Attachment Narrative & Exhibits SAT-MOD-20121026-00188

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20121026-00188 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2012102600188_973073

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 706 (S2401)

APPLICATION OF INTELSAT LICENSE LLC
TO MODIFY AUTHORIZATION FOR INTELSAT 706

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 706 (Call Sign S2401) satellite. Specifically, this

modification seeks permanent authority to relocate Intelsat 706 to, and to operate the satellite at,

157.0° E.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 706 began operating in inclined orbit mode in 2011. See Letter from Susan H.
Crandall to Marlene H. Dortch, Call Sign S2401 (filed July 20, 2011).
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 706 to, and operate

the satellite at, 157.0° E.L. On August 16, 2012, Intelsat commenced redeployment of Intelsat

706 to 157.0° E.L. pursuant to a grant of special temporary authority.4 Intelsat expects to have

Intelsat 706 on-station at 157.0° E.L. in mid-February 2013, and to operate Intelsat 706 at 157.0°

E.L. until the satellite is de-orbited in the second half of 2014.

Intelsat commenced the drift of Intelsat 706 to 157.0° E.L. as part of a redeployment plan

necessitated by the August 2012 failure of a Proton rocket and the resulting delay in the launch

of Intelsat 23 (Call Sign S2831). Intelsat 23 is a replacement satellite for Intelsat 707 (Call Sign

S2398) at 307.0° E.L.5 Intelsat 23 was scheduled for launch in August 2012, so that Intelsat 707

could replace Intelsat 801 at 330.5° E.L. 6 As a result of the launch delay, however, it was

anticipated that Intelsat 707 may not have had sufficient fuel to be redeployed to replace Intelsat

801 at 330.5° E.L. as planned. Accordingly, to ensure service continuity at 330.5° E.L., Intelsat

developed a plan to redeploy Intelsat 701 (Call Sign S2400) from 157.0° E.L. to 330.5° E.L.
4
See Letter from Susan H. Crandall to Marlene H. Dortch, File No. SAT-STA-20120810-
00127 (filed Aug. 17, 2012); see also Request for Special Temporary Authority to Drift Intelsat
706, Call Sign S2401, File No. SAT-STA-20120810-00127 (filed Aug. 10, 2012; granted Aug.
16, 2012) (“Intelsat 706 Drift STA”). Intelsat 706 was previously authorized under Special
Temporary Authority to operate at 72.0° E.L See Policy Branch Information; Actions Taken,
Report No. SAT-00846, File No. SAT-STA-20111230-00253 (Feb. 17, 2012) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00842, File No. SAT-STA-
20120109-00002 (Feb. 3, 2012) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00829, File No. SAT-STA-20111209-00237 (Dec. 16, 2011) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00826, File No. SAT-STA-
20111107-00214 (Dec. 2, 2011) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00816, File No. SAT-STA-20111010-00196 (Oct. 21, 2011) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT00813, File No. SAT-STA-
20110912-00177 (Oct. 7, 2011) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00802, File No. SAT-STA-20110810-00159 (Aug. 19, 2011) (Public Notice).
5
Intelsat 23 was launched on October 14, 2012. The satellite is currently undergoing in-
orbit testing at 51.5º W.L. See Policy Branch Information; Actions Taken, Report No. SAT-
00907, File No. SAT-STA-20121015-00181 (Oct. 26, 2012) (Public Notice)
6
See Intelsat 706 Drift STA.

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This request to relocate Intelsat 706 to 157.0° E.L. will free up Intelsat 701 to move to 330.5°

E.L.

During the drift of Intelsat 706 from 72.0° E.L. to 157.0° E.L., Intelsat will utilize only

the satellite’s TT&C frequencies. The specific TT&C frequencies are as follows:

Uplink:

6173.7 (LHCP)
6176.3 (LHCP)

Downlink:

3947.5 (RHCP)
3948.0 (RHCP)
3952.5 (RHCP)
3952.0 (RHCP)

Once located at 157.0° E.L., Intelsat also will operate the satellite’s communications

frequencies. Set forth below is a comparison of the frequencies on Intelsat 706, as well as the

frequencies currently being operated on Intelsat 701 at 157.0° E.L.:

Frequencies (in MHz) Intelsat 706 Intelsat 701
5925 – 6425 √ √
3700 – 4200 √ √

14000 – 14500 √ √
10950 – 11200 √ √
11450 – 11700 √ √
11700 – 11950 √
12500 – 12750 √ √

Intelsat 706 operates on all of the same frequencies as the Intelsat 701 satellite except for

the 11700 – 11950 MHz band.

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II. PUBLIC INTEREST SHOWING

Grant of this modification application will serve the public interest by enabling Intelsat to

provide continuity of service at 157.0° E.L. as well as at 330.5° E.L. At 157.0° E.L., Intelsat 706

will replace Intelsat 701, which then will replace Intelsat 801 at 330.5° E.L.7

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

eliminate such interference. Once Intelsat 706 is on-station at 157.0° E.L., Intelsat will operate

the communications payload and TT&C frequencies in conformance with its coordination

agreements and the FCC’s rules governing operations vis-à-vis adjacent locations.

III. WAIVERS

As described in the attached Engineering Statement, Intelsat requests that, to the extent

necessary, the Part 25 waivers originally granted to the Intelsat 706 spacecraft continue to apply

at the 157.0º E.L. location, namely, the waivers of Sections 25.202(g), 25.210(a)(1),

25.210(a)(3), 25.210(i) and 25.211(a) of the Commission’s rules.8

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. Except briefly

while collocated with Intelsat 701, Intelsat 706 will not be located at the same orbital location as

7
See Policy Branch Information; Actions Taken, Report No. SAT-00890, File No. SAT-
STA-20120809-00126 (Aug. 17, 2012) (Public Notice).
8
See Applications of Intelsat LLC for Authority to Operate and Further Construct,
Launch, and Operate C-Band and Ku-Band Satellites that Form a Global Communications
System in Geostationary Orbit, 15 FCC Rcd 15460, 15529 (Appendix C) (2000) (Memorandum
Opinion and Order and Authorization), recon. denied, 15 FCC Rcd 25234 (2000) (Order on
Reconsideration).

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another satellite or at an orbital location that has an overlapping station-keeping volume with

another satellite. Further, Intelsat is not aware of any other FCC-licensed system, or any other

system applied for and under consideration by the FCC, having an overlapping station-keeping

volume with Intelsat 706 at 157.0º E.L. Finally, Intelsat is not aware of any system with an

overlapping station-keeping volume with Intelsat 706 at 157.0º E.L. that is the subject of an ITU

filing and that is either in orbit or progressing toward launch. Intelsat previously was granted de-

orbit authority, which will be adhered to at the 157.0º E.L. location.9

V. INTELSAT ACCEPTS SECTION 316 PETITION CONDITIONS

Intelsat understands and accepts that its license to operate Intelsat 706 at 157.0º E.L.,

with the exception of the 12.5-12.75 GHz band frequencies, will be conditioned as follows:

(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 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 Assembly of Parties,
as amended.10

VI. 10950-11200 MHZ, 11450-11700 MHZ AND 12500-12750 MHZ
FREQUENCY BANDS

Intelsat understands that operations in the 10950-11200 MHz, 11450-11700 MHz and 12500-

12750 MHz frequency bands are subject to certain limitations and obligations, which Intelsat accepts and

will fulfill. Specifically, for operations in the 10950-11200 MHz and 11450-11700 MHz frequency

bands, Intelsat accepts the following conditions:

9
See Policy Branch Information; Actions Taken, Report No. SAT-00768, File No. SAT-
MOD-20100511-00098 (Mar. 25, 2011) (Public Notice).
10
See Petition of the Int’l. Telecomms. Satellite Org. under Section 316 of the Commc’ns
Act, as amended, IB 06-137, File No. SAT-MSC-20060710-00076, Order of Modification, 23
FCC Rcd 2764, 2769-71 (¶¶11-13) (Int’l Bur. 2008).

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 Intelsat’s use of the 10950-11200 MHz (space-to-Earth) and 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.

 Intelsat’s operation of the Intelsat 706 space station in the 10950-11200 MHz and 11450-
11700 MHz band is limited to international operations in accordance with footnote NG
104 to the United States Table of Frequency Allocations, 47 C.F.R. § 2.106, NG 104, and
footnote 2 of Section 25.202(a)(1) of the Commission’s rules, 47 C.F.R. § 25.202(a)(1).

For operations in the 12500-12750 MHz frequency band, Intelsat accepts the following

condition:

 Use of the 12500-12750 MHz frequency band is not permitted for fixed-satellite service
in the space-to-Earth direction in Region 2.

VII. 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

October 26, 2012

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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).

Document Created: 2012-10-26 14:02:51
Document Modified: 2012-10-26 14:02:51

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