Attachment Narrative & Exhibits SAT-MOD-20170523-00077

Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20170523-00077 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2017052300077_1230607

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 3C (S2381)

APPLICATION OF INTELSAT LICENSE LLC
TO MODIFY AUTHORIZATION FOR GALAXY 3C

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 Galaxy 3C (Call Sign S2381), a C- and Ku-band satellite operating at 95.05°

W.L.2 Specifically, Intelsat seeks to extend the license term for the Galaxy 3C satellite, and a

previously granted waiver,3 through June 30, 2026.

1
47 C.F.R. § 25.117.
2
See PanAmSat Licensee Corp., Application to Launch and Operate Galaxy III-C, SAT-
LOA-19980812-00082 (granted May 29, 2002); as modified by PanAmSat Licensee Corp.,
Galaxy III-C Modification, SAT-MOD-20040405-0079 (granted June 15, 2004); as further
modified by PanAmSat Licensee Corp., Galaxy 3C Waiver, SAT-MOD-20060303-00019
(granted Oct. 26, 2006). See also Policy Branch Information; Actions Taken, Report No. SAT-
00399, File No. SAT-MOD-20060303-0019 (Oct. 27, 2006) (Public Notice). The licenses
originally held by PanAmSat Licensee Corp. were assigned in 2005 to Intelsat North America,
which later changed its name to Intelsat Licensee LLC.
3
Specifically, Intelsat seeks an extension of the previously granted waiver of 47 C.F.R.
§ 2.106, NG52 (formerly NG104). See id. Due to recent rule changes, Intelsat is not seeking
waiver extension of footnote 2 of Section 202(a)(1) of the Commission rules, which has been
eliminated. 47 C.F.R. § 202(a)(1) n. 2 (rule section at time of 2006 grant).

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 information previously provided regarding the operations of Galaxy 3C.5 Consistent with

Section 1.62 of the Commission’s rules,6 Intelsat will continue to operate the Galaxy 3C 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.

I. REQUEST FOR EXTENSION OF LICENSE TERM

Intelsat seeks to extend the license term for the Galaxy 3C satellite, and a previously

granted waiver,7 through June 30, 2026. The Galaxy 3C satellite was placed into service on

September 22, 2002.8 Pursuant to Sections 25.121(a) and (d)(1) of the Commission’s rules, the

license term for Galaxy 3C will expire on September 22, 2017.9 This expiration date is well

before the expected end of service life of the satellite, which was most recently estimated to be

early 2023, assuming no inclined orbit operation; inclined orbit operation would extend Galaxy
4
47 C.F.R. § 25.117(c).
5
See supra n. 2. To the extent necessary, Intelsat requests a waiver of § 25.114(a)(1) of
the Commission’s rules, which requires submission of Schedule S. 47 C.F.R. § 25.114(a)(1). At
the time of filing Galaxy 3C’s prior application providing technical information, a Schedule S
was not required. Given that this modification request seeks only to extend the satellite’s license
term and does not change any of the operational information previously provided to the FCC,
there is good cause not to require Intelsat to provide a Schedule S.
6
47 C.F.R. § 1.62 (permitting continued operations by a licensee where there is a proper
and timely pending application for renewal of the license).
7
See supra n. 3.
8
See Letter from Joseph A. Godles, Attorney for PanAmSat Licensee Corp., to Ms.
Marlene H. Dortch, Federal Communications Commission, File No. SAT-LOA-19990812-00082
(March 3, 2003) (certifying that the Galaxy 3C spacecraft had been successfully placed into
orbit).
9
47 C.F.R. §§ 25.121(a), (d)(1).

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3C’s expected end of service life an additional three to four years. In order to accommodate the

planned inclined orbit operation of Galaxy 3C, Intelsat is requesting that the license term be

extended through June 30, 2026. To the extent the satellite’s projected end of service life is

extended in the future, Intelsat will seek an additional extension of the license term.

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 3C at the 95.05° W.L.

orbital location. The Galaxy 3C satellite’s subsystems and solar panels are functioning normally,

and there are no single points of failure on Galaxy 3C that would result in an inability to de-orbit

the satellite. Additionally, the satellite’s TT&C functions are operating normally and most of the

payload is operational. 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.10

III. POST-MISSION DISPOSAL PLAN

At the end of the Galaxy 3C mission, Intelsat will dispose of the satellite by moving it to

an altitude of at least 265.9 kilometers above the geostationary arc. For that purpose, 7.2

kilograms of xenon propellant has been reserved.

In calculating the disposal orbit, Intelsat used simplifying assumptions as permitted under

the Commission’s Orbital Debris Report and Order.11 The effective area to mass ratio

(Cr*A/M) of the Galaxy 3C spacecraft is 0.028 m2/kg, resulting in a minimum perigee disposal

10
See e.g., Policy Branch Information; Actions Taken, Report No. SAT-01156, File No.
SAT-MOD-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 inclined orbit operation).
11
Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 (2004).

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altitude under the Inter-Agency Space Debris Coordination Committee formula of 265.9

kilometers above the geostationary arc. Accordingly, the Galaxy 3C planned disposal orbit

complies with the FCC’s rules.

The reserved fuel figure was determined by the spacecraft manufacturer and provided for

in the propellant budget. This figure was calculated taking into account the expected mass of the

satellite at the end of life and the required delta-velocity to achieve the desired orbit. The fuel

gauging uncertainty has been taken into account in these calculations.

Additionally, 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 by leaving the batteries in a permanent discharge state.

IV. 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
WILEY REIN LLP
1776 K Street, N.W.
Washington, D.C. 20006
May 23, 2017

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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”),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: 2017-05-23 15:31:24
Document Modified: 2017-05-23 15:31:24

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