Attachment Narrative & Exhibits SAT-MOD-20130513-00068

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20130513-00068 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2013051300068_996945

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 701 (S2400)

APPLICATION OF INTELSAT LICENSE LLC
TO MODIFY AUTHORIZATION FOR INTELSAT 701

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 701 (Call Sign S2400) satellite. Specifically, this

modification application seeks permanent authority to operate Intelsat 701 at 29.5º W.L. (330.5°

E.L.) in inclined orbit mode in order to ensure service continuity at 29.5° W.L., as explained

more fully below.

In accordance with the requirements of the Commission’s rules,1 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.2

1
47 C.F.R. § 25.117(c).
2
47 C.F.R. § 25.114.

I. PROPOSED MODIFICATION

Intelsat 701 currently is drifting from 157.0° E.L. to 29.5º W.L. pursuant to Special

Temporary Authority.3 By this modification, Intelsat requests permanent authority to relocate

the Intelsat 701 satellite to 29.5° W.L., where it will operate in inclined orbit mode.

During the drift of Intelsat 701 from 157.0° E.L. to 29.5º W.L., Intelsat will utilize only

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

Uplink:

6173.7 MHz (LHCP)
6176.3 MHz (LHCP)

Downlink:

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

Once located at 29.5° W.L., Intelsat also will operate the satellite’s communications

frequencies. Set forth below is a comparison of the frequencies on Intelsat 701, as well as the

frequencies currently being operated on Intelsat 801 at 29.5° W.L.:

3
See Policy Branch Information; Actions Taken, Report No. SAT-00941, File Nos. SAT-
STA-20121211-00216 and SAT-STA-20130312-00029 (filed Mar. 12, 2013); Policy Branch
Information; Actions Taken, Report No. SAT-00932, File No. SAT-STA-20130204-00015 (Feb.
22, 2013) (Public Notice).

2

Frequency Band (MHz) Intelsat 701 Intelsat 801
5850 – 5925 √
5925 – 6425 √ √
3625 – 3700 √
3700 – 4200 √ √
14000 – 14500 √ √
10950 – 11200 √ √
11450 – 11700 √ √
11700 – 11950 √ √
12500 – 12750 √ √

Intelsat 701 operates on all of the same frequencies as the Intelsat 801 satellite except for the

5850-5925 and 3625-3700 MHz bands.

II. PUBLIC INTEREST SHOWING

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

redeploy Intelsat 701 in order to ensure continuity of service at 29.5° W.L., where Intelsat 801

(call sign S2391) currently operates. Intelsat 801 is expected to be de-orbited in late 2013.

Given the failure of the Proton rocket in August 2012, the launch of Intelsat 23 (call sign S2831),

which replaced Intelsat 707 (call sign S2398) at 53.0° W.L., was delayed. As a result, Intelsat

707 did not have sufficient fuel to be redeployed to 29.5° W.L. as originally planned.4

Accordingly, Intelsat decided to redeploy Intelsat 701, which previously operated at 157.0° E.L.,

to 29.5° W.L. in order to ensure service continuity at the latter location. Intelsat 706 is currently

being operated at 157° E.L. in order to ensure continuity of service at that location.5

4
See Letter from Susan H. Crandall to Marlene H. Dortch, File No. SAT-STA-20121126-
00202 (filed Jan. 22, 2013) (notifying the FCC of the successful de-orbit of Intelsat 707).
5
See Intelsat License LLC Request for Extension of Special Temporary Authority, File No.
SAT-STA-20130408-00057 (filed Apr. 8, 2013); Policy Branch Information; Actions Taken,
Report No. SAT-00931, File No. SAT-STA-20130206-00017 (Feb. 15, 2013) (Public Notice);
Policy Branch Information; Actions Taken, Report No. SAT-00928, File No. SAT-STA-
20130107-00004 (Feb. 1, 2013) (Public Notice); Policy Branch Information; Actions Taken,
Report No. SAT-00921, File No. SAT-STA-20121210-00214 (Dec. 21, 2012) (Public Notice);
Actions Taken, Report No. SAT-00914, File No. SAT-STA-20121107-00193 (Nov. 30, 2012)
(Public Notice); Policy Branch Information; Actions Taken, Report No. SAT-00909, File No.

3

Moreover, grant of this modification application will not result in increased risk of

harmful interference. Intelsat will operate Intelsat 701 at 29.5° W.L. in accordance with

Intelsat’s existing coordination agreements regarding the location and the FCC’s rules governing

operations at the location vis-à-vis adjacent locations.

III. WAIVERS

As described in the attached Engineering Statement, Intelsat requests that the Part 25

waivers originally granted to the Intelsat 701 spacecraft continue to apply at the 29.5º W.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.6 In addition, Intelsat requests that the waiver of the

provisions of Section 25.202(a)(1) of the FCC’s rules and footnote NG 104 of the U.S. Table of

Frequency Allocation, to permit Intelsat to provide domestic U.S. service in the 10950 – 11200

MHz and 11450 – 11700 MHz frequency bands on a non-interference, non-protected basis,

previously grant to the Intelsat 701 spacecraft continues to apply at the 29.5° W.L. orbital

location.7

SAT-STA-20121008-00179 (Nov. 2, 2012) (Public Notice); Policy Branch Information; Actions
Taken, Report No. SAT-00902, File No. SAT-STA-20120910-00146 (Public Notice) (Sep. 28,
2012); Policy Branch Information; Actions Taken, Report No. SAT-00890, File No. SAT-STA-
20120809-00126 (Public Notice) (Aug. 17, 2012) (Public Notice); Policy Branch Information;
Actions Taken, Report No. SAT-00890, File No. SAT-STA-20120809-00126 (Aug. 17, 2012)
(Public Notice). Intelsat has a pending permanent license modification application seeking
operational authority for Intelsat 706 at 157.0° E.L. See Intelsat License LLC Application to
Modify License, File No. SAT-MOD-20121026-00188 (filed October 26, 2012).
6
See Applications of Intelsat LLC for Authority to Operate and Further Construct,
Launch, and Operate C-band and Ku-band Satellites, Memorandum Opinion, Order and
Authorization, 15 FCC Rcd 15460, 15,537 (Appendix C) (2000), recon. denied, 15 FCC Rcd
25234 (2000).
7
See Policy Branch Information; Actions Taken, Report No. SAT-00324, File No. SAT-
MOD-20050610-00122 (Public Notice) (Oct. 7, 2005) (Public Notice).

4

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 801, Intelsat 701 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. 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 701 at 29.5º W.L. Finally, Intelsat is not aware of any system with an

overlapping station-keeping volume with Intelsat 701 at 29.5º W.L. that is the subject of an ITU

filing and that is either in orbit or progressing toward launch.

V. INTELSAT ACCEPTS SECTION 316 PETITION CONDITIONS

Intelsat understands and accepts that its license to operate Intelsat 701 at 29.5º W.L. 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.8

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

8
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).

5

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

bands, Intelsat accepts the following condition:

 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.

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

May 13, 2013

6

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).

7

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).

8

Document Created: 2013-05-13 16:13:06
Document Modified: 2013-05-13 16:13:06

© 2024 FCC.report
This site is not affiliated with or endorsed by the FCC