Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20160425-00040 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2016042500040_1134447

                                         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”),1 hereby seeks to modify the

authorization for the Intelsat 701 satellite (Call Sign S2400).2 Specifically, Intelsat seeks to

extend the license term for the Intelsat 701 satellite, and all previously granted waivers,3 through

December 31, 2018.

       In accordance with the requirements of the Commission’s rules,4 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 701.5

1
       47 C.F.R. § 25.117.
2
     See Intelsat License LCC, Application to Modify Authorization for Intelsat 701, File No.
SAT-MOD-20130513-00068 (stamp grant June 27, 2014) (“2014 Intelsat 701 Modification”).
3
       Intelsat 701 has received waivers of the following FCC rules: Sections 25.202(g),
25.210(a)(1), 25.210(a)(3), 25.210(i), and 25.211(a), and Section 2.106, note NG52. See id.
4
       47 C.F.R. § 25.117(c).
5
       See 2014 Intelsat 701 Modification, supra note 2.


Consistent with Section 1.62 of the Commission’s rules,6 Intelsat will continue to operate the

Intelsat 701 satellite pursuant to the terms and conditions of its expiring license until such time as

the Commission makes a determination with request to this request.7

I.      REQUEST FOR EXTENSION OF LICENSE TERM

        Intelsat seeks to extend the license term for the Intelsat 701 satellite, and all previously

granted waivers, through December 31, 2018. The Intelsat 701 satellite was placed into service

on July 18, 2001.8 Pursuant to Sections 25.121(a) and (d)(1) of the Commission’s rules, the

license term for Intelsat 701 will expire on July 18, 2016.9 This expiration date is well before the

expected end of service life of the satellite, which was most recently estimated to be late 2018.

Accordingly, Intelsat herein is seeking an extension of the Intelsat 701 license term based on the

satellite’s current projected end of service life.

II.     PUBLIC INTEREST SHOWING

        Grant of this modification to extend the license will serve the public interest by enabling

customers to continue receiving service from Intelsat 701. The Intelsat 701 satellite subsystems

and solar panels are functioning normally, and there are no single points of failure on Intelsat

701 that would result in an inability to de-orbit the satellite. Additionally, the satellite’s TT&C

functions are operating normally. Extending the license term will promote the continued




6
        47 C.F.R. § 1.62.
7
        See id. § 25.117.
8
       Applications of Intelsat LLC for Authority to Operate, and to Further Construct, Launch,
and Operate C-band and Ku-band Satellites that Form a Global Communications System in
Geostationary Orbit, Memorandum Opinion, Order, and Authorization, 15 FCC Rcd 15,460
(2000) (authorizing operation of INTELSAT 701 at 180° E.L.).
9
        47 C.F.R. §§ 25.121(a) & (d)(1).


                                                     -2-


efficient use of orbital resources and is consistent with recent decisions by the Commission to

extend satellite license terms.10

       Moreover, extending the license term of the Intelsat 701 satellite will not affect the

satellite’s post-mission disposal plan. As previously approved by the Commission, Intelsat

intends to dispose of the Intelsat 701 satellite by moving it to a minimum altitude of 150

kilometers above the geostationary arc.11 Intelsat has reserved 26.53 kg of fuel for this purpose.

Grant of the requested license extension will not affect the 26.53 kg fuel reserve.

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

April 25, 2016

10
         See, e.g., Policy Branch Information; Actions Taken, Report No. SAT-01117, File No.
SAT-MOD-20150820-00059 (Nov. 6, 2015) (Public Notice) (extending license term of an SES
satellite for an additional eight 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 terms of Sirius XM satellites for an additional seven years).
11
         See 2014 Intelsat 701 Modification, supra note 2. The Commission has found that
satellites launched prior to March 18, 2002, such as Intelsat 701, 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 (2004).

                                                 -3-


                                           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).


                                          Exhibit C
                          FCC Form 312, Response to Question 40:
                Officers, Directors, and Ten Percent or Greater Shareholders

The officers and directors/managers of Intelsat License LLC are as follows:
Officers:
Franz Russ, Deputy Chairman
Michelle Bryan, Secretary
Mirjana Hervy, Director, Finance

Board of Managers:
Franz Russ
Michelle Bryan

The business address of all Intelsat License LLC officers and members of the Board of Managers
is:
4 rue Albert Borschette
L-1246 Luxembourg

Intelsat License LLC is a Delaware limited liability company that is wholly owned by Intelsat
License Holdings LLC, also a Delaware limited liability company. Intelsat License Holdings
LLC is wholly owned by Intelsat Jackson Holdings S.A., a Luxembourg company. Intelsat
Jackson Holdings S.A. is wholly owned by Intelsat (Luxembourg) S.A., a Luxembourg
company. Intelsat (Luxembourg) S.A. is wholly owned by Intelsat Investments S.A., a
Luxembourg company. Intelsat Investments S.A. is wholly owned by Intelsat Holdings S.A., a
Luxembourg company. Intelsat Holdings S.A. is wholly owned by Intelsat Investment Holdings
S.à r.l., a Luxembourg company. Intelsat Investment Holdings S.à r.l. is wholly owned by
Intelsat S.A., a Luxembourg company. Each of these entities may be contacted at the following
address: 4 rue Albert Borschette, L-1246 Luxembourg.

Intelsat S.A.’s ownership was approved by the Commission as part of the Intelsat-Serafina
Order and the recent Intelsat Pro Forma and is incorporated by reference. See 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) (“Intelsat-Serafina Order”); 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) (“Intelsat Pro Forma”). On May 16, 2012, the International Bureau
granted an application to transfer control of Intelsat pursuant to a public offering of newly issued
voting shares by Intelsat, subsequent voting share sales by current shareholders and possible
private placements of newly issued voting shares. In the Matter of Intelsat Global Holdings,
S.A., Applications to Transfer Control of Intelsat Licenses and Authorizations from BC Partners
Holdings Limited to Public Ownership, Order, DA 12-768 (rel. May 16, 2012). This change of
control has not yet been fully consummated.



Document Created: 2016-04-25 14:25:47
Document Modified: 2016-04-25 14:25:47

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