Attachment Intelsat - Grant Aug

Intelsat - Grant Aug

DECISION submitted by IB,FCC

Grant

2013-08-09

This document pretains to SAT-MOD-20120619-00100 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012061900100_1006773

                                                                                                                            *«see also
                                                                            File #_SBT— MOD—20120619— Goi60                         Sot—AmD—20120815—0013]
                                                                            Call Sign S2460_ Grant Date_O§/3/j3
                                                                            (or other identifier)
                                                                                                     Term Dates See | _         Approved by OMB
                                                                                /03/i3
                                                                            From_O8                         q: conditions                3060—0678
                                                         CGRANTED®

Date & Time Filed: Jun 19 2012 2:00:00:956PM         International Bureau   Approved:
                                                                                 fl%— QM
File Number: SAT—MOD—20120619—00100                ¥Eutorh condlffione                . Duail
                                                                                                    Ch\ef Me Aicy Branch
   FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD — MAIN FORM                                       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 Modify Authorization for Intelsat 8 (Call Sign $2460)
1—8. Legal Name ofApplicant

           Name:        Intelsat License LLC               Phone Number:                              202—944—7848

           DBA                                             Fax Number:                                202—944—7870
           Name:

           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 No. SAT—MOD—20120619—00100 & SAT—AMD—20120815—00131
                                                Call Sign $2460

The application of Intelsat License LLC (Intelsat) to modify the authorization for its Intelsat 8
space station (Call Sign $2460),‘ IBFS File No. SAT—MOD—20120619—00100, as amended by
IBFS File No. SAT—AMD—20120815—00131, is GRANTED." Specifically, Intelsat is authorized
to operate Intelsat 8 at the 169.0° E.L. orbital location to provide Fixed—Satellite Service (FSS) in
the 3700—4200 MHz (space—to—Earth), 5925—6425 MHz (Earth—to—space), and 14.0—14.5 GHz
(Earth—to—space) frequency bands. In addition, Intelsat is authorized to provide FSS in the 12.25—
12.75 GHz (space—to—Earth) frequency band, including in ITU Region 2 and portions of the
United States that are within the antenna beam patterns provided by Intelsat in its application for
Intelsat 8 space station at the 169.0° E.L., subject to the conditions below." Intelsat is also
authorized to conduct telemetry, tracking, and command functions necessary to maintain Intelsat
8 at the 169.0° E.L. orbital location using the following center frequencies: 12.747 GHz (space—
to—Earth), 12.748 GHz (space— to—Earth), and 13.998 GHz (Earth—to—space). Operations must be
in accordance with the terms and technical specifications contained in Intelsat‘s application and
the Federal Communications Commission‘s rules not waived herein, and are subject to the
following conditions:


        1. Intelsat shall maintain Intelsat 8 within an east/west longitudinal station—keeping
tolerance of + 0.05 degrees of the 169.0° E.L. orbital location.

       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 is granted a waiver of the Table of Frequency Allocations, Section 2.106
of the Commission‘s rules, 47 C.F.R. § 2.106, and Section 25.202(a)(1) of the Commission‘s
rules, 47 C.F.R. § 25.202(a)(1), to provide FSS in the 12.25—12.70 GHz band in ITU Region 2,
including portions of the United States that are within the antenna beam patterns provided by
Intelsat in its application for Intelsat 8 space station at the 169.0° E.L. in this band."* In the
United States, the 12.25—12.70 GHz band is allocated to Broadcasting Satellite Service (BSS) and


‘ At the time of its launch, Intelsat 8 was named PAS—8 for commercial purposes, but PAS—5 for FCC filings. In
2007, Intelsat filed a letter notifying the Commission that it had renamed PAS—8/PAS—5 (Call Sign 2460) as Intelsat
8. See Letter from Susan Crandall, Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary,
FCC, filed Jan. 8, 2007, available in IBFS File No. SAT—MOD—20060228—00017.
* The application was placed on public notice as accepted for filing on July 20, 2012. See Policy Branch
Information, Satellite Space Applications Acceptedfor Filing, Public Notice, Report No. SAT—00883, IBFS File No.
SAT—MOD—20120619—00100. Comments were filed by DIRECTV Enterprises, LLC (DIRECTV) on August 20,
2012 (DIRECTV Comments). DIRECTV is authorized by the Commission to provide Direct Broadcast Satellite
(DBS) service in the 12.2—12.7 GHz (space—to—Earth) frequency band in the United States on a primary basis. DBS
is the name for Broadcasting Satellite Service in the United States. Intelsat responded to DIRECTV‘s comments on
September 5, 2012 (Intelsat Response).
> The 12.25—12.75 GHz (space—to—Earth) and 14.0—14.5 GHz (Earth—to—space) frequency bands at the 169.0° E.L.
orbital location were previously made available by the Commission for reassignment. See Policy Branch
Information; Actions Taken, Report No. SAT—00875, Public Notice, 27 FCC Red 6383 (Jun. 15, 2012).

* See Letter from Susan Crandall, Assistant General Counsel, Intelsat Corp., to Marlene H. Dortch, Secretary, FCC,
filed Dec. 14, 2012.


                                   Intelsat License LLC
            IBFS File No. SAT—MOD—20120619—00100 & SAT—AMD—20120815—00131
                                      Call Sign $2460

the Fixed Service (FS). In ITU Region 2, the 12.25—12.70 GHz band is allocated on a primary
basis to BSS, FS, Mobile (except aeronautical mobile), and broadcasting service. In addition, in
both the United States and ITU Region 2, the 12.25—12.70 GHz band is allocated to non—
geostationary satellite (NGSO) orbit FSS pursuant to footnote 5.487A. There is no allocation for
the type of GSO FSS that Intelsat seeks to provide in this band either in the United States or ITU
Region 2. Nevertheless, a U.S.—authorized space station with a similar beam pattern operated in
the 12.25—12.7 GHz band at the 169.0° E.L. orbital location for an extended time with no
reported instances of interference." Further, under the ITU Region 2 BSS Plan, there is at least
 15 degrees of orbital separation between Intelsat 8 at 169.0° E.L. and the nearest possible BSS
network that could provide service to any portion of the ITU Region 2. Moreover, based upon
the technical information in Intelsat application, we conclude that Intelsat 8‘s operations will
comply with the PFD limits specified in Art. 21.16 of the ITU Radio Regulations.6 Accordingly,
we find that waiver of Section 2.106 and Section 25.202(a)(1) of the Commission‘s rules is
justified in this instance because Intelsat 8‘s operations, as authorized, are unlikely to interfere
with existing or future users operating in accordance with the Table of Allocations in ITU
Region 2 and the Commission‘s rules.‘ As a non—conforming user of the 12.25—12.7 GHz band
in ITU Region 2, Intelsat must not cause harmful interference to existing and future authorized
users who are operating in accordance with the Table of Allocations in ITU Region 2, and must
accept interference from such authorized users. In the event Intelsat 8‘s operations in the 12.25—
12.7 GHz band cause harmful interference to any authorized service operating in accordance
with the Table of Frequency Allocations in Region 2, Intelsat must immediately cease operations
in that band and inform the Commission in writing within 1 business day of the interference
incident.
        4.     Intelsat is granted a waiver of the Table of Frequency Allocations, Section 2.106
of the Commission‘s rules, 47 C.F.R. § 2.106, and Section 25.202(a)(1) of the Commission‘s
rules, 47 C.F.R. § 25.202(a)(1), to use the 12.70—12.75 GHz band to provide FSS (space—to—
Earth) in ITU Region 2, including portions of the United States that are within the antenna beam


° See Panamsat Licensee Corp. Application for Final Authority to Construct Hybrid Separate System International
Communications Satellites, File Nos. CSS 88—003M, CSS—91—003, CSS—91—006, Memorandum Opinion and Order, 9
FCC Red 1867 (1994); see also Policy Branch Information: Action Taken, Report No. SAT—00574, Public Notice,
IBFS File No. SAT—MOD—20080811—00153 (authorizing 12.25—12.7 GHz band operations of Intelsat 2 at 169.1°
EL., instead of 169.0° E.L.). Intelsat relocated Intelsat 2 from 169.1° EL.to 157.0° E.L. in June 2010, see IBFS
File No. SAT—STA—20100330—000059, and from 157.0° E.L. to 174.0° E.L. in September 2010, see IBFS File No.
SAT—STA—20100810—00176. Intelsat 2 was removed to a disposal orbit on February 28, 2011. See IBFS File No.
SAT—STA—20110112—00011.
© ITU Radio Regulations, Art. 21.16 (2008).
‘ DIRECTV did not object to the particular proposal to operate Intelsat 8 in the 12.25—12.75 GHz (space—to—Earth)
frequency band, but asks that the Commission make clear that it is appropriate to waive the Table of Frequency
Allocations to permit FSS operations in this band solely because of the unique cirecumstances presented by the
operations of Intelsat 8 at 169.0° E.L., and that grant of a waiver in this instance is not an invitation for future waiver
requests that could impinge upon BSS operations in ITU Region 2. See DIRECTV Comments at 2. Intelsat agrees
with DIRECTV that the particular facts of the proposed operations of Intelsat 8 support Intelsat‘s request to waive
Sections 2.106 and 25.121(a) in this instance. Intelsat Response at 2. The grounds for the waiver granted for FSS
operations in the 12.2—12.7 GHz band — and the conditions placed on such operations — are consistent with
DIRECTV‘s request.


                                     Intelsat License LLC
              IBFS File No. SAT—MOD—20120619—00100 & SAT—AMD—20120815—00131
                                        Call Sign $2460

patterns provided by Intelsat in its application for Intelsat 8 operations at 169.0° E.L. in this
band. The 12.70—12.75 GHz band is allocated to FS, FSS (Earth—to—space), and Mobile in ITU
Region 2, including the United States. Nevertheless, a U.S.—authorized space station with a
similar beam pattern had operated in the 12.70—12.75 GHz band at the 169.0° E.L. orbital
location for an extended time with no reported instances of interference.® Accordingly, we find
that waiver of Sections 2.106 and 25.202(a)(1) is justified in this instance because Intelsat 8‘s
operations, as authorized, are unlikely to interfere with existing or future users operating in
accordance with the Table of Allocations in ITU Region 2 and the Commission‘s rules. As a
non—conforming user of the 12.7—12.75 GHz band in ITU Region 2, Intelsat must not cause
harmful interference to existing and future authorized users who are operating in accordance
with the Table of Allocations in ITU Region 2, and must accept interference from such
authorized users. In the event Intelsat 8‘s operations in the 12.70—12.75 GHz band cause harmful
interference to any authorized service operating in accordance with the Table of Frequency
Allocations, Intelsat must immediately cease operations in that band and inform the Commission
in writing within 1 business day of the interference incident.
        5.     The EIRP density in the 5925—6425 MHz and 14.0—14.5 GHz frequency bands
will not exceed —38.7 dBW/Hz and —45 dBW/Hz, respectively; within the 3700—4200 MHz band
the downlink EIRP density of the Intelsat 8 digital carriers will not exceed —32 dBW/Hz; and
within the 12.25—12.75 GHz bands the downlink EIRP density of the Intelsat 8 digital carriers
will not exceed —18.0 dBW/Hz.
         6.        Intelsat requests waiver of the requirement to meet milestones or post a bond for
operations at 169.0° E.L., pursuant to Sections 25.164(a) and 25.165 of the Commission‘s rules,
47 C.F.R. §§ 25.164(a) and 25.165. Because Intelsat 8 is in—orbit and already operating at 169.0°
E.L. pursuant to grants of special temporary authority," grant of authority to operate Intelsat 8 at
169.0° E.L. is not subject to milestone conditions and Intelsat is not required to post a bond. As
such, waiver of Sections 25.164(a) and 25.165 of the Commission‘s rules is not necessary.
       7. Intelsat states that Intelsat 8 will not use the 10.7—10.95 GHz (space—to—Earth), 11.2—
11.45 GHz (space—to—Earth), 11.45—11.7 GHz (space—to—Earth), and 12.75—13.25 GHz (Earth—to—
space) frequency bands that were used by the Intelsat 5 space at 169.0° E.L.‘ Therefore, these
frequency bands at the 169.0° E.L. orbital location will be made available for re—assignment in a
Public Notice.



8 See supra, note. 5.

° See Policy Branch Information: Action Taken, Report No. SAT—00896, Public Notice, IBFS File No. SAT—STA—
20120815—00132; Policy Branch Information: Action Taken, Report No. SAT—00914, Public Notice, IBFS File No.
SAT—STA—20121105—00191; Policy Branch Information: Action Taken, Report No. SAT—00923, Public Notice,
IBFS File No. SAT—STA—20130102—00003; Policy Branch Information: Action Taken, Report No. SAT—00935,
Public Notice, IBFS File No. SAT—STA—20130228—00027.
* Application of Intelsat License LLC to Modify Authorization for Intelsat 8, IBFS. File No. SAT—MOD—20120619—
0010, as amended by IBFS File No. SAT—AMD—20120815—00131, at 3; see also Policy Branch Information: Action
Taken, Report No. SAT—00561, Public Notice, IBFS File No. SAT—MOD—20080725—00150. Intelsat 5 departed from
the 169.0° E.L. orbital location on Oct. 31, 2012, pursuant to a grant of special temporary authority. IBFS File No.
SAT—STA—20120911—00147 (granted Oct. 25, 2012).


                                  Intelsat License LLC
           IBFS File No. SAT—MOD—20120619—00100 & SAT—AMD—20120815—00131
                                     Call Sign $2460

       8. Nothing in this authorization extends the license term for Intelsat 8, Call Sign $2460,
which expires on December 4, 2013."

        9.      Intelsat is afforded 30 days from the date of release of this grant and authorization
to decline this authorization as conditioned. Failure to respond within this period will constitute
formal acceptance of the authorization as conditioned.
        10.    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 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 date of the
public notice indicating that this action was taken.


                                                       SBT— AMD— 2012 0§ 15— 0013 )
                                                File # S$AT— MoOD—201206193— o0100

                                                Call Sign 82460         GrantDate_68/09/%
                                                (or other identifier)
                                                 j                      Term Dates S€€
                                                From 0€/03/13                o. conditions

                         International Bureau   Approved:
                        ¥with concitions                            Stepngn/3, Duall
                                                                    Chief,   Satellite Po)ic':j Branch




4 See PanAmSat Licensee Corp. Application for Authority to Construct, Launch and Operate a Hybrid International
Communications Satellite, 14 FCC Red 2719 (1998); Policy Branch Information; Actions Taken, Report No. SAT—
00358, Public Notice, IBFS File No. SAT—MOD—20060228—00017 (May 5, 2006).


9—16. Name of Contact Representative

            Name:          Susan H. Crandall                      Phone Number:                       202—944—7848
            Company:       Intelsat Corporation                   Fax Number:                         202—944—7870
            Street:        3400 International Drive, N.W.         E—Mail:                             susan.crandall@intelsat.com


            City:     _    Washington                             State:                               DC
            Country:        USA                                   Zipcode:                            20008—3006
            Attention:                                            Relationship:                        Legal Counsel


CLASSIFICATION OF FILING
17. Choose the button next to the
classification that applies to this filing for    (N/A) 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.                     C3 b3. Amendment to a Pending Application
                                                  @ b4. Modification of License or Registration
   Cp al. Earth Station
                                                 b5. Assignment of License or Registration
   @ a2. Space Station                           b6. Transfer of Control of License or Registration
                                                 e b7. Notification of Minor Modification
                                                  (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                 Satellite
                                                  (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                 States
                                                  (N/A) b10. Other (Please specify)
                                                    (N/A) b11. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized
                                                 to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                    (N/A) b12. Application for Database Entry
                                                  y b13. Amendment to a Pending Database Entry Application
                                                  {J b14. Modification of Database Entry


 17c¢. Is a fee submitted with this application?
@ IfYes, complete and attach FCC Form 159.         If No, indicate reason for fee exemption (see 47 C.ER.Section 1.1114).
«3 Governmental Entity        &3 Noncommercial educational licensee
«74 Other(please explain):

17d.

Fee Classification BFY — Space Station Modification(Geostationary)




18. If this filing is in reference to an     19. If this filing is an amendment to a pending application enter both fields, if this filing is a
existing station, enter:                     modification please enter only the file number:
(a) Call sign of station:                    (a) Date pending application was filed:              (b) File number:
    $2460
                                                                                                  SATMOD2006022800017


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 the button next to the applicable status. Choose      122. If earth station applicant, check all that apply.
only one.                                                                D Using U.S. licensed satellites
C Common Carrier        @ Non—Common Carrier                             D Using Non—U.S. licensed satellites

23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
C3 Connected to a Public Switched Network   ) 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)
[:] 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.
£54 a. Fixed Earth Station
{74 b. Temporary—Fixed Earth Station
34 c 12/14 GHz VSAT Network
3 d. Mobile Earth Station
@ c Geostationary Space Station
4 £. Non—Geostationary Space Station
«4 g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
<34 Transmit/Receive [an] Transmit—Only         3 Receive—Only     @ N/A
"For Space Station applications, select N/A."


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an ‘X" in the box(es) next to all that apply.)


    D a —— authorization to add new emission designator and related service
    D b — authorization to change emission designator and related service
    E] c —— authorization to increase EIRP and EIRP density
    E] d — authorization to replace antenna
    D e — authorization to add antenna
    D f — authorization to relocate fixed station
    E] g —— authorization to change frequency(ies)
     D h —— authorization to add frequency
    D i—— authorization to add Points of Communication (satellites &amp; countries)
    D j — authorization to change Points of Communication (satellites &amp; countries)
         k —authorization for facilities for which environmental assessment and
radiation hazard reporting is required
     E 1 —— authorization to change orbit location
    D m —— authorization to perform fleet management
    E] n — authorization to extend milestones
    [:] o —— Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental         3 Yes @ No
impact as defined by 47 CFR 1.1307? IfYES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission‘s rules, 47 C.ER. 1.1308 and 1.1311, as an exhibit to this application.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
aeronautical fixed radio station services are not required to respond to Items 30—34.


 29. Is the applicant a foreign government or the representative of any foreign government?                            y Yes @ No




 30. Is the applicant an alien or the representative of an alien?                                                      3 Yes @ No 4 N/A




31. Is the applicant a corporation organized under the laws of any foreign government?                                 3 Yes ® No g4 N/A




32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by    o Yss & N 5 N/A
aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          @ Yes ; No 54 N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?




34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commussion‘s Rules?                                  @ Yes      IQ.N:a
IfYes, 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              @ Yos      D,No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? IfYes, attach as an exhibit, an explination of circumstances.
                                                                                                                          EngineeringStatement


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    3 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   «y 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        «y 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,         {3 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,            pursuant to Section 25.117 of the rules of the Federal
     Communications Commission,               hereby seeks to modify the authorization for the Intelsat 8
     (Call Sign §$2460)         satellite.        Specifically,         this modification seeks permanent authority to
     relocate     Intelsat      8   to,   and to operate the satellite at,                    169.10 E.L.

Narrative & Exhibits




10


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 specified in 47 C.F.R. Part 25.
                                                                                                                              «y 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.
                                                                                                                              4 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.




11


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


 «y Individual
 g4 Unincorporated Association
 C Partnership
 C Corporation
 C Governmental Entity
 @ Other (please specify)




     45. Name of Person Signing                                             46. Title of Person Signing
     Susan H. Crandall                                                      Asst. General Counsel, Intelsat Corporation
       ——>


             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).




12


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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 LAW 104—13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.




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Document Created: 2013-08-09 10:37:35
Document Modified: 2013-08-09 10:37:35

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