Attachment Intelsat - Grant Aug

Intelsat - Grant Aug

DECISION submitted by IB, FCC

Grant

2019-08-01

This document pretains to SAT-MOD-20190422-00031 for Modification on a Satellite Space Stations filing.

IBFS_SATMOD2019042200031_1822665

                                                                               File#   gRT-Mo~-2o%g c42..Z-~I
S2408        SAT-MOD-20190422-00031      1B2019001161
Intelsat License LLC                                                           Call Sign S2~4 ‘        Grant Date O~/O
Intelsat 904
                                                                               (or other identifier)
                                                                                                       Term Dates                Approved by 0MB
                                                                               From    O~   ~l   iS          To~ I 2/31 2.              3060 0678
                                                          GRANTED
  Date & Time Filed: Apr22 2019 6:33:10:383PM           I eeI1H1:oeaI !3ucao   Approved:           ~
  File Number: SAT—MOD—201 90422—00031                                                                 ~ ~L~II
                                                                                                                               ~3ønth
        FCC APPLICATION FOR SPACE AND EARTH STATION:MOD OR AMD                     -   MAIN FORM             FCC Use Only

                            FCC 312 MAIN FORM FOR OFFICIAL USE ONLY

   APPLICANT INFORMATION
   Enter a description of this application to identify it on the main menu:
   Request to Modify Authorization for Intelsat 904 Satellite (Call Sign S2408)
   1—8. Legal Name of Applicant

               Name:        Intelsat License LLC             Phone Number:                             703 559 7848
               DBA                                           Fax Number:                               703 559 8539
               Na me:
               Street:      do Intelsat US LLC               E—Mail:                                   susan.crandall@intelsat.com
                            7900 Tysons One Place
               City:        McLean                           State:                                     VA
               Country:      USA                             Zipcode:                                  22102          5972
               Attention:    Susan H. Crandall


                                          ATTACHMENT TO GRANT
                                               Intelsat Licensee LLC
                                     IBFS File No. SAT-MOD-20190422-00031


 IBFS File No(s):          SAT-MOD-20190422-0003 1                                                     GRANTED             —


 Licensee/Grantee:         Intelsat Licensee LLC                                                       With Conditions
 Call Sign:                S2408
 Satellite Name:           Intelsat 904
 Orbital Location:         29.5° W.L.
 (required station-        (± 0.05 degrees east/west)
 keeping tolerance)
 Administration:           United States of America
 Nature of Service:        Fixed-Satellite Service (FSS)                                     International Bureau
                                                                                                Satellite_Division
 Scope of Grant:           Modification of the authorization for the Intelsat 904 space station to provide FSS in C-and
                           Ku-band frequencies at the 29.5° W.L. orbital location. Extension of license term for
                           Intelsat_904_through_December_31,_2024.
 Previous Grant(s):        Modification of the authorization for the Intelsat 904 space station to specify operations at
                           the 45.1° E.L. orbital location, instead of 60.0° E.L., IBFS File No. SAT-MOD-20160805-
                           00079 (granted Nov. 3, 2016).

                           Modification of the authorization for the Intelsat 904 space station to permit the
                           deployment of this satellite at 60° E.L. following launch rather than at 34.5° W.L. IBFS
                           File No. SAT-MOD-2001 1221-00140 (granted Mar. 22, 2002).

                           Authority to Construct, Launch and Operate a Geostationary Orbit Satellite at 34.55° W.L.
                           Applications of Intelsat LLC For Authority to Operate, and to Further Construct, Launch
                           and Operate C-Band and Ku-Band Global Satellites That Form a Global Communications
                           System in Geostationary Orbit, Memorandum Opinion and Order and Authorization, 15
                           FCC Rcd 15460, at Appendix C (2000), recon. denied, 15 FCC Rcd 25234.

 Service Area(s):          See Engineering Statement at 2.
 Frequencies:              3625-4200 MHz (space-to-Earth)
                           5850-6425 MHz (Earth-to-space)
                           1 0.95-1 1.2 GHz (space-to-Earth)
                           1 1.45-1 1.7 GHz (space-to-Earth)
                           14.0-14.5 GHz (Earth-to-space)

                           TT&C center frequencies:
                           3947.5 MHz, 3948.0 MHz, 3952.0 MHz, and 3952.5 M1-Iz (space-to-Earth); and 6173.7
                           MHz and 6176.3 MHz (Earth-to-space)

 Operations under this grant must comport with the legal and technical specifications set forth by the
 applicant or petitioner and with Federal Communication Commission’s rules not waived herein. This grant
 is also subject to the following conditions:
      1.   Intelsat must prepare the necessary information, as may be required, for submission to the International
           Telecommunication Union (ITU) to initiate and complete the advance publication, coordination, due
           diligence, and notification process of this space station, in accordance with the ITU Radio Regulations.
           Intelsat will be held responsible for all cost-recovery fees associated with ITU filings. No protection
           from interference caused by radio stations authorized by other administrations is guaranteed unless


‘Intelsat notifies that Intelsat 904 is operating in inclined orbit. See Letter from Cynthia J. Grady, Senior Counsel, Intelsat, to
Marlene H. Dortch, Secretary, Federal Communications Commission, dated Oct. 15, 2018.
                                                            Page 1 of 4


                                       ATTACHMENT TO GRANT
                                            Intelsat Licensee LLC
                                  IBFS File No. SAT-MOD-20190422-00031

          coordination and notification procedures are timely completed or, with respect to individual
          administrations, coordination agreements are successfully completed. Any radio station authorization for
          which coordination has not been completed may be subject to additional terms and conditions as required
          to effect coordination of the frequency assignments of other administrations. See 47 CFR § 25.111(b).
     2.   Intelsat must operate the Intelsat 904 space station at the 29.5° W.L. orbital location in compliance with
          all existing or future coordination agreements for that location. In the absence of a coordination
          agreement, such communications must comply with applicable provisions of the ITU Radio Regulations
          as the Commission cannot guarantee the success of the required coordination.
     3.   In connection with the provision of any service to any particular country, Intelsat is obligated to comply
          with the applicable laws, regulations, rules, and licensing procedures of that country.
     4.   While at the 29.5° W.L. orbital location, Intelsat must maintain the Intelsat 904 spacecraft with an eastlwest
          longitudinal station-keeping tolerance of +1- 0.05 degrees.
     5.   The operations of Intelsat 904 and associated earth stations must comport with the applicable uplink and
          downlink limits in 47 CFR § 25.140(a)(3) of the Commission’s rules, unless Intelsat coordinates any non
          conforming operations with the operations of U.S.-licensed geostationary orbit space stations within 6
          degrees of the 29.5° W.L. orbital location. Intelsat must also comport with the maximum power limits
          indicated in existing or future coordination agreements at 29.5° W.L. Non-conforming operation must
          also be coordinated with respect to those operations of non-U.S.-licensed space stations within 6 degrees
          of 29.5° W.L. involving approved communications with U.S.-licensed earth stations.
     6.   Intelsat’s use of the 3625-3 650 MHz (space-to-Earth) band is subject to GN Docket No. 12-354, which
          limits FSS communications within the United States in the 3600-3 650 MHz band on a primary basis to
          existing earth stations or to new earth stations within 10 miles of existing earth stations.2 All other FSS
          earth station operations in the band 3600-3650 MHz must be on a secondary basis.
     7.   Intelsat’s use of the 3625-3650 MHz (space-to-Earth) band is subject to footnote US245 of the United
          States Table of Frequency Allocations, 47 CFR § 2.106, US245, which states that the 3600-3650 MHz
          use of the non-Federal FSS is limited to international inter-continental systems and is subject to case-by-
          case electromagnetic compatibility analysis.
     8.   Intelsat’s use of the 3650-3700 MHz (space-to-Earth) band is subject to footnote NG185 of the United
          States Table of Frequency Allocations, 47 CFR § 2.106, NG185, which states that the 3650-3700 MHz
          use of the non-Federal FSS is limited to international inter-continental systems.
     9.   Intelsat’s use of the 3650-3700 MHz (space-to-Earth) band is subject to footnote NG169 of the United
          States Table of Frequency Allocations, which states that after December 1, 2000, operations on a primary
          basis by the FSS (space-to-Earth) in the band 3650-3700 MHz must be limited to grandfathered earth
          stations. All other FSS earth station operations in the band 3650-3700 MHz must be on a secondary
          basis.
     10. The power flux-density (PFD) at the Earth’s surface produced by the emissions from the Intelsat 904
         space station in the 3400-4200 MHz frequency band (space-to-Earth), must not exceed the applicable
         power flux-density limits contained in Section 25.208(a), 47 CFR § 25.208(a), and in Article 21.16 of the
         ITU Radio Regulations.
     11. Use of the 5850-5925 MHz frequency band shall comply with the terms of footnote U5245 to the U.S.
         Table of Frequency Allocations, 47 CFR § 2.106, US245, and Section 2.108 of the Commission’s rules,
         47 CFR § 2.108, which states that the 5850-5925 MHz use of the non-Federal fixed-satellite service is


2Amendment of the Commission’s Rules with Regard to Commercial Operations in the 3550-3 650 MHz Band, GN Docket
No. 12-354, Notice of Proposed Rulemaking and Order, 27 FCC Rcd 15594, 15646, ¶ 168 (2012).

                                                     Page 2 of 4


                                       ATTACHMENT TO GRANT
                                            Intelsat Licensee LLC
                                  IBFS File No. SAT-MOD-20190422-00031

          limited to international, intercontinental satellite systems and is subject to case-by-case electromagnetic
          compatibility analysis. Intelsat shall not claim protection from radiolocation transmitting stations
          operating in accordance with footnote G2.3
     12. Intelsat is directed to bear in mind the needs of the passive services when operating the Intelsat 904 space
         station in the 6425-6650 MHz frequency band pursuant to Footnote 5.45 8 to the United States Table of
         Frequency Allocations, 47 CFR §2.106, Footnote 5.458.
     13. Intelsat’s use of the 11.45-11.7 GHz frequency band is limited to international operations in accordance
         with footnote NG52 to the United States Table of Frequency Allocations, 47 CFR § 2.106, NG52.
     14. Intelsat’s use of the 10.95-11.2 GHz and 11.45-11.7 GHz (space-to-Earth) frequency bands is subject to
         footnote US2 11 to the United States Table of Frequency Allocations, 47 CFR § 2.106, US2 11, 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, consistent with footnote US74.
     15. Intelsat’s request for waiver of footnote NG52 of the U.S. Table of Frequency Allocations, 47 CFR §
         2.106, NG52, to use the 10.95-11.2 GHz band to offer domestic services on an unprotected, non-harmful
         interference basis in the United States IS GRANTED, as conditioned. We find that waiver does not
         undermine the purpose of the rule because the waiver involves only earth stations that are receive-only in
         the 10.95-11.2 GHz frequency band and thus are not capable of causing interference into fixed stations
         operating in this band. Furthermore, because Intelsat has agreed to accept any level of interference from
         fixed stations into receive earth stations in this band, fixed station operators will not be required to
         coordinate their station operations with Intelsat’s earth stations’ operations. Under these circumstances,
         we determine that an additional coordination burden is not placed upon fixed station operators and their
         ability to expand service in the future would not be restricted in any manner.
     16. Intelsat’s space-to-Earth transmissions in the 10.95-11.2 GHz band are to be conducted without
         interference protection from fixed stations to earth stations receiving these transmissions. This applies to
         fixed stations to which frequencies in the 10.95-11.2 GHz band have either been already assigned, or to
         which frequencies in the 10.95-11.2 GHz band may be assigned at a later date.
     17. Intelsat must inform its customers, in writing, including end-users receiving service from resellers
         accessing capacity on the Intelsat 904 space station, that domestic service in the 10.95-1 1.2 GHz band is
         being provided on an unprotected basis, and that the potential exists that future licensed fixed stations
         may cause harmful interference to unprotected receive earth stations in the 10.95-11.2 GHz band.
     18. Pursuant to footnote US342 of the United States Table of Frequency Allocations, 47 C.F.R. § 2.106,
         services operating in the 14.47-14.5 GHz band shall take all practicable steps to protect the radio
         astronomy service from harmful interference.

     19. Intelsat’s request that the prior waiver granted to Intelsat 904 for Section 25.202(g)) of the Commission’s
         rules be extended to the operation of Intelsat 904 at 29.5° E.L. is GRANTED, subject to the conditions in
         the prior grants.4



  For technical information of these radiolocation systems, see NTIA Report 83-115, Spectrum Resource Assessment in the
5650-5925 MHz Band, and NTIA Report 00-373, Measured Occupancy of 5850-5925 MHz and Adjacent 5-GHz Spectrum
in the United States at http:f/www.its.bldrdoc.gov/pub/pubs.php.
~ See IBFS File No. SAT-MOD-20160805-00079, grant stamp Nov. 3, 2016; IBFS File No. SAT-MOD-2001 1221-00140,
grant stamp Mar. 22, 2002; Applications ofIntelsat LLC For Authority to Operate, and to Further Construct, Launch and
Operate C-Band and Ku-Band Global Satellites That Form a Global Communications System in Geostationary Orbit,
Memorandum Opinion and Order and Authorization, 15 FCC Rcd 15460, at Appendix C (2000), recon. denied, 15 FCC Rcd
25234.
                                                      Page 3 of 4


                                       ATTACHMENT TO GRANT
                                            Intelsat Licensee LLC
                                  IBFS File No. SAT-MOD-20190422-00031

     20. Intelsat’s operations of the Intelsat 904 space station at the 29.5° E.L. orbital location are subject to the
         following additional conditions:
              a. Intelsat shall remain a signatory to the Public Services Agreement between Intelsat and the
         International Telecommunications Satellite Organization (ITSO) that was approved by the ITSO Twenty-
         fifth and Thirty-seventh Assembly of Parties, as amended.
             b. No entity shall be considered a successor-in-interest to Intelsat under the ITSO Agreement for
         licensing purposes unless it has undertaken to perform the obligations of the Public Services Agreement
         approved by the Twenty-fifth and Thirty-seventh Assembly of Parties, as amended.
     21. The license term for the Intelsat 904 space station is extended from December 3 1, 2019 through
         December 31, 2024.~
 Licensee/grantee is afforded thirty (30) days from the date of release of this action to decline the grant as
 conditioned. Failure to respond within this period will constitute formal acceptance of the grant as conditioned.

 This action is taken pursuant to Section 0.261 of the Commission’s rules on delegated authority, 47 CFR         §   0.26 1,
 and is effective upon release.

 Station licenses are subject to the conditions specified in Section 309(h) of the Communications Act of 1934, as
 amended, 47 U.S.C. § 309(h).

 Action          August 1, 2019
 Date:
 Term Dates      From: August 1,2019                  To: December 31, 2024

 Approved:



                Stephe J Duall
                Chief, Satellite Policy Branch




~ See IBFS File No. SAT-MOD-20l60805-00079 (granted Feb. 24, 2016).
                                                     Page 4 of 4


9—16. Name of Contact Representative

                Name:          Jennifer D Hindin                     Phone Number:                        202—719—4975
                Company:       Wiley Rein LLP                        Fax Number:                          202—719—7049
                Street:        1776 K Street, NW                     E—Mail:                              jhindin@wileyrein.com


                City:          Washington                            State:                               DC
                Country:        USA                                  Zipcode:                             20006—
                Attention:     Jennifer D Hindin                     Relationship:                        Legal Counsel


CLASSIFICATION OF FILING
    17. Choose the button next to the
    classification that applies to this filing for   (N/A) bI. Application for License of New Station
    both questions a. and b. Choose only one         (N/A) b2. Application for Registration of New Domestic Receive—Only Station
    for 17a and only one for 17b.                     0  b3. Amendment to a Pending Application

                                                     • b4. Modification of License or Registration
       0   al. Earth Station                         b5. Assignment of License or Registration
                                                                          .



       • a2. Space Station                           b6. Transfer of Control of License or Registration
                                                      o   b7. Notification of Minor Modification
                                                      (N/A) b8. Application for License of New Receive—Only Station Using Non—U.S. Licensed
                                                     Satellite
                                                      (N/A) b9. Letter of Intent to Use Non—U.S. Licensed Satellite to Provide Service in the United
                                                     States
                                                      (N/A) blO. Other (Please specify)
                                                        (N/A) bI 1. Application for Earth Station to Access a Non—U.S.satellite Not Currently Authorized
                                                     to Provide the Proposed Service in the Proposed Frequencies in the United States
                                                        (N/A) b12. Application for Database Entry
                                                      o b 13. Amendment to a Pending Database Entry Application
                                                      o b 14. Modification of Database Entry
2


   17c. Is a fee submitted with this application?
• If Yes, complete and attach FCC Form 159.            If No, indicate reason for fee exemption (see 47 C.F.R.Section 1.1114).
0       Governmental Entity       ~ Noncommercial educational licensee
o Other(please explain):
I 7d.

Fee Classification BFY        —   Space Station Modification(Geostationary)




18. If this filing is in reference to an          19. If this filing is an amendment to a pending application enter both fields, if this filing is a
existing station, enter:                          modification please enter only the file number:
(a) Call sign of station:                         (a) Date pending application was filed:              (b) File number:
    S2408
                                                                                                       SATMOD20 16080500079


TYPE OF SERVICE
20. NATURE OF SERVICE: This filing is for an authorization to provide or use the following type(s) of service(s): Select all that apply:

     a. Fixed Satellite
     b. Mobile Satellite
     c. Radiodetermination Satellite

Q d. Earth Exploration Satellite
     e. Direct to Home Fixed Satellite
     f. Digital Audio Radio Service

 EJ g. Other (please specify)
21. STATUS: Choose the button next to the applicable status. Choose      22. If earth station applicant, check all that apply.
only one.                                                                 EJ  Using U.S. licensed satellites
0    Common Carrier          Non—Common Carrier                           Q Using Non—U.S. licensed satellites
23. If applicant is providng INTERNATIONAL COMMON CARRIER service, see instructions regarding Sec. 214 filings. Choose one. Are these
facilities:
 0   Connected to a Public Switched Network          Not connected to a Public Switched Network             N/A
   24. FREQUENCY BAND(S): Place an ‘X’ in the box(es) next to all applicable frequency band(s).
     a. C—Band (4/6 GHz) ~ b. Ku—Band (12/14 GHz)
     c.Other (Please specify upper and lower frequencies in MHz.)
         Frequency Lower:       Frequency Upper: (Please specify additional frequencies in an attachment)


TYPE OF STATION
25. CLASS OF STATION: Choose the button next to the class of station that applies. Choose only one.
 O   a. Fixed Earth Station
 o b. Temporary—Fixed Earth Station
 o c. 12/14 GHz VSAT Network
 o d. Mobile Earth Station
 O   e. Geostationary Space Station
 o ~ Non—Geostationary Space Station
 O   g. Other (please specify)


26. TYPE OF EARTH STATION FACILITY:
o   Transmit/Receive 0 Transmit—Only            ~ Receive—Only      0   N/A
“For Space Station applications, select N/A.”


PURPOSE OF MODIFICATION


27. The purpose of this proposed modification is to: (Place an ‘X’ in the box(es) next to all that apply.)


    EJ a       ——   authorization to add new emission designator and related service
          b    —     authorization to change emission designator and related service

     EJ c      —     authorization to increase EIRP and EIRP density
     EJ d      ——    authorization to replace antenna
     EJ e      —     authorization to add antenna
     EJ   ~——        authorization to relocate fixed station
     EJ g      —     authorization to change frequency(ies)
     EJ h       —     authorization to add frequency
           i   ——    authorization to add Points of Communication (satellites & countries)
          j    ——    authorization to change Points of Communication (satellites & countries)

     EJ   k    authorization for facilities for which environmental assessment and
                ——

 radiation hazard reporting is required
               authorization to change orbit location
               ——




     EJ m       ——    authorization to perform fleet management
     EJ n       —     authorization to extend milestones
           o    —     Other (Please specify)


ENVIRONMENTAL POLICY


28. Would a Commission grant of any proposal in this application or amendment have a significant environmental     0   Yes   No
impact as defined by 47 CFR 1.1307? If YES, submit the statement as required by Sections 1.1308 and 1.1311 of
the Commission’s rules, 47 C.F.R. 1.1308 and 1.131 1, as an exhibit to this application.A Radiation Hazard Study
must accompany all applications for new transmitting facilities, major modifications, or major amendments.



ALIEN OWNERSHIP Earth station applicants not proposing to provide broadcast, common carrier, aeronautical en route or
aeronautical fixed radio station services are not required to respond to Items 30—34.


 29. Is the applicant a foreign government or the representative of any foreign government?                        0   Yes    No




 30. Is the applicant an alien or the representative of an alien?                                                  0   Yes    No   0   N/A




 31. Is the applicant a corporation organized under the laws of any foreign government?                            0   Yes    No   0   N/A




 32. Is the applicant a corporation of which more than one—fifth of the capital stock is owned of record or voted by ~ Yes    No   0   N/A
 aliens or their representatives or by a foreign government or representative thereof or by any corporation organized
 under the laws of a foreign country?


33. Is the applicant a corporation directly or indirectly controlled by any other corporation of which more than          Yes         No    N/A
one—fourth of the capital stock is owned of record or voted by aliens, their representatives, or by a foreign
government or representative thereof or by any corporation organized under the laws of a foreign country?



34. If any answer to questions 29, 30, 31, 32 and/or 33 is Yes, attach as an exhibit an identification of the aliens or
foreign entities, their nationality, their relationship to the applicant, and the percentage of stock they own or vote.



BASIC QUALIFICATIONS


35. Does the Applicant request any waivers or exemptions from any of the Commission’s Rules?                                    Yes        No
If Yes, attach as an exhibit, copies of the requests for waivers or exceptions with supporting documents.




36. Has the applicant or any party to this application or amendment had any FCC station authorization or license          0 Yes            No
revoked or had any application for an initial, modification or renewal of FCC station authorization, license, or
construction permit denied by the Commission? If Yes, attach as an exhibit, an explination of circumstances.


37. Has the applicant, or any party to this application or amendment, or any party directly or indirectly controlling    0   Yes   No
the applicant ever been convicted of a felony by any state or federal court? IfYes, attach as an exhibit, an
explination of circumstances.




38. Has any court finally adjudged the applicant, or any person directly or indirectly controlling the applicant,        0 Yes     No
guilty of unlawfully monopolizing or attemptiing unlawfully to monopolize radio communication, directly or
indirectly, through control of manufacture or sale of radio apparatus, exclusive traffic arrangement or any other
means or unfair methods of competition?If Yes, attach as an exhibit, an explanation of circumstances




39. Is the applicant, or any person directly or indirectly controlling the applicant, currently a party in any pending   0   Yes   No
matter referred to in the preceding two items? If yes, attach as an exhinit, an explanation of the circumstances.




40. If the applicant is a corporation and is applying for a space station license, attach as an exhibit the names,
address, and citizenship of those stockholders owning a record and/or voting 10 percent or more of the Filer’s
voting stock and the percentages so held. In the case of fiduciary control, indicate the beneficiary(ies) or class of
beneficiaries. Also list the names and addresses of the officers and directors of the Filer.


41. By checking Yes, the undersigned certifies, that neither applicant nor any other party to the application is                Yes      0   No
subject to a denial of Federal benefits that includes FCC benefits pursuant to Section 5301 of the Anti—Drug Act of
1988, 21 U.S.C. Section 862, because of a conviction for possession or distribution of a controlled substance. See
47 CFR 1.2002(b) for the meaning of "party to the application" for these purposes.



42a. Does the applicant intend to use a non—U.S. licensed satellite to provide service in the United States? If Yes,        0   Yes          No
answer 42b and attach an exhibit providing the information specified in 47 C.F.R. 25.137, as appropriate. If No,
proceed to question 43.




42b. What administration has licensed or is in the process of licensing the space station? If no license will be issued, what administration has
coordinated or is in the process of coordinating the space station?



43. Description. (Summarize the nature of the application and the services to be provided).    (If the complete description does not appear in this
box, please go to the end of the form to view it in its entirety.)
     Intelsat License LLC, pursuant to Section 25.117 of the rules of the Federal
     Communications Commission, hereby seeks to modify the authorization for the Intelsat 904
     satellite (Call Sign S2408)   Specifically, this modification application seeks authority
                                               .


     to relocate Intelsat 904 to, and operate the satellite at, 29.5 W.L. and to extend the
Narrative&Exhibits


43a. Geographic Service Rule Certification
By selecting A, the undersigned certifies that the applicant is not subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25.

By selecting B, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will comply with such requirements.

By selecting C, the undersigned certifies that the applicant is subject to the geographic service or geographic
coverage requirements specified in 47 C.F.R. Part 25 and will not comply with such requirements because it is not
feasible as a technical matter to do so, or that, while technically feasible, such services would require so many
compromises in satellite design and operation as to make it economically unreasonable. A narrative description
and technical analysis demonstrating this claim are attached.
                                                                                                                              Engineering Statemt



CERTIFICATION
The Applicant waives any claim to the use of any particular frequency or of the electromagnetic spectrum as against the regulatory power of the
United States because of the previous use of the same, whether by license or otherwise, and requests an authorization in accordance with this
application. The applicant certifies that grant of this application would not cause the applicant to be in violation of the spectrum aggregation limit
in 47 CFR Part 20. All statements made in exhibits are a material part hereof and are incorporated herein as if set out in full in this application.
The undersigned, individually and for the applicant, hereby certifies that all statements made in this application and in all attached exhibits are
true, complete and correct to the best of his or her knowledge and belief, and are made in good faith.


44. Applicant is a (an): (Choose the button next to applicable response.)


0    Individual
~ Unincorporated Association
O    Partnership
o Corporation
o Governmental Entity
• Other (please specify)




    45. Name of Person Signing                                              46. Title of Person Signing
    Susan H. Crandall                                                       Assoc. Gen. Counsel, Intelsat US LLC
       ——>




             WILLFUL FALSE STATEMENTS MADE ON THIS FORM ARE PUNISHABLE BY FINE AND / OR IMPRISONMENT
                      (U.S. Code, Title 18, Section 1001), AND/OR REVOCATION OF ANY STATION AUTHORIZATION
                    (U.S. Code, Title 47, Section 312(a)(1)), AND/OR FORFEITURE (U.S. Code, Title 47, Section 503).


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searching existing data sources, gathering and maintaining the required data, and completing and reviewing the collection of information. If you
have any comments on this burden estimate, or how we can improve the collection and reduce the burden it causes you, please write to the
Federal Communications Commission, AMD—PERM, Paperwork Reduction Project (3060—0678), Washington, DC 20554. We will also accept
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THE FOREGOING NOTICE IS REQUIRED BY THE PAPERWORK REDUCTION ACT OF 1995, PUBLIC LAW 104-13, OCTOBER
1, 1995, 44 U.S.C. SECTION 3507.


43. Description. (Summarize the nature of the application and the services to be provided).

Intelsat License LLC, pursuant to Section 25.117 of the rules of the Federal Communications
Commission, hereby seeks to modify the authorization for the Intelsat 904 satellite (Call Sign
S2408)   Specifically, this modification application seeks authority to relocate Intelsat 904 to,
         .


and operate the satellite at, 29.5 W.L. and to extend the license term of the satellite through
December 2024.



Document Created: 2019-08-01 14:31:07
Document Modified: 2019-08-01 14:31:07

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