Attachment Narrative & Exhibits SAT-MOD-20151021-00073

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20151021-00073 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2015102100073_1111570

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 8 (S2460)

APPLICATION OF INTELSAT LICENSE LLC
TO MODIFY AUTHORIZATION FOR INTELSAT 8

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 8 (Call Sign S2460) satellite. Specifically, this modification seeks

authority to relocate Intelsat 8 to, and to operate the satellite at, 168.9° E.L. At this location,

which is 0.1° from its current licensed location of 169.0° E.L., Intelsat 8 will continue to provide

services in the C- and Ku-bands. Intelsat specifically requests authority to continue operating the

communications payload on the satellite while drifting Intelsat 8 to 168.9° E.L. In addition,

Intelsat seeks to extend the license term for Intelsat 8, and extend all previously granted waivers,

for approximately three years through September 30, 2018, which is the current projected end of

service life.

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

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

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information relating to the proposed modification on Schedule S and in narrative form in the

attached Engineering Statement.3

I. PROPOSED MODIFICATIONS

A. Relocation to 168.9° E.L.

Intelsat requests authority to relocate Intelsat 8 to, and operate the satellite at, 168.9° E.L.

Intelsat 8 currently is authorized to operate at 169.0° E.L.,4 and is expected to begin inclined

orbit operations on or about March 1, 2016. Intelsat 805 (Call Sign S2404) is expected to arrive

at 169.0° E.L. on or about March 1, 2016.5 Following the transfer of some of the Intelsat 8

traffic to Intelsat 805, Intelsat 8 will be relocated to the 168.9° E.L. orbital location. Intelsat

expects to begin drifting Intelsat 8 on or about April 1, 2016 and have the satellite on station at

168.9º E.L. a few days later. Intelsat 8 and Intelsat 805 are expected to remain collocated at the

nominal 169.0º E.L. orbital location.

For the Commission’s convenience, the following chart reflects the frequencies that will

be used by Intelsat 8 at 168.9° E.L. and by Intelsat 805 at 169.0° E.L. upon receipt of

Commission approvals and completion of drifts.

Frequency Bands Intelsat 8 Intelsat 805
3400-3700 MHz X
3700-4200 MHz X X
5850-5925 MHz X
5925-6425 MHz X X
6425-6650 MHz X
12250-12500 MHz X
12500-12750 MHz X X

3
47 C.F.R. § 25.114.
4
See Policy Branch Information; Actions Taken, Report No. SAT-00987, File No. SAT-
MOD-20130830-00110 (Dec. 20, 2013) (Public Notice).
5
See Application of Intelsat License LLC for Special Temporary Authority, Call Sign
S2404, File No. SAT-STA-20151002-00068 (filed Oct. 2, 2015).

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13997-14000 MHz X6
14000-14250 MHz X X
14250-14500 MHz X

The specific Intelsat 8 TT&C frequencies are as follows:

Uplink:

13998 MHz (RHCP)

Downlink:
3702 (H)
12747 (H)
12748 (V)
12747 (LHCP)
12748 (LHCP)

B. Extension of License Term

Intelsat seeks to extend the license term for the Intelsat 8 satellite for approximately three

years through September 30, 2018. The Intelsat 8 satellite was launched on November 3, 1998,

and placed into service in December 4, 1998.7 The license term for Intelsat 8 will expire on June

30, 2016.8 That expiration date is well before the expected end of service life of the satellite,

which was most recently estimated to be in September 2018, assuming commencement of

inclined orbit operations by March 2016.

6
Included for the purpose of authorizing Intelsat’s use of the 13998.0 MHz command link.
7
PanAmSat Licensee Corp., Order and Authorization, 14 FCC Rcd 2719 (1998); see also
Letter from Joseph A. Godles, Attorney for PanAmSat Corporation, to Marlene H. Dortch,
Federal Communications Commission, PanAmSat Corporation Annual Status Report, (Jul. 1,
2002) (stating that the satellite was put into service on December 4, 1998).
8
Intelsat License LLC, Application to Modify Authorization for Intelsat 8 (S2460), File No.
SAT-MOD-20130830-00110 (stamp grant Dec. 19, 2013).

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II. PUBLIC INTEREST SHOWING

Grant of this modification application to relocate and extend the license term of Intelsat 8

will serve the public interest by enabling Intelsat to provide continuity of service to customers at

the nominal 169.0° E.L. location. Although Intelsat 805, upon its arrival at 169.0° E.L., will

provide station-kept service for those customers requiring such service, Intelsat 8 will continue to

serve customers in inclined orbit mode from 168.9° E.L and can continue providing such service

well beyond the current license term’s June 30, 2016 expiration date.

Grant of the relocation request will not result in an increased risk of harmful interference.

During the short drift from 169.0° E.L to 168.9° E.L., Intelsat will operate the above listed

TT&C frequencies, as well as the communications frequencies, and will coordinate the Intelsat 8

transmissions internally with the operations of Intelsat 805. There are no other operators of co-

frequency satellites in the drift path. Customers on Intelsat 8 will not experience service

degradation because they will be tracking the satellite during the drift.9 Once on-station at

168.9° E.L., Intelsat will operate the Intelsat 8 satellite’s communications payload and TT&C

frequencies in conformance with Intelsat’s coordination agreements regarding the nominal

169.0° E.L. orbital location and the FCC’s rules governing operations vis-à-vis adjacent

locations.

Grant of the license term extension request will serve the public interest by enabling

customers to continue receiving service from an operational satellite with at least three years of

useful life remaining. There are no single points of failure on Intelsat 8 that would result in an

9
The Commission previously has authorized a .1° drift during which the satellite’s
communications payload remained operational. See Policy Branch Information; Actions Taken,
Report No. SAT-00998, File No. SAT-STA-20140212-00022 (Feb. 21, 2014) (Public Notice).

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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 past decisions by the Commission to extend satellite license

terms.10

III. WAIVER

Intelsat requests that the waiver previously granted to Intelsat 8 at 169.0° E.L. be

extended to the satellite at 168.9° E.L and to Intelsat 8’s extended license term. In particular,

Intelsat requests that the previously-granted waiver of Section 2.106 -- to permit Intelsat 8 to

transmit in the 12250–12750 MHz frequency band for commercial Fixed-Satellite Service

(“FSS”) on a non-interference, non-protected basis to any earth station in International

Telecommunication Union (“ITU”) Region 2 -- be extended to the satellite at 168.9° E.L., for the

reasons set forth in the previous grant.11

IV. ORBITAL DEBRIS STATEMENT

Intelsat has assessed and limited the probability of the Intelsat 8 space station becoming a

source of debris as a result of collision with large debris or other operational space stations at

168.9° E.L. Intelsat 8 and Intelsat 805 will be operated in the same 169.0° E.L. station-keeping

box until Intelsat 8 is relocated. Once relocated to 168.9° E.L., Intelsat 8 will not have an

overlapping station-keeping volume with any other satellite. Further, Intelsat is not aware of any

other FCC-licensed system, or any other system applied for and under consideration by the FCC,

10
See, e.g., 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).
11
See supra n. 4.

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having an overlapping station-keeping volume with Intelsat 8 at 168.9° E.L. Finally, Intelsat is

not aware of any system with an overlapping station-keeping volume with Intelsat 8 at 168.9º

E.L. that is the subject of an ITU filing and that is either in orbit or progressing toward launch.

Intelsat expects to operate Intelsat 8 at 168.9° E.L. until its end-of-service life, which, as

discussed above, currently is anticipated to be September 2018, assuming commencement of

inclined orbit operations by March 2016. The Commission has previously concluded that

Intelsat’s post-mission disposal plan, which would dispose of the Intelsat 8 satellite to minimum

altitude of 150 km above GEO arc, “demonstrates its operation raises no public interest concerns

related to orbital debris.”12 Intelsat has reserved 26.1 kilograms of fuel for this purpose.13

V. 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
Jennifer D. Hindin Associate General Counsel
Colleen King Intelsat Corporation
WILEY REIN LLP
1776 K Street, N.W.
Washington, D.C. 20006

October 21, 2015

12
See In the Matter of PanAmSat License Corp. Application for Modification of Authority
to Operate the Pas-5 Satellite at the 166° degrees E.L. Orbital Location, Order and
Authorization, DA 06-6, File Nos. SAT-MOD-19980928-00078, SAT-AMD-19990222-00024,
SAT-AMD-20020326-00055, SAT-STA-20020705-00097, and SAT-AMD-20051116-00220, 21
FCC Rcd 36, ¶ 16 (Jan. 4, 2006).
13
See Engineering Statement at 7.

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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 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: 2015-10-21 14:43:38
Document Modified: 2015-10-21 14:43:38

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