Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20161004-00097 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2016100400097_1152981

Before the Federal Communications Commission Washington, DC 20554 In the Matter of Intelsat License LLC File No. SAT-MOD- _____________ Application to Modify Authorization for Galaxy 25 (S2154) APPLICATION OF INTELSAT LICENSE LLC TO MODIFY AUTHORIZATION FOR GALAXY 25 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 Galaxy 25 satellite (Call Sign S2154).2 Specifically, Intelsat seeks to further extend the license term for the Galaxy 25 satellite, and all previously granted waivers, through April 30, 2025.3 1 47 C.F.R. § 25.117 2 See Policy Branch Information; Actions Taken, Report No. SAT-00902, File No. SAT- MOD-20120320-00057 (Sept. 28, 2012) (Public Notice). 3 Intelsat previously requested a license extension through June 30, 2021. See Intelsat License LLC Application to Modify Authorization for Galaxy 25, File No. SAT−MOD−20120320−00057 (filed Mar. 20, 2012). The FCC granted the license extension only through December 31, 2016. See supra note 2. The current projected end of service life for Galaxy 25, assuming no inclined orbit operation, is April 2019. Intelsat is seeking authority for approximately six years beyond the current projected end of Galaxy 25’s service life to accommodate possible inclined orbit operation.

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 Galaxy 25.5 Consistent with Section 1.62 of the Commission’s rules, Intelsat will continue to operate the Galaxy 25 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.6 I. REQUEST FOR EXTENSION OF LICENSE TERM Intelsat seeks to further extend the license term for the Galaxy 25 satellite through April 30, 2025. The Galaxy 25 satellite is currently operating at 93.10° W.L.7 and was placed into service on June 30, 1997.8 Pursuant to Section 25.121 of the Commission’s rules and the current space station license, the license term for Galaxy 25 will expire on December 31, 2016.9 This expiration date is well before the expected end of service life, which was most recently estimated to be April 2019, assuming no inclined orbit operation; inclined orbit operation would extend Galaxy 25’s expected end of service life into 2025. In order to accommodate the possibility of inclined orbit operation, Intelsat is requesting that the license term be extended through April 30, 4 47 C.F.R. § 25.117(c). 5 See Policy Branch Information; Actions Taken, Report No. SAT-00566, File No. SAT- MOD-20080825-00159 (Nov. 21, 2008) (Public Notice). 6 47 C.F.R. § 1.62. 7 See supra note 2. 8 See Letter from Philip L. Verveer and Jennifer L. Desmond, Counsel for Loral SpaceCom Corp., to William F. Caton, FCC, File Nos. 65-SAT-P-95; 58-SAT-LA-97 (filed Jul. 1, 1997). 9 47 C.F.R. §§ 25.121; see supra note 2. -2-

2025. To the extent the satellite’s projected end of service life is extended in the future, Intelsat will seek an additional license term extension. II. PUBLIC INTEREST SHOWING Grant of this modification application to extend the license term will serve the public interest by enabling customers to continue receiving service from Galaxy 25. Extending the license term will also promote the continued efficient use of orbital resources and is consistent with recent decisions by the Commission to extend satellite license terms.10 There are no single points of failure on Galaxy 25 that would result in an inability to de-orbit the satellite. Additionally, the satellite’s TT&C functions are operating nominally. Moreover, extending the license term of the Galaxy 25 satellite will not affect the satellite’s post-mission disposal plan. As previously approved by the Commission, Intelsat intends to dispose of the Galaxy 25 satellite by moving it to a minimum altitude of 300 kilometers above the geostationary arc.11 Intelsat has reserved at least 63.5 kilograms of fuel for this purpose. 10 See Policy Branch Information; Actions Taken, Report No. SAT-01156, File No. SATMOD-20160219-00019 (May 6, 2016) (Public Notice) (granting license extension for Intelsat 1R, a station-kept satellite, based on the satellite’s current projected end of service including future inclination). 11 See supra note 2. -3-

III. CONCLUSION For the reasons set forth above, Intelsat respectfully requests that the Commission grant this modification application to extend the Galaxy 25 license term through April 30, 2025. 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 October 4, 2016 -4-

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: Jacques Kerrest, Chairman Franz Russ, Deputy Chairman Michelle Bryan, Secretary Mirjana Hervy, Director, Finance Board of Managers: Jacques Kerrest 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: 2016-10-04 12:05:52
Document Modified: 2016-10-04 12:05:52
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