Attachment july 14 2006

This document pretains to SAT-PPL-20040318-00038 for Permitted List on a Satellite Space Stations filing.

IBFS_SATPPL2004031800038_513170

                                                   S2592       SATPPL-2002042740092         18200500090!
                                                   lntelsat North America LLC
                                                   lntelsat Americas 13
                                                   S2592       SATPPL-2004031800038         IB200400062:
                                                   lntelsat North America LLC
                                                   TELSTAR 13




I NT E L SAT                Policy BI;:ICh
                         InternationalBureau
   July 2 1,2006

   Ms. Marlene H. Dortch, Secretary
   Federal Communications Commission
   445 1 2 Street,
            ~ ~ S.W.
   Washington, D.C. 20554

   Re:    Notification of Change in Regulatory Classification for Intelsat Americas-13,
          Call Sign S2592


   Dear Ms. Dortch:

            Intelsat North America LLC (“Intelsat”) hereby notifies the Commission that it
   intends to change the regulatory classification of its Permitted Space Station List
   (“Permitted List”) authorization for Intelsat Americas-13 (“IA-13”) to provide fixed-
   satellite service from “dual-use” (common carrierhon-common carrier) to non-common
   carrier, effective immediately. This notification is filed pursuant to the streamlined
   process for changing the regulatory classification of FSS licenses adopted by the
   Commission in the DISCO I Order:

                   [Llicensees wishing to change their regulatory
                   classification should notify us in writing of such change,
                   including the date on which they intend to do so. No prior
                   approval from the Commission will be necessary.
                   Commission staff will include the notification of a change
                   in status as an informational listing in the Satellite and
                   Radiocommunication Division’s weekly Public Notice of
                   actions taken. The staff will also place a copy of the
                   notification in the station file.’

           As the Commission anticipated when it adopted this notification procedure,
   Intelsat has based its election of non-common carrier status “on the realities of the service

   1
          Amendment to the Commission’s Regulatory Policies Governing Domestic Fixed Satellites and
  Separate International Satellite Systems, Report and Order, 1 1 FCC Rcd 2429, 2436 (7 50) (1996)
  (“DISCO I Order”).




                                                                  www intelsat coin


provided consistent with the factors set forth in NARUC I.”2 When Intelsat notified the
Commission of the change in ownership of Permitted List Satellite IA-13 (then named
Telstar 13), Intelsat asked the Commission to authorize IA-13 for both common carrier
and non-common carrier operation^.^ To date, however, Intelsat has not operated the
satellite on a common carrier basis. As such, the change in regulatory status will not
result in the discontinuance of service to existing customers. Intelsat does not anticipate
any future business need to provide space segment services on a common carrier basis.
In addition, this action is consistent with Intelsat’s prior notification to the Commission
of the change in regulatory classification to non-common carrier of its U.S.-licensed
satel~ites.~

        Accordingly, Intelsat respectfully requests that the International Bureau include
notification of the change in status of the IA-13 Permitted List authorization as an
informational listing in the Satellite and Radiocommunication Division’s weekly Public
Notice of actions taken and place a copy of this notification in the relevant files,
consistent with the procedure set forth by the Commission in the DISCO I Order.6




2
          Id., 11 FCC Rcd at 2436 (f 49). NARUC I requires the Commission to (1) analyze the likelihood
that space station capacity in the services in question will be offered indifferently to the public; and (2) if
there is no such likelihood, determine whether there are sufficient public policy reasons to place the
licensee under a legal compulsion to serve the public indifferently. Nat ’I Ass ’n of Regulatory Utility
Commissioners v. FCC, 525 F.2d 630, 642 (D.C. Cir. 1976) (“NARUCI”).
3
         Loral SpaceCom Corp., Petition for Declaratory Ruling to Add Telstar 13 to the Permitted Space
Station List, Order 18 FCC Rcd. 16374 (2003).
4
         See Exhibit C to IB File No. SAT-PPL-20040318-00038.
5
          See Letter from Susan H. Crandall, Assistant General Counsel, Intelsat Global Service
Corporation, to Marlene H. Dortch, Secretary, Federal Communications Commission (June 8, 2005)
(notifying Commission of change in regulatory classification for 27 Intelsat North America fixed satellite
service space station licenses from “dual-use” (common carrierhon-common carrier) to non-common
carrier).
6
          The Commission followed this procedure when SES Americom, Inc. elected non-common carrier
status for certain of its satellites in 2003. See SES Americom, Inc., Applications for Modlfication of Fixed-
Satellite Service Space Station Licenses and Columbia Communications Corp.; AppIications for
Modification of Fixed-Satellite Sewice Space Station Licenses, Order and Authorization, 18 FCC Rcd
16,589 (7 7) (2003) (“SEYColumbia Order”), Erratum, (Aug. 21, 2003) (“the Applicants ... have notified
us of a change in the regulatory classification from common carrier to non-common carrier for the AMC-1,
GSTAR 4, and Satcom SN-4 satellite licenses”); SES/Columbia Order, 18 FCC Rcd at 16,592-93 (f 6)
(“we note the status change from common carrier to non-common carrier for SES AMERICOM‘s license
for AMC-1, GSTAR 4, and Satcom C-4 and will include notification of this change in the Satellite
Division’s weekly Public Notice of actions taken and update our database to reflect this change”).


                            Respectfully submitted,



                            Susan H. Crandall
                            Assistant General Counsel
                            Intelsat Corporation


Jennifer D. Hindin
Jennifer R. Schaum
WILEY REIN & FIELDING LLP
1776 K Street, N.W.
Washington, D.C. 20006
(202) 719-7000

cc:   Robert Nelson
      Andrea Kelly



Document Created: 2006-07-25 16:08:43
Document Modified: 2006-07-25 16:08:43

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