Attachment Narrative & Exhibits SAT-MOD-20130819-00107

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20130819-00107 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2013081900107_1008352

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 7 (S2229)

APPLICATION OF INTELSAT LICENSE LLC TO
MODIFY AUTHORIZATION FOR INTELSAT 7

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 Intelsat 7 satellite (Call Sign S2229).2 Specifically, Intelsat seeks to extend

the license term for the Intelsat 7 satellite for approximately five and a half years through April

1, 2019, which is the current projected end of service life.

In accordance with the requirements of the Commission’s rules,3 this application has

been filed electronically as an attachment to FCC Form 312. Intelsat incorporates by reference

the technical information previously provided regarding the operations of Intelsat 74 and attaches

an orbital debris mitigation statement for the Intelsat 7 satellite. Consistent with Section 1.62 of

1
47 C.F.R. § 25.117.
2
Intelsat 7 was formerly known as PAS-21/PAS-7. See Letter from Susan H. Crandall, Intelsat,
to Marlene H. Dortch, FCC, Notification of New Space Station Names (Filed Jan. 8, 2007).
3
47 C.F.R. § 25.117(c).
4
See Policy Branch Information; Actions Taken, Report No. SAT-00222, File No. SAT-MOD-
20040405-00078 (Jun. 18, 2004)(Public Notice).

1

the Commission’s rules, Intelsat will continue to operate the Intelsat 7 satellite pursuant to the

terms and conditions of its expiring license until such time as the Commission makes a

determination with respect to this request.5

I. REQUEST FOR EXTENSION OF LICENSE TERM

Intelsat seeks to extend the license term for the Intelsat 7 satellite for approximately five

and a half years through April 1, 2019. The Intelsat 7 satellite was launched on September 16,

1998,6 and placed into service in November 1998.7 The FCC records state that the license term

will expire on September 14, 2013.8 That expiration date is well before the expected end of

service life of the satellite.

Intelsat’s most recent SEC filing lists the estimated end of Intelsat 7’s station-kept life as

the end of September 2013.9 Since that filing, however, Intelsat has placed the Intelsat 7 satellite

5
47 C.F.R. § 1.62.
6
See PanAmSat Licensee Corp., Request for Special Temporary Authority, File No. SAT-LOA-
19960202-00017 (filed Sept. 15. 1998)(requesting special temporary authority to launch and
operate PAS-21, now called Intelsat 7).
7
See Letter from Joseph A. Godles, Attorney for PanAmSat Corporation, to Marlene H. Dortch,
FCC, PanAmSat Corporation Annual Status Report at 7 (Jul. 1, 2012).
8
47 C.F.R. §§ 25.121(a) & (d)(1). Because the satellite commenced service in November 1998,
the license term should expire in November 2013, rather than September 2013. Nonetheless, this
license extension request is timely filed with respect to either date.
9
See Amendment No. 9 to Form F-1 Registration Statement, Intelsat Global Holdings S.A. (Apr.
9, 2013), available at
http://www.sec.gov/Archives/edgar/data/1525773/000119312513147847/d204908df1a.htm.

2

into inclined orbit.10 With the increased fuel savings from inclined orbit operations, the current

projected end of service life for Intelsat 7 is April 1, 2019.

II. PUBLIC INTEREST SHOWING

Grant of this modification application to extend the Intelsat 7 license term will serve the

public interest by enabling customers to continue receiving service from this operational satellite.

The Intelsat 7 satellite has more than five years of useful life remaining. There are no single

points of failure on Intelsat 7 that would result in an inability to de-orbit the satellite.

Additionally, the satellite’s TT&C functions are operating nominally. Extending the license term

will promote the continued efficient use of orbital resources and is consistent with recent

decisions by the Commission to extend satellite license terms.11

In the attached Orbital Debris Mitigation Plan, Intelsat has provided a post-mission

disposal plan for the Intelsat 7 satellite. This plan demonstrates that the Intelsat 7 satellite has

sufficient fuel to be disposed by moving it to a minimum altitude of 276.3 km above the

geostationary arc, which is consistent with the IADC formula and well above the 150 km altitude

10
Intelsat filed notice of commencement of inclined orbit operations for Intelsat 7 at 68.65° E.L.
on May 7, 2013. See Letter from Susan H. Crandall, Intelsat, to Marlene H. Dortch, FCC, Notice
of Commencement of Inclined Orbit Operations for Intelsat 7 (May 7, 2013).
11
See Policy Branch Information; Actions Taken, Report No. SAT-00905, DA 12-1680, File No.
SAT-MOD-20120629-00109 (Oct. 19, 2012) (Public Notice) (extending license terms of an SES
satellite for an additional five years); Policy Branch Information; Actions Taken, Report No.
SAT-00664, DA 10-236, File No. SAT-MOD-20091119-00123 (Feb. 5, 2010)(Public Notice)
(extending license term of Sirius XM satellites for an additional seven years).

3

typically approved for satellites launched prior to March 18, 2002.12 Intelsat has reserved 42.8

kilograms of fuel for this purpose.

III. 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

August 19, 2013

12
The Commission has found that satellites launched prior to March 18, 2002, such as Intelsat 7,
would be designated as grandfathered satellites not subject to a specific disposal altitude. See
Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567, 11600-01 (2004).

4

Orbital Debris Mitigation Plan

Intelsat is proactive in ensuring safe operation and disposal of the Intelsat 7
satellite and all spacecraft under its control. The four elements of debris mitigation
are addressed below.

1) Spacecraft Hardware Design: The spacecraft is designed such that no debris
will be released during normal operations. Intelsat has assessed the probability of
collision with meteoroids and other small debris (<1 cm diameter) and has taken
the following steps to limit the effects of such collisions: (1) critical spacecraft
components are located inside the protective body of the spacecraft and properly
shielded; and (2) all spacecraft subsystems have redundant components to ensure
no single-point failures. The spacecraft does not use any subsystems for end-of-
life disposal that are not used for normal operations.

2) Minimizing Accidental Explosions: Intelsat has assessed the probability of
accidental explosions during and after completion of mission operations. The
spacecraft is designed in a manner to minimize the potential for such explosions.
Propellant tanks and thrusters are isolated using redundant valves and electrical
power systems are shielded in accordance with standard industry practices. At the
completion of the mission, and upon disposal of the spacecraft, Intelsat will ensure
the removal of all stored energy on the spacecraft by depleting all propellant tanks,
venting all pressurized systems, and turning off all active units.

3) Safe Flight Profiles: Intelsat has assessed and limited the probability of the
space station becoming a source of debris as a result of collisions with large debris
or other operational space stations. 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 7. Intelsat is also not
aware of any non-Intelsat system with an overlapping station-keeping volume with
Intelsat 7 that is the subject of an ITU filing and that is either in orbit or
progressing towards launch.

4) Post Mission Disposal: At the end of the mission, Intelsat expects to dispose of
the spacecraft by moving it to a planned minimum altitude of 276.3 kilometers
(perigee) above the geostationary arc, which is the altitude established by the

IADC formula.1 Nevertheless, as the Commission is aware, because there is no
mechanism for precisely calculating the amount of fuel left on the spacecraft once
it is in orbit, it is possible that the spacecraft will not meet the planned minimum
de-orbit altitude.

In its Second Report and Order in IB Docket 02-54 (FCC Document Number: 04-
130), the FCC declared that satellites launched prior to March 18, 2002, such as
Intelsat 7, would be designated as grandfathered satellites not subject to a specific
disposal altitude. Therefore, the Intelsat 7 planned disposal orbit complies with the
FCC’s rules.

In addition, Intelsat provides the following information:

1) Planned orbital eccentricity: 1.1262E-04 (This is a best estimate of optimal
eccentricity to match the natural eccentricity circle due to Sun and Moon
perturbations after decommission.2)
2) Planned apogee altitude: 285.86 km3
3) Information concerning the methods that will be used to assess and provide
adequate margins concerning fuel gauging uncertainty: For the Intelsat 7
spacecraft, in addition to the nominal hold-back and reserves provided to us
by the manufacturer, Intelsat propulsion engineers review the current
propellant usage – particularly the mixing ratio – to properly allocate
sufficient margin to account for unavailable propellant that may result from
a non-optimal mixing ratio. In addition, Intelsat performs thermal gauging
near the spacecraft’s end of life by inferring the remaining propellant from
the thermal signature when Intelsat applies heat to different parts of the
propellant tank system. This information is considered when determining
the additional hold-back and adjustments to book values to attempt to ensure
sufficient propellant to achieve the planned minimum altitude. There are,
1
Intelsat has reserved 42.8 kilograms of fuel for this purpose. The fuel gauging uncertainty has
been taken into account in these calculations.
2
Because it is extremely difficult to anticipate end-of-life thruster performance and operational
conditions, it is extremely difficult to achieve the planned eccentricity. Intelsat’s priority is to
achieve the planned minimum perigee of 276.3 kilometers. In order to achieve the planned
eccentricity, not only must there be sufficient propellant reserved but, in addition, individual
thrusters must be fired at specific times during satellite decommissioning because the timing of
thruster firing will affect eccentricity. Due to difficulties in predicting the thruster end-of-life
performance, as well as earth station availability and visibility as the satellite drifts, it may not be
possible to fire the right thrusters at the optimal times. Thus, optimal eccentricity may not be
achieved, which, in turn, will affect the apogee altitude.
3
See n.2.

however, many uncertainties to both methods that could lead to incorrect
conclusions regarding remaining fuel.

Certification Statement

I hereby certify that I am a technically qualified person and am familiar with Part
25 of the Commission’s Rules and Regulations. The contents of this engineering
statement were prepared by me or under my direct supervision and to the best of
my knowledge are complete and accurate.

/s/ Abdolmajid Khalilzadeh August 15, 2013
Abdolmajid Khalilzadeh
Senior Principal Engineer,
Spectrum Strategy

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: 2013-08-19 13:50:08
Document Modified: 2013-08-19 13:50:08

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