Attachment Narrative & Exhibits SAT-MOD-20160201-00009

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20160201-00009 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2016020100009_1124761

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 16 (S2750)

APPLICATION OF INTELSAT LICENSE LLC
TO MODIFY AUTHORIZATION FOR INTELSAT 16

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 16 satellite (Call Sign S2750). Specifically, this

modification application seeks authority to redeploy Intelsat 16 to, and operate the satellite at,

58.1° W.L.

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. REQUEST TO RELOCATE INTELSAT 16 TO 58.1° W.L.

Intelsat requests authority to relocate Intelsat 16 to, and operate the satellite at, 58.1°

W.L. Intelsat 16 is currently operating at 79.0° W.L.3 Intelsat has been granted Special

Temporary Authority to drift to, and operate the satellite to 58.1° W.L.4

Once located at 58.1° W.L., Intelsat 16 will be nominally co-located with Intelsat 21,

which currently operates at 58.0° W.L.5 Intelsat 16 will operate in the communications

frequencies as set forth below:

Frequency Band INTELSAT 21 INTELSAT 16
3700 – 4200 MHz √
5925 – 6425 MHz √
10700 – 11450 MHz √
11450 – 11700 MHz √
11700 – 12200 MHz √ √
12750 – 13250 MHz √
13750 – 14000 MHz √
14000 – 14500 MHz √ √

Intelsat 16’s specific telemetry, tracking, and command (“TT&C”) frequencies are as

follows: 12198.25 MHz, 12198.75 MHz, 13997.5 MHz, and 14499.5 MHz.

3
See Policy Branch Information; Actions Taken, Report No. SAT-01078, File No. SAT-MOD-20150105-
00003 (Apr. 17, 2015 (Public Notice).
4
See Policy Branch Information; Actions Taken, Report No. SAT-01127, File No. SAT-STA-20151222-
00085 (Jan. 8, 2016) (Public Notice); See Policy Branch Information; Actions Taken, Report No. SAT-
01103, File No. SAT-STA-20150625-00038 (Aug. 21, 2015) (Public Notice).
5
See Policy Branch Information; Actions Taken, Report No. SAT-00882, File No. SAT-RPL-20120326-
00061 (July 13, 2012) (Public Notice).

2

As indicated above, Intelsat 16 includes the 10700 – 11450 MHz, 12750 – 13250 MHz,

and 13750 – 14000 MHz frequency bands, which are not currently used by Intelsat 21 at the

58.0° W.L. location.6

II. PUBLIC INTEREST SHOWING

Grant of this modification application is in the public interest because it will allow

Intelsat to help satisfy customer demand at 58.1° W.L. Moreover, grant of this modification

application will not result in an increased risk of harmful interference. Intelsat will operate

Intelsat 16’s communications payload and TT&C frequencies at 58.1° W.L. in conformance with

existing coordination agreements and the FCC’s rules governing operations vis-à-vis adjacent

locations.

III. REQUEST FOR GRANT WITHOUT A BOND

Intelsat 16 seeks a waiver to the milestone and bond posting requirements set forth in

Sections 25.164 and 25.165 of the Commission’s rules for the 10700 – 11450 MHz, 12750 –

13250 MHz, and 13750 – 14000 MHz frequency bands, which are included on Intelsat 16 but not

on Intelsat 21. Intelsat understands that when the modified milestone and bond requirements

adopted in the Satellite Streamlining Second Report and Order come into force, the FCC will

apply them to pending space station applications, such as this one.7

The Commission should grant this application without imposing a bond8 because as

Intelsat 16 is already in-orbit, there is no risk of warehousing and Intelsat should not be required

6
The 10700 – 11450 MHz and 12750 – 13250 MHz bands were not previously licensed on Intelsat 16.
7
Comprehensive Review of Licensing and Operating Rules for Satellite Services, Second Report and
Order, IB Docket No. 12-267, FCC 15-167 at ¶ 333 (rel. Dec. 17, 2015).
8
47 C.F.R. §§ 25.164, 25.165.

3

to post a bond.9 Indeed, the Commission has granted similar applications for in-orbit satellites

without imposing milestones or a bond.10

IV. 10700 – 11450 MHZ AND 13750 – 14000 MHZ FREQUENCY BANDS

Intelsat understands that operations in the 10700 – 11450 MHz and 13750 – 14000 MHz

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

fulfill. Specifically, for operations in the 10950 – 11200 MHz frequency band, Intelsat accepts

the following conditions:

 Operations in the 10700 – 11450 MHz frequency band shall comply with the terms of
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.

 Operations in the 10700 – 11450 MHz frequency band are limited to international
operations in accordance with footnote NG 52 to the United States Table of Frequency
Allocations, 47 C.F.R. § 2.106, NG 52.
For operations in the 13750 – 14000 MHz frequency band, Intelsat accepts the following

condition:

 Pursuant to footnote US337 of the United States Table of Frequency Allocations, 47
C.F.R. § 2.106, any earth station in the United States and its possessions communicating
with the Intelsat 16 space station in the 13750-14000 MHz band (Earth-to-space) is
required to coordinate through National Telecommunications and Information
Administration’s (NTIA’s) Interdepartment Radio Advisory Committee’s (IRAC’s)
Frequency Assignment Subcommittee (FAS) to minimize interference to the National

9
See Loral Skynet Network Services, Inc., 21 FCC Rcd 14,365 (Int’l Bur. 2006) (“Because Telstar 18 is
in-orbit and operating, Loral is not required to post a bond.”).

10
See Policy Branch Information; Actions Taken, Report No. SAT-00541, File No. SAT-MOD-
20080225-00051 (July 25, 2008) (Public Notice); See Policy Branch Information; Actions Taken, Report
No. SAT-00561, File No. SAT-MOD-20080725-00150 (Oct. 24, 2008) (Public Notice). To the extent
necessary, Intelsat requests waiver of Sections 25.164(a) and 25.165 of the rules, 47 C.F.R. §§ 25.164(a)
and 25.165, for any bond associated with the operation of Intelsat 16 at 58.1° W.L. In this case, there is
no risk of warehousing because the Intelsat 16 satellite is already in-orbit and will be able to provide
service from the 58.1° W.L. location in a much more timely manner than the five years that would be
allowed to an applicant intending to construct, launch, and operate a new satellite at this location.

4

Aeronautics and Space Administration Tracking and Data Relay Satellite System,
including manned space flight.
V. CONCLUSION

For the reasons set forth above, Intelsat respectfully requests that the Commission grant

this modification application.

Respectfully submitted,

Intelsat License LLC

Susan H. Crandall
By: ___________________
Susan H. Crandall
Associate General Counsel
Intelsat Corporation
7900 Tysons One Place
McLean, VA 22102
(703) 559-7848

February 1, 2016

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”),1 based on the Bureau’s finding
that PanAmSat had not satisfied applicable construction milestones.2 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.

1
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).
2
See PanAmSat Licensee Corp., Memorandum Opinion and Order, 15 FCC Rcd 18720 (IB 2000).

Document Created: 2016-02-01 16:22:32
Document Modified: 2016-02-01 16:22:32

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