                                                                                                                  Engineering Stmt

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.




9


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


  o Individual
 0     Unincorporated Association

 O     Partnership

 o Corporation
 o Governmental Entity
 • Other (please specify)        Limited Liability Company


45. Name of Person Signing                                                 46. Title of Person Signing
Susan H. Crandall                                                          Assoc. Gen. 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 3 l2(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).




10


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II



Document Created: 2019-02-07 17:29:34
Document Modified: 2019-02-07 17:29:34

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