Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20110420-00073 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2011042000073_884626

                                         Before the
                             Federal Communications Commission
                                    Washington, DC 20554


      In the Matter of

      Intelsat License LLC                              File No. SAT-MOD-2011______

      Application to Modify Authorization to            Call Sign: S2469
      Relocate Galaxy 26 to 50.0° E.L.




                       APPLICATION OF INTELSAT LICENSE LLC
                     TO MODIFY AUTHORIZATION FOR GALAXY 26

       Intelsat License LLC (“Intelsat”), pursuant to Section 25.117 of the rules of the Federal

Communications Commission (“Commission” or “FCC”),1 hereby seeks to modify the

authorization for the Galaxy 26 satellite (call sign S2469).2 Specifically, this modification seeks

authority to relocate Galaxy 26 to, and operate the satellite at, the 50.0° E.L. orbital location in

the Ku-band and portions of the C-band3 pursuant to the ITU filings of the Turkish

Administration for that location. Galaxy 26 currently operates at 50.75° E.L. The proposed

slight relocation of Galaxy 26 is necessitated by the impending launch of Yahsat-1A to 52.5°

E.L. and the need to avoid harmful interference for Galaxy 26’s U.S. Government customers.




1
       47 C.F.R. § 25.117.
2
       Galaxy 26 (call sign S2469) formerly was known as Intelsat Americas 6 or IA-6.
3
        Command and telemetry will be performed in the C-band. In addition, specific portions
of the C-band communications payload will be used for ranging and back-up command, as
detailed in the attached Engineering Statement. The remainder of the satellite’s C-band
communications payload will not be used.


       This application has been filed electronically as an attachment to FCC Form 312.4

Intelsat provides the technical information relating to the proposed modification on Schedule S

and in narrative form in the attached Engineering Statement, pursuant to Section 25.114 of the

Commission’s rules.5

I.     PROPOSED MODIFICATION

       By this modification application, Intelsat requests authority to relocate Galaxy 26 to, and

operate the satellite at, 50.0° E.L. pursuant to the ITU filings of the Turkish Administration.

Intelsat is currently operating at the 50.75° E.L. orbital location.6 At 50.0° E.L., Intelsat will

operate Galaxy 26 satellite in the same frequencies as the satellite currently uses at the 50.75°

E.L. location.7 Specifically, Intelsat will operate the Galaxy 26 satellite on the Ku-band

frequencies of 14.0-14.5 GHz (Earth-to-space) and 11.7-12.2 GHz (space-to-Earth). Intelsat

will conduct Galaxy 26 command, telemetry and ranging in the following C- band frequencies:

                 Carrier                                      Frequency
            Primary Command                        5926.5 MHz (Earth-to-space) (RHCP)
            Back-Up Command                         6411 MHz (Earth-to-space) (RHCP)
                Telemetry                           4196.5 MHz (V) or 4199.5 MHz (V)
                 Ranging                              6315 MHz (V) (Earth-to-space)
                                                      4090 MHz (H) (space-to-Earth)


The remainder of the satellite’s C-band communications payload will not be used. Intelsat has

submitted a request for Special Temporary Authority to begin drifting the Galaxy 26 satellite to



4
       47 C.F.R. § 25.117(c).
5
       47 C.F.R § 25.114.
6
       See Policy Branch Information; Actions Taken, Report No. SAT-00613, DA 09-1363,
File No. SAT-MOD-20090309-00034 (Jun. 19, 2009) (Public Notice) (“Galaxy 26 Grant for
50.75° E.L.”).
7
       See Galaxy 26 Grant for 50.75° E.L.


                                                  2


50.0° E.L. and begin operating at that location pending grant of this modification application.8

The 50.0° E.L. location currently is unoccupied.


II.    PUBLIC INTEREST SHOWING

       Grant of this modification will serve the public interest because it will allow Intelsat to

continue to provide U.S. Government customers with capacity in the Indian Ocean region

without risk of harmful interference. The Galaxy 26 satellite is moving from 50.75° E.L. to

50.0° E.L. due to the impending launch of Yahsat-1A to 52.5° E.L.9 Once Yahsat-1A is on-

station, it likely will interfere with the operations of Galaxy 26 at 50.75° E.L. Moving Galaxy 26

to 50.0° E.L. prior to Yahsat-1A being brought into service will allow both satellites to operate

without harmful interference.

       Grant of this modification request will not result in increased risk of harmful interference.

At 50.0° E.L., Intelsat will operate Galaxy 26 pursuant to the coordination agreements of the

Turkish Administration for that location.10

III.   TECHNICAL WAIVER AND CONDITIONS

       Intelsat requests that the waiver of Section 25.202(g) previously granted for Galaxy 26 at

50.75° E.L. continue to apply at 50.0° E.L.11 In connection with this waiver, Intelsat agrees to

accept as a condition a requirement to accommodate future space station networks that are


8
      See Intelsat License LLC, Request for Special Temporary Authority for Galaxy 26, File
No. SAT-STA-20110314-00053 (filed Mar. 14, 2011).
9
       Yahsat-1A is expected to launch, with Intelsat’s New Dawn satellite, on April 22, 2011.
Yahsat-1A is a C-, Ku-, Ka-band satellite.
10
         Intelsat expects shortly to reach an agreement with TurkSat authorizing Intelsat to operate
a satellite at 50.0° E.L. and will file a copy of such agreement with the FCC.
11
       Galaxy 26 Grant for 50.75° E.L., ¶ 4.



                                                 3


compliant with Section 25.202(g) and to operate Galaxy 26 pursuant to any existing or future

coordination agreements for this location.12

       In addition, at the 50.0° E.L. location, Intelsat agrees to comply with the conditions

previously imposed on operation of Galaxy 26 at 50.75° E.L in the 11700-12200 MHz frequency

bands.13

IV.    CONCLUSION

       For the reasons set forth above, Intelsat respectfully requests that the Commission grant

this modification application.


                                                     Respectfully submitted,

                                                     Intelsat License LLC

                                                     By: /s/ Susan H. Crandall

                                                     Susan H. Crandall
                                                     Assistant General Counsel
                                                     Intelsat Corporation

Jennifer D. Hindin
Colleen King
WILEY REIN LLP
1776 K Street, N.W.
Washington, D.C. 20006
(202) 719-7000

April 20, 2011




12
       Id.
13
       Id., ¶ 3.


                                                4


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

The Commission previously approved foreign ownership in Intelsat License LLC (“Intelsat”)
(f/k/a Intelsat North America LLC), in the Intelsat-Serafina Order.14 In December 2009, the
Commission also approved the pro forma changes in Intelsat’s foreign ownership.15 There have
been no other material changes to Intelsat’s foreign ownership since the date of the Intelsat-
Serafina Order.




14
       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 22,151 (2007).
15
       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).


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

Intelsat License LLC (“Intelsat”) (f/k/a Intelsat North America LLC), has never had an FCC
license “revoked.” However, on June 26, 2000, the International Bureau “cancelled” two Ka-
band satellite authorizations issued to Intelsat’s former affiliate, PanAmSat Licensee Corp.
(“PanAmSat”),16 based on the Bureau’s finding that PanAmSat had not satisfied applicable
construction milestones.17 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.




16
       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).
17
         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:

Michael McDonnell, Chairman
Flavien Bachabi, Deputy Chairman
Phillip Spector, Secretary
Simon Van De Weg, Director, Finance

Board of Managers:

Michael McDonnell
Flavien Bachabi
Phillip Spector

The 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 wholly owned subsidiary of Intelsat License Holdings LLC, a
Delaware limited liability company. Intelsat License Holdings LLC is wholly owned by Intelsat
Subsidiary Holding Company S.A., a Luxembourg company. Intelsat Subsidiary Holding
Company S.A. is wholly owned by Intelsat Phoenix Holdings S.A., a Luxembourg company.
Intelsat Phoenix Holdings S.A. is wholly owned by Intelsat Intermediate Holding Company S.A.,
a Luxembourg company. Intelsat Intermediate Holding Company S.A. 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 S.A., a Luxembourg company. Intelsat S.A. is wholly owned
by Intelsat Holdings S.A., a Luxembourg company. Intelsat Holdings S.A. is wholly owned by
Intelsat Global Subsidiary S.A., a Luxembourg company. Intelsat Global Subsidiary S.A. is
wholly owned by Intelsat Global S.A., a Luxembourg company (“Intelsat Global”, formerly
“Serafina Holdings Limited”). Each of these entities may be contacted at the following address:
4 rue Albert Borschette, L-1246 Luxembourg.

Intelsat Global’s ownership was approved by the Commission in the Intelsat-Serafina Order, has
not changed materially 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
22,151 (2007) (“Intelsat-Serafina Order”).



Document Created: 2011-04-20 17:11:29
Document Modified: 2011-04-20 17:11:29

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