Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20120703-00110 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012070300110_958723

Before the Federal Communications Commission Washington, DC 20554 In the Matter of Intelsat License LLC File No. SAT-MOD- _____________ Application to Modify Authorization for Intelsat 9 (S2380) APPLICATION OF INTELSAT LICENSE LLC TO MODIFY AUTHORIZATION FOR INTELSAT 9 Intelsat License LLC (“Intelsat”), pursuant to Section 25.117 of the rules of the Federal Communications Commission (“Commission” or “FCC”), 47 C.F.R. § 25.117, hereby seeks to modify the authorization for the Intelsat 9 (Call Sign S2380) satellite. Specifically, this modification seeks permanent authority to relocate Intelsat 9 to, and to operate the satellite at, 43.10° W.L. in inclined orbit mode.1 In accordance with the requirements of the Commission’s rules,2 this application has been filed electronically as an attachment to FCC Form 312. Intelsat provides the technical information relating to the proposed modification on Schedule S and in narrative form, as contained in the attached Engineering Statement, pursuant to Section 25.114 of the Commission’s rules.3 1 Intelsat expects to begin inclined orbit operations after traffic has been transferred and before the satellite begins drifting. The satellite’s expected end of life, assuming the drift and inclined orbit operations, is September 2023. 2 47 C.F.R. § 25.117(c). 3 47 C.F.R. § 25.114.

I. PROPOSED MODIFICATION By this modification, Intelsat requests authority to relocate Intelsat 9 to, and operate the satellite at, 43.10° W.L. following traffic transfer to the Intelsat 21 satellite that is expected to be launched on August 15, 2012.4 Intelsat 9 is currently authorized to operate at 58.0° W.L.5 Intelsat expects to begin drifting Intelsat 9 on November 1, 2012 and have the satellite on station at 43.10º W.L. by the end of December 2012.6 During the drift of Intelsat 9 from 58.0° W.L. to 43.10° W.L., Intelsat will utilize only the satellite’s TT&C frequencies. The specific TT&C frequencies are as follows: Uplink: 14494.5 MHz (V) 14000.5 MHz (RHCP) Downlink: 11700.5 MHz (V) 11702.5 MHz (V) 11700.5 MHz (RHCP) 11702.5 MHz (RHCP) 11700.5 MHz (H) 11702.5 MHz (H) Once located at 43.10° W.L., Intelsat also will operate the satellite’s communications frequencies. Set forth below is a comparison of the frequencies on Intelsat 9, as well as the frequencies currently being operated on Intelsat 11 at 43.0º W.L.: 4 See Policy Branch Information; Satellite Space Applications Accepted for Filing, Report No. SAT-00862, File No. SAT-RPL-20120326-00061 (Apr. 27, 2012) (Public Notice). 5 See PanAmSat Licensee Corp. Application for Authority to Construct, Launch and Operate an Expansion Band Satellite in its Separate International Communications Satellite System, Order and Final Authorization, 13 FCC Rcd 4743 (1997) and PanAmSat Licensee Corp. Application for Authority to Use Extended Ku-Band Frequencies for Domestic Service, Order and Authorization, 20 FCC Rcd 14642 (2005). 6 Intelsat has a pending STA request for this redeployment. See Intelsat License LLC Request for Special Temporary Authority, File No. SAT-STA-20120621-00103 (filed June 21, 2012). -2-

Intelsat 9 Intelsat 11 5925 – 6425 √ √ 3700 - 4200 √ √ 12750 – 13250 √ 13750 – 14000 √ 14000 – 14500 √ 10700 – 10950 √ 10950 – 11200 √ 11200 – 11450 √ 11450 – 11700 √ 11700 - 12200 √ Intelsat has a pending waiver request to allow the 11700-12200 MHz and 14000-14500 MHz bands to remain vacant for a reasonable period of more than 90 days following the departure of Intelsat 3R from 43.10° W.L.7 In that pending request, Intelsat noted that it had a concrete plan to bring Intelsat 9 to the nominal 43.0º E.L. location in the fall of 2012 following the launch of Intelsat 21, as is contemplated by this license modification application.8 II. PUBLIC INTEREST SHOWING Grant of this modification application will serve the public interest by enabling Intelsat to expand customer services at 43.10° W.L. At 43.10° W.L., Intelsat 9 will be collocated with Intelsat 11 (Call Sign S2237), which currently operates at the 43.0° W.L. location.9 Grant of this modification application will not result in an increased risk of harmful interference. As noted above, Intelsat will operate only the above listed TT&C frequencies during the drift, and will coordinate its TT&C transmissions with operators of satellites in the drift path. Should any interference occur during the drift, Intelsat will take all reasonable steps to 7 See Policy Branch Information; Satellite Space Applications Accepted for Filing, Report No. SAT-00737, File No. SAT-MSC-20101102-00232 (Nov. 12, 2010) (Public Notice). 8 See id. at 2-3. 9 See Policy Branch Information; Actions Taken, Report No. SAT-00617, File No. SAT- MOD-20090108-00004 (July 10, 2009) (Public Notice). -3-

eliminate such interference. Once Intelsat 9 is on-station at 43.10° W.L., Intelsat will operate the communications payload and TT&C frequencies in conformance with its coordination agreements regarding the nominal 43.0° W.L. orbital location and the FCC’s rules governing operations vis-à-vis adjacent locations. III. WAIVER Intelsat also requests that the waiver previously granted Intelsat 9 of footnote NG 104 of Section 2.106 and footnote 2 of Section 25.202(a)(1) with respect to the domestic use of the 11450-11700 MHz band continue to apply at 43.10° W.L.10 IV. ORBITAL DEBRIS STATEMENT Intelsat has assessed and limited the probability of the space station becoming a source of debris as a result of collision with large debris or other operational space stations. Intelsat 9 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.11 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 Intelsat 9 at 43.10° W.L. Finally, Intelsat is not aware of any system with an overlapping station-keeping volume with Intelsat 9 at 43.10º W.L. that is the subject of an ITU filing and that is either in orbit or progressing toward launch. V. 11450-11700 MHZ FREQUENCY BAND Intelsat understands that operations in the 11450-11700 MHz frequency band are subject to certain limitations and obligations, which Intelsat accepts and will fulfill. Specifically, for operations in the 11450-11700 MHz frequency band, Intelsat accepts the following condition: 10 PanAmSat Licensee Corp. Application for Authority to Use Extended Ku-Band Frequencies for Domestic Service, Order and Authorization, 20 FCC Rcd 14642 (2005). 11 Intelsat 9 and Intelsat 11 will be operated in adjacent station-keeping boxes. -4-

 Intelsat’s use of the 11450-11700 MHz band (space-to-Earth) is subject to footnote US211 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, US211, which urges applicants for airborne or space station assignments to take all practicable steps to protect radio astronomy observations in the adjacent bands from harmful interference, consistent with footnote US74. VI. 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 July 3, 2012 -5-

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 22,151 (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: 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 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 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 Investment Holdings S.à r.l., a Luxembourg company. Intelsat Investment Holdings S.à r.l. is wholly owned by Intelsat Global Holdings S.A., a Luxembourg company. Each of these entities may be contacted at the following address: 4 rue Albert Borschette, L-1246 Luxembourg. Intelsat Global Holding 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 22,151 (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 transaction has not yet been consummated.


Document Created: 2012-07-03 14:43:10
Document Modified: 2012-07-03 14:43:10
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