Attachment Narrative & Exhibits

This document pretains to SAT-MOD-20171023-00142 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2017102300142_1294777

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 907 (S2411) APPLICATION OF INTELSAT LICENSE LLC TO MODIFY AUTHORIZATION FOR INTELSAT 907 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 907 satellite (Call Sign S2411), a C- and Ku-band satellite operating at 27.5° W.L.2 Specifically, Intelsat seeks to extend the license term for the Intelsat 907 satellite through March 30, 2025.3 1 47 C.F.R. § 25.117. 2 See Policy Branch Information; Actions Taken, Report No. SAT-00134, File No. SAT- MOD-20020918-00183 (Feb. 12, 2003) (Public Notice). 3 Due to recent rule changes, Intelsat is not seeking waiver extension for the following Commission rules, which have been eliminated: 47 C.F.R. §§ 25.140(b)(2), 25.202(g), 25.210(a)(1), 25.210(a)(3), 25.210(i), and 25.211(a) (rule sections as of the time of the 2002 grant). Also due to rule changes, in 2016 Intelsat filed a letter notifying the FCC of its coordinated, non-routine, transmission levels on Intelsat 907. See Letter from Susan H. Crandall, Intelsat Corporation, to Ms. Marlene H. Dortch, Federal Communications Commission, File No. SAT-MOD-20020918-00183 (Sept. 19, 2016).

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 information previously provided regarding the operations of Intelsat 907.5 Additionally, Intelsat is providing a Schedule S. Consistent with Section 1.62 of the Commission’s rules,6 Intelsat will continue to operate the Intelsat 907 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 Intelsat 907 satellite through March 30, 2025. The Intelsat 907 satellite was placed into service on March 25, 2003.7 Pursuant to Sections 25.121(a) and (d)(1) of the Commission’s rules, the license term for Intelsat 907 will expire on March 25, 2018.8 This expiration date is well before the expected end of service life of the satellite, which was most recently estimated to be early 2020, assuming no inclined orbit operation; inclined orbit operation would extend Intelsat 907’s expected end of service life an additional five years. In order to accommodate the planned inclined orbit operation of Intelsat 907, Intelsat is requesting that the license term be extended through March 30, 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. 4 47 C.F.R. § 25.117(c). 5 See supra n. 2. 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 Letter from Carl R. Frank, Counsel to Intelsat LLC, to Ms. Marlene H. Dortch, Federal Communications Commission, File No. SAT-MOD-20020918-00183 (Mar. 26, 2003) (certifying that the Intelsat 907 spacecraft had been successfully placed into orbit). 8 47 C.F.R. §§ 25.121(a), (d)(1). -2-

II. PUBLIC INTEREST SHOWING Grant of this modification to extend the license term will serve the public interest by enabling customers to continue receiving service from Intelsat 907 at the 27.5º W.L. orbital location. The Intelsat 907 satellite subsystems and solar panels are functioning normally, and there are no single points of failure on Intelsat 907 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.9 III. POST-MISSION DISPOSAL PLAN At the end of the Intelsat 907 mission, the satellite will be disposed of by moving it to an altitude of at least 283.8 kilometers above the geostationary arc. For that purpose, 48.4 kilograms of fuel has been reserved. In calculating the disposal orbit, Intelsat used simplifying assumptions as permitted under the Commission’s Orbital Debris Report and Order.10 The effective area to mass ratio (Cr*A/M) of the Intelsat 907 spacecraft is 0.044 m2/kg, resulting in a minimum perigee disposal altitude under the Inter-Agency Space Debris Coordination Committee formula of 283.8 kilometers above the geostationary arc. Accordingly, the Intelsat 907 planned disposal orbit complies with the FCC’s rules. 9 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 inclination). 10 Mitigation of Orbital Debris, Second Report and Order, 19 FCC Rcd 11567 (2004). -3-

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 Cynthia J. Grady Regulatory Counsel Intelsat Corporation Jennifer D. Hindin WILEY REIN LLP 1776 K Street, N.W. Washington, D.C. 20006 October 23, 2017 -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”),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).

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: 2017-10-23 10:56:00
Document Modified: 2017-10-23 10:56:00
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